Privacy policy
Introduction
With the following data protection declaration we would like to inform you about what types of your personal data (hereinafter also referred to briefly as “data”) 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, mobile, as well as within external online presences, such as our social media profiles (collectively referred to as “Online Offer”).
The terms used are not gender specific.
As of: 11/07/2020
Index
- Introduction
- Responsible
- Overview of processing operations
- Relevant legal bases
- Security
- Transfer and disclosure of personal data
- Data processing in third countries
- Use of cookies
- Commercial and business services
- Payment
- Provision of the online offer and web hosting
- Contact
- Newsletters and electronic notifications
- Web analysis, monitoring and optimization
- Online marketing
- Social media presences
- Plugins and embedded functions as well as content
- Deletion of data
- Modification and updating of the Privacy Policy
- Rights of data subjects
- Definitions
Responsible
MABruenisholz
Ruettistrasse 29
3183 Schwarzenburg
Switzerland
Persons entitled to represent: Mark Bruenisholz
E-mail address: support@alien-snake.com
Overview of processing operations
The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
- inventory data (e.g. names, addresses).
- content data (e.g. entries in online forms).
- Contact details (e.g. e-mail, telephone numbers).
- Meta/communication data (e.g. device information, IP addresses).
- Usage data (e.g. websites visited, interest in content, access times).
- Location data (information about the geographic location of a device or person).
- Contract data (e.g. subject matter of the contract, term, customer category).
- Payment data (e.g. bank details, invoices, payment history).
Categories of affected persons
- business and contractual partners.
- Interested parties.
- Communication.
- Customers.
- users (e.g. website visitors, users of online services).
Purposes of processing
- Provision of our online offer and user-friendliness.
- Visiting action evaluation.
- office and organizational procedures.
- Cross-device tracking (cross-device processing of user data for marketing purposes).
- Direct marketing (e.g. by e-mail or postal).
- Interest-based and behavioral marketing.
- Contact requests and communication.
- Conversion measurement (measurement of the effectiveness of marketing measures).
- Profiling.
- Range measurement (e.g. access statistics, detection of returning visitors).
- Security.
- Tracking (e.g. interest/behavioural profiling, use of cookies).
- provision of contractual services and customer service.
- Manage and respond to requests.
- Target group ingesity (determination of target groups relevant for marketing purposes or other content output).
Relevant legal bases
In the following, we provide the legal bases of the General Data Protection Regulation (GDPR), on the basis of which we process the personal data. Please note that in addition to the provisions of the GDPR, the national data protection requirements may apply in your or our country of residence and residence. Should more specific legal bases be relevant in individual cases, we will inform you of them in the data protection declaration.
- Consent (Art. 6 sec. 1 p. 1 lit. a. GDPR) – The data subject has given his consent to the processing of the personal data concerning him for a specific purpose or several specific purposes.
- Performance of the contract and pre-contractual enquiries (Art. 6 sec. 1 p. 1 lit. b. GDPR) – The processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures, which take place at the request of the data subject.
- Legal obligation (Art. 6 sec. 1 p. 1 lit. c. GDPR) – The processing is necessary for the fulfilment of a legal obligation to which the controller is subject.
- Eligible interests (Art. 6 sec. 1 p. 1 lit. f. GDPR) – The processing is necessary to safeguard the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, prevail.
Security
We shall take appropriate technical and organisational measures to ensure a level of protection commensurate with the risk, taking into account the state of the art, the cost of implementation and the nature, the scope of the processing, as well as the different probability of occurrence and the extent of the threat to the rights and freedoms of natural persons.
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, entry, disclosure, securing availability and separation. In addition, we have established procedures that ensure the exercise of data subjects’ rights, the erasure of data and reactions to the risk of the data. Furthermore, we take into account the protection of personal data already in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technical design and through data protection-friendly presets.
SSL encryption (https): In order to protect your data transmitted via our online offer, we use SSL encryption. You can detect encrypted connections by the prefix https:// in the address bar of your browser.
