Privacy Policy
Preamble
With the following privacy policy we would like to inform you which types of your personal data (hereinafter also
abbreviated as "data") we process for which purposes and in which scope. The privacy statement 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 collectively referred to as "online services").
The terms used are not gender-specific.
Last Update: 9. March 2024
Table of contents
Controller
XENBIT UG (haftungsbeschränkt)
Leinefelder Str. 12
37115 Duderstadt
Germany
E-mail address:
[email protected]
Legal Notice:
https://www.sim-dispatcher.com/en-US/Home/Imprint
Overview of processing operations
The following table summarises the types of data processed,
the purposes for which they are processed and the concerned data subjects.
Categories of Processed Data
- Inventory data.
- Payment Data.
- Contact data.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and process data.
- Audio recordings.
- Event Data (Facebook).
Categories of Data Subjects
- Customers.
- Employees.
- Prospective customers.
- Communication partner.
- Users.
- Business and contractual partners.
Purposes of Processing
- Provision of contractual services and fulfillment of contractual obligations.
- Contact requests and communication.
- Security measures.
- Direct marketing.
- Web Analytics.
- Targeting.
- Office and organisational procedures.
- Conversion tracking.
- Affiliate Tracking.
- Managing and responding to inquiries.
- Content Delivery Network (CDN).
- Feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online services and usability.
- Information technology infrastructure.
Relevant legal bases
Relevant legal bases according to the GDPR: In the
following, you will find an overview of the legal basis 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 provisions of your or our
country of residence or domicile may apply. If, in addition, more specific legal bases are applicable in individual
cases, we will inform you of these in the data protection declaration.
- Consent (Article 6 (1) (a) GDPR) - The data subject has given consent to
the processing of his or her personal data for one or more specific purposes.
- Performance of a contract and prior requests (Article 6 (1) (b) GDPR) -
Performance of a contract to which the data subject is party or in order to take steps at the request of the
data subject prior to entering into a contract.
- Compliance with a legal obligation (Article 6 (1) (c) GDPR) - Processing
is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate Interests (Article 6 (1) (f) GDPR) - Processing is necessary
for the purposes of the legitimate interests pursued by the controller or by a third party, except where such
interests are overridden by the interests or fundamental rights and freedoms of the data subject which require
protection of personal data.
National data protection regulations in Germany: In addition to the data protection regulations
of the GDPR, national regulations apply to data protection in Germany. This includes 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 provisions on the right to access, the right to erase, the right to object, the processing
of special categories of personal data, processing for other purposes and transmission as well as automated
individual decision-making, including profiling. Furthermore, data protection laws of the individual federal states
may apply.
Relevant legal basis according to the Swiss Data Protection Act: If you are located in Switzerland,
we process your data based on the Federal Data Protection Act (abbreviated as "Swiss DPA"). This also applies if our
processing of your data otherwise affects you in Switzerland and you are affected by the processing. The Swiss DPA
does not generally provide that a legal basis for the processing of personal data must be stated (unlike, for
example, the GDPR). We process personal data only when the processing is lawful, is conducted in good faith, and is
proportionate (Article 6 (1) and (2) of the Swiss DPA). Furthermore, we only collect personal data for a specific
purpose that is recognisable to the person concerned and process it only in a manner that is compatible with these
purposes (Article 6 (3) of the Swiss DPA).
Reference to the applicability of the GDPR and the Swiss DPA: These privacy notices serve both to
provide information in accordance with the Swiss Federal Act on Data Protection (Swiss DPA) and the General Data
Protection Regulation (GDPR).
Security Precautions
We take appropriate technical and organisational measures in accordance with
the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope,
context and purposes of processing as well as the risk of varying likelihood and severity for the rights and
freedoms of natural persons, in order to ensure a level of security appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by
controlling physical and electronic access to the data as well as access to, input, transmission, securing and
separation of the data. In addition, we have established procedures to ensure that data subjects' rights are
respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take
the protection of personal data into account as early as the development or selection of hardware, software and
service providers, in accordance with the principle of privacy by design and privacy by default.
Masking of the IP address: If IP addresses are processed by us or by the service providers and technologies used and
the processing of a complete IP address is not necessary, the IP address is shortened (also referred to as "IP
masking"). In this process, the last two digits or the last part of the IP address after a full stop are removed or
replaced by wildcards. The masking of the IP address is intended to prevent the identification of a person by means
of their IP address or to make such identification significantly more difficult.
TLS/SSL encryption (https): To protect the data of users transmitted via our online services, we use TLS/SSL
encryption. Secure Sockets Layer (SSL) is the standard technology for securing internet connections by encrypting
the data transmitted between a website or app and a browser (or between two servers). Transport Layer Security (TLS)
is an updated and more secure version of SSL. Hyper Text Transfer Protocol Secure (HTTPS) is displayed in the URL
when a website is secured by an SSL/TLS certificate.
Transmission of Personal Data
In the context of our processing of personal data, it may happen that
the data is transferred to other places, companies or persons or that it is disclosed to them. Recipients of this
data may include, for example, service providers commissioned with IT tasks or providers of services and content
that are embedded in a website. In such cases, the legal requirements will be respected and in particular
corresponding contracts or agreements, which serve the protection of your data, will be concluded with the
recipients of your data.
International data transfers
Data Processing in Third Countries: If we process data in a third
country (i.e., outside the European Union (EU) or the European Economic Area (EEA)), or if the processing is done
within the context of using third-party services or the disclosure or transfer of data to other individuals,
entities, or companies, this is only done in accordance with legal requirements. If the data protection level in the
third country has been recognized by an adequacy decision (Article 45 GDPR), this serves as the basis for data
transfer. Otherwise, data transfers only occur if the data protection level is otherwise ensured, especially through
standard contractual clauses (Article 46 (2)(c) GDPR), explicit consent, or in cases of contractual or legally
required transfers (Article 49 (1) GDPR). Furthermore, we provide you with the basis of third-country transfers from
individual third-country providers, with adequacy decisions primarily serving as the foundation. "Information
regarding third-country transfers and existing adequacy decisions can be obtained from the information provided by
the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.
EU-US Trans-Atlantic Data Privacy Framework: Within the context of the so-called "Data Privacy Framework" (DPF), the
EU Commission has also recognized the data protection level for certain companies from the USA as secure within the
adequacy decision of 10th July 2023. The list of certified companies as well as additional information about the DPF
can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/s/.
We will inform you which of our service providers are certified under the Data Privacy Framework as part of our data
protection notices.
