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With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what 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 the “Online Offer”).
The terms used are not gender specific.
Status: February 16, 2021
Daniel Leonforte
Eigenart Film Production
Wielandstrasse 4
65187 Wiesbaden
GERMANY
E-mail address: d.leonforte@eigenart-filmproduktion.de
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
In the following, we share the legal basis of the General Data Protection Regulation(GDPR) on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence and domicile. If, in addition, more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.
National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. This includes, in particular, the Act 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 information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.
We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, ensuring the availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to data compromise. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
In the course of our processing of personal data, the data may be transferred to or disclosed to other entities, companies, legally independent organizational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.
If we collect data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of services of third parties or the disclosure or transfer of data to other persons, bodies or companies, this shall only take place in accordance with the statutory requirements.
Subject to express consent or contractually or legally required transfer, we process or have the data processed only in third countries with a recognized level of data protection, contractual obligation by 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, EU Commission information page: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).
Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after his visit within an online offer. Stored information may include, for example, language settings on a website, login status, a shopping cart, or where a video was watched. The term cookies also includes other technologies that perform the same functions as cookies (e.g., when user information is stored on the basis of pseudonymous online identifiers, also referred to as “user IDs”).
The following cookie types and functions are distinguished:
Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this applies and you consent to the use of cookies, the legal basis for the processing of your data is the declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the business 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 explicit information on the storage period of permanent cookies (e.g. in the context of a so-called cookie opt-in), please assume that the storage period 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 any consent you have given or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection by means of your browser settings, e.g. by deactivating the use of cookies (whereby this may also limit the functionality of our online offer). An objection to the use of cookies for online marketing purposes may also be declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further instructions on how to object 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 cookie consent management procedure under which users’ consents to the use of cookies, or to the processing operations and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users. The declaration of consent is stored so that it does not have to be repeated and the consent can be proven 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 their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. Here, a pseudonymous user identifier is formed and stored with the time of consent, information on the scope of consent (e.g., which categories of cookies and/or service providers), as well as the browser, system, and end device used.
Services used and service providers:
Cookies and messages about access numbers
We use “session cookies” from VG Wort, Munich, to measure accesses to texts in order to record the copy probability. Session cookies are small pieces of information that a provider stores in the RAM of the visitor’s computer. In a session cookie, a randomly generated unique identification number is stored, a so-called session ID. In addition, a cookie contains information about its origin and the storage period. Session cookies cannot store any other data. These measurements are carried out by Kantar Germany GmbH according to the Scalable Central Measurement Method (SZM). They help to determine the copying probability of individual texts for the remuneration of legal claims of authors and publishers. We do not collect any personal data via cookies.
Many of our pages are provided with JavaScript calls, via which we report the accesses to the Verwertungsgesellschaft Wort (VG Wort). [PLEASE CHECK whether this is the case with your publishing house!] We thus enable our authors to participate in the distributions of VG Wort, which is the statutory remuneration for the uses of copyrighted works according to the German Copyright Act. Ensure § 53 UrhG.
It is also possible to use our offers without cookies. Most browsers are set to accept cookies automatically. However, you can disable the storage of cookies or set your browser to notify you when cookies are sent.
Privacy policy for the use of the Scalable Centralized Measurement System
Our website and our mobile website use the “Scalable Central Measurement Method” (SZM) of Kantar Germany GmbH to determine statistical parameters for determining the copy probability of texts.
Anonymous measured values are collected in the process. The access count measurement alternatively uses a session cookie or a signature created from various automatically transmitted information from your browser to recognize computer systems. IP addresses are only processed in anonymized form.
The procedure was developed in compliance with data protection. The sole aim of the method is to determine the copy probability of individual texts.
At no time are individual users identified. Your identity always remains protected. You will not receive any advertising through the system.
We process data of 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 contractual partners (or pre-contractual), e.g. to answer inquiries.
We process this data to fulfill our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with this information as well as for business organization. Within the framework of applicable law, we only disclose the data of the contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or for the fulfillment of legal obligations or with the consent of the persons concerned (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about further 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 in the course of data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.
