Privacy policy

Introduction

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 in the context of providing our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter also referred to collectively as “online offer”).

The terms used are not gender-specific.

Status: 23 July 2020

Table of contents

 

  • Introduction
  • Responsible
  • Overview of processing
  • Relevant legal bases
  • Security measures
  • Transmission and disclosure of personal data
  • Data processing in third countries
  • Use of cookies
  • Commercial and business services
  • Use of online marketplaces for e-commerce
  • Payment service provider
  • Provision of the online offer and web hosting
  • Special notes on applications (apps)
  • Purchase of applications via Appstores
  • Registration, login and user account
  • Single sign-on registration
  • Blogs and publication media
  • Contact
  • Communication via Messenger
  • Chatbots and chat functions
  • Push News
  • Video conferences, online meetings, webinars and screen sharing
  • Music and podcasts
  • Application procedure
  • Cloud services
  • Newsletter and electronic notifications
  • Advertising communication via e-mail, post, fax or telephone
  • Raffles and competitions
  • Surveys and questionnaires
  • Web analysis, monitoring and optimisation
  • online marketing
  • Affiliate programmes and affiliate links
  • Offer of an affiliate programme
  • Evaluation platforms
  • Presence in social networks (social media)
  • Plugins and embedded functions and content
  • Planning, organisation and support tools
  • Deletion of data
  • Amendment and update of the privacy policy
  • Rights of data subjects
  • Definitions of terms

Responsible

Academy for Personal Development & Entrepreneurship Dr.
Akuma Saningong Jevenstedter
 Straße 53 22547
 Hamburg

E-mail address: info@drsaningong.com

Overview of processing

The following table summarises the types of data processed and the purposes of their processing, and refers to the data subjects.

Types of data processed

  • inventory data (e.g. names, addresses).
  • Applicant data (e.g. personal details, postal and contact addresses, the documents pertaining to the application and the information contained therein, such as cover letter, curriculum vitae, certificates and other information about the applicant’s person or qualification provided voluntarily by the applicant with regard to a specific position or on a voluntary basis)
  • Content data (e.g. text entries, photographs, videos).
  • Contact details (e.g. e-mail, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Location data (data indicating the location of an end user’s terminal equipment).
  • Contract data (e.g. subject matter of the contract, duration, customer category).
  • Payment data (e.g. bank details, invoices, payment history).

Special categories of data

  • data revealing racial and ethnic origin.

Categories of data subjects

  • Employees (e.g. employees, applicants, former employees).
  • applicants.
  • Business and contractual partners.
  • interested parties.
  • communication partner.
  • customers.
  • Users (e.g. website visitors, users of online services).
  • patients.
  • Competition and contest participants.

Purposes of the processing

  • Affiliate tracking.
  • Registration procedure.
  • Provision of our online offer and user-friendliness.
  • Visit action evaluation.
  • Application procedure (justification and possible later implementation and possible later termination of employment.)
  • Office and organisational procedures.
  • Click tracking.
  • Content Delivery Network (CDN).
  • Cross-device tracking (cross-device processing of user data for marketing purposes).
  • Direct marketing (e.g. by e-mail or post).
  • Organisation of competitions and contests.
  • Target group formation.
  • Interest-based and behaviour-based marketing.
  • Contact requests and communication.
  • Conversion measurement (measuring the effectiveness of marketing measures).
  • Profiling (creation of user profiles).
  • remarketing.
  • Range measurement (e.g. access statistics, recognition of returning visitors).
  • security measures.
  • Tracking (e.g. interest/behavioural profiling, use of cookies).
  • Server monitoring and error detection.
  • Surveys and questionnaires (e.g. surveys with input options, multiple choice questions).
  • Contractual performance and service.
  • Management and response to requests.
  • Target group formation (determination of target groups relevant for marketing purposes or other output of content).

Relevant legal bases

In the following, we provide the legal basis for the Basic Data Protection Regulation (DSGVO), on the basis of which we process personal data. Please note that in addition to the regulations of the DSGVO, national data protection regulations may apply in your or our country of residence and domicile. Should more specific legal provisions apply in individual cases, we will inform you of these in the data protection declaration.

 

  • Consent (Art. 6 para. 1 sentence 1 letter a FADP) – The data subject has given his or her consent to the processing of personal data relating to him or her for one or more specific purposes.
  • Fulfilment of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. FADP) – Processing is necessary for the performance of a contract to which the data subject is party or for carrying out pre-contractual measures taken at the request of the data subject.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c. DSGVO) – The processing is necessary to fulfil a legal obligation to which the controller is subject.
  • Protection of vital interests (Art. 6 para. 1 sentence 1 lit. d. DPA) – Processing is necessary in order to protect the vital interests of the data subject or of another natural person.
  • Legitimate interests (Art. 6 para. 1 sentence 1 letter f. DSGVO) – The processing is necessary to safeguard the legitimate interests of the controller or of a third party, unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data outweigh these.
  • Art. 9 para. 1 sentence 1 letter b DSGVO (application procedure as a pre-contractual or contractual relationship) (Insofar as special categories of personal data within the meaning of Art. 9 para. 1 DSGVO (e.g. health data, such as severely handicapped status or ethnic origin) are requested from applicants during the application procedure in order to enable the responsible person or the data subject to exercise the rights arising to him or her from labour law and social security and social protection law and to fulfil his or her obligations in this respect, they are processed in accordance with Art. 9 Paragraph 2 letter b. DSGVO, in the case of protection of vital interests of applicants or other persons pursuant to Art. 9 para. 2 lit. c. DSGVO or for purposes of health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnosis, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 para. 2 lit. h. DSGVO. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 para. 2 lit. a. DSGVO) – .
  • Fulfilment of contract and pre-contractual enquiries (EKD) (Article 6 No. 5 DSG-EKD) – Processing is necessary for the performance of a contract to which the data subject is a party or for carrying out pre-contractual measures taken at the request of the data subject.

National data protection regulations in Germany: In addition to the data protection regulations of the basic data protection regulation, national regulations on data protection apply in Germany. These include in particular the law on 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 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 (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

 

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 commensurate with the risk.

These measures include in particular ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, disclosure, safeguarding of availability and separation of data. Procedures have also been put in place to ensure that data subjects’ rights are respected, that data are deleted and that responses to data breaches are made. 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, by designing technology and by using data protection-friendly default settings.

Transmission and disclosure of personal data

In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. The recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases we observe the legal requirements and in particular conclude appropriate 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 if 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 will only take place in accordance with the legal requirements.

Subject to express consent or transmission required by contract or by law, we only process or allow the data to be processed in third countries with a recognised level of data protection, a contractual obligation through so-called standard protection clauses of the EU Commission, in the case of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

Use of cookies

Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after his visit within an online offer. The stored information can include, for example, the language settings on a website, the login status, a shopping basket or the place where a video was viewed. The term “cookies” also includes other technologies that perform the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also known as “user IDs”).

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
  • Permanent cookies: Permanent cookies remain stored even after closing the browser. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users used for reach measurement or marketing purposes can be stored in such a cookie.
  • First-party cookies: First-party cookies are set by ourselves.
  • Third-party cookies (also: third-party cookies): third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or absolutely necessary) cookies: Cookies can be absolutely necessary for the operation of a website (e.g. to save logins or other user entries or for security reasons).
  • Statistical, marketing and personalisation cookies: Furthermore, cookies are generally also used in the context of range measurement as well as when the interests of a user or his behaviour (e.g. viewing certain content, using functions etc.) are stored in a user profile on individual websites. Such profiles are used to show users e.g. content that corresponds to their potential interests. This procedure is also known as “tracking”, i.e. following the potential interests of users. . If we use cookies or “tracking” technologies, we will inform you separately in our privacy policy or when you give your consent.

Information on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed with the aid of cookies will be processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfil our contractual obligations.

Storage duration: Unless we provide you with explicit information on the storage duration of permanent cookies (e.g. within the framework of a so-called cookie opt-in), please assume that the storage duration can be up to two years.

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the possibility at any time to revoke any consent given or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection by means of the settings of your browser, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online service). An objection to the use of cookies for online marketing purposes can also be declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further notices of objection in the context of the information on the service providers and cookies used.

Processing of cookie data based on consent: Before we process or have processed data in the context of the use of cookies, we ask users for their consent, which can be revoked at any time. Before consent has not been given, cookies are used if necessary, which are absolutely necessary for the operation of our online service.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Commercial and business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) within the framework of contractual and comparable legal relationships and associated measures and within the framework of communication with the contractual partners (or pre-contractual), e.g. to answer enquiries.

We process these data to fulfil our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with these data as well as for business organisation. Within the framework of the applicable law, we only pass on the data of the contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations or with the consent of the persons concerned (e.g. to participating telecommunication, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.

We inform the contractual partners which data are required for the above-mentioned purposes before or within the scope of data collection, e.g. in online forms, by means of special marking (e.g. colours) or symbols (e.g. asterisks or similar), or personally.

We delete the data after the expiry of legal warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g., as long as it must be kept for legal archiving reasons (e.g., for tax purposes usually 10 years). We will delete data that has been disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, generally after the end of the order.

If we use third-party providers or platforms to provide our services, the terms and conditions and data protection information of the respective third-party providers or platforms apply in the relationship between the users and the providers.

customer account: Contracting parties can create an account within our online offer (e.g. customer or user account, in short “customer account”). If the registration of a customer account is required, contractual partners are informed of this as well as of the information required for registration. The customer accounts are not public and cannot be indexed by search engines. Within the scope of the registration and subsequent logins and use of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove the registration and prevent possible misuse of the customer account.

If customers have cancelled their customer account, the data relating to the customer account will be deleted, subject to retention of the data for legal reasons. It is the responsibility of the Customers to secure their data when the Customer account is cancelled.

Economic analyses and market research: For economic reasons and in order to be able to identify market trends, wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., whereby contractual partners, interested parties, customers, visitors and users of our online offer may fall into the group of persons concerned.

The analyses are carried out for the purpose of business management evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we can take into account the profiles of registered users, if available, together with their details, e.g. on services used. The analyses serve solely to serve us and are not disclosed externally, unless they are anonymous analyses with summarised, i.e. anonymised, values. Furthermore, we respect the privacy of the users and process the data for the purposes of analysis as pseudonymously as possible and, if feasible, anonymously (e.g. as summarised data).

Shop and e-commerce: We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and related services, as well as their payment and delivery or execution.

The required information is identified as such within the scope of the order or comparable acquisition process and includes the information required for delivery, or provision and invoicing as well as contact information in order to be able to consult with you if necessary.

Agency services: We process the data of our customers within the scope of our contractual services, which may include, for example, conceptual and strategic consulting, campaign planning, software and design development/consultancy or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consultancy services and training services.

Education and training services: We process the data of the participants of our education and training offers (uniformly referred to as “training and further training participants”) in order to be able to provide our training services to them. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and training relationship. The forms of processing also include the performance assessment and evaluation of our services and those of the instructors.