Disclosure of Personal Data Abroad: In accordance with the Swiss Data Protection Act (DSG), we only disclose personal
data abroad when an appropriate level of protection for the affected persons is ensured (Art. 16 Swiss DSG). If the
Federal Council does not determine that there is an adequate level of protection (list of states: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html),
we implement alternative security measures. These measures may include international agreements, specific
guarantees, data protection clauses in contracts, standard data protection clauses approved by the Federal Data
Protection and Information Commissioner (FDPIC), or internal company data protection regulations previously
recognised by the FDPIC or a competent data protection authority of another country.
Under Art. 16 of the Swiss DSG, exceptions can be made for the disclosure of data abroad if certain conditions are
met, including the consent of the affected person, contract execution, public interest, protection of life or
physical integrity, publicly made data or data from a legally provided register. Such disclosures always comply with
the legal requirements.
Erasure of data
The data processed by us will be erased in accordance with the statutory provisions
as soon as their processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this
data no longer applies or they are not required for the purpose). If the data is not 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 restricted and not processed for other purposes. This applies, for example, to data that must be
stored for commercial or tax reasons or for which storage is necessary to assert, exercise or defend legal claims or
to protect the rights of another natural or legal person. In the context of our information on data processing, we
may provide users with further information on the deletion and retention of data that is specific to the respective
processing operation.
Rights of Data Subjects
Rights of the Data Subjects under the GDPR: As data subject, you are
entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:
- Right to Object: You have the right, on grounds arising from your particular
situation, to object at any time to the processing of your personal data which is based on letter (e) or (f) of
Article 6(1) GDPR, including profiling based on those provisions. Where personal data are processed for direct
marketing purposes, you have the right to object at any time to the processing of the personal data concerning
you for the purpose of such marketing, which includes profiling to the extent that it is related to such direct
marketing.
- Right of withdrawal for consents: You have the right to revoke consents at
any time.
- Right of access: You have the right to request confirmation as to whether
the data in question will be processed and to be informed of this data and to receive further information and a
copy of the data in accordance with the provisions of the law.
- Right to rectification: You have the right, in accordance with the law, to
request the completion of the data concerning you or the rectification of the incorrect data concerning you.
- Right to Erasure and Right to Restriction of Processing: In accordance
with the statutory provisions, you have the right to demand that the relevant data be erased immediately or,
alternatively, to demand that the processing of the data be restricted in accordance with the statutory
provisions.
- Right to data portability: You have the right to receive data concerning
you which you have provided to us in a structured, common and machine-readable format in accordance with the
legal requirements, or to request its transmission to another controller.
- Complaint to the supervisory authority: In accordance with the law 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 where
you habitually reside, the supervisory authority of your place of work or the place of the alleged infringement,
if you consider that the processing of personal data concerning you infringes the GDPR.
Rights of the data subjects under the Swiss DPA:
As the data subject, you have the following rights in accordance with the provisions of the Swiss DPA:
- Right to information: You have the right to request confirmation as to
whether personal data concerning you are being processed, and to receive the information necessary for you to
assert your rights under the Swiss DPA and to ensure transparent data processing.
- Right to data release or transfer: You have the right to request the
release of your personal data, which you have provided to us, in a common electronic format, as well as its
transfer to another data controller, provided this does not require disproportionate effort.
- Right to rectification: You have the right to request the rectification of
inaccurate personal data concerning you.
- Right to object, deletion, and destruction: You have the right to object
to the processing of your data, as well as to request that personal data concerning you be deleted or destroyed.
Use of Cookies
Cookies are small text files or other data records that store information on end
devices and read information from the end devices. For example, to store the login status in a user account, the
contents of a shopping cart in an e-shop, the contents accessed or the functions used. Cookies can also be used for
various purposes, e.g. for purposes of functionality, security and convenience of online offers as well as the
creation of analyses of visitor flows.
Information on consent: We use cookies in accordance with the statutory provisions. Therefore, we
obtain prior consent from users, except when it is not required by law. In particular, consent is not required if
the storage and reading of information, including cookies, is strictly necessary in order to provide an information
society service explicitly requested by the subscriber or user. Essential cookies usually include cookies with
functions related to the display and operability of the onlineservice, load balancing, security, storage of users'
preferences and choices or similar purposes related to the provision of the main and secondary functions of the
onlineservice requested by users. The revocable consent will be clearly communicated to the user and will contain
the information on the respective cookie use.
Information on legal bases under data protection law: The legal basis under data protection law on
which we process users' personal data with the use of cookies depends on whether we ask users for consent. If users
consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed with the
help of cookies is processed on the basis of our legitimate interests (e.g. in a business operation of our online
services and improvement of its usability) or, if this is done in the context of the fulfillment of our contractual
obligations, if the use of cookies is necessary to fulfill our contractual obligations. For which purposes the
cookies are processed by us, we do clarify in the course of this privacy policy or in the context of our consent and
processing procedures.
Retention period: With regard to the retention period, a distinction is drawn between the following
types of cookies:
- Temporary cookies (also known as "session cookies"): Temporary cookies are
deleted at the latest after a user has left an online service and closed his or her end device (i.e. browser or
mobile application).
- Permanent cookies: Permanent cookies remain stored even after the terminal
device is closed. For example, the login status can be saved, or preferred content can be displayed directly
when the user visits a website again. Likewise, user data collected with the help of cookies can be used for
reach measurement. Unless we provide users with explicit information about the type and storage duration of
cookies (e.g., as part of obtaining consent), users should assume that cookies are permanent and that the
storage period can be up to two years.
General notes on revocation and objection (so-called "Opt-Out"): Users can revoke the consents
they have given at any time and object to the processing in accordance with legal requirements. Users can restrict
the use of cookies in their browser settings, among other options (although this may also limit the functionality of
our online offering). A objection to the use of cookies for online marketing purposes can also be made through the
websites https://optout.aboutads.info and https://www.youronlinechoices.com/.
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
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 context of contractual and
comparable legal relationships as well as associated actions and communication with the contractual partners or
pre-contractually, e.g. to answer inquiries.
We process this data in order to fulfill our contractual obligations. These include, in particular, the obligations
to provide the agreed services, any update obligations and remedies in the event of warranty and other service
disruptions. In addition, we process the data to protect our rights and for the purpose of administrative tasks
associated with these obligations and company organization. Furthermore, we process the data on the basis of our
legitimate interests in proper and economical business management as well as security measures to protect our
contractual partners and our business operations from misuse, endangerment of their data, secrets, information and
rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as
subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework
of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is
necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed
about further forms of processing, e.g. for marketing purposes, within the scope of this privacy policy.
Which data are necessary for the aforementioned purposes, we inform the contracting partners before or in the context
of the data collection, e.g. in online forms by special marking (e.g. colors), and/or symbols (e.g. asterisks or the
like), or personally.
