Data protection

introduction

With the following data protection declaration, we would like to explain to 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 the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”) ).

The terms used are not gender specific.

As of May 23, 2021

Contents overview

Responsible person

Patrik Tesar
xyndata sro
Braunerova 563/7
CZ-180 00 Prague – Libeň

E-mail address: info@xyndata.com .

Imprint: https://xyndata.com/imprint .

Overview of the processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

  • Event data (Facebook) (“event data” are data that can be transmitted from us to Facebook, for example via Facebook pixels (via apps or in other ways) and relate to people or their actions; Data includes, for example, information about visits to websites, interactions with content, functions, installation of apps, purchases of products, etc .; the event data is processed in order to create target groups for content and advertising information (custom audiences); event data do not contain the actual content (such as written comments), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Facebook will delete event data after a maximum of two years formed target groups with the deletion of our Facebook account).
  • Inventory data (e.g. names, addresses).
  • Content data (e.g. entries in online forms).
  • 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).
  • Contract data (e.g. subject of the contract, duration, customer category).
  • Payment data (e.g. bank details, invoices, payment history).

Categories of data subjects

  • Employees (e.g. employees, applicants, former employees).
  • Business and contractual partners.
  • Interested persons.
  • Communication partner.
  • Customers.
  • Users (e.g. website visitors, users of online services).

Purposes of processing

  • Provision of our online offer and user-friendliness.
  • Conversion measurement (measurement of the effectiveness of marketing measures).
  • Office and organizational procedures.
  • Direct marketing (e.g. by email or post).
  • Feedback (e.g. collecting feedback via an online form).
  • Marketing.
  • Contact requests and communication.
  • Profiles with user-related information (creation of user profiles).
  • Remarketing.
  • Provision of contractual services and customer service.
  • Management and answering of inquiries.
  • Target group formation (determination of target groups relevant for marketing purposes or other output of content).

Relevant legal bases

Below you will find an overview of the legal bases of the GDPR on which we base the processing of personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations of your or our country of residence or domicile may apply. Furthermore, if more specific legal bases are relevant in individual cases, we will inform you of this in the data protection declaration.

  • Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR) – The data subject has given their consent to the processing of their personal data for a specific purpose or for several specific purposes.
  • Fulfillment of the contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b.GDPR) – Processing is necessary for the performance of a contract to which the data subject is a party, or for the implementation of pre-contractual measures that are carried out at the request of the data subject.
  • Legal obligation (Art. 6 Para. 1 S. 1 lit. c. GDPR) – The processing is necessary to fulfill a legal obligation to which the person responsible is subject.
  • Legitimate interests (Art. 6 Para. 1 S. 1 lit.f. GDPR) – The processing is necessary to safeguard the legitimate interests of the person responsible or a third party, unless the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, outweigh this.

Safety measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons to ensure a level of protection appropriate to the risk.

The measures include, in particular, securing the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, transfer, securing of availability and their separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to the threat to the data. Furthermore, we consider the protection of personal data already in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and data protection-friendly default settings.

Transmission of personal data

As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons or they are disclosed to them. The recipients of this data can include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such a case, we observe the legal requirements and in particular conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.

Data processing in third countries

Insofar as we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing in the context of the use of third-party services or the disclosure or transfer of data to other persons, offices or companies takes place, this is only done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

Use of cookies

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

A distinction is made between the following types of cookies and functions:

  • Temporary cookies (also: 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 are saved even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The interests of users who are used to measure reach or for marketing purposes can also 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: On the one hand, cookies may be absolutely necessary for the operation of a website (e.g. to save logins or other user input or for security reasons).
  • Statistics, marketing and personalization cookies : Furthermore, cookies are usually also used in the context of range measurement and when the interests of a user or his behavior (e.g. viewing certain content, using functions, etc.) are stored in a user profile on individual websites. Such profiles are used to show users, for example, content that corresponds to their potential interests. This process is also referred to as “tracking”, ie following up the potential interests of users. Insofar as we use cookies or “tracking” technologies, we will inform you separately in our data protection declaration or in the context of obtaining consent.

Notes on legal bases: The legal basis on which we process your personal data with the help of cookies depends on whether we ask 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 help 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 fulfill our contractual obligations.