Within the scope of our activities, we may also process special categories of data, in particular data concerning the health of persons undergoing training and further training, as well as data revealing ethnic origin, political opinions, religious or ideological beliefs. To this end, we obtain the express consent of the trainees, if necessary, and otherwise process the special categories of data only if it is necessary for the provision of training services, for purposes of health care, social protection or the protection of vital interests of the trainees.

Insofar as it is necessary for the fulfilment of our contract, for the protection of vital interests or legally required, or if the consent of the person to be trained has been obtained, we disclose or transfer the data of the person to be trained to third parties or agents, such as public authorities or in the field of IT, office or comparable services, in compliance with the requirements of professional law.

Coaching: We process the data of our clients as well as interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to be able to provide them with our services. The processed data, the nature, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship.

Within the scope of our activities, we may also process special categories of data, in particular data concerning the health of clients, possibly with reference to their sexual life or sexual orientation, as well as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership. To this end, we obtain the express consent of clients where necessary and otherwise process the special categories of data provided that this is in the interests of the health of the client, the data is public or other legal permits are available.

Insofar as it is necessary for the fulfilment of our contract, for the protection of vital interests or legally required, or if the client’s consent has been obtained, we disclose or transfer the client’s data to third parties or agents, such as authorities, accounting offices, as well as in the field of IT, office or comparable services, in compliance with the professional regulations.

Consulting: We process the data of our clients, clients as well as interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to provide them with our consulting services. The processed data, the nature, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship.

Insofar as it is necessary for our fulfilment of the contract, for the protection of vital interests or legally required, or if the consent of the clients has been obtained, we disclose or transfer the clients’ data to third parties or agents, such as authorities, subcontractors or in the field of IT, office or comparable services, in compliance with the professional legal requirements.

Publication activity: We process the data of our contact partners, interview partners and other persons who are the subject of our publishing, editorial and journalistic and related activities. In this context, we refer to the validity of protective regulations of freedom of opinion and freedom of the press according to Art. 85 DSGVO in connection with the respective national laws. The processing serves the fulfilment of our commissioned activities and otherwise takes place in particular on the basis of the public interest in information and media offers.

Management consultancy: We process the data of our customers, clients as well as interested parties and other clients or contractual partners (uniformly referred to as “customers”) in order to be able to provide them with our contractual or pre-contractual services, in particular consultancy services. The processed data, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and business relationship.

Insofar as it is necessary for our fulfilment of the contract or required by law, or if the consent of the customer has been obtained, we disclose or transfer the customer’s data to third parties or agents, such as authorities, courts or in the field of IT, office or comparable services, in compliance with the requirements of professional law.

Events and functions: We process the data of participants in the events, functions and similar activities offered or organised by us (hereinafter uniformly referred to as “participants” and “functions”) in order to enable them to participate in the functions and to make use of the services or activities associated with participation.

If we process health-related data, religious, political or other special categories of data in this context, then this is done in the context of publicity (e.g. at thematically oriented events or serves health care, security or is done with the consent of the persons concerned).

The required information is identified as such within the scope of the order, contract or comparable contract conclusion and includes the information required for the provision of services and invoicing as well as contact information in order to be able to make any necessary arrangements. Insofar as we have access to information from end customers, employees or other persons, we process this information in accordance with legal and contractual requirements.

brokerage services: We process the information provided by the interested parties in the context of the placement request for the purpose of establishing, implementing and, if applicable, terminating a contract for the placement of offers from providers of the products or services requested by them.

We use the contact data of interested parties to specify their enquiry by means of the agreed or otherwise permitted communication channel (e.g. telephone or e-mail) and to suggest suitable suppliers or offers to them on the basis of the specified enquiry. In addition, we can ask interested parties at a later date, in accordance with legal requirements, questions about the success of our mediation service.

We process the data of the interested parties as well as of the providers in order to fulfil our contractual obligations, in order to link the enquiry of the interested parties with the offers of the providers that are suitable for them and to forward them to the corresponding providers or to suggest the providers.

We can record the entries in the online form sent by interested parties in order to be able to prove the existence of the contractual relationship and the interested parties’ consents in accordance with the statutory accountability obligations (Art. 5 Para. 2 DSGVO). This information will be stored for a period of three to four years if we need to prove the original request (e.g. to prove the authorisation to contact the interested parties).

Further information on commercial services: We process the data of our clients and principals (hereinafter referred to collectively as “clients”) in order to enable them to select, purchase or commission the selected services or works and related activities, as well as to pay for and deliver or execute or provide them.

The required information is identified as such within the scope of the order, contract or comparable contract conclusion and includes the information required for the provision of services and invoicing as well as contact information in order to be able to make any necessary arrangements.

  • Processed data types: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Special categories of personal data: Health data (Art. 9 para. 1 DGSVO), data concerning sexual life or sexual orientation (Art. 9 para. 1 DGSVO), religious or philosophical beliefs (Art. 9 para. 1 DGSVO), data revealing racial or ethnic origin.
  • Persons concerned: Interested parties, business and contractual partners, customers.
  • Purposes of the processing: Contractual services and performances, contact requests and communication, office and organisational procedures, management and answering of requests, security measures, visit evaluation, interest based and behavioural marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing actions).
  • Legal bases: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), Legal obligation (Art. 6 para. 1 sentence 1 lit. c. DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO), Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO).

Use of online marketplaces for e-commerce

We offer our services on online platforms operated by other service providers. In this context, the data protection notices of the respective platforms apply in addition to our data protection notices. This applies in particular with regard to the methods used on the platforms for measuring reach and for interest-based marketing.

  • Processed data types: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: customers.
  • Purposes of processing: contractual and service.
  • Legal bases: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Services used and service providers:

  • Amazon: Online marketplace for e-commerce; service provider: Amazon Europe Core S.à.r.l., Amazon EU S.à.r.l., Amazon Services Europe S.à.r.l. and Amazon Media EU S.à.r.l., all four located at 38, avenue John F. Kennedy, L-1855 Luxembourg, and Amazon Instant Video Germany GmbH, Domagkstr. 28, 80807 Munich (together “Amazon Europe”), parent company: Amazon.com, Inc, 2021 Seventh Ave, Seattle, Washington 98121, USA; Website: https://www.amazon.de/; Privacy Policy: https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010.
  • Digistore24: Online marketplace for e-commerce; service provider: Digistore24 GmbH, St.-Godehard-Straße 32, 31139 Hildesheim, Germany; Website: https://www.digistore24.com/; Privacy policy: https://www.digistore24.com/de/home/extern/cms/page/frontend/legal/privacy.
  • elopage: Online marketplace for e-commerce; service provider: elopay GmbH, Skalitzer Straße 138, 10999 Berlin, Germany, Germany; website: https://elopage.com/; privacy policy: https://elopage.com/privacy.

Payment service provider

Within the framework of contractual and other legal relationships, due to legal obligations or otherwise based on our legitimate interests, we offer the persons concerned efficient and secure payment options and use other payment service providers in addition to banks and credit institutions (collectively “payment service providers”).

The data processed by the payment service providers include inventory data, such as name and address, bank data, such as account or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient related data. These details are required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored by them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the payment service providers may transfer the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the general terms and conditions and the data protection information of the payment service providers.

For payment transactions, the terms and conditions and the data protection information of the respective payment service providers apply, which can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and the assertion of rights of revocation, information and other rights of affected persons.

  • Processed data types: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Customers, interested parties.
  • Purposes of processing: contractual benefits and services, contact requests and communication, affiliate tracking.
  • Legal bases: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Services used and service providers:

  • Giropay: Payment Services; Service Provider: giropay GmbH, An der Welle 4, 60322 Frankfurt, Germany; Website: https://www.giropay.de; Privacy Policy: https://www.giropay.de/rechtliches/datenschutzerklaerung/.
  • Klarna / Sofortüberweisung: payment services; service provider: Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden; website: https://www.klarna.com/de; privacy policy: https://www.klarna.com/de/datenschutz.
  • Mastercard: payment services; service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; website: https://www.mastercard.de/de-de.html; privacy policy: https://www.mastercard.de/de-de/datenschutz.html.
  • PayPal: payment services and solutions (e.g. PayPal, PayPal Plus, Braintree); service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; website: https://www.paypal.com/de; privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
  • Stripe: payment services; service provider: Stripe, Inc, 510 Townsend Street, San Francisco, CA 94103, USA; website: https://stripe.com/de; privacy policy: https://stripe.com/de/privacy.
  • Visa: payment services; service provider: Visa Europe Services Inc, London Branch, 1 Sheldon Square, London W2 6TT, UK; website: https://www.visa.de; privacy policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html.

Provision of the online offer and web hosting

In order to be able to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security and technical maintenance services.

The data processed within the framework of the provision of the hosting offer may include all data relating to the users of our online offer, which are generated within the framework of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as other information concerning the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The above-mentioned 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 in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of the e-mails between the sender and the receipt on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files called up, the date and time of the call-up, the amount of data transferred, notification of successful call-up, 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 on the one hand for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and on the other hand to ensure the capacity utilisation of the servers and their stability.

Content Delivery Network: We use a “Content Delivery Network” (CDN). A CDN is a service that enables the content of an online offer, especially large media files such as graphics or programme scripts, to be delivered more quickly and securely with the help of regionally distributed servers connected via the Internet.

  • Processed data types: Content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Content Delivery Network (CDN), contractual services and service, coverage measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behaviour-related profiling, use of cookies), visitor action evaluation, server monitoring and error recognition, contact requests and communication, remarketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures).
  • Legal bases: legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO), consent (Art. 6 para. 1 sentence 1 lit. a DSGVO).

Services used and service providers:

  • 1&1 IONOS: Hosting platform for e-commerce / websites; service provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany; website: https://www.ionos.de; privacy policy: https://www.ionos.de/terms-gtc/terms-privacy.
  • Homepage-Baukasten.de: Hosting platform for blogs / websites; service provider: webme GmbH, Virchowstraße 20B, 90409 Nürnberg, Germany; website: https://www.homepage-baukasten.de/; privacy policy: https://www.homepage-baukasten.de/de/Datenschutzerklaerung.php.
  • Jimdo: hosting platform for blogs / websites; service provider: Jimdo GmbH, Stresemannstr. 375, 22761 Hamburg, Germany; Website: https://de.jimdo.com; Privacy Policy: https://de.jimdo.com/info/datenschutzerklaerung.
  • Squarespace: Squarespace offers software as a service for the creation and hosting of websites. service provider: Squarespace, Inc. 8 Clarkson St, New York, NY 10014, USA; website: https://www.squarespace.com; privacy policy: https://www.squarespace.com/privacy.
  • Webflow: We use webflow services to create static websites, which can also contain online forms. Service provider: Webflow, Inc. 208 Utah, Suite 210, San Francisco, CA 94103, USA; website: https://webflow.com; privacy policy: https://webflow.com/legal/eu-privacy-policy.
  • Webnode: hosting platform for e-commerce / websites; service provider: Webnode AG, Gartenstrasse 3, 6304 Zug, Switzerland; Website: https://de.webnode.com; Privacy policy: https://de.webnode.com/datenschutzerklaerung/.
  • Weebly: hosting platform for e-commerce / websites; service provider: Square, Inc., 1455 Market Street Suite 600 San Francisco, CA 94103, USA; website: https://www.weebly.com/de; privacy policy: https://www.weebly.com/de/privacy/.
  • Wix: hosting platform for websites; service provider: Wix.com ltd., Tel Aviv, 500 Terry A. Francois Boulevard, San Francisco, California 94158, USA; website: https://www.wix.com; privacy policy: https://de.wix.com/about/privacy.