We delete the data after expiry of statutory warranty and comparable obligations, i.e. in principle after expiry of 4
years, unless the data is stored in a customer account or must be kept for legal reasons of archiving. The statutory
retention period for documents relevant under tax law as well as for commercial books, inventories, opening balance
sheets, annual financial statements, the instructions required to understand these documents and other
organizational documents and accounting records is ten years and for received commercial and business letters and
reproductions of sent commercial and business letters six years. The period begins at the end of the calendar year
in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial
statements or the management report was prepared, the commercial or business letter was received or sent, or the
accounting document was created, furthermore the record was made or the other documents were created.
If we use third-party providers or platforms to provide our services, the terms and conditions and privacy policies
of the respective third-party providers or platforms shall 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 data (e.g. e-mail, telephone numbers); Contract data
(e.g. contract object, duration, customer category); Usage data (e.g. websites visited, interest in content,
access times). Meta, communication and process data (e.g. IP addresses, time information, identification
numbers, consent status).
- Data subjects: Customers; Prospective customers. Business and contractual
partners.
- Purposes of Processing: Provision of contractual services and fulfillment
of contractual obligations; Security measures; Contact requests and communication; Office and organisational
procedures. Managing and responding to inquiries.
- Legal Basis: Performance of a contract and prior requests (Article 6 (1)
(b) GDPR); Compliance with a legal obligation (Article 6 (1) (c) GDPR). Legitimate Interests (Article 6 (1) (f)
GDPR).
Further information on processing methods, procedures and services used:
- Customer Account: Customers can create an account within our online offer
(e.g. customer or user account, "customer account" for short). If the registration of a customer account is
required, customers will be informed of this as well as of the details required for registration. The customer
accounts are not public and cannot be indexed by search engines. In the course of registration and subsequent
registration and use of the customer account, we store the IP addresses of the contractual partners along with
the access times, in order to be able to prove the registration and prevent any misuse of the customer account.
If the customer account has been terminated, the customer account data will be deleted after the termination
date, unless it is retained for purposes other than provision in the customer account or must be retained for
legal reasons (e.g. internal storage of customer data, order transactions or invoices). It is the customers'
responsibility to back up their data when terminating the customer Account; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
- Online shop, order forms, e-commerce and delivery.: 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 performance of other services. If necessary for the
execution of an order, we use service providers, in particular postal, freight and shipping companies, in order
to carry out the delivery or execution to our customers. For the processing of payment transactions we use the
services of banks and payment service providers. The required details are identified as such in the course of
the ordering or comparable purchasing process and include the details required for delivery, or other way of
making the product available and invoicing as well as contact information in order to be able to hold any
consultation; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
- IT Services: We process the data of our customers and clients to enable
them to plan, implement, and support IT solutions and related services. The required information is marked as
such during the contract, project, or comparable conclusion of the contract and includes the information needed
for service provision and billing, as well as contact information for possible consultations. To the extent that
we have access to information from end customers, employees, or other persons, we process this in accordance
with legal and contractual requirements; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
- Software and Platform Services: We process the data of our users,
registered and any test users (hereinafter uniformly referred to as "users") in order to provide them with our
contractual services and on the basis of legitimate interests to ensure the security of our offer and to develop
it further. The required details are identified as such within the context of the conclusion of the agreement,
order or comparable contract and include the details required for the provision of services and invoicing as
well as contact information in order to be able to hold any further consultations; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
Providers and services used in the course of business
As part of our business activities, we use
additional services, platforms, interfaces or plug-ins from third-party providers (in short, "services") in
compliance with legal requirements. Their use is based on our interests in the proper, legal and economic management
of our business operations and internal organization.
- 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); Content data
(e.g. text input, photographs, videos). Contract data (e.g. contract object, duration, customer category).
- Data subjects: Customers; Prospective customers; Users (e.g. website
visitors, users of online services); Business and contractual partners. Employees (e.g. Employees, job
applicants).
- Purposes of Processing: Provision of contractual services and fulfillment
of contractual obligations. Office and organisational procedures.
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
Payment Procedure
Within the framework of contractual and other legal relationships, due to legal
obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure
payment options and use other service providers for this purpose in addition to banks and credit institutions
(collectively referred to as "payment service providers").
The data processed by the payment service providers includes inventory data, such as the name and address, bank data,
such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and
recipient-related information. The information is required to carry out the transactions. However, the data entered
is only processed by the payment service providers and stored with them. I.e. we do not receive any account or
credit card related information, but only information with confirmation or negative information of the payment.
Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The
purpose of this transmission is to check identity and creditworthiness. Please refer to the terms and conditions and
data protection information of the payment service providers.
The terms and conditions and data protection information of the respective payment service providers apply to the
payment transactions and can be accessed within the respective websites or transaction applications. We also refer
to these for further information and the assertion of revocation, information and other data subject rights.
- Processed data types: Inventory data (e.g. names, addresses); Payment Data
(e.g. bank details, invoices, payment history); Contract data (e.g. contract object, duration, customer
category); Usage data (e.g. websites visited, interest in content, access times). Meta, communication and
process data (e.g. IP addresses, time information, identification numbers, consent status).
- Data subjects: Customers. Prospective customers.
- Purposes of Processing: Provision of contractual services and fulfillment
of contractual obligations.
- Legal Basis: Performance of a contract and prior requests (Article 6 (1)
(b) GDPR).
Further information on processing methods, procedures and services used:
- Stripe: Payment-Service-Provider (technical integration of
online-payment-methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA
94103, USA; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Website:
https://stripe.com/de; Privacy Policy: https://stripe.com/en-de/privacy. Basis
for third-country transfers: EEA - Data Privacy Framework (DPF).
Provision of online services and web hosting
We process user data in order to be able to provide
them with our online services. For this purpose, we process the IP address of the user, which is necessary to
transmit the content and functions of our online services to the user's browser or terminal device.
- Processed data types: Usage data (e.g. websites visited, interest in
content, access times); Meta, communication and process data (e.g. IP addresses, time information,
identification numbers, consent status). Content data (e.g. text input, photographs, videos).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of Processing: Provision of our online services and usability;
Information technology infrastructure (Operation and provision of information systems and technical devices,
such as computers, servers, etc.).); Security measures. Content Delivery Network (CDN).
