Preamble
With the following privacy policy, we would like to inform you about what types of your personal data (hereinafter also referred to as „data“) we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as „online offer“).
The terms used are not gender-specific.
Status: 26 July 2023
Table of contents
- Preamble
- Responsible
- Overview of the processing
- Relevant legal bases
- Security measures
- Transmission of personal data
- International data transfers
- Data deletion
- Rights of the data subjects
- Use of cookies
- Provision of the online offer and web hosting
- Registration, login and user account
- Single sign-on login
- Blogs and publication media
- Contact and enquiry management
- Communication via messenger
- Cloud services
- Newsletter and electronic notifications
- Web analysis, monitoring and optimisation
- Presence in social networks (social media)
- Plugins and embedded functions and content
- Amendment and update of the privacy policy
- Definitions of terms
Responsible
Patrick Ruppelt
On the egg meadow 20
82031 Grünwald
Germany
Relevant legal bases
Relevant legal bases according to the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.
- Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO) - The data subject has given their consent to the processing of their personal data for one or more specific purposes.
- Contract fulfilment and pre-contractual enquiries (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.
- Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by 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.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, 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. The data protection laws of the individual federal states may also apply.
Reference to the applicability of the GDPR and the Swiss DPA: This data protection notice serves to provide information in accordance with both the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). For this reason, please note that the terms of the GDPR are used due to the broader geographical application and comprehensibility. In particular, instead of the terms „processing“ of „personal data“, „overriding interest“ and „sensitive personal data“ used in the Swiss DPA, the terms „processing“ of „personal data“, „legitimate interest“ and „special categories of data“ used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of application of the Swiss DPA.
Overview of the processing
The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
- Inventory data.
- Location data.
- Contact details.
- Content data.
- Usage data.
- Meta, communication and procedural data.
- Picture and/or video recordings.
- Event data (Facebook).
Categories of persons concerned
- Customers.
- Employees.
- Interested parties.
- Communication partner.
- Users.
Purposes of the processing
- Provision of contractual services and fulfilment of contractual obligations.
- Contact requests and communication.
- Safety measures.
- Direct marketing.
- Reach measurement.
- Office and organisational procedures.
- Conversion measurement.
- Click tracking.
- A/B testing.
- Managing and responding to enquiries.
- Content Delivery Network (CDN).
- Feedback.
- Heatmaps.
- Marketing.
- Profiles with user-related information.
- Application procedure.
- Provision of our online offer and user-friendliness.
- Information technology infrastructure.
Security measures
We take appropriate technical and organisational measures in accordance with the legal requirements, 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 probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data threats. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and processes in accordance with the principle of data protection, through technology design and data protection-friendly default settings.
TLS encryption (https): We use TLS encryption to protect your data transmitted via our online offering. You can recognise such encrypted connections by the prefix https:// in the address bar of your browser.
Transmission of personal data
As part of our processing of personal data, data may be transferred to other bodies, companies, legally independent organisational units or persons or disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.
International data transfers
Data processing in third countries: If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements.
Subject to express consent or contractually or legally required transfer (see Art. 49 GDPR), we only process or have the data processed in third countries with a recognised level of data protection (Art. 45 GDPR), in the presence of and compliance with contractual obligations through so-called standard protection clauses of the EU Commission (Art. 46 GDPR) or in the presence of certifications or binding internal data protection regulations (see 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).
EU-US Trans-Atlantic Data Privacy Framework: As part of the so-called „Data Privacy Framework” (DPF), the level of data protection in the EU has also been recognised for certain companies from the USA. The list of certified companies as well as further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). Information in German and other languages can be found on the website of the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/eu-us-data-transfers_de We also inform you about the companies we use that are certified under the Data Privacy Framework.
Data deletion
The data processed by us will be deleted in accordance with the legal requirements as soon as the consent given for processing is revoked or other authorisations cease to apply (e.g. if the purpose for processing this data no longer applies or it is not required for the purpose). If the data is not deleted because it is required for other and legally permissible purposes, its processing is restricted to these purposes. This means that the data is 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 for the assertion, exercise or defence of legal claims or to protect the rights of another natural or legal person.
As part of our data protection information, we can provide users with further information on the deletion and retention of data that applies specifically to the respective processing operations.
Rights of the data subjects
Data subjects' rights under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
- Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those 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 such marketing, which includes profiling to the extent that it is related to such direct marketing.
- Right of withdrawal for consents: You have the right to revoke any consent you have given 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 request information about this data as well as further information and a copy of the data in accordance with the legal requirements.