Special notes on applications (apps)

We process the data of the users of our application to the extent necessary to provide the users with the application and its functionalities, to monitor its security and to develop it further. We may also contact users in compliance with the legal requirements if the communication is necessary for purposes of administration or use of the application. In addition, with regard to the processing of user data, we refer to the data protection information in this privacy policy.

Legal basis: The processing of data required for the provision of the functionalities of the application serves the fulfilment of contractual obligations. This also applies if the provision of the functions requires user authorisation (e.g. release of device functions). If the processing of data is not necessary for the provision of the functionalities of the application, but serves the security of the application or our business interests (e.g. collection of data for the purpose of optimising the application or security purposes), it is carried out on the basis of our legitimate interests. If users are expressly requested to give their consent to the processing of their data, the data covered by the consent will be processed on the basis of the consent.

Device authorisations for access to functions and data: The use of our application or its functionalities may require user authorisations for access to certain functions of the devices used or to the data stored on the devices or accessible by means of the devices. By default, these authorisations must be granted by the users and can be revoked at any time in the settings of the respective devices. The exact procedure for controlling app authorisations may depend on the device and the software used by the users. Users can contact us if they require further explanation. We would like to point out that the refusal or revocation of the respective authorisations can affect the functionality of our application.

  • Processed data types: inventory data (e.g. names, addresses), meta/communication data (e.g. device information, IP addresses).
  • Purposes of processing: contractual and service.
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Purchase of applications via Appstores

Our application can be obtained via special online platforms operated by other service providers (so-called “appstores”). In this context, the data protection notices of the respective Appstores apply in addition to our data protection notices. This applies in particular with regard to the methods used on the platforms for measuring reach and for interest-related marketing as well as possible cost obligations.

  • Processed data types: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: customers.
  • Purposes of processing: contractual and service.
  • Legal bases: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Services used and service providers:

  • Apple App Store: app and software sales platform; service provider: Apple Inc, Infinite Loop, Cupertino, CA 95014, USA; Web site: https://www.apple.com/de/ios/app-store/; Privacy policy: https://www.apple.com/legal/privacy/de-ww/.
  • Google Play: app and software sales platform; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://play.google.com/store/apps?hl=de; privacy policy: https://policies.google.com/privacy.
  • Microsoft Store: app and software sales platform; service provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Web site: https://www.microsoft.com/de-de/store/b/home; privacy statement: https://privacy.microsoft.com/de-de/privacystatement, security notice: https://www.microsoft.com/de-de/trustcenter.

Registration, login and user account

Users can create a user account. Within the scope of registration, users are provided with the required mandatory data and processed for the purpose of providing the user account on the basis of contractual obligation fulfilment. The processed data includes in particular the login information (name, password and an e-mail address). The data entered during registration is used for the purpose of using the user account and its purpose.

Users can be informed by e-mail about processes relevant to their user account, such as technical changes. If users have cancelled their user account, their data with regard to the user account will be deleted, subject to a legal obligation to keep records. It is the responsibility of the users to save their data before the end of the contract if they have terminated their user account. We are entitled to irretrievably delete all user data stored during the term of the contract.

When using our registration and login functions and the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests and those of the users in protection against misuse and other unauthorised use. As a matter of principle, 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.

online forum: Participation in the Forum requires registration, in which, unless otherwise specified in the registration form, you must provide a name or your name, a password and the 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 are advised of this during registration if necessary) and not used elsewhere. Contributions in the forum are visible to the public, unless their visibility is restricted 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 content of the entry. When registering and writing entries, the IP addresses of users are also stored if the entries contain illegal content and the IP addresses could be used for legal prosecution. The person responsible reserves the right to delete registrations and entries on the basis of an appropriate consideration.

Two-Factor Authentication: Two-Factor Authentication provides an additional layer of security for your account and ensures that only you can access your account, even if someone else knows your password.

For this purpose, you must perform another authentication operation in addition to your password (for example, enter a code sent to a mobile device). We will inform you about the procedure we use.

  • 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 concerned: Users (e.g. website visitors, users of online services).
  • Purposes of the processing: contractual and other services, security measures, management and response to requests.
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Single sign-on registration

Single sign-on” or “single sign-on registration or authentication” are procedures that allow users to register with a provider of single sign-on procedures (e.g. a social network), including our online service, with the help of a user account. The prerequisite for single sign-on authentication is that the users are registered with the respective single sign-on provider and enter the necessary 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 button.

Authentication takes place directly with the respective single sign-on provider. Within the scope of such authentication, we receive a user ID with the information that the user is logged in under this user ID at the respective single sign-on provider 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 selected data releases within the scope 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 choice of the users, different data can be used, usually the e-mail address and the user name. The password entered with the single sign-on provider within the scope 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 compared with their user account with the single sign-on provider, but that this is not always possible or actually takes place. If, for example, the users’ e-mail addresses change, they must change them manually in their user account with us.

We can use the Single Sign-On registration, if agreed with the users, within the framework of or prior to the fulfilment of the contract, if the users have been asked to do so, we can process the Single Sign-On registration within the framework of a consent and otherwise we use it on the basis of the legitimate interests on our part and the interests of the users in an effective and secure registration system.

If users should ever decide that they no longer want to use the link of 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 from our system, they must cancel their registration with us.

  • Data types processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Purposes of processing: contractual and other services, registration procedures.
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data are processed for the purposes of the publication medium only 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 within the framework of this data protection notice.

comments and contributions: If users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone leaves illegal content in comments and contributions (insults, prohibited political propaganda etc.). In this case we can be prosecuted ourselves for the comment or contribution and are therefore interested in the identity of the author.

Furthermore, we reserve the right, based on our legitimate interests, to process user data for the purpose of spam detection.

On the same legal basis, in the case of surveys, we reserve the right to store the IP addresses of users for the duration of the survey and to use cookies to avoid multiple votes.

The personal information provided in the comments and contributions, any contact and website information as well as the content data will be permanently stored by us until the user objects.

Profile pictures of Gravatar: We use the service Gravatar within our online offer and especially in our blog.

Gravatar is a service where users can register and store profile pictures and their email addresses. If users leave contributions or comments on other websites (especially blogs) using their e-mail address, their profile pictures can be displayed alongside the contributions or comments. For this purpose, the e-mail address provided by users is transmitted in encrypted form to Gravatar 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 Gravatar enables authors of articles and comments to personalise their contributions with a profile picture.

By displaying the images, Gravatar obtains the IP address of users, as this is necessary for communication between a browser and an online service.

If users do not want a user picture linked to their email address at Gravatar to appear in their comments, they should use an email address that 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 want their own e-mail address to be sent to Gravatar. Users can completely prevent the transmission of data 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 entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Purposes of processing: contractual services and service, feedback (e.g. collecting feedback via online form), security measures, administration and answering of enquiries, provision of our online offer and user-friendliness.
  • Legal bases: Performance of the contract and pre-contractual enquiries (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 used and service providers:

  • Profile pictures of Gravatar: Profile pictures; Service provider: Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA; website: https://automattic.com; privacy policy: https://automattic.com/privacy.

Contact

When contacting us (e.g. by contact form, e-mail, telephone or via social media), the data of the inquiring persons will be processed to the extent necessary to answer the contact enquiries and any requested measures.

The answering of contact enquiries within the framework of contractual or pre-contractual relations is carried out in order to fulfil our contractual obligations or to answer (pre)contractual enquiries and otherwise on the basis of our legitimate interest in answering the enquiries.

  • 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), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: communication partners.
  • Purposes of processing: contact requests and communication.
  • Legal bases: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Communication via Messenger

We use Messenger for communication purposes and therefore ask you to observe the following instructions regarding the functionality of the Messenger, encryption, use of the metadata of the communication and your right to object.

You can also contact us in alternative ways, e.g. by telephone or e-mail. Please use the contact details provided to you or the contact details given 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 a current version of Messenger with encryption enabled to ensure that the message content is encrypted.

However, we would like to point out to our communication partners that although the messenger providers cannot view the content, they can find out that and when communication partners communicate with us, as well as technical information on the communication partner’s device used and, depending on the settings of their device, also location information (so-called metadata) is processed.

Information 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 your consent and you contact us, for example, on your own initiative, we will use Messenger in relation to our contractual partners and in the context of contract preparation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our justified interests in fast and efficient communication and meeting the needs of our communication partners for communication via Messenger. Furthermore, we would like to point out that we will not transmit the contact data provided to us to Messenger for the first time without your consent.

Revocation, objection and deletion: You can revoke a given 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., 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 provided by the communication partners, if no reference to a previous conversation is to be expected and no legal storage obligations stand in the way of deletion.

Reservation of the reference to other communication channels: Finally, we would like to point out that for reasons of your security, we reserve the right not to answer enquiries via Messenger. This is the case if, for example, internal contractual matters require special confidentiality or if a reply via Messenger does not meet the formal requirements. In such cases we will refer you to more appropriate communication channels.

Skype: The end-to-end encryption of Skype requires its activation (unless it should be activated by default).