Storage period: If we do not provide you with any explicit information on the storage duration of permanent cookies (e.g. in the context 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 option at any time to revoke your consent or to object to the processing of your data using cookie technologies (collectively referred to as “opt-out”). You can first explain your objection using the settings of your browser, e.g. by deactivating the use of cookies (which can also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be made using a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ be explained. In addition, you can receive further objection notices in the context of the information on the service providers and cookies used.

Processing of cookie data on the basis of consent : We use a procedure for cookie consent management, within the framework of which the consent of the user to the use of cookies or the processing and providers mentioned in the context of the cookie consent management procedure is obtained and administered and managed by the users can be revoked. The declaration of consent is saved so that you do not have to repeat the query again and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and / or in a cookie (so-called opt-in cookie, or with the help of comparable technologies) in order to be able to assign the consent to a user or his device. Subject to individual information about the providers of cookie management services, the following information applies: The duration of the storage of the consent can be up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of the consent (e.g. which categories of cookies and / or service providers) as well as the browser, system and end device used.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information, IP addresses).
  • Affected people: Users (e.g. website visitors, users of online services).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), Legitimate Interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Business services

We process data from our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with the contractual partners (or pre-contractual), e.g. to answer inquiries answer.

We process this data to fulfill our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as the business organization. We only pass on the data of the contractual partners to third parties within the framework of applicable law to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations or with the consent of the persons concerned (e.g. to telecommunications, transport and other auxiliary services involved as well 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 aforementioned purposes before or as part of the data collection, e.g. in online forms, by means of special labeling (e.g. colors) or symbols (e.g. asterisks or similar), or personally.

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

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

  • Processed data types: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact details (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of the contract, duration, customer category).
  • Affected people: Interested parties, business and contractual partners.
  • Purposes of processing: Provision of contractual services and customer service, contact inquiries and communication, office and organizational procedures, administration and answering inquiries.
  • Legal basis: Fulfillment of the contract and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. GDPR), legal obligation (Art. 6 para. 1 p. 1 lit. c. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit.f. GDPR).

Provision of the online offer and web hosting

In order to be able to provide our online offer safely 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 can use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.

The data processed as part of the provision of the hosting offer can include all information relating to the users of our online offer that is generated in the context of use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or from websites.

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 can include the address and name of the websites and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP Addresses and the requesting provider belong.

The server log files can be used on the one hand for security purposes, e.g. to avoid overloading the server (especially in the case of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the load on the server and its stability.

  • Processed data types: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information, IP addresses).
  • Affected people: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Special notes on applications (apps)

We process the data of the users of our application insofar as this is necessary in order to be able to provide the application and its functionalities to the users, to monitor their security and to be able to develop them further. We can also contact users in compliance with the legal requirements, provided that communication is required for purposes of administration or use of the application. For the rest, we refer to the data protection information in this data protection declaration with regard to the processing of user data.

Legal basis: The processing of data, which is necessary for the provision of the functionalities of the application, serves the fulfillment of contractual obligations. This also applies if the provision of the functions requires user authorization (e.g. enabling 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 optimizing the application or security purposes), it is carried out on the basis of our legitimate interests Interests. If users are expressly asked for their consent to the processing of their data, the processing of the data covered by the consent takes place on the basis of the consent.

commercial use : We process the data of the users of our application, registered and any test users (hereinafter uniformly referred to as “users”) in order to be able to provide them with our contractual services and on the basis of legitimate interests to ensure the security of our application and to be able to further develop it . The information required is marked as such in the context of the conclusion of use, order, order or comparable contract and can include the information required for the provision of services and any billing as well as contact information in order to be able to hold any consultations.

Device permissions for access to functions and data : The use of our application or its functionalities may require user authorizations to access certain functions of the devices used or to the data stored on the devices or accessible with the help of the devices. By default, these authorizations 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 authorizations may depend on the device and the software of the users. Users can contact us if they need more information. We point out that the denial or revocation of the respective authorizations 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), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of the contract, term, customer category).
  • Affected people: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and customer service.
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit.f. GDPR).

contact

When contacting us (e.g. via the contact form, email, telephone or via social media), the details of the inquiring person are processed, insofar as this is necessary to answer the contact inquiries and any requested measures.