- Right of rectification: In accordance with the legal requirements, you have the right to request the completion of data concerning you or the correction of incorrect data concerning you.
- Right to cancellation and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the legal requirements.
- Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request its transmission to another controller.
- Complaint to supervisory authority: In accordance with the statutory provisions and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State in which you are habitually resident, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.
Use of cookies
Cookies are small text files or other storage notes that store information on end devices and read information from the end devices. For example, to store the login status in a user account, the contents of a shopping basket in an e-shop, the content accessed or the functions of an online service used. Cookies can also be used for various purposes, e.g. to ensure the functionality, security and convenience of online offers and to create analyses of visitor flows.
Notes on consent: We use cookies in accordance with the statutory provisions. We therefore obtain prior consent from users, unless this is not required by law. In particular, consent is not required 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 (i.e. our online offering). Strictly necessary cookies generally include cookies with functions that serve the display and operability of the online service, load balancing, security, storage of user preferences and selection options or similar purposes related to the provision of the main and secondary functions of the online service requested by the user. The revocable consent is clearly communicated to the users and contains the information on the respective use of cookies.
Information on the legal basis for data protection: The legal basis under data protection law on which we process users' personal data with the help of cookies depends on whether we ask users for their consent. If users consent, the legal basis for processing their data is the consent they have given. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and improving its usability) or, if this is done in the context of the fulfilment of our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. We explain the purposes for which we process cookies in the course of this privacy policy or as part of our consent and processing procedures.
Storage period: 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 service and closed their end device (e.g. browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or favourite content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. If we do not provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and can be stored for up to two years.
General information on cancellation and objection (so-called „opt-out“): Users can [borlabs-cookie type=“btn-cookie-preference“ title=“revoke the consent they have given at any time“ element=“link“/] and object to processing in accordance with the legal requirements. Among other things, users can restrict the use of cookies in their browser settings (although this may also restrict the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be made via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ be explained.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
Further guidance on processing operations, procedures and services:
- Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the user's consent to the use of cookies or the processing and providers named in the cookie consent management procedure can be obtained, managed and revoked by the user. The declaration of consent is stored so that it does not have to be requested again and the consent can be proven in accordance with the legal obligation. Consent can be stored 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 the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: Consent may be stored for up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); .
- BorlabsCookie: Cookie consent management; Service provider: Hosted locally on our server, no data transfer to third parties; Website: https://de.borlabs.io/borlabs-cookie/; Further information: An individual user ID, language and types of consent and the time they were given are stored on the server and in the cookie on the user's device.
Provision of the online offer and web hosting
We process users' data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or end device.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status); content data (e.g. entries in online forms).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Provision of our online services and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); security measures; content delivery network (CDN).
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Provision of online offer on rented storage space: To provide our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also known as a „web host“); Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); .
- Collection of access data and log files: Access to our online offering is logged in the form of so-called „server log files“. 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 log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks) and to ensure the utilisation of the servers and their stability; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further storage is required for evidence purposes is excluded from deletion until the respective incident has been finally clarified.
- Email sending and hosting: The web hosting services we use also include sending, receiving and storing e-mails. For these purposes, the addresses of the recipients and senders as well as other information relating to the sending of e-mails (e.g. the providers involved) and the content of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of recognising SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, emails are encrypted in transit, but not on the servers from which they are sent and received (unless an end-to-end encryption method is used). We can therefore accept no responsibility for the transmission path of e-mails between the sender and receipt on our server; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); .
- Cloudflare: Content Delivery Network (CDN) - Service with the help of which the content of an online offering, in particular large media files such as graphics or programme scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet; Service provider: Cloudflare, Inc, 101 Townsend St, San Francisco, CA 94107, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.cloudflare.com; Privacy policy: https://www.cloudflare.com/privacypolicy/; Order processing contract: https://www.cloudflare.com/cloudflare-customer-dpa; Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://www.cloudflare.com/cloudflare-customer-scc).
Registration, login and user account
Users can create a user account. As part of 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 (user name, password and an e-mail address).
As part of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. This data is stored on the basis of our legitimate interests and those of the user in protection against misuse and other unauthorised use. This data is not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users can be informed by e-mail about processes that are relevant to their user account, such as technical changes.
- Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Provision of contractual services and fulfilment of contractual obligations; security measures; administration and answering of enquiries; provision of our online offer and user-friendliness.
- Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further guidance on processing operations, procedures and services:
- Registration with pseudonyms: Users may use pseudonyms as usernames instead of real names; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); .