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Provision of online offer on rented hosting space: For the provision of
our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from
a corresponding server provider (also referred to as a "web hoster"); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
- Provision of online services on own/ dedicated server hardware: For the
provision of our online services, we use server hardware operated by us as well as, the storage space, computing
capacity and software associated with it; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
- Collection of Access Data and Log Files: The access to our online services
is logged in the form of so-called "server log files". Server log files may include the address and name of the
web pages and files accessed, the date and time of access, data volumes transferred, notification of successful
access, browser type and version, the user's operating system, referrer URL (the previously visited page) and,
as a general rule, IP addresses and the requesting provider. The server log files can be used for security
purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS
attacks) and to ensure the stability and optimal load balancing of the servers; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Retention
period: Log file information is stored for a maximum period of 30 days and then deleted or
anonymized. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion
until the respective incident has been finally clarified.
- E-mail Sending and Hosting: The web hosting services we use also include
sending, receiving and storing e-mails. For these purposes, the addresses of the recipients and senders, as well
as other information relating to the sending of e-mails (e.g. the providers involved) and the contents of the
respective e-mails are processed. The above data may also be processed for SPAM detection purposes. Please note
that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted during
transport, but not on the servers from which they are sent and received (unless a so-called end-to-end
encryption method is used). We can therefore accept no responsibility for the transmission path of e-mails
between the sender and reception on our server; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
- Content-Delivery-Network: We use a so-called "Content Delivery Network"
(CDN). A CDN is a service with whose help contents of our online services, in particular large media files, such
as graphics or scripts, can be delivered faster and more securely with the help of regionally distributed
servers connected via the Internet; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
- Hetzner: Services in the field of the provision of information technology
infrastructure and related services (e.g. storage space and/or computing capacities); Service
provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website:
https://www.hetzner.com; Privacy Policy:
https://www.hetzner.com/de/rechtliches/datenschutz;
Data Processing Agreement: https://docs.hetzner.com/de/general/general-terms-and-conditions/data-privacy-faq/.
Basis for third-country transfers: Switzerland - Adequacy decision (Germany).
- Cloudflare: Content-Delivery-Network (CDN) - service with whose help
contents of our online services, in particular large media files, such as graphics or scripts, can be delivered
faster and more securely with the help of regionally distributed servers connected via the Internet; Service
provider: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website:
https://www.cloudflare.com; Privacy
Policy: https://www.cloudflare.com/privacypolicy/;
Data Processing Agreement: https://www.cloudflare.com/cloudflare-customer-dpa/.
Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Standard
Contractual Clauses (https://www.cloudflare.com/cloudflare-customer-scc/).
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. Furthermore, we may contact users in compliance with the statutory provisions if communication
is necessary for the purposes of administration or use of the application. In addition, we refer to the data
protection information in this privacy policy with regard to the processing of user data.
Legal basis: The processing of data necessary for the provision of the functionalities of the
application serves to fulfil 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 is processed on the basis of the consent.
- Processed data types: Inventory data (e.g. names, addresses); Meta,
communication and process data (e.g. IP addresses, time information, identification numbers, consent status);
Payment Data (e.g. bank details, invoices, payment history); Contract data (e.g. contract object, duration,
customer category). Audio recordings.
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of Processing: Provision of contractual services and fulfillment
of contractual obligations.
- Legal Basis: Consent (Article 6 (1) (a) GDPR); Performance of a contract
and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- 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 provide them with our
contractual services and on the basis of legitimate interests to ensure the security of our application and to
develop it further. The required details are identified as such within the scope of the conclusion of a contract
for the use of the application, the conclusion of an order, an order or a comparable contract and may include
the details required for the provision of services and any invoicing as well as contact information in order to
be able to hold any consultations; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
- Storage of the universally unique identifier (UUID): The application
stores a so-called Universally Unique Identifier (UUID) for the purpose of analysing the use and functionality
of the application and storing the user's settings. This identifier is generated when the application is
installed (but is not connected to the device, so no device ID in this sense), remains stored between the start
of the application and its updates and is deleted when users remove the application from their device.
- Storage of an own unique identifier: In order to provide the application
and ensure its functionality, we use a pseudonymous identifier. The identifier is a mathematical value (i.e. no
clear data such as names are used) that is assigned to a device and/or the installation of the application
installed on it. This identifier is generated during the installation of the application, remains stored between
the start of the application and its updates and is deleted when users remove the application from the device.
- Device authorizations for access to functions and data: The use of certain
functions of our application may require access to the camera and the stored recordings of the users. By
default, these authorizations must be granted by the user and can be revoked at any time in the settings of the
respective devices. The exact procedure for controlling app permissions may depend on the user's device and
software. Users can contact us if they require further explanation. We would like to point out that the refusal
or revocation of the respective authorizations can affect the functionality of our application.
- Use of the microphone functions: The use of certain functions of our
application may require access to the camera and the stored recordings of the users. By default, these
authorizations must be granted by the user and can be revoked at any time in the settings of the respective
devices. The exact procedure for controlling app permissions may depend on the user's device and software. Users
can contact us if they require further explanation. We would like to point out that the refusal or revocation of
the respective authorizations can affect the functionality of our application.
- Location history and movement profiles: The location data is only used
selectively and is not processed to create a location history or a movement profile of the devices used or of
their users.
Purchase of applications via Appstores
The purchase of our apps is done 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 webanalytics and for interest-related marketing as well as possible
costs.
- 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. contract object, duration, customer category); Usage data (e.g. websites visited, interest in content,
access times); Meta, communication and process data (e.g. IP addresses, time information, identification
numbers, consent status). Content data (e.g. text input, photographs, videos).
- Data subjects: Customers. Users (e.g. website visitors, users of online
services).
- Purposes of Processing: Provision of contractual services and fulfillment
of contractual obligations. Marketing.
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
Registration, Login and User Account
Users can create a user account. Within the scope of
registration, the required mandatory information is communicated to the users and processed for the purposes of
providing the user account on the basis of contractual fulfilment of obligations. The processed data includes in
particular the login information (name, password and an e-mail address).
Within the scope of using our registration and login functions as well as the use of the user account, we store the
IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as
the user's protection against misuse and other unauthorized use. This data will not be passed on to third parties
unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users may be informed by e-mail of information relevant to their user account, such as technical changes.
- Processed data types: Inventory data (e.g. names, addresses); Contact data
(e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos). Meta, communication and
process data (e.g. IP addresses, time information, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of Processing: Provision of contractual services and fulfillment
of contractual obligations; Security measures; Managing and responding to inquiries. Provision of our online
services and usability.
- Legal Basis: Performance of a contract and prior requests (Article 6 (1)
(b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Registration with pseudonyms: Users may use pseudonyms as user names
instead of real names; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
- Users' profiles are public: Users' profiles are publicly visible and
accessible.