The answering of contact inquiries in the context of contractual or pre-contractual relationships takes place to fulfill our contractual obligations or to answer (pre) contractual inquiries and otherwise on the basis of the legitimate interests in answering the inquiries.

  • Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms).
  • Affected people: Communication partner.
  • Purposes of processing: Contact requests and communication.
  • Legal basis: Fulfillment of the contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Communication via messenger

We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messenger, on encryption, on the use of the communication metadata and on your options for objection.

You can also contact us in alternative ways, e.g. by phone or email. Please use the contact options provided to you or the contact options given within our online offer.

In the case of end-to-end encryption of content (ie the content of your message and attachments), we point out that the communication content (ie 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 the latest version of Messenger with activated encryption to ensure that the message content is encrypted.

However, we also point out to our communication partners that the messenger providers do not see the content, but can find out that and when communication partners are communicating with us as well as technical information about the device used by the communication partner and, depending on the settings of their device, location information ( so-called metadata).

Notes on legal bases: If we ask communication partners for permission before communicating with them via messenger, the legal basis for our processing of their data is their consent. In addition, if we do not ask for your consent and you contact us, for example, we use Messenger in relation to our contractual partners and in the context of contract initiation as a contractual measure and in the case of other interested parties and communication partners on the basis of our legitimate interests fast and efficient communication and meeting the needs of our communication partner for communication via messenger. Furthermore, we would like to point out that we do not transmit the contact details provided to us to the messenger for the first time without your consent.

Revocation, objection and deletion: You can revoke your consent at any time and object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete the messages in accordance with our general deletion guidelines (i.e. for example, as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information from the communication partner, if no reference to a previous conversation is to be expected and the deletion does not conflict with any statutory retention requirements.

Reservation of 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 inquiries via Messenger. This is the case if, for example, internal contract information requires special secrecy or a response via Messenger does not meet the formal requirements. In such cases, we refer you to more appropriate communication channels.

  • 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).
  • Affected people: Communication partner.
  • Purposes of processing: Contact inquiries and communication, direct marketing (e.g. by email or post).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), Legitimate Interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Cloud services

We use software services (so-called “cloud services”, also known as “software as a service”) that are accessible via the Internet and run on the servers of their providers for the following purposes: document storage and administration, calendar management, sending e-mails, spreadsheets and presentations, exchange of documents, content and information with specific recipients or publication of websites, forms or other content and information as well as chats and participation in audio and video conferences.

In this context, personal data can be processed and stored on the servers of the provider, insofar as they are part of communication processes with us or otherwise processed by us, as set out in this data protection declaration. This data can include, in particular, master data and contact details of the users, data on transactions, contracts, other processes and their content. The cloud service providers also process usage data and metadata, which they use for security purposes and for service optimization.

If we use the cloud services to provide forms or other documents and content for other users or publicly accessible websites, the providers can place cookies on the users’ devices for the purposes of web analysis or to change user settings (e.g. in the case of media control) remember, save.

Notes on legal bases: If we ask for consent to the use of cloud services, the legal basis for processing is consent. Furthermore, their use can be part 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 (ie, interest in efficient and secure administrative and collaboration processes)

  • Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information, IP Addresses).
  • Affected people: Customers, employees (e.g. employees, applicants, former employees), interested parties, communication partners.
  • Purposes of processing: Office and organizational procedures.
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit.f. GDPR).

Newsletters and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter “newsletter”) only with the consent of the recipient or legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the consent of the user. Incidentally, our newsletters contain information about our services and us.

To register for our newsletters, it is generally sufficient to provide your email address. However, we can ask you to provide a name for the purpose of addressing you personally in the newsletter, or to provide further information if this is necessary for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registration you will receive an email in which you will be asked to confirm your registration. This confirmation is necessary so that nobody can register with someone else’s e-mail address. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider are also logged.

Deletion and restriction of processing: We can save the unsubscribed email addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time. In the event of obligations to permanently observe contradictions, we reserve the right to store the e-mail address in a blacklist (so-called “blocklist”) for this purpose alone.