- Deletion of data after cancellation: If users have cancelled their user account, their data relating to the user account will be deleted, subject to legal permission, obligation or user consent; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); .
- No obligation to retain data: Users are responsible for backing up their data before the end of the contract in the event of cancellation. We are authorised to irretrievably delete all user data stored during the term of the contract; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); .
Single sign-on login
Single sign-on„ or “single sign-on registration or authentication„ refers to procedures that allow users to log in to a provider of single sign-on procedures (e.g. a social network), including our online offering, with the help of a user account. The prerequisite for single sign-on authentication is that users are registered with the respective single sign-on provider and enter the required access data in the online form provided for this purpose, or are already registered with the single sign-on provider and confirm the single sign-on registration via a button.
Authentication takes place directly with the respective single sign-on provider. As part of such authentication, we receive a user ID with the information that the user is logged in to the respective single sign-on provider under this user ID and an ID that cannot be used by us for other purposes (so-called „user handle“). Whether additional data is transmitted to us depends solely on the single sign-on procedure used, on the data releases selected as part of authentication and also on which data users have released in the privacy or other settings of the user account with the single sign-on provider. Depending on the single sign-on provider and the user's choice, it can be different data, usually the e-mail address and the user name. The password entered with the single sign-on provider as part of the single sign-on procedure is neither visible to us nor is it stored by us.
Users are asked to note that their details stored with us can be automatically synchronised with their user account with the single sign-on provider, but that this is not always possible or actually takes place. If, for example, users' e-mail addresses change, they must change them manually in their user account with us.
If agreed with the users, we can use single sign-on registration as part of or before the fulfilment of the contract, insofar as the users have been asked to do so, as part of consent processing and otherwise use it on the basis of our legitimate interests and the interests of the users in an effective and secure registration system.
Should users ever decide that they no longer wish to use the link to their user account with the single sign-on provider for the single sign-on procedure, they must cancel this link within their user account with the single sign-on provider. If users wish to delete their data with us, they must cancel their registration with us.
- Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status); event data (Facebook) („event data“ is data that can be transmitted by us to Facebook via Facebook pixels (via apps or in other ways) and relates to people or their actions; the data includes, for example, information about visits to websites, interactions with content, installations of apps, purchases of products, etc.; the event data is used to create target groups for content (custom audiences). The data includes, for example, information about visits to websites, interactions with content, functions, app installations, product purchases, etc.; the event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); event data does not include the actual content (such as comments written), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data is deleted by Facebook after a maximum of two years, and the target groups created from it are deleted when our Facebook account is deleted.).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Provision of contractual services and fulfilment of contractual obligations; security measures; registration procedure.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Facebook Single Sign-On: Authentication service of the Facebook platform; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Order processing contract: https://www.facebook.com/legal/terms/dataprocessing; Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
- Microsoft Single Sign-On: Authentication service; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland, Parent Company: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.microsoft.com/de-de/security/business/identity-access-management/single-sign-on; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement; Basis third country transfer: EU-US Data Privacy Framework (DPF); Further information: https://www.microsoft.com/de-de/trustcenter.
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter „publication medium“). Readers' data is only 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. In addition, we refer to the information on the processing of visitors to our publication medium in the context of this data protection notice.
- Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Provision of contractual services and fulfilment of contractual obligations; feedback (e.g. collecting feedback via online form); provision of our online services and user-friendliness; security measures; managing and responding to enquiries.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Comments and contributions: If users leave comments or other contributions, their IP addresses may be stored on the basis of our legitimate interests. This is done for our security in case someone leaves illegal content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves may be prosecuted for the comment or post and are therefore interested in the identity of the author. Furthermore, we reserve the right to process user data for the purpose of spam detection on the basis of our legitimate interests. On the same legal basis, we reserve the right to store the IP addresses of users for the duration of surveys and to use cookies in order to avoid multiple votes. The personal information provided as part of the comments and contributions, any contact and website information as well as the content information will be permanently stored by us until the user objects; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); .
- Retrieve WordPress emojis and smilies: Retrieval of WordPress emojis and smilies - Graphic emojis (or smilies), i.e. small graphic files that express feelings, are used within our WordPress blog for the purpose of efficient integration of content elements, obtained from external servers. The providers of the servers collect the IP addresses of the users. This is necessary so that the emoji files can be transmitted to the user's browser; Service provider: Aut O'Mattic A8C Ireland Ltd, Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://automattic.com; Privacy policy: https://automattic.com/privacy; Basis third country transfer: EU-US Data Privacy Framework (DPF).