Transfer and disclosure of personal data
In the context of our processing of personal data, the data may be transferred to other bodies, companies, legally independent organizational units or persons or disclosed to them. Recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers entrusted with IT tasks or providers of services and content that are integrated into a website. In such a case, we comply with the legal requirements and in particular conclude corresponding contracts or agreements with the recipients of your data, which serve the protection of your data.
Data processing in third countries
If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies, this is only in accordance with the legal requirements.
Subject to express consent or contractual or legally required transmission, we process or have the data processed only in third countries with a recognised level of data protection, contractual obligation by so-called standard safeguard clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the European Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).
Use of cookies
Cookies are text files that contain data from websites or domains visited and are stored by a browser on the user’s computer. A cookie is primarily used to store the information about a user during or after his visit within an online offer. The stored information may include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was viewed. The term cookies also includes other technologies that perform the same functions as cookies (e.g. when user information is stored on the basis of pseudonymous online identifiers, also known as “user IDs”)
The following types of cookies and functions are distinguished:
- Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
- Permanent cookies: Permanent cookies remain stored even after closing the browser. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Similarly, the interests of users used for range measurement or marketing purposes may be stored in such a cookie.
- First-party cookies: First-party cookies are set by us.
- Third-party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
- Necessary (also: essential or absolutely necessary) cookies: On the one hand, cookies may be strictly necessary for the operation of a website (e.g. to store logins or other user entries or for reasons of security).
- Statistics, marketing and personalization cookies: In addition, cookies are usually also used in the context of range measurement and when the interests of a user or his behaviour (e.g. viewing certain content, benefits of functions, etc.) are stored on individual websites in a user profile. Such profiles are used to display to users, for example, content that corresponds to their potential interests. This procedure is also referred to as “tracking”, i.e. tracking the potential interests of users. . Insofar as we use cookies or “tracking” technologies, we will inform you separately in our privacy policy or in the context of obtaining consent.
Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for your consent. If this is the case and you consent to the use of cookies, the legal basis for the processing of your data is the declared consent. Otherwise, the data processed by cookies will be 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, in order to fulfil our contractual obligations.
Storage time: Unless we provide you with explicit information about the storage period of permanent cookies (e.g. as part of a so-called cookie opt-in), please assume that the storage period can be up to two years.
General notes on revocation and opposition (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke your consent or to object to the processing of your data by cookie technologies (collectively, “opt-out”). You can first declare your objection by means of the settings of your browser, e.g. by disabling the use of cookies (whereby the functionality of our online offer may also be limited). An objection to the use of cookies for online marketing purposes can also be explained by means of a variety of services, especially in the case of tracking, through the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further notices of objection within the scope of the information on the service providers and cookies used.
Processing of cookie data on the basis of consent: Before we process or have data processed in the context of the use of cookies, we ask the users for a revocable consent at any time. Until consent has been given, cookies are used, which are absolutely necessary for the operation of our online offer.
Cookie settings/opposition option:
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Persons affected: users (e.g. website visitors, users of online services).
- Legal bases: Consent (Art. 6 sec. 1 p. 1 lit. a. GDPR), legitimate interests (Art. 6 sec. 1 p. 1 lit. f. GDPR).
Commercial and business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractors”) within the framework of contractual and comparable legal relationships as well as related measures and in the context of communication with the contractual partners (or pre-contractual), e.g. in order to answer enquiries.
We process this data for the purpose of fulfilling our contractual obligations, for the protection of our rights and for the purposes of the administrative tasks associated with this information as well as the business organization. Within the scope of the applicable law, we only pass on the data of the contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or is carried out with the consent of the data subjects (e.g. to involved 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 other forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.
We will inform the contracting parties before or within the scope of the data collection, e.g. in online forms, by means of special marking (e.g. colours) or symbols (e.g. asterisks or similar), or in person.
We delete the data after expiry of legal warranty and comparable obligations, i.e. basically after 4 years, unless the data is stored in a customer account, e.g. as long as it has to be stored for legal reasons of archiving (e.g. for tax purposes usually 10 years). Data disclosed to us in the context of an order by the contractual partner, we delete 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 privacy notices of the respective third parties or platforms apply in the relationship between the users and the providers.