We delete the data after the expiry of legal warranty and comparable obligations, i.e., generally after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons (e.g., for tax purposes generally 10 years). We delete data disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, in principle 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 shall apply in the relationship between the users and the providers.
Economic analyses and market research: For business reasons and in order to be able to recognize market trends, wishes of contractual partners and users, we analyze the data we have on business transactions, contracts, inquiries, etc., whereby the group of data subjects may include contractual partners, interested parties, customers, visitors and users of our online offer.
The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we can take into account the profiles of registered users, if available, together with their details, e.g. on services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarized, i.e. anonymized values. Furthermore, we take into account the privacy of users and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g., as aggregated data).
Agency Services: We process our customers’ data as part of our contractual services, which may include, for example, conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consulting services, and training services.
Artistic and literary services: We process the data of our clients to enable them to select, acquire or commission the chosen services or works and related activities, as well as their payment and delivery or execution or performance.
The required information is identified as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for delivery and invoicing as well as contact information in order to be able to hold any consultations.
Events: We process the data of the participants of the events offered or hosted by us, events and similar activities (hereinafter uniformly referred to as “Participants” and “Events”) in order to enable them to participate in the events and to benefit from the services or promotions associated with participation.
If we process health-related data, religious, political or other special categories of data in this context, then this is done within the scope of disclosure (e.g. for thematically oriented events or serves health care, security or is done with the consent of the data subjects).
The required information is identified as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations. To the extent that we have access to information of end customers, employees or others, we process it in accordance with legal and contractual requirements.
Further information on commercial services: We process the data of our customers and clients (hereinafter uniformly referred to as “Customers”) in order to enable them to select, purchase or commission the selected services or works and related activities, as well as their payment and delivery or execution or performance.
The required information is identified as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations.
In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services.
The data processed in the course of providing the hosting service may include all information concerning the users of our online service that is generated in the course of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.
E-mail sending and hosting: The web hosting services we use also include the sending, receiving and storing of e-mails. For these purposes, the addresses of the recipients and senders as well as further information concerning the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for SPAM detection purposes. We ask you to note that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. Therefore, we cannot assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.
Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume 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.
The server log files may be used, on the one hand, for security purposes, e.g., to prevent server overload (especially in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability.
We process the data of the users of our application insofar as this is necessary to provide the users with the application and its functionalities, to monitor its security and to further develop it. We may also contact users in compliance with legal requirements, provided that the communication is necessary for purposes of administration or use of the application. In all other respects, 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 required 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., 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 purposes of optimizing the application or security purposes), it is based on our legitimate interests. If users are expressly asked for their consent to the processing of their data, the processing of the data covered by the consent is based on the consent.
Commercial use: We process the data of the users of our application, registered users and any test users (hereinafter uniformly referred to as “Users”) in order to be able to provide our contractual services to them and on the basis of legitimate interests to be able to ensure the security of our application and to develop it further. The required information is identified as such in the context of the conclusion of the use, order, purchase order or comparable contract and may include the information required for the provision of services and for 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 permissions for access to certain functions of the devices used or to the data stored on the devices or accessible by means of the devices. By default, these permissions must be granted by users 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 users’ device and software. Users can contact us if they need clarification. We would like to point out that the denial or revocation of the respective permissions may affect the functionality of our application.
No location history and no movement profiles: Location data is only used selectively and is not processed to create a location history or a movement profile of the devices used, or their users.
We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data are processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.
Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests. This is done for our security, in case someone leaves illegal content in comments and posts (insults, forbidden political propaganda, etc.). In this case, we ourselves may be prosecuted for the comment or post and are therefore interested in the identity of the author.
Furthermore, we reserve the right to process the user’s data for the purpose of spam detection on the basis of our legitimate interests.
On the same legal basis, in the case of surveys, we reserve the right to store the IP addresses of users for their duration and to use cookies to avoid multiple votes.
The personal information provided in the context of comments and contributions, any contact and website information as well as the content-related information will be stored permanently by us until the user objects.