  • Processed data types: contact data (e.g. e-mail, telephone numbers), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), content data (e.g. text entries, photographs, videos).
  • Persons concerned: communication partners.
  • Purposes of processing: contact requests and communication, direct marketing (e.g. by e-mail or by post).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Services used and service providers:

  • Facebook Messenger: Facebook Messenger with end-to-end encryption (the end-to-end encryption of the Facebook Messenger requires activation unless it should be enabled by default); 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; opt-out: https://www.facebook.com/settings?tab=ads.
  • Microsoft Teams: Microsoft Teams – Messenger; Service Provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Web site: https://products.office.com; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, Security notice: https://www.microsoft.com/de-de/trustcenter.
  • Skype: Skype Messenger with end-to-end encryption; service provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; website: https://www.skype.com/de/; privacy policy: https://privacy.microsoft.com/de-de/privacystatement, security advice: https://www.microsoft.com/de-de/trustcenter.
  • Slack: Slack Messenger without end-to-end encryption; service provider: Slack Technologies, Inc, 500 Howard Street, San Francisco, CA 94105, USA; website: https://slack.com/intl/de-de/; privacy policy: https://slack.com/intl/de-de/legal.
  • Snapchat: Snapchat Messenger with end-to-end encryption; service provider: Snap Inc, 63 Market Street Venice, CA 90291 USA; Website: https://www.snapchat.com/l/de-de/; Privacy Policy: https://www.snap.com/de-DE/privacy/privacy-policy/.
  • Telegram Broadcasts: Telegram Broadcasts – Messenger with end-to-end encryption; service provider: Telegram, Dubai; Website: https://telegram.org/; Privacy Policy: https://telegram.org/privacy.
  • Threema: Threema Messenger with end-to-end encryption; service provider: Threema GmbH, Churerstrasse 82, 8808 Pfäffikon SZ, Switzerland; Website: https://threema.ch/en; Privacy policy: https://threema.ch/de/privacy.
  • WhatsApp: WhatsApp Messenger with end-to-end encryption; service provider: WhatsApp Inc WhatsApp Legal 1601 Willow Road Menlo Park, California 94025, USA; Web site: https://www.whatsapp.com/; Privacy policy: https://www.whatsapp.com/legal.

Chatbots and chat functions

We offer online chats and chatbot functions as a means of communication (collectively referred to as “Chat Services”). A chat is an online conversation conducted with a certain amount of timeliness. A chatbot is a piece of software which answers users’ questions or informs them of messages. If you use our chat functions, we may process your personal data.

If you use our chat services within an online platform, your identification number is also stored within the respective platform. We may also collect information about which users interact with our chat services and when. Furthermore, we store the content of your conversations via the chat services and log registration and consent processes in order to be able to prove these in accordance with legal requirements.

We point out to users that the respective platform provider may find out that and when users communicate with our chat services and collect technical information on the user’s device used and, depending on the settings of their device, also location information (so-called metadata) for the purpose of optimising the respective services and for security purposes. Likewise, the metadata of communication via chat services (i.e. information on who has communicated with whom, for example) could be used by the respective platform providers for marketing purposes or to display advertising tailored to users in accordance with their regulations, to which we refer for further information.

If users agree to activate information with regular messages to a chatbot, they have the possibility to unsubscribe at any time. The chatbot will point out to Users how and with what terms they can unsubscribe from the messages. By unsubscribing from the chatbot messages, Users’ data are deleted from the directory of message recipients.

We use the aforementioned information to operate our chat services, e.g. to address users personally, to answer their queries, to transmit any requested content and also to improve our chat services (e.g. to “teach” chat offers answers to frequently asked questions or to identify unanswered queries).

Legal notice: We use the chat services on a consent basis where we have previously obtained permission from users to process their data as part of our chat services (this applies to cases where users are asked for consent, e.g. so that a chatbot can send them regular messages). If we use chat services to answer users’ questions about our services or our company, this is done for contractual and pre-contractual communication. In addition, we use chat services on the basis of our legitimate interests in optimising the chat services, their economic efficiency and increasing the positive user experience.

Revocation, objection and deletion: You can revoke a given consent or object to the processing of your data within the scope of our chat services at any time.

  • Processed data types: contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: communication partners.
  • Purposes of processing: contact requests and communication, direct marketing (e.g. by e-mail or by post).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Push News

With the consent of the users, we can send the users so-called “push notifications”. These are messages that are displayed on users’ screens, terminals or browsers, even if our online service is not being actively used.

In order to register for the push messages, users must confirm that their browser or terminal device has been queried to receive the push messages. This approval process is documented and stored. The storage is necessary to recognise whether users have consented to receive the push messages and to be able to prove their consent. For these purposes, a pseudonymous identifier of the browser (so-called “push token”) or the device ID of a terminal device is stored.

Push messages may be necessary for the fulfilment of contractual obligations (e.g. technical and organisational information relevant to the use of our online offer) and are otherwise sent, unless specifically mentioned below, on the basis of the user’s consent. Users can change the receipt of push messages at any time using the notification settings of their respective browsers or terminals.

Push messages with promotional content: The push notifications we send may contain promotional information. The promotional push messages are processed on the basis of user consent. If the contents of the push messages are specifically described in the context of consent to receive the advertising push messages, the descriptions are decisive for the consent of the users. In addition, our newsletters contain information about our services and us.

Location-dependent sending of push messages: The push notifications sent by us can be displayed depending on the location of the users, based on the location data transmitted by the terminal device used.

Analysis and performance measurement: We statistically evaluate push messages and can thus identify if and when push messages were displayed and clicked on. This information is used for the technical improvement of our push messages based on the technical data or the target groups and their retrieval behaviour or retrieval times. This analysis also includes determining whether push messages are opened, when they are opened and whether users interact with their content or buttons. For technical reasons, this information can be allocated to the individual push message recipients. However, it is neither our intention nor, if used, that of the push message service provider to monitor individual users. Rather, the evaluations serve to identify the usage habits of our users and to adapt our push messages to them or to send different push messages according to the interests of our users.

The evaluation of the push messages and the measurement of success are based on the explicit consent of the users, which is given with their consent to receive the push messages. Users may object to the analysis and performance measurement by unsubscribing from the Push Messages. Unfortunately, it is not possible to cancel the analysis and performance measurement separately.

  • Types of data processed: location data (data indicating the location of an end-user’s terminal equipment), usage data (e.g. web pages visited, interest in content, access times).
  • Purposes of processing: Contractual services and service, direct marketing (e.g. by e-mail or post), range measurement (e.g. access statistics, recognition of returning visitors).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), performance of the contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO).

Video conferences, online meetings, webinars and screen sharing

We use platforms and applications of other providers (hereinafter referred to as “Third Party Providers”) for the purpose of holding video and audio conferences, webinars and other types of video and audio meetings. When selecting the third-party providers and their services, we observe the legal requirements.

In this context, data of the communication participants are processed and stored on the servers of third party providers, as far as they are part of communication processes with us. This data may include, in particular, registration and contact data, visual and vocal contributions, as well as entries in chats and shared screen content.

If users are referred to the third-party providers, or their software or platforms, in the course of communication, business or other relations with us, the third-party providers may process usage data and metadata for security, service optimisation or marketing purposes. We therefore ask you to observe the data protection notices of the respective third party providers.

Notes on legal bases: If we ask users for their consent to use the third-party providers or certain functions (e.g. consent to a recording of conversations), the legal basis for processing is consent. Furthermore, their use can be a component of our (pre)contractual services, provided that the use of the third-party providers has been agreed in this context. Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners. In this context we would like to refer you additionally to the information on the use of cookies in this data protection declaration.

  • 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), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Communication partners, users (e.g. website visitors, users of online services).
  • Purposes of processing: contractual services and performances, contact requests and communication, office and organisational procedures, direct marketing (e.g. by e-mail or by post).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Services used and service providers:

  • Google Hangouts / Meet: Messenger and conference software; 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://hangouts.google.com/; privacy policy: https://policies.google.com/privacy.
  • GoToMeeting: conference software; service provider: LogMeIn Ireland Limited, Bloodstone Building Block C 70, Sir John Rogerson’s Quay Dublin 2, Ireland, parent company: LogMeIn, Inc, 320 Summer Street, Boston, MA 02210 320 Summer Street Boston, Massachusetts 02210, USA; website: https://www.gotomeeting.com/de-de; privacy policy: https://www.logmeininc.com/de/legal/privacy.
  • Microsoft Teams: messenger and conferencing software; service providers: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Web site: https://products.office.com; privacy statement: https://privacy.microsoft.com/de-de/privacystatement, security notice: https://www.microsoft.com/de-de/trustcenter.
  • Skype: messenger and conference software; service provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Website: https://www.skype.com/de/; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement, Security Notice: https://www.microsoft.com/de-de/trustcenter.
  • Slack: messenger and conferencing software; service provider: Slack Technologies, Inc, 500 Howard Street, San Francisco, CA 94105, USA; website: https://slack.com/intl/de-de/; privacy policy: https://slack.com/intl/de-de/legal.
  • TeamViewer: conference software; service provider: TeamViewer GmbH, Jahnstr. 30, 73037 Göppingen, Germany; Website: https://www.teamviewer.com/de; Privacy policy: https://www.teamviewer.com/de/datenschutzerklaerung/.
  • Zoom: video conferences, web conferences and webinars; service providers: Zoom Video Communications, Inc., 55 Almaden Blvd., Suite 600, San Jose, CA 95113, USA; Website: https://zoom.us; Privacy Policy: https://zoom.us/docs/de-de/privacy-and-legal.html; Standard Contractual Clauses (Ensuring Level of Data Protection for Processing in Third Countries): https://zoom.us/docs/de-de/privacy-and-legal.html (Referred to as Global DPA).

Music and podcasts

We use hosting and analysis services provided by service providers to make our audio content available for listening or downloading and to obtain statistical information on the retrieval of the audio content.

Podlove: Both the Podlove Subscribe Button and the Podlove Web Player are delivered by keycdn.com (keycdn GDPR statement). The Podlove Publisher records download statistics. IP addresses are used to estimate geographical location (city / country). They are stored temporarily (up to 48 hours) as part of a request ID. This is necessary so that the podcast operator can understand the viability of his or her efforts. In order to be able to determine realistic download figures, the system must be able to detect renewed access to the same file by the same user. The only reliable way to achieve this is to look at the IP address together with the user agent. It is not possible to use an anonymous IP address, as this would lead to false results. Accessing the same file from the same user on different days can be considered as a separate download. It is therefore sufficient to keep IP addresses only for up to 48 hours. After 48 hours, request IDs are anonymised. This makes it impossible to restore the originally contained IP address. The user agent of the browser used is also saved.

The podcast downloads can be made available through https://bitlove.org/ via BitTorrent, where your browser connects directly to Bitlove’s servers.