- Setting the visibility of profiles: By setting preferences, users can
determine the extent to which their profiles are visible or accessible to the public or only to certain groups
of people; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
Community Functions
The community functions provided by us allow users to engage in conversations
and other forms of interaction with each other. Please note that the use of the community functions is only
permitted in compliance with the applicable legal situation, our terms and guidelines and the rights of other users
and third parties.
- Processed data types: Usage data (e.g. websites visited, interest in
content, access times). Meta, communication and process data (e.g. IP addresses, time information,
identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of Processing: Provision of contractual services and fulfillment
of contractual obligations. Security measures.
- Legal Basis: Performance of a contract and prior requests (Article 6 (1)
(b) GDPR).
Further information on processing methods, procedures and services used:
- User contributions are public: The posts and content created by users are
publicly visible and accessible; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
- Storage of data for security purposes: The posts and other entries of the
users are processed for the purposes of the community and conversation functions and, subject to legal
obligations or legal permission, are not disclosed to third parties. An obligation to disclosure may arise in
particular in the case of unlawful posts for the purposes of legal prosecution. We would like to point out that,
in addition to the content of the posts, their time and the IP address of the user are also stored. This is done
in order to be able to take appropriate measures to protect other users and the community; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
- Restricted deletion of posts: Out of consideration for other users, the
user's contributions to conversations remain stored even after termination and account deletion, so that
conversations, comments, advice and similar communications do not lose their meaning or become inverted.This
ensures that conversations, comments, advice or similar communication between and among users do not lose their
meaning or become inverted. User names will be deleted or pseudonymised if they were not already
pseudonyms.Users can request the complete deletion of their posts at any time; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
- Protection of own data: Users decide for themselves what data they
disclose about themselves within our online services. For example, when users provide personal information or
participate in conversations. We ask users to protect their data and to publish personal data only with caution
and only to the extent necessary. In particular, we ask users to note that they must protect their login
credentials in particular and use secure passwords (preferably long and random combinations of characters);
Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
Contact and Inquiry Management
When contacting us (e.g. via mail, contact form, e-mail, telephone
or via social media) as well as in the context of existing user and business relationships, the information of the
inquiring persons is processed to the extent necessary to respond to the contact requests and any requested
measures.
- Processed data types: Contact data (e.g. e-mail, telephone numbers);
Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content,
access times); Meta, communication and process data (e.g. IP addresses, time information, identification
numbers, consent status). Inventory data (e.g. names, addresses).
- Data subjects: Communication partner (Recipients of e-mails, letters,
etc.).
- Purposes of Processing: Contact requests and communication; Managing and
responding to inquiries; Feedback (e.g. collecting feedback via online form). Provision of our online services
and usability.
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Performance of
a contract and prior requests (Article 6 (1) (b) GDPR).
Further information on processing methods, procedures and services used:
- Contact form: When users contact us via our contact form, e-mail or other
communication channels, we process the data provided to us in this context to process the communicated request;
Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
- LiveChat: Chatbot and assistance software and related services; Service
provider: LiveChat Inc., One International Place, Suite 1400 Boston, Massachusetts 02110, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website:
https://www.livechatinc.com; Privacy
Policy: https://www.livechatinc.com/legal/privacy-policy/.
Basis for third-country transfers: EEA - Data Privacy Framework (DPF).
Push notifications
With the consent of the users, we can send the users so-called "push
notifications". These are messages that are displayed on users' screens, devices or browsers, even if our online
services are not being actively used.
In order to sign up for push messages, users must confirm that their browser or device has requested to receive push
messages. This approval process is documented and stored. The storage is necessary to recognize 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.
The push messages may be necessary for the fulfilment of contractual obligations (e.g. technical and organisational
information relevant for the use of our online offer) and will otherwise be sent, unless specifically mentioned
below, on the basis of user consent. Users can change the receipt of push messages at any time using the
notification settings of their respective browsers or end devices.
- Processed data types: Usage data (e.g. websites visited, interest in
content, access times). Meta, communication and process data (e.g. IP addresses, time information,
identification numbers, consent status).
- Data subjects: Communication partner (Recipients of e-mails, letters,
etc.).
- Purposes of Processing: Provision of our online services and usability.
- Legal Basis: Consent (Article 6 (1) (a) GDPR). Performance of a contract
and prior requests (Article 6 (1) (b) GDPR).
Cloud Services
We use Internet-accessible software services (so-called "cloud services", also
referred to as "Software as a Service") provided on the servers of its providers for the storage and management of
content (e.g. document storage and management, exchange of documents, content and information with certain
recipients or publication of content and information).
Within this framework, personal data may be processed and stored on the provider's servers insofar as this data is
part of communication processes with us or is otherwise processed by us in accordance with this privacy policy. This
data may include in particular master data and contact data of data subjects, data on processes, contracts, other
proceedings and their contents. Cloud service providers also process usage data and metadata that they use for
security and service optimization purposes.
If we use cloud services to provide documents and content to other users or publicly accessible websites, forms,
etc., providers may store cookies on users' devices for web analysis or to remember user settings (e.g. in the case
of media control).
- Processed data types: Inventory data (e.g. names, addresses); Contact data
(e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data (e.g. websites
visited, interest in content, access times). Meta, communication and process data (e.g. IP addresses, time
information, identification numbers, consent status).
- Data subjects: Customers; Employees (e.g. Employees, job applicants);
Prospective customers. Communication partner (Recipients of e-mails, letters, etc.).
- Purposes of Processing: Office and organisational procedures. Information
technology infrastructure (Operation and provision of information systems and technical devices, such as
computers, servers, etc.).).
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
Newsletter and Electronic Communications
We send newsletters, e-mails and other electronic
communications (hereinafter referred to as "newsletters") only with the consent of the recipient or a legal
permission. Insofar as the contents of the newsletter are specifically described within the framework of
registration, they are decisive for the consent of the user. Otherwise, our newsletters contain information about
our services and us.
In order to subscribe to our newsletters, it is generally sufficient to enter your e-mail address. We may, however,
ask you to provide a name for the purpose of contacting you personally in the newsletter or to provide further
information if this is required for the purposes of the newsletter.
Double opt-in procedure: The registration to our newsletter takes place in general in a so-called
Double-Opt-In procedure. This means that you will receive an e-mail after registration asking you to confirm your
registration. This confirmation is necessary so that no one can register with external e-mail addresses.
The registrations for the newsletter are logged in order to be able to prove the registration process according to
the legal requirements. This includes storing the login and confirmation times as well as the IP address. Likewise
the changes of your data stored with the dispatch service provider are logged.