Services used and service providers:
When contacting us (e.g. by contact form, e-mail, telephone or via social media), the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.
The response to contact requests in the context of contractual or pre-contractual relationships is made in order to fulfill our contractual obligations or to respond to (pre)contractual inquiries and otherwise on the basis of legitimate interests in responding to the inquiries.
Services used and service providers:
We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, on encryption, on the use of the metadata of the communication and on your objection options.
You can also contact us by alternative means, e.g. via telephone or e-mail. Please use the contact options provided to you or the contact options specified within our online offer.
In the case of end-to-end encryption of content (i.e., the content of your message and attachments), please note that the communication content (i.e., the content of the message and attached images) is encrypted from end to end. This means that the content of the messages is not viewable, not even by the messenger providers themselves. You should always use an up-to-date version of messengers with encryption enabled to ensure that message content is encrypted.
However, we additionally point out to our communication partners that the providers of the messengers cannot view the content, but can learn that and when communication partners communicate with us as well as technical information about the device used by the communication partners and, depending on the settings of their device, also location information (so-called metadata) is processed.
Notes on legal bases: If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and they contact us, for example, on their own initiative, we use Messenger in relation to our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners in communication via Messenger. Furthermore, we would like to point out that we do not transmit the contact data provided to us to the messengers for the first time without your consent.
Revocation, objection and deletion: You can revoke any consent you have given 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., e.g., as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information provided by the communication partners, if no reference to a previous conversation is to be expected and the deletion does not conflict with any legal retention obligations.
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 requests via Messenger. This is the case if, for example, contractual internals require special secrecy or a reply via Messenger does not meet formal requirements. In such cases, we refer you to more adequate communication channels.
Skype: Skype’s end-to-end encryption requires its activation (if it should not be activated by default).
Services used and service providers:
We offer online chats and chatbot features (collectively, “Chat Services”) as a communication option. A chat is an online conversation conducted with a certain degree of timeliness. A chatbot is a software that answers users’ questions or informs them about messages. When you use our chat features, we may process your personal data.
If you use our chat services within an online platform, your identification number will also be stored within the respective platform. We may also collect information about which users interact with our chat services and when. Furthermore, we store the content of your conversations via the chat services and log registration and consent processes in order to be able to prove them in accordance with legal requirements.
We would like to point out to users that the respective platform provider may learn that and when users communicate with our chat services as well as collect technical information about the device used by users and, depending on the settings of their device, also location information (so-called metadata) for purposes of optimizing the respective services and for security purposes. Likewise, the metadata of communication via chat services (i.e., e.g., information about who communicated with whom) may be used by the respective platform providers for marketing purposes or to display advertising tailored to users in accordance with their terms and conditions, to which we refer for further information.
If users agree to a chatbot to activate information with regular messages, they have the option to unsubscribe from the information at any time in the future. The chatbot instructs users how and with which terms they can unsubscribe from messages. Unsubscribing from chatbot messages deletes user data from the list of message recipients.
We use the aforementioned information to operate our chat services, e.g., to personally address users, to respond to their inquiries, to deliver any requested content, and also to improve our chat services (e.g., to “teach” chatbots answers to frequently asked questions or to recognize unanswered inquiries).
Notes on legal bases: We use chat services on the basis of consent if we have previously obtained users’ permission to process their data as part of our chat services (this applies to cases where users are asked for consent, for example, for a chatbot to send them messages on a regular basis). If we use chat services to answer users’ inquiries about our services or our company, this is done for contractual and pre-contractual communication. Otherwise, we use chat services based on our legitimate interests in optimizing the chat services, their operational efficiency, and enhancing the positive user experience.
Revocation, objection and deletion: You can revoke a given consent or object to the processing of your data within the scope of our chat services at any time.
Services used and service providers:
With the consent of users, we may send users so-called “push notifications”. These are messages that are displayed on users’ screens, devices or browsers, even if our online service is not being actively used at the time.
To sign up for the push messages, users must confirm their browser or device’s request to receive the push messages. This approval process is documented and stored. The storage is necessary to recognize whether users have agreed to receive the push messages as well as to be able to prove the consent. For these purposes, a pseudonymous identifier of the browser (so-called “push token”) or the device ID of an end device is stored.