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving that it has proceeded 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 mailing system.

Notes on legal bases: The newsletter is sent on the basis of the recipient’s consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, 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 is recorded based on our legitimate interests to demonstrate that it was carried out in accordance with the law.

Contents: Information about us, our services, promotions and offers.

Measurement of opening and click rates: The newsletters contain a so-called “web beacon”, ie a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from its server. As part of this retrieval, technical information is initially collected , such as information about the browser and your system, as well as your IP address and the time of access.

This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. The evaluations enable us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The measurement of the opening rates and the click rates as well as the storage of the measurement results in the profiles of the users as well as their further processing are based on the consent of the users.

A separate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be canceled or contradicted. In this case, the saved profile information will be deleted.

  • 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).
  • Affected people: Communication partner.
  • Purposes of processing: Direct marketing (e.g. by email or post).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), Legitimate Interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
  • Opposition option (opt-out): You can cancel the receipt of our newsletter at any time, ie 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 given above, preferably e-mail.

Advertising communication via email, 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.

The recipients have the right to revoke their consent at any time or to object to promotional communication at any time.

After revocation or objection, we can store the data required to prove consent for up to three years on the basis of our legitimate interests before we delete them. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time.

  • Processed data types: Inventory data (e.g. names, addresses), contact details (e.g. e-mail, telephone numbers).
  • Affected people: Communication partner.
  • Purposes of processing: Direct marketing (e.g. by email or post).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), Legitimate Interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Online marketing

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

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

The IP addresses of the users are also saved. However, we use available IP masking procedures (ie, pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) are stored in the online marketing process, but pseudonyms. This means that we, as well as the providers of online marketing processes, 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 processes. These cookies can later generally also be read out on other websites that use the same online marketing process, analyzed for the purpose of displaying content and supplemented with additional data and stored on the server of the online marketing process provider.

As an exception, clear data can be assigned to the profiles. This is the case if the users are, for example, members of a social network whose online marketing process we use and the network connects the profiles of the users with the aforementioned information. We ask you to note that users can make additional agreements with the providers, e.g. by giving their consent during registration.

In principle, we only have access to summarized information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e., for example, to a contract with us. The conversion measurement is used solely to analyze the success of our marketing measures.

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

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data will be processed on the basis of our legitimate interests (ie interest in efficient, economical and recipient-friendly services). In this context, we would like to draw your attention to the information on the use of cookies in this data protection declaration.

Facebook pixels and target group formation (Custom Audiences) : With the help of the Facebook pixel (or comparable functions for the transmission of event data or contact information using interfaces in apps), Facebook is on the one hand able to target the visitors of our online offer as a target group for the display of advertisements (so-called “Facebook ads “) to be determined. Accordingly, we use the Facebook pixel to only send the Facebook ads placed by us to those users on Facebook and within the services of the partners cooperating with Facebook (so-called “Audience Network”). https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offer or who have 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 would also like to ensure that our Facebook ads correspond to the potential interest of the users and are not annoying. With the help of the Facebook pixel, we can also understand the effectiveness of Facebook advertisements for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook advertisement (so-called “conversion measurement”).