- Akismet anti-spam check: Akismet anti-spam check - We use the „Akismet“ service on the basis of our legitimate interests. With the help of Akismet, comments from real people are distinguished from spam comments. For this purpose, all comments are sent to a server in the USA, where they are analysed and stored for four days for comparison purposes. If a comment has been categorised as spam, the data is stored beyond this period. This data includes the name entered, the e-mail address, the IP address, the comment content, the referrer, details of the browser used and the computer system and the time of the entry. Users are welcome to use pseudonyms or refrain from entering their name or email address. You can completely prevent the transfer of data by not using our comment system. That would be a pity, but unfortunately we do not see any alternatives that work just as effectively; Service provider: Aut O'Mattic A8C Ireland Ltd, Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://automattic.com; Privacy policy: https://automattic.com/privacy; Basis third country transfer: EU-US Data Privacy Framework (DPF).
- UpdraftPlus: Backup software and backup storage; Service provider: Simba Hosting Ltd, 11, Barringer Way, St Neots, Cambs., PE19 1LW, GB; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://updraftplus.com/; Privacy policy: https://updraftplus.com/data-protection-and-privacy-centre/.
Contact and enquiry management
When contacting us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the data of the enquiring persons are processed insofar as this is necessary to answer the contact enquiries and any requested measures.
- Types of data processed: 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 and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Persons concerned: Communication partner.
- Purposes of the processing: Contact requests and communication; managing and responding to requests; feedback (e.g. collecting feedback via online form); providing our online service and user experience.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further guidance on processing operations, procedures and services:
- Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data provided to us in this context to process the communicated request; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); .
Communication via messenger
We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, on encryption, on the use of communication metadata and on your objection options.
You can also contact us by alternative means, e.g. by telephone or e-mail. Please use the contact options provided to you or the contact options specified within our online offer.
In the case of end-to-end encryption of content (i.e. the content of your message and attachments), we would like to point out that the communication content (i.e. the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use an up-to-date version of the messenger with encryption enabled to ensure that the message content is encrypted.
However, we would also like to point out to our communication partners that although the providers of the messengers cannot view the content, they can find out that and when communication partners communicate with us and that technical information about the device used by the communication partners and, depending on the settings of their device, location information (so-called metadata) is also processed.
Notes on legal bases: If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and you contact us, for example, on your own initiative, we use Messenger in relation to our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and fulfilment of our communication partners' needs for communication via Messenger. We would also like to point out that we will not transmit the contact data provided to us to Messenger for the first time without your consent.
Cancellation, objection and deletion: You can revoke your consent at any time and object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete the messages in accordance with our general deletion guidelines (i.e., for example, as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information from the communication partners, if no reference to a previous conversation is to be expected and the deletion does not conflict with any statutory retention obligations.
Reservation of reference to other communication channels: Finally, we would like to point out that, for your security, we reserve the right not to answer enquiries via Messenger. This is the case if, for example, internal contractual information requires special confidentiality or a reply via Messenger does not fulfil formal requirements. In such cases, we will refer you to more appropriate communication channels.
- Types of data processed: Contact data (e.g. e-mail, telephone numbers); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
- Persons concerned: Communication partner.
- Purposes of the processing: Contact requests and communication; direct marketing (e.g. by e-mail or post).
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Instagram: Sending messages via the social network Instagram; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
- Facebook Messenger: Facebook Messenger with end-to-end encryption (the end-to-end encryption of Facebook Messenger requires activation if it is not activated by default); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Order processing contract: https://www.facebook.com/legal/terms/dataprocessing; Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
- WhatsApp: WhatsApp Messenger with end-to-end encryption; Service provider: WhatsApp Ireland Limited, 4 Grand Canal Quay, Dublin 2, D02 KH28, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.whatsapp.com/; Privacy policy: https://www.whatsapp.com/legal; Basis third country transfer: EU-US Data Privacy Framework (DPF).
Cloud services
We use software services accessible via the internet and running on the servers of their providers (so-called „cloud services“, also referred to as „software as a service“) for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with certain recipients or publication of content and information).
In this context, personal data may be processed and stored on the provider's servers if they are part of communication processes with us or are otherwise processed by us as set out in this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their content. Cloud service providers also process usage data and metadata that they use for security purposes and to optimise their services.
If we use cloud services to provide other users or publicly accessible websites with forms or other documents and content, the providers may store cookies on users' devices for the purposes of web analysis or to remember user settings (e.g. in the case of media control).
- Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status); image and/or video recordings (e.g. photographs or video recordings of a person).
- Persons concerned: Customers; employees (e.g. employees, applicants, former employees); interested parties; communication partners.
- Purposes of the processing: Office and organisational procedures; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)); provision of contractual services and fulfilment of contractual obligations.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Adobe Creative Cloud: Applications and cloud storage for photo editing, video editing, graphic design and web development; Service provider: Adobe Systems Software Ireland Companies, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.adobe.com/de/creativecloud.html; Privacy policy: https://www.adobe.com/de/privacy.html; Order processing contract: Provided by the service provider; Basis third country transfer: EU-US Standard Contractual Clauses (Provided by the service provider).
- Apple iCloud: Cloud storage service; Service provider: Apple Inc, Infinite Loop, Cupertino, CA 95014, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.apple.com/de/; Privacy policy: https://www.apple.com/legal/privacy/de-ww/.
- Dropbox: Cloud storage service; Service provider: Dropbox, Inc., 333 Brannan Street, San Francisco, California 94107, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.dropbox.com/de; Privacy policy: https://www.dropbox.com/privacy; Order processing contract: https://assets.dropbox.com/documents/en/legal/dfb-data-processing-agreement.pdf; Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://assets.dropbox.com/documents/en/legal/dfb-data-processing-agreement.pdf).
- Microsoft Cloud Services: Cloud storage, cloud infrastructure services and cloud-based application software; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland, Parent Company: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://microsoft.com/de-de; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, safety instructions: https://www.microsoft.com/de-de/trustcenter; Order processing contract: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA; Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
Newsletter and electronic notifications
We only send newsletters, emails and other electronic notifications (hereinafter „newsletter“) with the consent of the recipient or with legal authorisation. If the contents of the newsletter are specifically described when registering for the newsletter, 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 generally sufficient to provide your e-mail address. However, we may ask you to provide a name so that we can address you personally in the newsletter, or other information if this is necessary for the purposes of the newsletter.
Double opt-in procedure: Registration for our newsletter is always carried out in a so-called double opt-in procedure. This means that after registering you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no-one can register with other people's e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the mailing service provider are also logged.
Erasure and restriction of processing: We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list solely for this purpose.
The registration process is logged on the basis of our legitimate interests for the purpose of verifying that it is 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.
Contents:Information on newly published articles on my website
- Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status); usage data (e.g. websites visited, interest in content, access times).
- Persons concerned: Communication partner.
- Purposes of the processing: Direct marketing (e.g. by e-mail or post).
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
- Possibility of objection (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 given above, preferably e-mail.
Further guidance on processing operations, procedures and services:
- Measurement of opening and click rates: The newsletters contain a so-called „web-beacon“, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a dispatch service provider, from their server. As part 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, is initially collected. This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. The analyses help us to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of opening rates and click rates as well as the storage of the measurement results in the user profiles and their further processing are carried out on the basis of the user's consent. Unfortunately, it is not possible to revoke the performance measurement separately; in this case, the entire newsletter subscription must be cancelled or objected to. In this case, the stored profile information will be deleted; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); .
- Mailchimp: E-mail dispatch and e-mail dispatch and automation services; Service provider: Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://mailchimp.com; Privacy policy: https://mailchimp.com/legal/; Order processing contract: https://mailchimp.com/legal/; Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (Provided by the service provider); Further information: Special safety measures: https://mailchimp.com/help/Mailchimp-european-data-transfers/.
Web analysis, monitoring and optimisation
Web analysis (also referred to as „reach measurement“) is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognise at what time our online offering or its functions or content are most frequently used or invite visitors to reuse them. We can also understand which areas require optimisation.
In addition to web analysis, we may also use test procedures, e.g. to test and optimise different versions of our online offering or its components.
Unless otherwise stated below, profiles, i.e. data summarised for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and read out from it. The information collected includes, in particular, websites visited and the elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data from us or from the providers of the services we use, location data may also be processed.
The IP addresses of users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored for web analysis, A/B testing and optimisation purposes, but pseudonyms. This means that we and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.
- Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles); provision of our online offer and user-friendliness; conversion measurement (measurement of the effectiveness of marketing measures); click tracking; A/B tests; heat maps (mouse movements by users that are summarised to form an overall picture).
- Safety measures: IP masking (pseudonymisation of the IP address).