Deletion and restriction of processing: We may store the unsubscribed email addresses for up to
three years based on our legitimate interests before deleting them to provide evidence of prior consent. The
processing of these data is limited to the purpose of a possible defense against claims. An individual deletion
request is possible at any time, provided that the former existence of a consent is confirmed at the same time. In
the case of an obligation to permanently observe an objection, we reserve the right to store the e-mail address
solely for this purpose in a blocklist.
The logging of the registration process takes place on the basis of our legitimate interests for the purpose of
proving its proper course. 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.
Contents: Information about us, our services, promotions and offers.
- Processed data types: Inventory data (e.g. names, addresses); Contact data
(e.g. e-mail, telephone numbers); Meta, communication and process data (e.g. IP addresses, time information,
identification numbers, consent status). Usage data (e.g. websites visited, interest in content, access times).
- Data subjects: Communication partner (Recipients of e-mails, letters,
etc.).
- Purposes of Processing: Direct marketing (e.g. by e-mail or postal).
- Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests
(Article 6 (1) (f) GDPR).
- Opt-Out: You can cancel the receipt of our newsletter at any time, i.e.
revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the
end of each newsletter or you can otherwise use one of the contact options listed above, preferably e-mail.
Further information on processing methods, procedures and services used:
- Measurement of opening rates and click rates: The newsletters contain a
so-called "web-beacon", i.e. a pixel-sized file, which is retrieved from our server when the newsletter is
opened or, if we use a mailing service provider, from its server. Within the scope of this retrieval, technical
information such as information about the browser and your system, as well as your IP address and time of
retrieval are first collected.
This information is used for the technical improvement of our newsletter
on the basis of technical data or target groups and their reading behaviour on the basis of their retrieval
points (which can be determined with the help of the IP address) or access times. This analysis also includes
determining whether newsletters are opened, when they are opened and which links are clicked. This information
is assigned to the individual newsletter recipients and stored in their profiles until the profiles are deleted.
The evaluations serve us much more 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 opening rates
and click rates as well as the storage of the measurement results in the profiles of the users and their further
processing are based on the consent of the users.
A separate objection to the performance measurement is
unfortunately not possible, in this case the entire newsletter subscription must be cancelled or objected to. In
this case, the stored profile information will be deleted; Legal Basis: Consent (Article 6 (1) (a) GDPR).
- Mailjet: Email distribution and email marketing platform; Service
provider: Mailjet SAS,13-13 bis, rue de l’Aubrac, 75012 Paris, France; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website:
https://www.mailjet.com; Privacy Policy:
https://www.mailjet.com/privacy-policy/.
Basis for third-country transfers: Switzerland - Adequacy decision (France).
Commercial communication by E-Mail, Postal Mail, Fax or Telephone
We process personal data for the
purposes of promotional communication, which may be carried out via various channels, such as e-mail, telephone,
post or fax, in accordance with the legal requirements.
The recipients have the right to withdraw their consent at any time or to object to the advertising communication at
any time.
After revocation or objection, we store the data required to prove the past authorization to contact or send up to
three years from the end of the year of revocation or objection on the basis of our legitimate interests. The
processing of this data is limited to the purpose of a possible defense against claims. Based on the legitimate
interest to permanently observe the revocation, respectively objection of the users, we further store the data
necessary to avoid a renewed contact (e.g. depending on the communication channel, the e-mail address, telephone
number, name).
- Processed data types: Inventory data (e.g. names, addresses). Contact data
(e.g. e-mail, telephone numbers).
- Data subjects: Communication partner (Recipients of e-mails, letters,
etc.).
- Purposes of Processing: Direct marketing (e.g. by e-mail or postal).
- Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests
(Article 6 (1) (f) GDPR).
Web Analysis, Monitoring and Optimization
Web analysis is used to evaluate the visitor traffic on
our website and may include the behaviour, interests or demographic information of users, such as age or gender, as
pseudonymous values. With the help of web analysis we can e.g. recognize, at which time our online services or their
functions or contents are most frequently used or requested for repeatedly, as well as which areas require
optimization.
In addition to web analysis, we can also use test procedures, e.g. to test and optimize different versions of our
online services or their components.
Unless otherwise stated below, profiles, i.e. data aggregated for a usage process, can be created for these purposes
and information can be stored in a browser or in a terminal device and read from it. The information collected
includes, in particular, websites visited and elements used there as well as technical information such as the
browser used, the computer system used and information on usage times. If users have agreed to the collection of
their location data from us or from the providers of the services we use, location data may also be processed.
Unless otherwise stated below, profiles, that is data summarized for a usage process or user, may be created for
these purposes and stored in a browser or terminal device (so-called "cookies") or similar processes may be used for
the same purpose. The information collected includes, in particular, websites visited and elements used there as
well as technical information such as the browser used, the computer system used and information on usage times. If
users have consented to the collection of their location data or profiles to us or to the providers of the services
we use, these may also be processed, depending on the provider.
The IP addresses of the users are also stored. However, we use any existing IP masking procedure (i.e.
pseudonymisation by shortening the IP address) to protect the user. In general, within the framework of web
analysis, A/B testing and optimisation, no user data (such as e-mail addresses or names) is stored, 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 processes.
- Processed data types: Usage data (e.g. websites visited, interest in
content, access times). Meta, communication and process data (e.g. IP addresses, time information,
identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of Processing: Web Analytics (e.g. access statistics, recognition
of returning visitors). Profiles with user-related information (Creating user profiles).
- Security measures: IP Masking (Pseudonymization of the IP address).
- Legal Basis: Consent (Article 6 (1) (a) GDPR).
Further information on processing methods, procedures and services used:
- Matomo: Matomo is software that is used for the purposes of web analysis
and reach measurement. As part of the use of Matomo, cookies are generated and stored on the user's terminal
device. User data collected through the use of Matomo is processed only by us and is not shared with third
parties. The cookies are stored for a maximum period of 13 months: https://matomo.org/faq/general/faq_146/; Legal Basis: Consent (Article 6 (1) (a) GDPR). Retention
period: The cookies have a maximum storage period of 13 months.
Online Marketing
We process personal data for the purposes of online marketing, 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 their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar
procedure is used by which the relevant user information for the display of the aforementioned content is stored.
This information may include, for example, content viewed, websites visited, online networks used, communication
partners and technical information such as the browser used, computer system used and information on usage times and
used functions. If users have consented to the collection of their sideline data, these can also be processed.
The IP addresses of the users are also stored. However, we use provided IP masking procedures (i.e. pseudonymisation
by shortening the IP address) to ensure the protection of the user's by using a pseudonym. In general, within the
framework of the online marketing process, no clear user data (such as e-mail addresses or names) is secured, but
pseudonyms. This means that we, as well as the providers of online marketing procedures, do not know the actual
identity of the users, but only the information stored in their profiles.