We are together with Facebook Ireland Ltd. for the collection or receipt as part of a transmission (but not further processing) of “event data” that Facebook collects using the Facebook pixel and comparable functions (e.g. interfaces) that are carried out on our online offer or received as part of a transfer for the following purposes, jointly responsible: a) Display of content advertising information that corresponds to the presumed interests of the users; b) Delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) Improving the delivery of advertisements and personalizing functions and content (e.g. improving the recognition of which content or advertising information presumably corresponds to the interests of the users). We have concluded a special agreement with Facebook (“Supplement for those responsible”, https://www.facebook.com/legal/controller_addendum ), which in particular regulates which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms ) and in which Facebook has agreed to fulfill the rights of the data subject (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with measured values, analyzes and reports (which are aggregated, i.e. they do not receive any information about individual users and are anonymous to us), this processing does not take place within the framework of joint responsibility, but on the basis of an order processing contract (“data processing conditions” , https://www.facebook.com/legal/terms/dataprocessing ), the “data security conditions” (https://www.facebook.com/legal/terms/data_security_terms ) as well as with regard to processing in the USA on the basis of standard contractual clauses (“Facebook-EU data transfer addendum, https://www.facebook.com/legal/EU_data_transfer_addendum ). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information, IP addresses), event data (Facebook) (“event data” are data that are e.g. via Facebook – Pixels can be transmitted from us to Facebook (via apps or in other ways) and relate to people or their actions; The data includes, for example, information about visits to websites, interactions with content, functions, installations of apps, Purchases of products, etc .; the event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); event data does not contain the actual content (such as written comments), no login information and no contact information (So no names, email addresses and telephone numbers. Event data will be deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account).
  • Affected people: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Marketing, profiles with user-related information (creation of user profiles), remarketing, conversion measurement (measurement of the effectiveness of marketing measures), target group formation, target group formation (determination of target groups relevant for marketing purposes or other output of content).
  • Safety measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), Legitimate Interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
  • Opposition option (opt-out): We refer to the data protection notices of the respective providers and the possibilities of objection given to the providers (so-called “opt-out”). Unless an explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. However, this can restrict the functions of our online offer. We therefore also recommend the following opt-out options, which are offered in summary 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 .

Used services and service providers:

Presence in social networks (social media)

We maintain an online presence within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.

We would like to point out that user data can be processed outside of the European Union. This can result in risks for the user because it could make it more difficult to enforce the rights of the user, for example.

Furthermore, the data of users within social networks are usually processed for market research and advertising purposes. For example, usage profiles can be created on the basis of user behavior and the interests of the users resulting therefrom. The usage profiles can in turn be used, for example, to place advertisements inside 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 behavior and the interests of the users are stored. Furthermore, data can be stored in the usage profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).

For a detailed description of the respective forms of processing and the possibilities of objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we point out that these can be most effectively asserted with the providers. Only the providers have access to the data of the users and can take appropriate measures and provide information directly. If you still need help, you can contact us.

Facebook : We are together with Facebook Ireland Ltd. responsible for collecting (but not further processing) data from visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content users view or interact with, or the actions they take (see “Things You and Others Do and Provide” in the Facebook Data Policy: https://www.facebook.com/policy ), as well as information about the devices used by the users (e.g. B. IP addresses, operating system, browser type, language settings, cookie data; see under “Device information” in the Facebook data policy declaration: https://www.facebook.com/policy ). As explained in the Facebook data policy under “How do we use this information?”, Facebook also collects and uses information to provide analysis services, so-called “Page Insights”, for website operators so that they can obtain information about how people are using their pages and interact with the content associated with them. We have concluded a special agreement with Facebook (“Information on Page Insights”, https://www.facebook.com/legal/terms/page_controller_addendum ), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of the data subject (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information on Page Insights” ( https://www.facebook.com/legal/terms/information_about_page_insights_data ).

  • Processed data types: Contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information, IP addresses).
  • Affected people: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Contact inquiries and communication, feedback (e.g. collecting feedback via online form), marketing.
  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Used services and service providers:

Plugins and embedded functions as well as content

We include functional and content elements in our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). This can be, for example, graphics, videos or city maps (hereinafter uniformly referred to as “content”).

The integration always presupposes that the third-party providers of this content process the IP address of the user, since without the IP address they would not be able to send the content to their browser. The IP address is therefore required for the display of this content or functions. We strive to only use content whose respective providers only use the IP address to deliver the content. Third-party providers can also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user’s device and contain, among other things, technical information about the browser and operating system, websites to be referred to, the time of visit and other information about the use of our online offer, as well as being linked to such information from other sources.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data will be processed on the basis of our legitimate interests (ie interest in efficient, economical and recipient-friendly services). In this context, we would like to draw your attention to the information on the use of cookies in this data protection declaration.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information, IP addresses).
  • Affected people: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness, provision of contractual services and customer service.
  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Used services and service providers:

  • Google Fonts: We integrate the fonts (“Google Fonts”) from the provider Google, whereby the user data is used solely for the purpose of displaying the fonts in the user’s browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform presentation and taking into account possible licensing restrictions for their integration. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://fonts.google.com/ ; Data protection: https://policies.google.com/privacy .
  • Google Maps: We integrate the maps of the “Google Maps” service provided by Google. The processed data may include, in particular, the users’ IP addresses and location data, which, however, are not collected without their consent (usually as part of the settings of their mobile devices); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://cloud.google.com/maps-platform ; Data protection: https://policies.google.com/privacy ; Opposition option (opt-out): Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de , Settings for the display of advertisements: https://adssettings.google.com/authenticated .