Customer account: Contractors can create an account within our online offer (e.g. customer or user account, short “customer account”). If registration of a customer account is required, contractual partners will be informed as well as the information required for registration. Customer accounts are not public and cannot be indexed by search engines. As part of the registration as well as subsequent registrations and uses of the customer account, we store the IP addresses of the customers in addition to the access times in order to prove the registration and to prevent any misuse of the customer account.
If customers have terminated their customer account, the data relating to the customer account will be deleted, subject to which their retention is required for legal reasons. It is the responsibility of the customers to secure their data in the event of termination of the customer account.
Economic analysis and market research: For business reasons and in order to be able to recognize market trends, wishes of the contracting parties and users, we analyze the data available to us on business transactions, contracts, enquiries, 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. for the determination of customer groups with different characteristics). In doing so, we may, if available, take into account the profiles of registered users and their details, e.g. on services used. The analyses are for 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 the users and process the data for the analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as summarized data).
Shop and E-Commerce: We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and related services, as well as their payment and delivery, or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution to our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such in the context of the order or comparable acquisition process and includes the information required for delivery, provision and settlement as well as contact information in order to be able to hold any consultation.
- Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Persons affected: interested parties, business and contractual partners, customers.
- Purposes of processing: Provision of contractual services and customer service, contact requests and communication, office and organizational procedures, management and response of enquiries, security measures, visit action evaluation, interest-based and behavioral marketing, profiling (creating user profiles).
- Legal bases: Performance of the contract and pre-contractual enquiries (Art. 6 abs. 1 p. 1 lit. b. GDPR), legal obligation (Art. 6 abs. 1 p. 1 lit. c. GDPR), Eligible Interests (Art. 6 sec. 1 p. 1 lit. f. GDPR).
Payment
In the context of contractual and other legal relationships, due to legal obligations or otherwise based on our legitimate interests, we offer the data subjects efficient and secure payment options and use other payment service providers in addition to banks and credit institutions (collectively, “payment service providers”).
The data processed by the payment service providers includes inventory data, such as name and address, bank details such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered will only be processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information of the payment. The data may be transmitted by payment service providers to business information agencies. The purpose of this transmission is to verify identity and creditworthiness. For this purpose, we refer to the terms and conditions and data protection notices of the payment service providers.
The terms and conditions and the data protection notices of the respective payment service providers apply to the payment transactions, which are available within the respective websites or transaction applications. We also refer to these for further information and the assertion of rights of revocation, information and other data subjects.
- Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. contract subject matter, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Persons affected: Customers, prospects.
- Purposes of processing: provision of contractual services and customer service.
- Legal bases: Performance of contracts and pre-contractual enquiries (Art. 6 sec. 1 p. 1 lit. b. GDPR), Legitimate interests (Art. 6 sec. 1 p. 1 lit. f. GDPR).
Services and service providers used:
- PayPal: payment services and solutions (e.g. PayPal, PayPal Plus, Braintree); Service providers: PayPal (Europe) S.A. r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Website: https://www.paypal.com/de; Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
Provision of the online offer and web hosting
In order to be able to provide our online offer securely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security and technical maintenance.
The data processed in the context of the provision of the hosting offer may include all information concerning the users of our online offer that is incurred in the context of use and communication. This regularly includes the IP address necessary to deliver the contents of online offers to browsers and all entries made within our online offer or from websites.
E-mail ingesice and hosting: The web hosting services we use also include sending, receiving and storing e-mails. For these purposes, the addresses of the recipients as well as senders as well as other information concerning the sending of e-mails (e.g. the participating providers) as well as the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that e-mails are not sent encrypted on the Internet. As a rule, e-mails are encrypted by transport, but (unless an end-to-end encryption method is used) are not encrypted on the servers from which they are sent and received. We therefore cannot accept any responsibility for the transmission of the e-mails between the sender and the receipt on our server.