On the one hand, the push messages may be necessary for the fulfillment of contractual obligations (e.g., technical and organizational information relevant for the use of our online offer) and are otherwise sent on the basis of user consent, unless specifically mentioned below. Users can change the receipt of push messages at any time using the notification settings of their respective browsers, or end devices.
Analysis and performance measurement: We evaluate push messages statistically and can thus see if and when push messages were displayed and clicked on. This information is used to technically improve our push messages based on technical data or target groups and their retrieval behavior or retrieval times. This analysis also includes determining whether push messages are opened, when they are opened, and whether users interact with their content or buttons. Although this information can be assigned to individual push message recipients for technical reasons. However, it is neither our intention nor, if used, that of the push message service provider to observe individual users. The evaluations rather serve us to recognize the usage habits of our users and to adapt our push messages to them or to send different push messages according to the interests of our users.
The evaluation of the push messages and the measurement of success take place, on the basis of an explicit consent of the users, which takes place with the consent to receive the push messages. Users can object to the analysis and performance measurement by unsubscribing from the push messages. A separate revocation of the analysis and performance measurement is unfortunately not possible.
We use software services accessible via the Internet and running on the servers of their providers (so-called “cloud services”, also referred to as “software as a service”) for the following purposes: document storage and management, calendar management, emailing, spreadsheets and presentations, sharing documents, content and information with specific recipients or publishing web pages, forms or other content and information, as well as chats and participation in audio and video conferences.
In this context, personal data may be processed and stored on the servers of the providers insofar as these are part of communication processes with us or are otherwise processed by us as set out in the context of this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents. The cloud service providers also process usage data and metadata, which they use for security purposes and service optimization.
If we use cloud services to provide forms or other documents and content to other users or publicly accessible websites, the providers may store cookies on users’ devices for the purposes of web analytics or to remember users’ settings (e.g., in the case of media control).
Notes on legal bases: If we ask for consent to use the cloud services, the legal basis of the processing is consent. Furthermore, their use may be a component of our (pre)contractual services, provided that the use of the cloud services has been agreed within this framework. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient and secure management and collaboration processes)
Services used and service providers:
We send newsletters, e-mails and other electronic notifications (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. Insofar as the contents of the newsletter are specifically described in the course of registration, they are decisive for the user’s consent. For the rest, our newsletters contain information about our services and us.
To subscribe to our newsletters, it is generally sufficient to enter your e-mail address. However, we may ask you to provide a name, for the purpose of personal address in the newsletter, or other information, if required for the purposes of the newsletter.
Double opt-in procedure: The registration for our newsletter is always carried out in a so-called double opt-in process. I.e., after registration you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can log in with foreign e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the subscription process in accordance with legal requirements. This includes the storage of the login and confirmation time as well as the IP address. Likewise, changes to your data stored with the shipping service provider are logged.
Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove consent formerly given. The processing of this 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 consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list (so-called “block list”) for this purpose alone.
The logging of the registration process takes place on the basis of our legitimate interests for the purposes 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 dispatch system.
Notes on legal basis: The newsletter is sent on the basis of the recipients’ 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 existing customer advertising. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to demonstrate that it has been carried out in accordance with the law.
Contents: Information about us, our services, promotions and offers.
Measurement of open and click ratesThe newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from their 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 the time of the retrieval, are initially collected.
This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading 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. We use the analyses to identify the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
The measurement of opening rates and click-through rates as well as the storage of the measurement results in the users’ profiles and their further processing are based on the users’ consent.
A separate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled, or it must be contradicted. In this case, the stored profile information will be deleted.
Services used and service providers:
We process personal data for the purposes of promotional communication, which may take place via various channels, such as e-mail, telephone, mail or fax, in accordance with legal requirements.
Recipients have the right to revoke consent given at any time or to object to promotional communications at any time.
After revocation or objection, we may store the data required to prove consent for up to three years based on our legitimate interests before deleting it. The processing of this 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 consent is confirmed at the same time.