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Google Analytics 4: We use Google Analytics to measure and analyse the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or e-mail addresses. It is used to assign analysis information to an end device in order to recognise which content users have called up within one or more usage processes, which search terms they have used, which they have called up again or which they have interacted with our online offering. The time of use and its duration are also stored, as well as the sources of the users who refer to our online offering and technical aspects of their end devices and browsers. Pseudonymised profiles of users are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: City (and the city's inferred latitude and longitude), Continent, Country, Region, Subcontinent (and ID-based counterparts). For EU traffic, the IP address data is used exclusively for this derivation of geolocalisation data before it is immediately deleted. It is not logged, is not accessible and is not used for other purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms/; Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://business.safety.google/adsprocessorterms); Possibility of objection (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of adverts: https://adssettings.google.com/authenticated; Further information: https://privacy.google.com/businesses/adsservices (Types of processing and data processed).
- Jetpack (WordPress Stats): Jetpack offers analysis functions for WordPress software; Service provider: Aut O'Mattic A8C Ireland Ltd, Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://automattic.com; Privacy policy: https://automattic.com/privacy; Basis third country transfer: EU-US Data Privacy Framework (DPF).
- Microsoft Clarity: Software for the analysis and optimisation of online offers on the basis of feedback functions and pseudonymised measurements and analyses of user behaviour, which may include in particular A/B tests (measurement of the popularity and user-friendliness of different content and functions), measurement of click paths and interaction with content and functions of the online offer; Service provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://clarity.microsoft.com/; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement; Basis third country transfer: EU-US Data Privacy Framework (DPF).
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 the 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 because, for example, it could make it more difficult to enforce users' rights.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behaviour and the resulting interests of users. The user profiles can in turn be used, for example, to place adverts 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 in to them).
For a detailed description of the respective forms of processing and the opt-out options, please refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the user's data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
- Types of data processed: 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 and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Contact requests and communication; feedback (e.g. collecting feedback via online form); marketing.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
- Facebook pages: Profiles within the social network Facebook - We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of 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 take (see „Things you and others do and provide“ in the Facebook Data Policy: https://www.facebook.com/policy), as well as 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, known as „Page Insights“, for page operators to help them understand how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook („Information on Page Insights“, https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the „Information on Page Insights“ (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; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://www.facebook.com/legal/EU_data_transfer_addendum); Further information: Agreement on joint responsibility: https://www.facebook.com/legal/terms/information_about_page_insights_data. The joint responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Order processing contract: https://legal.linkedin.com/dpa; Basis third country transfer: EU-US Standard contractual clauses (https://legal.linkedin.com/dpa); Possibility of objection (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Pinterest: Social network; Service provider: Pinterest Europe Limited, 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.pinterest.com; Privacy policy: https://policy.pinterest.com/de/privacy-policy; Further information: Pinterest Data Sharing Annex (ANNEX A): https://business.pinterest.com/de/pinterest-advertising-services-agreement/.
- YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Privacy policy: https://policies.google.com/privacy; Basis third country transfer: EU-US Data Privacy Framework (DPF); Possibility of objection (opt-out): https://adssettings.google.com/authenticated.
- Xing: Social network; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.xing.de; Privacy policy: 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 their respective providers (hereinafter referred to as „third-party providers”). These may be, for example, graphics, videos or city maps (hereinafter uniformly referred to as „content”).
The integration always requires that the third-party providers of this content process the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content or function. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as „web beacons“) for statistical or marketing purposes. Pixel tags can be used to analyse information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as being linked to such information from other sources.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status); inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); location data (information on the geographical position of a device or person); event data (Facebook) („event data“ are data that can be transmitted by us to Facebook via Facebook pixels (via apps or other means) and relate to persons or their actions). ("event data" is data that can be transmitted by us to Facebook via Facebook pixels (via apps or in other ways) and relates to people or their actions; the data includes, for example, information about visits to websites, interactions with content, functions, app installations, product purchases, etc.; the event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); event data does not include the actual content (such as comments written), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data is deleted by Facebook after a maximum of two years, and the target groups created from it are deleted when our Facebook account is deleted.).
- Persons concerned: Users (e.g. website visitors, users of online services); communication partners.
- Purposes of the processing: Provision of our online services and user-friendliness; marketing; profiles with user-related information (creation of user profiles); provision of contractual services and fulfilment of contractual obligations; contact enquiries and communication; direct marketing (e.g. by e-mail or post); security measures.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
Further guidance on processing operations, procedures and services:
- Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offering that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of displaying or user-friendliness of our online offering). The respective providers collect the IP address of the users and can process this for the purpose of transmitting the software to the user's browser and for security purposes, as well as for the evaluation and optimisation of their offer. - We integrate software into our online offering that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of displaying or user-friendliness of our online offering). The respective providers collect the IP address of the users and can process this for the purpose of transmitting the software to the user's browser and for security purposes, as well as for the evaluation and optimisation of their offer; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); .