Collection of access data and log files: We ourselves (or our web hosting provider) collect data for every access to the server (so-called server log files). The server log files may include the address and name of the retrieved websites and files, the date and time of the retrieval, the amount of data transferred, the notification of successful retrieval, the browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.
The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability.
- Types of data processed: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Persons affected: users (e.g. website visitors, users of online services).
- Legal bases: Eligible interests (Art. 6 sec. 1 p. 1 lit. f. GDPR).
Contact
When contacting us (e.g. via contact form, e-mail, telephone or via social media), the information of the requesting persons will be processed, insofar as this is necessary to answer the contact requests and any necessary measures requested.
The answer to contact requests in the context of contractual or pre-contractual relationships is to fulfil our contractual obligations or to answer (pre)contractual enquiries and, in addition, on the basis of the legitimate interests in answering the enquiries.
- Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Persons affected: Communication partners, interested parties.
- Purposes of processing: Contact requests and communication, management and response of enquiries.
- Legal bases: Performance of contracts and pre-contractual enquiries (Art. 6 sec. 1 p. 1 lit. b. GDPR), Legitimate interests (Art. 6 sec. 1 p. 1 lit. f. GDPR).
Services and service providers used:
- Help Scout: Management of contact requests and communication; Service provider: Help Scout Inc., 131 Tremont St, Boston, MA 02111-1338, USA; Website: https://www.helpscout.net; Privacy Policy: https://www.helpscout.net/company/legal/privacy/.
Newsletters and electronic notifications
We only send newsletters, e-mails and other electronic notifications (hereinafter “Newsletter”) with the consent of the recipients or a legal permission. If the contents of the newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. For the rest, our newsletters contain information about our services and us.
In order to subscribe to our newsletters, it is always sufficient if you provide your e-mail address. However, we may ask you to provide a name for 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 basically done 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 log in with foreign 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 time as well as the IP address. The changes to your data stored by the shipping service provider will also be logged.
Deletion and restriction of processing: We may store the e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defense of claims. An individual request for cancellation is possible at any time, provided that the former existence of a consent is confirmed at the same time. In the case of obligations to permanently observe contradictions, we reserve the right to store the e-mail address in a block list (so-called “blacklist”) for this purpose alone.
The registration procedure is logged on the basis of our legitimate interests for the purpose of proving its proper conduct. Insofar as we commission a service provider to send e-mails, this is based on our legitimate interests in an efficient and secure shipping system.
Notes on legal bases: The newsletters are sent on the basis of the consent of the recipients 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 prove that it was conducted in accordance with the law.
Contents: Information about us, our services, promotions and offers.
Analysis and success measurement: The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file that is retrieved from our server when opening the newsletter from our server or, if we use a shipping service provider, from its server. As part of this retrieval, technical information such as information about the browser and your system, as well as your IP address and the time of retrieval, are collected first.
This information is used to improve the technical aspects of our newsletter on the basis of the technical data or the target groups and their reading behaviour on the basis of their polling locations (which can be determined by means 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. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our intention nor, if used, that of the shipping service provider to observe individual users. Rather, the evaluations serve us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
The evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purposes of the use of a user-friendly and secure newsletter system, which serves both our business interests and meets the expectations of the users.
A separate revocation of the success measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled or must be contradicted.
- Types of data processed: Inventory data (e.g. names, addresses), contact details (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
- Persons affected: Communication.
- Purposes of processing: Direct marketing (e.g. by e-mail or postal).
- Legal bases: Consent (Art. 6 sec. 1 p. 1 lit. a. GDPR), legitimate interests (Art. 6 sec. 1 p. 1 lit. f. GDPR).
- Possibility of opposition (opt-out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consents or object to further receipt. You can either find a link to cancel the newsletter at the end of each newsletter or otherwise use one of the above-mentioned contact options, preferably e-mail.
Services and service providers used:
- CleverReach: Email marketing platform; Service provider: CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede, Germany; Website: https://www.cleverreach.com/de; Privacy Policy: https://www.cleverreach.com/de/datenschutz/.