Web analytics (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimization.
In addition to web analytics, we may also use testing procedures, for example, to test and optimize different versions of our online offering or its components.
For these purposes, so-called user profiles may be created and stored in a file (so-called “cookie”) or similar procedures may be used with the same purpose. This information may include, for example, content viewed, web pages visited and elements used there, and technical information such as the browser used, the computer system used, and information about usage times. If users have consented to the collection of their location data, this may also be processed, depending on the provider.
The IP addresses of the users are also stored. However, we use an IP masking method (i.e., pseudonymization by shortening the IP address) to protect users. In general, the data stored in the context of web analytics, A/B testing and optimization is not clear user data (such as e-mail addresses or names), but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Services used and service providers:
We process personal data for online marketing purposes, which may include, in particular, marketing advertising space or displaying promotional and other content (collectively, “Content”) based on users’ potential interests and measuring its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which the user data relevant to the presentation of the aforementioned content is stored. This information may include, for example, content viewed, web pages 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, this can also be processed.
The IP addresses of the users are also stored. However, we use available IP masking methods (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of the users (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 the online marketing methods, do not know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can later generally be read on other websites that use the same online marketing method and analyzed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing method provider.
Exceptionally, clear data can be assigned to profiles. This is the case if, for example, the users are members of a social network whose online marketing methods we use and the network links the users’ profiles with the aforementioned information. We ask you to note that users can make additional agreements with the providers, e.g. by giving their consent as part of the registration process.
We generally only receive access to aggregate information about the success of our advertisements. However, in the context 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 being concluded with us. Conversion measurement is used solely to analyze the success of our marketing efforts.
Unless otherwise stated, we ask you to assume that 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 the processing of data is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Services used and service providers:
We participate in evaluation processes to evaluate, optimize and promote our services. If users rate us or otherwise provide feedback via the participating rating platforms or processes, the General Terms and Conditions of Business or Use and the data protection notices of the providers also apply. As a rule, the evaluation also requires registration with the respective providers.
In order to ensure that the persons rating have actually used our services, we transmit, with the consent of the customers, the data required for this purpose with regard to the customer and the service used to the respective rating platform (including name, e-mail address and order number or item number). This data is used solely to verify the authenticity of the user.
Rating widget: We integrate so-called “rating widgets” into our online offer. A widget is a functional and content element integrated into our online offer that displays variable information. It can be displayed, for example, in the form of a seal or comparable element, sometimes also called a “badge”. In doing so, the corresponding content of the widget is displayed within our online offer, but it is retrieved at that moment from the servers of the respective widget provider. This is the only way to always show the current content, especially the current rating. For this purpose, a data connection must be established from the website accessed within our online offer to the widget provider’s server and the widget provider receives certain technical data (access data, including IP address) that are necessary so that the widget’s content can be delivered to the user’s browser.
Furthermore, the widget provider receives information that users have visited our online offer. This information may be stored in a cookie and used by the widget provider to identify which online offers participating in the evaluation process have been visited by the user. The information may be stored in a user profile and used for advertising or market research purposes.
Services used and service providers:
We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.
We would like to point out that in the process, user data may be processed outside the area of the European Union. This may give rise to risks for users because, for example, it could make it more difficult to enforce users’ rights.
Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to display advertisements within and outside the networks that presumably correspond to the users’ interests. For these purposes, cookies are usually stored on the users’ computers, in which the usage behavior and interests of the users are stored. Furthermore, data may also 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 presentation of the respective forms of processing and the options to object (opt-out), we refer to the privacy statements and information provided by the operators of the respective networks.
Also in the case of requests for information and the assertion of data subject rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data in each case and can take appropriate measures and provide information directly. If you still need help, then you can contact us.
Facebook: We are jointly responsible with Facebook Ireland Ltd. for the collection (but not the further processing) of data from visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content users view or interact with, or the actions they take (see under “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 Statement: https://www.facebook.com/policy). As explained in the Facebook Privacy Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, called “Page Insights,” to Page operators to provide them with insights into how people interact with their Pages and with content associated with them. We have entered into a special agreement with Facebook (“Page Insights Information,” 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 data subject rights (i.e., users can direct information or deletion requests to Facebook, for example). 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).