Buttons of the micropayment service “Flattr”, Flattr AB, Box 4111, 203 12 Malmö, Sweden, can also be integrated, whereby your browser establishes a direct connection to Flattr’s servers. If you have created an account with Flattr with which you are logged in at the same time, Flattr will receive information that you have visited the relevant page of our online service. If you have a Flattr account, are logged in and interact with the button, information about this is sent to Flattr and stored there for billing purposes in accordance with the guidelines applicable there. Even if you are not logged in, usage data may be collected and stored. You can find out exactly how your data is processed when you click on the Flattr button at flattr.com/privacy.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Purposes of processing: range measurement (e.g. access statistics, recognition of returning visitors), visitor action evaluation, profiling (creation of user profiles), tracking (e.g. interest/behaviour-related profiling, use of cookies).
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Services used and service providers:

  • Anchor: Anchor – music and podcast hosting; service provider: Anchor, Spotify C/O Anchor, 150 Greenwich St, New York, NY 10007; website: https://anchor.fm/; privacy policy: https://anchor.fm/privacy.
  • Blubrry: Blubrry – Musik- und Podcasthosting; Dienstanbieter: Rawvoice, Inc. 5000 Arlington Centre Blvd., Building 2, Suite 2115, Upper Arlington, Ohio 43220 17525 Egan Drive Coopersville, Michigan 49404, USA; Website: https://soundcloud.com; Datenschutzerklärung: https://create.blubrry.com/resources/about-blubrry/privacy-policy/.
  • libsyn: libsyn – music and podcast hosting; service provider: Liberated Syndication Inc, Pittsburgh, Pennsylvania, USA; Website: https://www.libsyn.com/; Privacy Policy: https://www.libsyn.com/privacy-policy.
  • Podetize: Podetize – music and podcast hosting; service provider: Podetize; website: https://www.podetize.com.
  • Podhost: Podhost – music and podcast hosting; service provider: Podetize; website: https://www.podhost.de/; privacy policy: https://www.podhost.de/privacy.
  • Podlove: Podlove & Bitlove – distribution and playback of podcats; service provider: Podlove (an open initiative); website: https://podlove.org; privacy policy: https://docs.podlove.org/podlove-publisher/guides/dsgvo-gdpr.html.
  • Podigee: Podigee – music and podcast hosting; service provider: Podigee GmbH, Schlesische Straße 20, 10997 Berlin, Germany; Website: https://www.podigee.com/de; Privacy Policy: https://www.podigee.com/de/about/privacy/.
  • Podtrac: Metrics and data analysis of podcast target groups across all access sources; service providers: Podtrac, Inc., PO Box 30576, Alexandria, VA 22310, USA; website: https://podtrac.com; privacy policy: https://analytics.podtrac.com/product-privacy-statement.
  • Soundcloud: Soundcloud – music hosting; service provider: SoundCloud Limited, Rheinsberger Str. 76/77, 10115 Berlin, Germany; Website: https://soundcloud.com; Privacy Policy: https://soundcloud.com/pages/privacy.
  • Spotify: Spotify – music hosting and 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/.
  • Another hosting/analysis service provider: service provider: The audio content is stored and retrieved by a hosting provider in accordance with legal requirements.

Application procedure

The application procedure requires applicants to provide us with the data required for their assessment and selection. Which information is required can be found in the job description or, in the case of online forms, in the information provided there.

In principle, the required information includes personal details such as name, address, a contact option and proof of the qualifications required for a job. On request, we will also be happy to provide you with the necessary information.

If provided, applicants can send us their applications using an online form. The data will be encrypted and transmitted to us according to the state of the art. Applicants can also send us their applications by e-mail. Please note, however, that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received. We can therefore not accept any responsibility for the transmission path of the application between the sender and receipt on our server.

For the purposes of searching for applicants, submitting applications and selecting applicants, we may, subject to legal requirements, use applicant management or recruitment software and platforms and services of third parties.

Applicants are welcome to contact us regarding the method of submitting their application or send us their application by post.

Processing of special categories of data: If special categories of personal data within the meaning of Art. 9 Par. 1 DSGVO (e.g. health data such as severely disabled persons or ethnic origin) are requested from applicants in the context of the application procedure so that the person responsible or the data subject can exercise the rights arising to him or her from labour law and social security and social protection law and fulfil his or her obligations in this respect, their processing is carried out in accordance with Art. 9 Par. 2 letter b. DSGVO, in the case of protection of vital interests of applicants or other persons pursuant to Art. 9 para. 2 lit. c. DSGVO or for purposes of health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnosis, for care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 para. 2 lit. h. DSGVO. In the case of a communication of special categories of data based on voluntary consent, their processing is based on Art. 9 para. 2 lit. a. DSGVO.

Deletion of data: In the event of a successful application, the data provided by the applicants may be processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicants’ data will be deleted. The applicants’ data will also be deleted if an application is withdrawn, which the applicants are entitled to do at any time. Subject to a justified revocation by the applicants, the deletion will take place at the latest after a period of six months, so that we can answer any follow-up questions regarding the application and fulfil our obligations to provide evidence in accordance with the regulations on the equal treatment of applicants. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements.

Admission to an applicant pool: Admission to an applicant pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the current application procedure and that they can withdraw their consent at any time in the future.

  • Types of data processed: Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, CV, certificates and other information on the applicant’s person or qualification provided by applicants with regard to a specific position or voluntarily).
  • Persons concerned: applicants.
  • Purposes of processing: application procedure (establishment and possible subsequent implementation and possible subsequent termination of employment.)
  • Legal basis: Art. 9 (1) sentence 1 letter b DSGVO (application procedure as a pre-contractual or contractual relationship) (Insofar as special categories of personal data within the meaning of Art. 9 (1) DSGVO (e.g. health data, such as severely handicapped status or ethnic origin) are requested from applicants during the application procedure in order to enable the responsible person or the data subject to exercise the rights arising to him or her from labour law and social security and social protection law and to fulfil his or her obligations in this respect, they are processed in accordance with Art. 9 Paragraph 2 letter b. DSGVO, in the case of protection of vital interests of applicants or other persons pursuant to Art. 9 para. 2 lit. c. DSGVO or for purposes of health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnosis, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 para. 2 lit. h. DSGVO. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 para. 2 lit. a. DSGVO).

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 following purposes: document storage and management, calendar management, e-mailing, spreadsheets and presentations, exchanging documents, content and information with specific recipients or publishing web pages, forms or other content and information, as well as chatting and participating in audio and video conferences.

In this context, personal data may be processed and stored on the servers of the providers, as far as they are part of communication processes with us or otherwise processed by us as described in this privacy policy. This data may include, in particular, master data and contact details of users, data on procedures, contracts, other processes and their contents. The providers of the cloud services also process usage data and metadata which they use for security purposes and for service optimisation.

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 the users’ devices for web analysis purposes or to remember user settings (e.g. in the case of media control).

Notes on legal bases: If we ask for consent to use the cloud services, the legal basis for processing is consent. Furthermore, their use can be a component of our (pre)contractual services, provided that the use of the cloud services has been agreed in this context. Otherwise, user data will be processed on the basis of our legitimate interests (i.e., interest in efficient and secure administration and collaboration processes)

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), contract data (e.g. subject matter of the contract, duration, customer category).
  • Persons concerned: Customers, employees (e.g. employees, applicants, former employees), interested parties, communication partners.
  • Purpose of the processing: office and organisational procedures.
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Services used and service providers:

  • Apple iCloud: cloud storage services; service provider: Apple Inc, Infinite Loop, Cupertino, CA 95014, USA; Web site: https://www.apple.com/de/; Privacy policy: https://www.apple.com/legal/privacy/de-ww/.
  • Dropbox: Cloud storage services; service provider: Dropbox, Inc, 333 Brannan Street, San Francisco, California 94107, USA; website: https://www.dropbox.com/de; privacy policy: https://www.dropbox.com/privacy; standard contractual clauses (ensuring a level of data protection when processing in third countries): https://www.dropbox.com/terms/business-agreement-2016.
  • Google Cloud Services: cloud storage services; service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://cloud.google.com/; Privacy Policy: https://www.google.com/policies/privacy, Security Notice: https://cloud.google.com/security/privacy; Standard Contractual Clauses (ensuring a level of data protection when processing in third countries): https://cloud.google.com/terms/data-processing-terms; Additional Privacy Notice: https://cloud.google.com/terms/data-processing-terms.
  • Microsoft Cloud Services: cloud storage services; service providers: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; website: https://microsoft.com/de-de; privacy statement: https://privacy.microsoft.com/de-de/privacystatement, security advice: https://www.microsoft.com/de-de/trustcenter.
  • TeamDrive: cloud storage services; service provider: TeamDrive Systems GmbH, Max-Brauer-Allee 50, 22765 Hamburg, Germany; website: https://teamdrive.com; terms and conditions: https://teamdrive.com/datenschutzerklaerung/.
  • Telekom Magentacloud: cloud storage services; service provider: Telekom Deutschland GmbH, Landgrabenweg 151, 53227 Bonn, Germany; Website: https://cloud.telekom-dienste.de/; Privacy Policy: https://www.telekom.de/datenschutz-ganz-einfach.
  • Web.de Freemail Online storage: cloud storage services; service provider: 1&1 Mail & Media GmbH, Karlsruhe branch, Brauerstr. 48, 76135 Karlsruhe, Germany; website: https://web.de/online-speicher/; privacy policy: https://web.de/datenschutz/.

Newsletter and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter “newsletters”) only with the consent of the recipients or a legal permission. If, in the course of registering for the newsletter, its contents are specifically described, they are decisive for the consent of the users. Furthermore, 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 for the purpose of personal contact in the newsletter, or other details if these are required for the purposes of the newsletter.

Double-Opt-In procedure: The registration for our newsletter is always done in a so-called Double-Opt-In-Process. 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 foreign e-mail addresses. The newsletter registrations are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored by the dispatch service provider are also logged.

Deletion and restriction of processing: We may store the deleted e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that we have previously given our 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 case of obligations to permanently observe objections, we reserve the right to store the e-mail address in a blacklist for this purpose alone.

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 sending system.

Information on legal bases: The dispatch of the newsletters is based on the consent of the recipients or, if consent is not required, on our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of advertising to existing customers. If we commission a service provider to send 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 in order to prove that it has been carried out in accordance with the law.

contents: Information about us, our services, actions and offers.

Analysis and success measurement: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened, or from the server of the newsletter provider if we use a mailing service provider. Within the framework of this retrieval, technical information such as information on 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 on the basis of technical data or target groups and their reading behaviour on the basis of their retrieval locations (which can be determined by means of the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be allocated to individual newsletter recipients. However, it is neither our endeavour nor, if used, that of the dispatch service provider to observe individual users. The evaluations rather serve to identify 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 evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves our business interests and meets the expectations of the users.

A separate revocation of the performance measurement is unfortunately not possible. In this case, the entire newsletter subscription must be cancelled or objected to.

Condition for the use of free services: Consent to the sending of mailings may be made conditional as a prerequisite for the use of free services (e.g. access to certain contents or participation in certain campaigns). If users wish to take advantage of the free services without registering for the newsletter, please contact us.

Sending via SMS: Electronic notifications can also be sent as SMS text messages (or are sent exclusively via SMS if the authorisation to send, e.g. consent, only includes sending via SMS).

  • Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
  • Persons concerned: Communication partners, users (e.g. website visitors, users of online services).
  • Purposes of processing: direct marketing (e.g. by e-mail or postal mail), contractual services and service.
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
  • Opt-out: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably e-mail.