The information in the profiles is usually stored in the cookies or similar memorizing procedures. These cookies can
later, generally also on other websites that use the same online marketing technology, be read and analyzed for
purposes of content display, as well as supplemented with other data and stored on the server of the online
marketing technology provider.
Exceptionally, 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 technology we use and the network links the profiles of the users in the
aforementioned data. Please note that users may enter into additional agreements with the social network providers
or other service providers, e.g. by consenting as part of a registration process.
As a matter of principle, we only gain access to summarised information about the performance of our advertisements.
However, within the framework of so-called conversion measurement, we can check which of our online marketing
processes have led to a so-called conversion, i.e. to the conclusion of a contract with us. The conversion
measurement is used alone for the performance analysis of our marketing activities.
Unless otherwise stated, we kindly ask you to consider that cookies used will be stored for a period of two
years.
- Processed data types: Content data (e.g. text input, photographs, videos);
Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data
(e.g. IP addresses, time information, identification numbers, consent status); Event Data (Facebook) ("Event
Data" is data that can be transmitted from us to Facebook, e.g. via Facebook pixels (via apps or other means)
and relates to persons or their actions; the data includes, for example, information about visits to websites,
interactions with content, functions, installations of apps, purchases of products, etc.; Event data is
processed for the purpose of creating target groups for content and advertising information (Custom Audiences).
Event Data does not include the actual content (such as written comments), login information, and Contact
Information (such as names, email addresses, and phone numbers). Event Data is deleted by Facebook after a
maximum of two years, the Custom Audiences created from them with the deletion of our Facebook account).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of Processing: Web Analytics (e.g. access statistics, recognition
of returning visitors); Targeting (e.g. profiling based on interests and behaviour, use of cookies); Conversion
tracking (Measurement of the effectiveness of marketing activities); Affiliate Tracking; Marketing; Profiles
with user-related information (Creating user profiles). Provision of our online services and usability.
- Security measures: IP Masking (Pseudonymization of the IP address).
- Legal Basis: Consent (Article 6 (1) (a) GDPR).
- Opt-Out: We refer to the privacy policies of the respective service
providers and the possibilities for objection (so-called "opt-out"). If no explicit opt-out option has been
specified, it is possible to deactivate cookies in the settings of your browser. However, this may restrict the
functions of our online offer. We therefore recommend the following additional opt-out options, which are
offered collectively for each area:
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.
Further information on processing methods, procedures and services used:
- Meta Pixel and Custom Audiences (Custom Audiences): With the help of the
Meta-Pixel (or equivalent functions, to transfer Event-Data or Contact Information via interfaces or other
software in apps), Meta is on the one hand able to determine the visitors of our online services as a target
group for the presentation of ads (so-called "Meta ads"). Accordingly, we use Meta-Pixels to display Meta ads
placed by us only to Meta users and within the services of partners cooperating with Meta (so-called "audience
network" https://www.facebook.com/audiencenetwork/
) who have shown an interest in our online services or who have certain characteristics (e.g. interests in
certain topics or products that are determined on the basis of the websites visited) that we transmit to Meta
(so-called "custom audiences"). With the help of Meta-Pixels, we also want to ensure that our Meta ads
correspond to the potential interest of users and do not appear annoying. The Meta-Pixel also enables us to
track the effectiveness of Meta ads for statistical and market research purposes by showing whether users were
referred to our website after clicking on a Meta ad (known as "conversion tracking"); Service
provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website:
https://www.facebook.com; Privacy
Policy: https://www.facebook.com/about/privacy;
Data Processing Agreement: https://www.facebook.com/legal/terms/dataprocessing;
Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Adequacy
decision (Ireland). Further Information: User event data, i.e. behavioral and interest data, is
processed for the purposes of targeted advertising and audience building on the basis of the joint
controllership agreement ("Controller Addendum", https://www.facebook.com/legal/controller_addendum).
The joint controllership is limited to the collection and transfer of the data to Meta Platforms Ireland
Limited, a company located in the EU. Further processing of the data is the sole responsibility of Meta
Platforms Ireland Limited, which concerns in particular the transfer of the data to the parent company Meta
Platforms, Inc. in the USA (on the basis of standard contractual clauses concluded between Meta Platforms
Ireland Limited and Meta Platforms, Inc.).
- Facebook Ads: Placement of ads within the Facebook platform and analysis
of ad results; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04
X2K5, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website:
https://www.facebook.com; Privacy
Policy: https://www.facebook.com/about/privacy;
Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Adequacy
decision (Ireland); Opt-Out: We refer to the privacy and advertising settings in the users'
profiles on the Facebook platforms, as well as to Facebook's consent procedures and contact options for
exercising access and other data subject rights, as described in Facebook's privacy policy. Further
Information: User event data, i.e. behavioral and interest data, is processed for the purposes of
targeted advertising and audience building on the basis of the joint controllership agreement ("Controller
Addendum", https://www.facebook.com/legal/controller_addendum).
The joint controllership is limited to the collection and transfer of the data to Meta Platforms Ireland
Limited, a company located in the EU. Further processing of the data is the sole responsibility of Meta
Platforms Ireland Limited, which concerns in particular the transfer of the data to the parent company Meta
Platforms, Inc. in the USA (on the basis of standard contractual clauses concluded between Meta Platforms
Ireland Limited and Meta Platforms, Inc.).
Profiles in Social Networks (Social Media)
We maintain online presences within social networks and
process user data in this context in order to communicate with the users active there or to offer information about
us.
We would like to point out that user data may be processed outside the European Union. This may entail risks for
users, e.g. by making it more difficult to enforce users' rights.
In addition, user data is usually processed within social networks for market research and advertising purposes. For
example, user profiles can be created on the basis of user behaviour and the associated interests of users. The user
profiles can then be used, for example, to place advertisements within and outside the networks which are presumed
to correspond to the interests of the users. For these purposes, cookies are usually stored on the user's computer,
in which the user's usage behaviour and interests are stored. Furthermore, data can be stored in the user profiles
independently of the devices used by the users (especially if the users are members of the respective networks or
will become members later on).
For a detailed description of the respective processing operations and the opt-out options, please refer to the
respective data protection declarations and information provided by the providers of the respective networks.
Also in the case of requests for information and the exercise of rights of data subjects, we point out that these can
be most effectively pursued with the providers. Only the providers have access to the data of the users and can
directly take appropriate measures and provide information. If you still need help, please do not hesitate to
contact us.
- Processed data types: Contact data (e.g. e-mail, telephone numbers);
Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content,
access times). Meta, communication and process data (e.g. IP addresses, time information, identification
numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of Processing: Contact requests and communication; Feedback (e.g.
collecting feedback via online form). Marketing.