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as the consent permitted for processing is revoked or other permissions are no longer applicable (e.g. if the purpose of processing this data is no longer applicable or is not required for the purpose).

If the data is not deleted because it is required for other and legally permissible purposes, its processing will be limited to these purposes. In other words, the data is blocked and not processed for other purposes. This applies, for example, to data that must be kept for commercial or tax law reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.

As part of our data protection information, we can provide users with further information on the deletion and storage of data that applies specifically to the respective processing process.

Change and update of the data protection declaration

We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as the changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this data protection declaration, please note that the addresses can change over time and ask you to check the information before contacting us.

Rights of data subjects

As a data subject, you have various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

  • Right of objection: You have the right, for reasons that arise from your particular situation, to object at any time to the processing of your personal data, which is based on Art. 6 Para. 1 lit. e or f GDPR takes place, to file an objection; this also applies to profiling based on these provisions. If the personal data relating to you are processed in order to operate direct mail, you have the right to object at any time to the processing of the personal data relating to you for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct advertising.
  • Right to withdraw consent: You have the right to withdraw your consent at any time.
  • Right of providing information: You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the legal requirements, you have the right to request the completion of the data relating to you or the correction of incorrect data relating to you.
  • Right to deletion and restriction of processing: In accordance with the legal requirements, you have the right to request that the data relating to you be deleted immediately or, alternatively, to request a restriction on the processing of the data in accordance with the legal requirements.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us in accordance with the legal requirements in a structured, common and machine-readable format or to request that it be transmitted to another person responsible.
  • Complaint to the supervisory authority: In accordance with the legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State in which you usually reside, the supervisory authority of your workplace or the place of the alleged violation if you should be of the opinion that the processing of your personal data violates the GDPR.

Definitions of terms

This section gives you an overview of the terms used in this data protection declaration. Many of the terms are taken from the law and primarily defined in Art. 4 GDPR. The legal definitions are binding. In contrast, the following explanations are primarily intended to aid understanding. The terms are sorted alphabetically.

  • IP masking: “IP masking” is a method in which the last octet, ie the last two digits of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymising processing methods, especially in online marketing
  • Conversion measurement: The conversion measurement (also known as “visit action evaluation”) is a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users’ devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, we can see whether the advertisements we placed on other websites were successful.
  • Personal data: “Personal data” is all information that relates to an identified or identifiable natural person (hereinafter “data subject”); A natural person is regarded as identifiable who can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special features, which express the physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person.
  • Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any type of automated processing of personal data that consists of using this personal data to identify certain personal aspects that relate to a natural person (depending on Depending on the type of profile formation, different information regarding demographics, behavior and interests, such as the interaction with websites and their content, etc.) can be analyzed, evaluated or in order to predict them (e.g. the interests in certain content or products, the Click behavior on a website or the whereabouts). Cookies and web beacons are often used for profiling purposes.
  • Remarketing: One speaks of “remarketing” or “retargeting” when, for example, it is noted for advertising purposes which products a user was interested in on a website in order to remind the user of these products on other websites, for example in advertisements.
  • Responsible: “Responsible” is the natural or legal person, authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data.
  • Processing: “Processing” is any process carried out with or without the help of automated processes or any such series of processes in connection with personal data. The term goes far and includes practically every handling of data, be it the collection, evaluation, storage, transmission or deletion.
  • Target group formation: One speaks of target group formation (or “custom audiences”) when target groups are determined for advertising purposes, e.g. showing advertisements. For example, based on a user’s interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which he viewed the products. One speaks of “lookalike audiences” (or similar target groups), in turn, when the content assessed as 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 usually used for the purpose of creating custom audiences and lookalike audiences.

Created with the Datenschutz-Generator.de by Dr. Thomas Schwenke