Services used and service providers:

  • ActiveCampaign: E-Mail-Marketing-Plattform; Dienstanbieter: ActiveCampaign, Inc., 1 N Dearborn, 5th Floor Chicago, Illinois 60602, USA; Website: https://www.activecampaign.com; Datenschutzerklärung: https://www.activecampaign.com/privacy-policy/.
  • Click Tip: Service provider: KLICK-TIPP Ltd, 15 Cambridge Court, 210 Shepherd’s Bush Road, London W6 7NJ, GB; website: https://www.klick-tipp.com; privacy policy: https://www.klick-tipp.com/datenschutzerkl%C3%A4rung.
  • Mailchimp: email marketing platform; service provider: “Mailchimp” – Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; website: https://mailchimp.com; privacy policy: https://mailchimp.com/legal/privacy/.

Advertising communication via e-mail, post, fax or telephone

We process personal data for the purposes of advertising communication, which can take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.

Recipients have the right to revoke any consent given or to object to the promotional communication at any time.

After revocation or objection, we may store the data required to prove consent for up to three years on the basis of our legitimate interests before we delete it. 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.

  • Data types processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
  • Persons concerned: communication partners.
  • Purposes of processing: direct marketing (e.g. by e-mail or by post).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Raffles and competitions

We process personal data of participants in competitions and contests only in compliance with the relevant data protection regulations, insofar as the processing is contractually necessary for the provision, implementation and handling of the competition, the participants have consented to the processing or the processing serves our legitimate interests (e.g. in the security of the competition or the protection of our interests from misuse by possible recording of IP addresses when submitting competition entries).

If contributions of the participants are published in the context of the competitions (e.g. in the context of a vote or presentation of the competition contributions or the winners or the reporting on the competition), we point out that the names of the participants can also be published in this context. The participants can object to this at any time.

If the competition takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as “online platform”), the usage and data protection provisions of the respective platforms shall apply in addition. In these cases, we would like to point out that we are responsible for the information provided by the participants in the course of the competition and that enquiries regarding the competition should be addressed to us.

The participants’ data will be deleted as soon as the competition or contest is over and the data is no longer required to inform the winners or because further inquiries about the competition can be expected. In principle, the participants’ data will be deleted at the latest 6 months after the end of the competition. Winners’ data may be retained for longer, e.g. in order to be able to answer questions about the prizes or to fulfil the prize services; in this case the retention period depends on the type of prize and is up to three years in the case of items or services, for example, in order to be able to process warranty claims. Furthermore, the participants’ data may be stored for longer, e.g. in the form of reports on the competition in online and offline media.

If data has also been collected for other purposes within the framework of the competition, its processing and the duration of storage are governed by the data protection information on this use (e.g. in the case of registration for the newsletter within the framework of a competition).

  • Processed data types: inventory data (e.g. names, addresses), content data (e.g. text entries, photographs, videos).
  • Persons concerned: Competitors and participants in competitions.
  • Purpose of processing: organisation of competitions and contests.
  • Legal basis: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO).

Surveys and questionnaires

The surveys and questionnaires we conduct (hereinafter referred to as “surveys”) are evaluated anonymously. Personal data is only processed to the extent that this is necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address to display the survey in the user’s browser or to enable a resumption of the survey by means of a temporary cookie (session cookie)) or users have consented to this.

Legal basis: If we ask the participants to give their consent to the processing of their data, this is the legal basis for the processing, otherwise the processing of the participants’ data is based on our legitimate interest in conducting an objective survey.

  • Processed data types: contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Communication partners, users (e.g. website visitors, users of online services).
  • Purposes of processing: contact requests and communication, direct marketing (e.g. by e-mail or postal mail), tracking (e.g. interest/behavioural profiling, use of cookies), profiling (creation of user profiles), feedback (e.g. collection of feedback via online form), surveys and questionnaires (e.g. surveys with input options, multiple choice questions).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Services used and service providers:

  • Crowdsignal: Crowdsignal survey services; service provider: Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA; Website: https://crowdsignal.com/; Privacy Policy: https://automattic.com/privacy/.
  • Google form: Google Cloud Forms; 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://firebase.google.com; privacy policy: https://policies.google.com/privacy; opt-out: opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, advertising display settings: https://adssettings.google.com/authenticated.
  • LimeSurvey: LimeSurvey survey services; service provider: LimeSurvey GmbH Survey Services & Consulting, Papenreye 63, 22453 Hamburg, Germany; Website: https://www.limesurvey.org/de; Privacy Policy: https://www.limesurvey.org/de/richtlinien/datenschutzrichtlinie.
  • Qualtrics: Qualtrics survey services; service provider: Qualtrics LLC, Address: 2250 N. University Pkwy, 48-C, Provo, Utah 84604, USA; website: https://www.qualtrics.com/de/; privacy policy: https://www.qualtrics.com/privacy-statement/.
  • SurveyMonkey: SurveyMonkey Umfragedienste; Dienstanbieter: SurveyMonkey Inc., 1 Curiosity Way, San Mateo, California 94403, USA; Website: https://www.surveymonkey.de; Datenschutzerklärung: https://www.surveymonkey.de/mp/policy/privacy-policy/?ut_source=footer.
  • Survmetrics: Survmetrics survey services; service provider: Survmetrics, Inc. Chihuahua 230, Roma Norte, Ciudad de Mexico, DF 06700, USA; website: https://survmetrics.com/; privacy policy: https://survmetrics.com/privacy-policy/.
  • Typeform: creation of forms as well as surveys and management of participant contributions; service provider: TYPEFORM SL, Carrer Bac de Roda, 163, local, 08018 – Barcelona, Spain; website: https://www.typeform.com/; privacy policy: https://admin.typeform.com/to/dwk6gt/.

Web analysis, monitoring and optimisation

Web analysis (also known as “reach measurement”) is used to evaluate the streams of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the reach analysis we can, for example, identify at what time our online offer or its functions or contents are most frequently used or invite reuse. We can also understand which areas require optimisation.

In addition to web analysis, we can also use test procedures, for example to test and optimise different versions of our online offer or its components.

For these purposes, so-called user profiles can be created and stored in a file (so-called “cookie”) or similar procedures with the same purpose can be used. This information may include, for example, the content viewed, the websites visited and the elements used on them, and technical details such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this data may also be processed, depending on the provider.

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 the users. In general, no clear user data (such as e-mail addresses or names) are stored in the context of web analysis, A/B testing and optimisation, but pseudonyms. This means that we as well as the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

Information on legal bases: If we ask users for their consent to use the third party providers, the legal basis for processing data is consent. Otherwise, the users’ 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.

  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Purposes of processing: range measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behaviour-related profiling, use of cookies), visitor action evaluation, profiling (creation of user profiles).
  • security measures: IP masking (pseudonymisation of the IP address).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

online marketing

We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the display of advertising and other content (collectively referred to as “Content”) based on the potential interests of users and the measurement of its effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which the user information relevant to the presentation of the aforementioned contents is stored. This information may include, for example, the content viewed, websites visited, online networks used, but also communication partners and technical details such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this data may also be processed.

The IP addresses of users are also stored. However, we use available IP masking procedures (i.e., pseudonymisation by shortening the IP address) to protect the users. In general, no clear user data (such as e-mail addresses or names) are stored within the framework of the online marketing procedure, but pseudonyms. This means that we as well as the providers of the online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can later generally also be read out on other websites that use the same online marketing procedure, analysed for the purpose of presenting content and supplemented with further data and stored on the server of the online marketing procedure provider.

As an exception, clear 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 methods we use and the network links the users’ profiles with the aforementioned data. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.

As a matter of principle, we only have access to summarised information about the success of our advertisements. However, in the course of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyse the success of our marketing measures.

Unless otherwise stated, we ask you to assume that cookies used are stored for a period of two years.

Information on legal bases: If we ask users for their consent to use the third party providers, the legal basis for processing data is consent. Otherwise, the users’ 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.

Facebook pixel: With the help of the Facebook pixel, Facebook is on the one hand able to determine the visitors of our online offer as a target group for the presentation of ads (so-called “Facebook ads”). Accordingly, we use the Facebook pixel in order to display the Facebook ads placed by us only to those users on Facebook and within the services of partners cooperating with Facebook (so-called “Audience Network” https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offering or who exhibit certain characteristics (e.g. interest in certain topics or products that can be seen from the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook Ads correspond to the potential interest of the users and do not appear annoying. The Facebook Pixel also enables us to track the effectiveness of Facebook Ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook Ad (so-called “conversion measurement”).

Advanced Facebook pixel matching: When using the Facebook pixel, the additional function “extended adjustment” is used. In this context, data, such as e-mail addresses or Facebook IDs of users, are transmitted (encrypted) to Facebook to form target groups.

Facebook – Target groups education via data upload: Uploading data, such as telephone numbers, e-mail addresses or Facebook IDs to the Facebook platform. The data is encrypted. The upload process is only used to display advertisements to the owners of the data or persons whose user profiles correspond to any user profiles of the owners of the data on Facebook. In this way we want to ensure that the ads are only displayed to users who have an interest in our information and services.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (data indicating the location of an end user’s terminal equipment).
  • Persons concerned: Users (e.g. website visitors, users of online services), interested parties.
  • Purposes of processing: Tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, visitor action evaluation, interest-based and behaviour-based marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors), target group formation (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes), click tracking.
  • security measures: IP masking (pseudonymisation of the IP address).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
  • Possibility of objection (Opt-Out): We refer to the data protection information of the respective providers and the possibilities of objection (so-called “Opt-Out”) indicated for the providers. If no explicit opt-out option has been specified, it is possible to switch off cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary form for the respective areas:a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-regional: https://optout.aboutads.info.

Services used and service providers:

  • Google Analytics: online marketing and web analytics; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com/intl/de/about/analytics/; privacy policy: https://policies.google.com/privacy; opt-out: opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, advertising display settings: https://adssettings.google.com/authenticated.
  • Google Ads and conversion measurement: We use the online marketing process “Google Ads” to place ads in the Google advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. We also measure the conversion of the ads. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page with a so-called “conversion tracking tag”. However, we do not receive any information that can identify users ourselves. Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy.
  • Google Ad Manager: We use the “Google Marketing Platform” (and services such as “Google Ad Manager”) to place ads on the Google advertising network (e.g., in search results, in videos, on web pages, etc.). The Google Marketing Platform is characterised by the fact that ads are displayed in real time based on presumed interests of users. This allows us to display ads for and within our online offering in a more targeted manner in order to show users only ads that potentially match their interests. For example, if a user is shown ads for products that he or she has been interested in on other websites, this is called “remarketing”. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy.
  • Facebook pixels: 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; opt-out: https://www.facebook.com/settings?tab=ads.

Affiliate programmes and affiliate links

We include so-called affiliate links or other references (which may include search masks, widgets or discount codes) to the offers and services of third parties in our online offer (collectively referred to as “affiliate links”). If users follow the affiliate links or subsequently take advantage of the offers, we may receive commission or other benefits from these third party providers (collectively referred to as “commission”).