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Instagram: Social network; Service provider: Meta
Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website:
https://www.instagram.com; Privacy
Policy: https://instagram.com/about/legal/privacy.
Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Adequacy
decision (Ireland).
- Facebook Pages: Profiles within the social network Facebook; Service
provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website:
https://www.facebook.com; Privacy
Policy: https://www.facebook.com/about/privacy;
Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Adequacy
decision (Ireland); Further Information: We are jointly responsible (so called "joint
controller") with Meta Platforms Ireland Limited for the collection (but not the further processing) of data of
visitors to our Facebook page. This data includes information about the types of content users view or interact
with, or the actions they take (see "Things that you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/policy), and
information about the devices used by users (e.g., IP addresses, operating system, browser type, language
settings, cookie information. see "Device Information" in the Facebook Data Policy: https://www.facebook.com/policy). As
explained in the Facebook Data Policy under "How we use this information?" Facebook also collects and uses
information to provide analytics services, known as "page insights," to site operators to help them understand
how people interact with their pages and with content associated with them. We have concluded a special
agreement with Facebook ("Information about Page-Insights", https://www.facebook.com/legal/terms/page_controller_addendum),
which regulates in particular the security measures that Facebook must observe and in which Facebook has agreed
to fulfill the rights of the persons concerned (i.e. users can send information access or deletion requests
directly to Facebook). The rights of users (in particular to access to information, erasure, objection and
complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further
information can be found in the "Information about Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data).
The joint controllership is limited to the collection and transfer of the data to Meta Platforms Ireland
Limited, a company located in the EU. Further processing of the data is the sole responsibility of Meta
Platforms Ireland Limited.
Plugins and embedded functions and content
Within our online services, we integrate functional and
content elements that are obtained from the servers of their respective providers (hereinafter referred to as
"third-party providers"). These may, for example, be 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 they could not send the content to their browser without the IP address. The IP address is therefore required
for the presentation of these contents or functions. We strive to use only those contents, whose respective offerers
use the IP address only for the distribution of the contents. Third parties may 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 may
also be stored in cookies on the user's device and may include technical information about the browser and operating
system, referring websites, visit times and other information about the use of our website, as well as may be linked
to such information from other sources.
- Processed data types: Usage data (e.g. websites visited, interest in
content, access times). Meta, communication and process data (e.g. IP addresses, time information,
identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of Processing: Provision of our online services and usability.
Provision of contractual services and fulfillment of contractual obligations.
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Integration of third-party software, scripts or frameworks: We incorporate
into our online services software which we retrieve from servers of other providers (e.g. function libraries
which we use for the purpose of displaying or user-friendliness of our online services). The respective
providers collect the user's IP address and can process it for the purposes of transferring the software to the
user's browser as well as for security purposes and for the evaluation and optimisation of their services; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
- Google Fonts (Provision on own server): Provision of font files for the
purpose of a user-friendly presentation of our online services; Service provider: The Google
Fonts are hosted on our server, no data is transmitted to Google; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
- reCAPTCHA: We integrate the "reCAPTCHA" function to be able to recognise
whether entries (e.g. in online forms) are made by humans and not by automatically operating machines (so-called
"bots"). The data processed may include IP addresses, information on operating systems, devices or browsers
used, language settings, location, mouse movements, keystrokes, time spent on websites, previously visited
websites, interactions with ReCaptcha on other websites, possibly cookies and results of manual recognition
processes (e.g. answering questions asked or selecting objects in images). The data processing is based on our
legitimate interest to protect our online services from abusive automated crawling and spam; Service
provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, , parent company:
Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website:
https://www.google.com/recaptcha/; Privacy
Policy: https://policies.google.com/privacy;
Basis for third-country transfers: EEA - Data Privacy Framework (DPF).
Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en,
Settings for the Display of Advertisements: https://myadcenter.google.com/personalizationoff.
Changes and Updates to the Privacy Policy
We kindly ask you to inform yourself regularly about the
contents of our data protection declaration. We will adjust the privacy policy as changes in our data processing
practices 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 privacy policy, we ask you to
note that addresses may change over time and to verify the information before contacting us.
Terminology and Definitions
In this section, you will find an overview of the terminology used in
this privacy policy. Where the terminology is legally defined, their legal definitions apply. The following
explanations, however, are primarily intended to aid understanding.
- Affiliate Tracking: Custom Audiences refers to the process of determining
target groups for advertising purposes, e.g. the display of advertisements. For example, a user's interest in
certain products or topics on the Internet may be used to conclude that the user is interested in advertisements
for similar products or the online store in which the user viewed the products. "Lookalike Audiences" is the
term used to describe content that is viewed as suitable by users whose profiles or interests presumably
correspond to the users for whom the profiles were created. For the purposes of creating custom audiences and
lookalike audiences, cookies and web beacons are typically used.
- Content Delivery Network (CDN): A "Content Delivery Network" (CDN) is a
service with whose help contents of our online services, in particular large media files, such as graphics or
scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via
the Internet.
- Controller: "Controller" means the natural or legal person, public
authority, agency or other body which, alone or jointly with others, determines the purposes and means of the
processing of personal data.
- Conversion tracking: Conversion tracking is a method used to evaluate the
effectiveness of marketing measures. For this purpose, a cookie is usually stored on the devices of the users
within the websites on which the marketing measures take place and then called up again on the target website
(e.g. we can thus trace whether the advertisements placed by us on other websites were successful).
- Personal Data: "personal data" means any information relating to an
identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be
identified, directly or indirectly, in particular by reference to an identifier such as a name, an
identification number, location data, an online identifier or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Processing: The term "processing" covers a wide range and practically
every handling of data, be it collection, evaluation, storage, transmission or erasure.
- Profiles with user-related information: The processing of "profiles with
user-related information", or "profiles" for short, includes any kind of automated processing of personal data
that consists of using these personal data to analyse, evaluate or predict certain personal aspects relating to
a natural person (depending on the type of profiling, this may include different information concerning
demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g.
interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are
often used for profiling purposes.
- Targeting: "Tracking" is the term used when the behaviour of users can be
traced across several websites. As a rule, behavior and interest information with regard to the websites used is
stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information
can then be used, for example, to display advertisements to users presumably corresponding to their interests.
- Web Analytics: Web Analytics serves the evaluation of visitor traffic of
online services and can determine their behavior or interests in certain information, such as content of
websites. With the help of web analytics, website owners, for example, can recognize at what time visitors visit
their website and what content they are interested in. This enables them, for example, to better adapt the
content of their websites to the needs of their visitors. For the purposes of web analytics , pseudonymous
cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of
the use of an online service.