- Facebook plugins and content: Facebook social plugins and content - This may include, for example, content such as images, videos or text and buttons with which users can share content from this online offering within Facebook. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/ - We are jointly responsible withMeta Platforms Ireland Limited for the collection or receipt in the context of a transmission (but not the further processing) of „event data“ that Facebook collects or receives in the context of a transmission by means of the Facebook social plugins (and embedding functions for content) that are executed on our online offer for the following purposes: a) Display of content and advertising information that corresponds to the presumed interests of the users; b) Delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) Improvement of ad delivery and personalisation of functions and content (e.g. improvement of the recognition of which content or advertising information presumably corresponds to the interests of the users). (e.g. addressing users via Facebook Messenger); c) improving the delivery of ads and personalisation of functions and content (e.g. improving the recognition of which content or advertising information presumably corresponds to the interests of users). We have concluded a special agreement with Facebook („Controller Addendum“, https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with measured values, analyses 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 within the framework of joint responsibility, but on the basis of an order processing contract („data processing conditions„), https://www.facebook.com/legal/terms/dataprocessing) the „data security conditions“ (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 to information, deletion, objection and complaint to the competent 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; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Basis third country transfer: EU-US Data Privacy Framework (DPF).
- Google Fonts (obtained from the Google server): Obtaining fonts (and symbols) for the purpose of a technically secure, maintenance-free and efficient use of fonts and symbols with regard to up-to-dateness and loading times, their uniform presentation and consideration of possible licence restrictions. The provider of the fonts is informed of the user's IP address so that the fonts can be made available in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) are transmitted that are necessary for the provision of the fonts depending on the devices used and the technical environment. This data may be processed on a server of the font provider in the USA - When visiting our online offer, the user's browser sends HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving fonts). The Google Fonts Web API provides users with the Google Fonts Cascading Style Sheets (CSS) and then the fonts specified in the CCS. These HTTP requests include (1) the IP address used by the respective user to access the Internet, (2) the requested URL on the Google server and (3) the HTTP headers, including the user agent, which describes the browser and operating system versions of the website visitors, as well as the referrer URL (i.e. the web page on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and are not analysed. The Google Fonts Web API logs details of HTTP requests (requested URL, user agent and referrer URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wishes to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must adapt the font that is generated for the respective browser type. The user agent is primarily logged for debugging and used to generate aggregated usage statistics to measure the popularity of font families. These summarised usage statistics are published on the „Analyses“ page of Google Fonts. Finally, the referral URL is logged so that the data can be used for production maintenance and to generate an aggregated report on the top integrations based on the number of font requests. According to Google, it does not use any of the information collected by Google Fonts to create profiles of end users or to place targeted adverts; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy; Basis third country transfer: EU-US Data Privacy Framework (DPF); Further information: https://developers.google.com/fonts/faq/privacy?hl=de.
- Google Maps: We integrate the maps of the “Google Maps” service provided by Google. The processed data may include, in particular, IP addresses and user location data; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy; Basis third country transfer: EU-US Data Privacy Framework (DPF).
- Google Maps APIs and SDKs: Interfaces to Google's map and location services, which allow, for example, the addition of address entries, location determination, distance calculations or the provision of additional information on locations and other places; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy; Basis third country transfer: EU-US Data Privacy Framework (DPF).
- Instagram plugins and content: Instagram plugins and content - This may include, for example, content such as images, videos or text and buttons with which users can share content from this online offering within Instagram. - We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt in the context of a transmission (but not the further processing) of „event data“ that Facebook collects using Instagram functions (e.g. embedding functions for content) that are executed on our online offer or receives in the context of a transmission for the following purposes: a) Display of content and advertising information that corresponds to the presumed interests of the users; b) Delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger). (e.g. addressing users via Facebook Messenger); c) improving the delivery of ads and personalisation of functions and content (e.g. improving the recognition of which content or advertising information presumably corresponds to the interests of users). We have concluded a special agreement with Facebook („Controller Addendum“, https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with measured values, analyses 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 within the framework of joint responsibility, but on the basis of an order processing contract („data processing conditions„), https://www.facebook.com/legal/terms/dataprocessing) the „data security conditions“ (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 to information, deletion, objection and complaint to the competent 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; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
- LinkedIn plugins and content: LinkedIn plugins and content- This may include, for example, content such as images, videos or text and buttons with which users can share content from this online offering within LinkedIn; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Order processing contract: https://legal.linkedin.com/dpa; Basis third country transfer: EU-US Standard contractual clauses (https://legal.linkedin.com/dpa); Possibility of objection (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Basis third country transfer: EU-US Data Privacy Framework (DPF); Possibility of objection (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of adverts: https://adssettings.google.com/authenticated.