In order to be able to track whether users have taken advantage of the offers of an affiliate link used by us, it is necessary for the respective third party providers to learn that users have followed an affiliate link used within our online offer. The assignment of the affiliate links to the respective business transactions or other actions (e.g. purchases) serves the sole purpose of the commission settlement and is cancelled as soon as it is no longer necessary for the purpose.

For the purposes of the above-mentioned allocation of affiliate links, the affiliate links may be supplemented by certain values which are a component of the link or may be stored elsewhere, e.g. in a cookie. These values may include in particular the initial website (referrer), the time, an online identification of the operator of the website on which the affiliate link was located, an online identification of the respective offer, the type of link used, the type of offer and an online identification of the user.

Information on legal bases: If we ask users for their consent to use the third party providers, the legal basis for processing data is consent. Furthermore, their use can be a component of our (pre-)contractual services, provided that the use of the third party providers has been agreed in this context. Otherwise, the users’ 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: contract data (e.g. subject matter of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Purpose of the processing: affiliate tracking.
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Services used and service providers:

  • Amazon Partner Program: Amazon – Affiliate Program – Amazon and the Amazon logo are trademarks of Amazon.com, Inc. or one of its affiliates. service provider: Amazon Europe Core S.à.r.l., Amazon EU S.à.r.l., Amazon Services Europe S.à.r.l. and Amazon Media EU S.à.r.l., all four located at 38, avenue John F. Kennedy, L-1855 Luxembourg, and Amazon Instant Video Germany GmbH, Domagkstr. 28, 80807 Munich (together “Amazon Europe”), parent company: Amazon.com, Inc., 2021 Seventh Ave, Seattle, Washington 98121, USA; website: https://www.amazon.de; privacy policy: https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010.
  • Digistore24 Partner Program: Service Provider: Digistore24 GmbH, St.-Godehard-Straße 32, 31139 Hildesheim, Germany; Website: https://www.digistore24.com; Privacy Policy: https://www.digistore24.com/page/privacy.

Offer of an affiliate programme

We offer an affiliate programme, i.e., commissions or other benefits (collectively referred to as “commissions”) to users (referred to as “affiliates”) who refer to our offers and services. The reference is made by means of a link assigned to the respective Affiliate or other methods (e.g. discount codes) that allow us to recognise that the use of our services was based on the reference (collectively referred to as “Affiliate Links”).

In order to be able to track whether users have taken advantage of our services due to the affiliate links used by the affiliates, it is necessary for us to know that users have followed an affiliate link. The assignment of the affiliate links to the respective business transactions or to the other use of our services serves the sole purpose of the commission settlement and is cancelled as soon as it is no longer necessary for the purpose.

For the purposes of the above-mentioned allocation of affiliate links, the affiliate links may be supplemented by certain values which are a component of the link or may be stored elsewhere, e.g. in a cookie. These values may include in particular the initial website (referrer), the time, an online identification of the operator of the website on which the affiliate link was located, an online identification of the respective offer, the type of link used, the type of offer and an online identification of the user.

Information on legal bases: If we ask users for their consent to use the third party providers, the legal basis for processing data is consent. Furthermore, their use can be a component of our (pre-)contractual services, provided that the use of the third party providers has been agreed in this context. Otherwise, the users’ 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: contract data (e.g. subject matter of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times).
  • Persons concerned: Users (e.g. website visitors, users of online services), business and contractual partners.
  • Purposes of processing: contractual benefits and services, affiliate tracking.
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Evaluation platforms

We participate in assessment procedures to evaluate, optimise and promote our services. If users evaluate or otherwise provide feedback to us via the participating evaluation platforms or procedures, the General Terms and Conditions of Business or Use and the data protection information of the providers also apply. As a rule, evaluation also requires registration with the respective providers.

In order to ensure that the persons evaluating have actually made use of our services, we transmit, with the consent of the customer, the necessary data regarding the customer and the service used to the respective evaluation platform (including name, e-mail address and order number or item number). This data is used solely to verify the authenticity of the user.

  • Processed data types: contract data (e.g. subject matter of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Customers, users (e.g. website visitors, users of online services).
  • Purpose of the processing: feedback (e.g. collecting feedback via online form).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

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.

Please note that user data may be processed outside the European Union. This may entail risks for the users, as it could, for example, make it more difficult to enforce the rights of the users.

Furthermore, user data within social networks is usually processed for market research and advertising purposes. Thus, for example, user profiles can be created on the basis of user behaviour and the resulting interests of the users. The user profiles can in turn 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 users’ computers, in which the usage behaviour and interests of the users are stored. Furthermore, data may 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 these).

For a detailed presentation of the respective forms of processing and the possibilities of 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 data subject rights, we would like to point out that these can most effectively be asserted with the providers. Only the providers have access to the data of the users and can take appropriate measures and provide information directly. Should you nevertheless require assistance, 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 entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Purposes of processing: contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors), affiliate tracking.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Services used and service providers:

  • Instagram : Social network; Service provider: Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA; website: https://www.instagram.com; privacy policy: https://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; Opt-Out: Advertising Settings: https://www.facebook.com/settings?tab=ads; Additional Privacy Notice: 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.
  • Flickr: Social network; Service provider: Flickr Inc, 475 Sansome St San Francisco, California 94111, USA; Website: https://www.flickr.com; Privacy Policy: https://www.flickr.com/help/privacy.
  • 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; opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • Pinterest: social network; service provider: Pinterest Inc, 635 High Street, Palo Alto, CA, 94301, USA; Website: https://www.pinterest.com; Privacy Policy: https://about.pinterest.com/de/privacy-policy; Opt-Out: https://about.pinterest.com/de/privacy-policy.
  • SlideShare: platform for presentations; 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.
  • Snapchat: social network; service provider: Snap Inc, 3000 31st Street, Santa Monica, California 90405, USA; website: https://www.snapchat.com/; privacy policy: https://www.snap.com/de-DE/privacy/privacy-policy, cookie policy: https://www.snap.com/de-DE/cookie-policy; standard contractual clauses (ensuring a level of data protection when processing in third countries): https://www.snap.com/en-US/terms/standard-contractual-clauses.
  • TikTok: social network / video platform; service provider: musical.ly Inc., 10351 Santa Monica Blvd #310, Los Angeles, CA 90025 USA; website: https://www.tiktok.com; privacy policy: https://www.tiktok.com/de/privacy-policy.
  • Twitter: social network; service provider: Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Privacy Policy: https://twitter.com/de/privacy, (Settings) https://twitter.com/personalization.
  • 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 Policy: https://policies.google.com/privacy; Opt-out: https://adssettings.google.com/authenticated.
  • Xing: social network; service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Website: https://www.xing.de; Privacy Policy: https://privacy.xing.com/de/datenschutzerklaerung.

Plugins and embedded functions and content

We integrate into our online offer functional and content elements 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 social media buttons and contributions (hereinafter referred to uniformly as “content”).

The integration always presupposes that the third party providers of this content process the IP address of the users, as without the IP address they would not be able to send the content to their browsers. The IP address is therefore necessary for the display of these contents or functions. We make every effort to use only such content whose respective providers use the IP address only 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 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 technical information on the browser and operating system, websites to be referred to, the time of visit and other details on the use of our online offer, as well as being linked to such information from other sources.

Information on legal bases: If we ask users for their consent to use the third party providers, the legal basis for processing data is consent. Otherwise, the users’ 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), content data (e.g. text entries, photographs, videos), location data (data indicating the location of an end user’s terminal device), contact data (e.g. e-mail, telephone numbers), inventory data (e.g. names, addresses).
  • Persons concerned: Users (e.g. website visitors, users of online services), communication partners.
  • Purposes of processing: Provision of our online offer and user-friendliness, contractual benefits and service, contact enquiries and communication, direct marketing (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 form), security measures, administration and answering of enquiries.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO), consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO).

Services used and service providers:

  • Facebook plugins and content: Facebook social plugins and content – This can include 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/; 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; opt-out: advertising settings: https://www.facebook.com/settings?tab=ads.
  • Giphy: Embedded plug-ins and content – This can include content such as images, videos or text and buttons; service providers: Giphy, Inc, 416 West 13th Street, Suite 207 New York, NY 10014, USA; website: https://giphy.com; privacy policy: https://support.giphy.com/hc/en-us/articles/360032872931.
  • Google Custom Search: Use of Google’s search engine technology within our online offer; 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://developers.google.com/custom-search; privacy policy: https://policies.google.com/privacy.
  • Google Maps: We integrate the maps of the service “Google Maps” of the provider Google. The processed data may include, in particular, IP addresses and location data of the users, which, however, cannot be collected without their consent (usually within the framework of the settings of their mobile devices); service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://cloud.google.com/maps-platform; privacy policy: https://policies.google.com/privacy; opt-out: opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, advertising display settings: https://adssettings.google.com/authenticated.
  • Getty Images content: integration of Getty Images images; service provider: Getty Images, Inc, 605 5th Avenue South, Suite 400, Seattle, Washington 98104, USA; website: https://www.gettyimages.de; privacy policy: https://www.gettyimages.de/company/privacy-policy.
  • Instagram plugins and content: Instagram Plugins and Content – This may include content such as images, videos or text and buttons that allow users to share content from this online offering 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: https://instagram.com/about/legal/privacy.
  • LinkedIn plugins and content: LinkedIn plugins and content – This can include content such as images, videos or text and buttons that allow users to share content from this online offering 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; Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • Reddit: Embedded plug-ins and content – This can include content such as images, videos or text and buttons; service providers: Reddit, Inc, 548 Market Street #16093, San Francisco, California 94104, USA; Website: https://www.redditinc.com; Privacy Policy: https://www.redditinc.com/policies/privacy-policy-january-10-2020.
  • 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/.
  • TikTok plugins and content: TikTok plugins and content – This can include content such as images, videos or text and buttons. Service Provider: musical.ly Inc, 10351 Santa Monica Blvd #310, Los Angeles, CA 90025 USA; Website: https://www.tiktok.com; Privacy Policy: https://www.tiktok.com/de/privacy-policy.
  • Twitter plugins and content: Twitter plugins and buttons – This can include content such as images, videos or text and buttons that allow users to share content from this online offering within Twitter. Service provider: Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; website: https://twitter.com/de; privacy policy: https://twitter.com/de/privacy.
  • YouTube videos: Video content; service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://www.youtube.com; privacy policy: https://policies.google.com/privacy; opt-out: opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, advertising display settings: https://adssettings.google.com/authenticated.
  • Xing plugins and buttons: Xing plugins and buttons – These may include content such as images, videos or text and buttons that allow users to share content from this online offering within Xing. Service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; website: https://www.xing.com; privacy policy: https://privacy.xing.com/de/datenschutzerklaerung.
  • Vimeo videos: Video content; service provider: Vimeo Inc., Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA; Website: https://vimeo.com; Privacy Policy: https://vimeo.com/privacy; Opt-out: Please note that Vimeo may use Google Analytics and refer to the privacy policy (https://policies.google.com/privacy) and the opt-out options for Google Analytics (https://tools.google.com/dlpage/gaoptout?hl=de) or the settings of Google for the use of data for marketing purposes (https://adssettings.google.com/).