Services used and service providers:
We incorporate into our online offering functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). This may include, for example, graphics, videos or city maps (hereinafter uniformly referred to as “Content”).
The integration always requires that the third-party providers of this content process the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus required for the display of these contents or functions. We endeavor to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers 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 contain, among other things, technical information about the browser and operating system, referring websites, time of visit, and other information about the use of our online offering, 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 the processing of data is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offer that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of presentation or user-friendliness of our online offer). In doing so, the respective providers collect the IP address of the users and may process it for the purpose of transmitting the software to the users’ browser and for security purposes, as well as for the evaluation and optimization of their offer.
Facebook plugins and content: We are jointly responsible with Facebook Ireland Ltd. for the collection or receipt in the course of a transmission (but not the further processing) of “Event Data” that Facebook collects or receives in the course of a transmission by means of the Facebook social plugins (and content embedding features) running on our Online Offer for the following purposes: a) Displaying content as well as advertising information that corresponds to the presumed interests of the users; b) Delivery of commercial and transactional messages (e.g., addressing users via Facebook Messenger); c) Improving ad delivery and personalization of features and content (e.g., improving the identification of which content or advertising information is likely to be of interest to users). We have entered into a special agreement with Facebook (“Responsible Party Addendum”, https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the data subject rights (i.e., users can, for example, provide information or make deletion requests directly to Facebook). Note: When Facebook provides us with metrics, analytics, and reports (which are aggregated, i.e., do not receive information about individual users and are anonymous to us), this processing is not done under shared responsibility, but rather on the basis of a data processing agreement (“Data Processing Terms “, https://www.facebook.com/legal/terms/dataprocessing) , the “Data security conditions” (https://www.facebook.com/legal/terms/data_security_terms) and with regard to processing in the USA based on 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.
Instagram plugins and content: We are jointly responsible with Facebook Ireland Ltd. for the collection or receipt in the course of a transmission (but not the further processing) of “Event Data” that Facebook collects or receives in the course of a transmission by means of Instagram features (e.g., content embedding features) running on our Online Service for the following purposes: a) Displaying content as well as advertising information that corresponds to the presumed interests of the users; b) Delivery of commercial and transactional messages (e.g., addressing users via Facebook Messenger); c) Improving ad delivery and personalization of features and content (e.g., improving the identification of which content or advertising information is likely to be of interest to users). We have entered into a special agreement with Facebook (“Responsible Party Addendum”, https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the data subject rights (i.e., users can, for example, provide information or make deletion requests directly to Facebook). Note: When Facebook provides us with metrics, analytics, and reports (which are aggregated, i.e., do not receive information about individual users and are anonymous to us), this processing is not done under shared responsibility, but rather on the basis of a data processing agreement (“Data Processing Terms “, https://www.facebook.com/legal/terms/dataprocessing) , the “Data security conditions” (https://www.facebook.com/legal/terms/data_security_terms) and with regard to processing in the USA based on 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.
Services used and service providers:
We use services, platforms and software of other providers (hereinafter referred to as “Third Party Providers”) for the purpose of organizing, managing, planning as well as providing our services. When selecting third-party providers and their services, we observe the legal requirements.
In this context, personal data may be processed and stored on the servers of the third-party providers. This may involve various data that we process in accordance with this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents.
If users are referred to the third-party providers or their software or platforms in the course of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security, service optimization or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Furthermore, their use may be a component of our (pre)contractual services, provided that the use of the third-party providers has been agreed within this framework. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose).
Unless the data is deleted because it is required for other and legally permissible purposes, its processing will be limited to these purposes. I.e., the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural person or legal entity.
Further information on the deletion of personal data can also be found in the individual data protection notices of this data protection declaration.
We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
Where we provide addresses and contact information for companies and organizations in this privacy statement, please note that the addresses may change over time and please check the information before contacting us.
As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