- Xing plugins and buttons: Xing plugins and buttons - This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online service within Xing; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.xing.com; Privacy policy: https://privacy.xing.com/de/datenschutzerklaerung.
- Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
- Facebook Single Sign-On: Authentication service of the Facebook platform; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Order processing contract: https://www.facebook.com/legal/terms/dataprocessing; Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
- Facebook Messenger: Facebook Messenger with end-to-end encryption (the end-to-end encryption of Facebook Messenger requires activation if it is not activated by default); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Order processing contract: https://www.facebook.com/legal/terms/dataprocessing; Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
- Facebook pages: Profiles within the social network Facebook - We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of 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 take (see „Things you and others do and provide“ in the Facebook Data Policy: https://www.facebook.com/policy), as well as 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, known as „Page Insights“, for page operators to help them understand how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook („Information on Page Insights“, https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the „Information on Page Insights“ (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; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://www.facebook.com/legal/EU_data_transfer_addendum); Further information: Agreement on joint responsibility: https://www.facebook.com/legal/terms/information_about_page_insights_data. The joint responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- Gymnastics styles: CAPTCHA service that is used to check whether the data entered within our online offering (e.g. on a login page or a contact form) has been entered by a human or an automated programme. For this purpose, the service analyses the behaviour of users of our online offering based on various characteristics. This analysis begins automatically as soon as a user uses our online offering. Various information is evaluated for the analysis (IP address, time spent by the visitor on the website or app or mouse movements by the user as well as technical information on the end device and browser used by the user); Service provider: Cloudflare, Inc, 101 Townsend St, San Francisco, CA 94107, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.cloudflare.com/lp/turnstile/; Privacy policy: https://www.cloudflare.com/privacypolicy/; Order processing contract: https://www.cloudflare.com/cloudflare-customer-dpa; Basis third country transfer: EU-US Data Privacy Framework (DPF).
Amendment and update of the privacy policy
We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organisations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.
Definitions of terms
This section provides you with an overview of the terms used in this privacy policy. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.
- A/B testing: A/B tests are used to improve the user-friendliness and performance of online offers. For example, users are shown different versions of a website or its elements, such as input forms, on which the placement of the content or the labelling of the navigation elements can differ. The behaviour of the user, e.g. longer time spent on the website or more frequent interaction with the elements, can then be used to determine which of these websites or elements are more likely to meet the needs of the user.
- Content Delivery Network (CDN): A „Content Delivery Network“ (CDN) is a service that can be used to deliver online content, especially large media files such as graphics or programme scripts, faster and more securely with the help of regionally distributed servers connected via the Internet.
- Heatmaps: „Heatmaps“ are mouse movements of users that are summarised to form an overall picture, which can be used, for example, to recognise which website elements are preferred and which website elements users prefer less.
- Click tracking: Clicktracking allows us to monitor the movements of users within an entire online offering. As the results of these tests are more accurate if the user's interaction can be tracked over a certain period of time (e.g. so that we can find out whether a user likes to return), cookies are usually stored on the user's computer for these test purposes.
- Conversion measurement: Conversion measurement (also referred to as „visit action evaluation“) 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 within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the adverts we have placed on other websites have been successful.
- Personal data: „Personal data“ means any information relating to an identified or identifiable natural person (hereinafter „data subject“); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Profiles with user-related information: The processing of „profiles with user-related information“, or „profiles“ for short, includes any type of automated processing of personal data that consists of using this personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information relating to demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
- Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behaviour or interests of visitors in certain information, such as website content. With the help of reach analysis, website owners can, for example, recognise at what time visitors visit their website and what content they are interested in. This enables them, for example, to better customise the content of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis purposes in order to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
- 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 means and functions of location determination. Location data is used to indicate the geographically determinable position on earth at which the respective device is located. Location data can be used, for example, to display map functions or other location-dependent information.
- Responsible: The „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, whether or not by automated means. The term is broad and encompasses practically every handling of data, whether it is collecting, analysing, storing, transmitting or deleting.