Planning, organisation and support tools

We use the services, platforms and software of other providers (hereinafter referred to as “third party providers”) for the purposes of organising, managing, planning and providing our services. When selecting third-party providers and their services, we observe the legal requirements.

In this context, personal data may be processed and stored on the servers of third party providers. This may affect various data which we process in accordance with this data protection declaration. This data may include in particular master data and contact details of users, data on procedures, contracts, other processes and their contents.

If users are referred to the third-party providers or their software or platforms in the course of communication, business or other relations with us, the third-party providers may process usage data and metadata for security, service optimisation or marketing purposes. We therefore ask you to observe the data protection notices of the respective third party providers.

Information on legal bases: If we ask users for their consent to use the third party providers, the legal basis for processing data is consent. Furthermore, their use can be a component of our (pre-)contractual services, provided that the use of the third party providers has been agreed in this context. Otherwise, the users’ 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: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Special categories of personal data: Health data (Art. 9 para. 1 DGSVO).
  • Persons concerned: Communication partners, users (e.g. website visitors, users of online services), patients, customers.
  • Purposes of processing: Contact requests and communication, range measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behavioural profiling, use of cookies), profiling (creation of user profiles), office and organisational procedures, contractual services and service, management and answering of requests, feedback (e.g.e.g. collecting feedback via online forms), surveys and questionnaires (e.g. surveys with input options, multiple choice questions), target group formation (determination of target groups relevant for marketing purposes or other output of content), visitor action evaluation, target group formation, conversion measurement (measurement of the effectiveness of marketing measures).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO), performance of contract and pre-contractual enquiries (EKD) (Art. 6 No. 5 DSG-EKD).

Services used and service providers:

  • Basecamp: project management tool; service provider: Basecamp, LLC., 30 N. Racine Ave, Suite 200 Chicago, Illinois 60607, USA; Website: https://basecamp.com; Privacy Policy: https://basecamp.com/about/policies.
  • Bitly: URL shortening service and link management platform; service provider: Bitly, Inc, 139 Fifth Avenue, 5th Floor, New York, NY 10010, USA; Website: https://bitly.com; Privacy Policy: https://bitly.com/pages/privacy.
  • calendly: Online scheduling; service provider: Calendly LLC, 271 17th St NW, Ste 1000, Atlanta, Georgia, 30363, USA; Website: https://calendly.com/de; Privacy Policy: https://calendly.com/pages/privacy.
  • Confluence: Software for the creation and administration of Wiki & knowledge platforms; service provider: Atlassian Inc. (San Francisco, Harrison Street Location), 1098 Harrison Street, San Francisco, California 94103, USA; Website: https://www.atlassian.com/software/confluence; Privacy Policy: https://www.atlassian.com/legal/privacy-policy.
  • Doctolib: online appointment management; service provider: Doctolib GmbH, Wilhelmstraße 118, Aufgang C, 10963 Berlin, Germany, parent company: Doctolib SAS, 32 rue de Monceau 75008 Paris, France; website: https://www.doctolib.de; privacy policy: https://www.doctolib.de/terms/agreement.
  • Doodle: Online scheduling; service provider: Doodle AG, Werdstrasse 21, P.O. Box, 8021 Zurich, Switzerland; website: https://doodle.com/de; privacy policy: https://doodle.com/de/datenschutzrichtlinie.
  • Hootsuite: Social Media Management Platform offering a range of integrated solutions for measurement & benchmarking, performance optimization, visualization & analysis, content creation and publishing and community maintenance; service provider: HootSuite Media Inc, 5 East 8th Avenue. Vancouver, V5T 1R6, Canada; website: https://hootsuite.com; privacy policy: https://hootsuite.com/legal/privacy.
  • HubSpot: social media publishing, reporting (e.g. traffic sources, access figures, web analytics), contact management (e.g. contact forms, direct communication and user segmentation), landing pages; service providers: HubSpot, Inc. 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; website: https://www.hubspot.de; privacy policy: https://legal.hubspot.com/de/privacy-policy.
  • Jira: web application for error management, troubleshooting and operational project management; service provider: Atlassian Inc. (San Francisco, Harrison Street Location), 1098 Harrison Street, San Francisco, California 94103, USA; website: https://www.atlassian.com/software/jira; privacy policy: https://www.atlassian.com/legal/privacy-policy.
  • Trello: project management tool; service provider: Trello Inc, 55 Broadway New York, NY 10006, USA, parent company: Atlassian Inc. (San Francisco, Harrison Street Location), 1098 Harrison Street, San Francisco, California 94103, USA; website: https://trello.com/; privacy policy: https://trello.com/privacy.
  • Twilio: Twilio is a cloud communications platform that allows users to programmatically make and receive calls, send and receive text messages, and perform other communication functions using the web service interfaces. Service provider: Twilio Inc, 375 Beale Street, Suite 300, San Francisco, California 94105, USA; website: https://www.twilio.com; privacy policy: https://www.twilio.com/legal/privacy.
  • WeTransfer: transfer of files over the Internet; service provider: WeTransfer BV, Oostelijke Handelskade 751, Amsterdam, 1019 BW, Netherlands; website: https://wetransfer.com; privacy policy: https://wetransfer.com/legal/privacy.

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consent permitted for processing is revoked or other permissions cease to apply (e.g. if the purpose for which the data were processed ceases to apply or if they are not necessary for the purpose).

Unless the data are deleted because they are required for other and legally permissible purposes, their processing is 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 retained for reasons of commercial or tax law or that must be stored for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.

Further information on the deletion of personal data can also be found in the individual data protection notes of this privacy policy.

Amendment 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 changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes make it necessary for you to take action to cooperate (e.g. to give your consent) or to receive 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.

Rights of data subjects

As a data subject, you are entitled to various rights under the DSGVO, which result in particular from Articles 15 to 21 DSGVO:

  • Right of objection: You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you that is carried out pursuant to Art. 6, paragraph 1, letter e or f of the DPA; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing, including profiling, insofar as it is linked to such direct marketing.
  • Right of withdrawal in case of consent: You have the right to revoke consents at any time.
  • Right of access: You have the right to obtain confirmation as to whether or not data in question is being processed and to obtain information about this data and other information and a copy of the data in accordance with the law.
  • Right of rectification: You have the right to ask for the completion of the data concerning you or the rectification of incorrect data concerning you, in accordance with the law.
  • Right to deletion and restriction of processing: You have the right, in accordance with the statutory provisions, to demand that data relating to you be deleted immediately, or alternatively, in accordance with the statutory provisions, to demand restriction of the 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 legal requirements or to request that it be transferred to another responsible party.
  • Complaints to the supervisory authority: You also have the right, in accordance with the law, to lodge a complaint with a supervisory authority, in particular in the Member State in which you are habitually resident, your place of work or the place where the alleged infringement occurred, if you consider that the processing of personal data concerning you is in breach of the DPA.

Definitions of terms

This section provides 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. The terms are sorted alphabetically.

 

  • Affiliate tracking: As part of affiliate tracking, links are logged with the help of which the linking websites refer users to websites with product or other offers. The operators of the respective linking websites can receive a commission if users follow these so-called affiliate links and then take advantage of the offers (e.g. buy goods or services). To this end, it is necessary for the providers to be able to track whether users who are interested in certain offers subsequently take notice of them at the instigation of the affiliate links. It is therefore necessary for the functionality of affiliate links that they are supplemented by certain values which become part of the link or are stored in some other way, e.g. in a cookie. These values include in particular the initial website (referrer), the time, an online identification of the operator of the website on which the affiliate link was located, an online identification of the respective offer, an online identification of the user as well as tracking specific values, such as advertising material ID, partner ID and categorisations.
  • Conversion tracking: Conversion tracking is a method of determining the effectiveness of marketing activities. For this purpose, a cookie is usually stored on the user’s device within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, we can then track whether the ads we have placed on other websites have been successful).
  • Content Delivery Network (CDN): A “Content Delivery Network” (CDN) is a service that enables the contents of an online offer, especially large media files such as graphics or programme scripts, to be delivered more quickly and securely with the help of regionally distributed servers connected via the Internet.
  • Cross-Device Tracking: Cross-Device Tracking is a form of tracking in which the behaviour and interest information of users is recorded in so-called profiles across devices by assigning users an online identifier. In this way, the user information can be analysed for marketing purposes independently of the browsers or devices used (e.g. mobile phones or desktop computers). With most providers, the online identification is not linked to clear data, such as names, postal or e-mail addresses.
  • IP masking: IP masking is a method of deleting the last octet, i.e. the last two numbers of an IP address, so that the IP address can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymising processing methods, particularly in online marketing
  • Interest-based and behavioural marketing: We speak of interest-based and/or behavioural marketing when the potential interests of users in advertisements and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behaviour (e.g. visiting and staying on certain websites, purchasing behaviour or interaction with other users), which is stored in a so-called profile. As a rule, cookies are used for these purposes.
  • Click tracking: Clicktracking allows you to keep track of the movements of users within an entire online offering. Since the results of these tests are more accurate if the interaction of the users 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 users’ computers for these test purposes.
  • Conversion measurement: Conversion measurement is a method of determining the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user’s devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, we are able to track whether the ads 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 referred to as “data subject”); an identifiable 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. a cookie) or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
  • Profiling: “Profiling” is any automated processing of personal data which consists of using personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information on age, gender, location and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people) (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 the content of websites. With the help of reach analysis, website owners can, for example, identify at what time visitors visit their website and what content they are interested in. This enables them to better adapt the contents of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for the purpose of range analysis in order to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Remarketing: We speak of “remarketing” or “retargeting”, for example, when it is noted for advertising purposes which products a user has been interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Server monitoring and error detection: With the help of server monitoring and error detection we ensure the availability and integrity of our online offer and use the processed data to technically optimise our online offer. Performance, capacity utilisation and comparable technical values are processed, which provide information about the stability and any conspicuous features of our online offer. In the event of errors and anomalies, individual enquiries from users of our online service are recorded in order to identify and eliminate sources of problems.
  • Tracking: We speak of “tracking” when the behaviour of users can be traced across several online offers. As a rule, behavioural and interest information regarding the online offers used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
  • Controller: “Controller” means the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data.
  • Processing: “processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually all processing of data, whether it be collection, analysis, storage, communication or deletion.
  • Target group formation: One speaks of target group formation (or “custom audiences”) when target groups are determined for advertising purposes, e.g. insertion of advertisements. For example, based on a user’s interest in certain products or topics on the Internet, it can be concluded that the user is interested in advertisements for similar products or the online shop where he viewed the products. Lookalike Audiences” (or similar target groups) are again referred to when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used to create custom audiences and lookalike audiences.