- Mailchimp: Email marketing platform; Service Provider: “Mailchimp” – Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Website: https://mailchimp.com; Privacy Policy: https://mailchimp.com/legal/privacy/.
Web analysis, monitoring and optimization
The web analysis (also referred to as “range measurement”) is used to evaluate the visitor flows of our online offer and may include behaviour, interests or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of the range analysis, we can, for example, identify at what time our online offer or its functions or contents are used most often or invite to reuse. We can also understand which areas require optimization.
In addition to web analysis, we can also use test methods to test and optimize different versions of our online offer or its components, for example.
For these purposes, so-called user profiles can be created and stored in a file (so-called “cookie”) or similar methods can be used for the same purpose. This information may include, for example, content viewed, websites visited and elements and technical information used there, such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, these can also be processed 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 web analysis, A/B testing and optimization do not store 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 the users for their consent to the use of the third-party providers, the legal basis for the processing of data is the consent. Otherwise, the data of the users will be 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 draw your attention to the information on the use of cookies in this privacy policy.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Persons affected: users (e.g. website visitors, users of online services).
- Purposes of processing: Range measurement (e.g. access statistics, detection of returning visitors), tracking (e.g. interest/behavioural profiling, use of cookies), visit action evaluation, profiling (creating user profiles).
- Security measures: IP masking (pseudonymization of the IP address).
- Legal bases: Consent (Art. 6 sec. 1 p. 1 lit. a. GDPR), legitimate interests (Art. 6 sec. 1 p. 1 lit. f. GDPR).
Services and service providers used:
- etracker: Web analysis/range measurement; Service provider: etracker GmbH, Erste Brunnenstraße 1 20459 Hamburg, Germany; Website: https://www.etracker.com; Privacy Policy: https://www.etracker.com/datenschutz/; Opt-out: https://www.etracker.de/privacy?et= [BITTE-EINSETZEN-IHRE-Account-ID] .
- Matomo (without cookies): Matomo is a privacy-friendly web analysis software that is used without cookies and in which the identification of returning users is carried out with the help of a so-called “digital fingerprint”, which is stored anonymously and changed every 24 hours; In the case of “digital fingerprints”, user movements within our online offer are recorded with the help of pseudonymized IP addresses in combination with user-side browser settings in such a way that conclusions about the identity of individual users are not possible; Service provider: web analysis/range measurement in self-hosting; Website: https://matomo.org/.
Online marketing
We process personal data for the purposes of online marketing, which may include in particular the marketing of advertising space or the presentation of advertising and other content (collectively referred to as “content”) based on 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 methods are used by which the information relevant to the presentation of the aforementioned contents about the user is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information, such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, these can also be processed.
The IP addresses of the users are also stored. However, we use available IP masking methods (i.e., pseudonymization by shortening the IP address) to protect users. As a general rule, the online marketing process does not store clear user data (such as e-mail addresses or names), 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 cookies or by similar procedures. These cookies can later generally also be used on other websites that use the same online marketing method, read out and analyzed for the purposes of displaying content as well as supplemented with further data and stored on the server of the online marketing process 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 procedures we use and the network connects the profiles of the users with the aforementioned information. We kindly ask you to note that users can make additional agreements with the providers, e.g. by consent in the context of registration.
In principle, we only have access to aggregated information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to a contract 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 the users for their consent to the use of the third-party providers, the legal basis for the processing of data is the consent. Otherwise, the data of the users will be 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 draw your attention to the information on the use of cookies in this privacy policy.
Facebook pixels: With the help of the Facebook pixel, Facebook is able to determine the visitors of our online offer as the target group for the display of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to use the Facebook ads we serve only to such users on Facebook and within the services of the partners cooperating with Facebook (so-called “Audience Network” https://www.facebook.com/audiencenetwork/ ) which have also shown an interest in our online offer or which have certain characteristics (e.g. interest in certain topics or products that can be seen by the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads meet the potential interest of users and do not have a harassing effect. With the help of the Facebook pixel, we can also understand the effectiveness of Facebook ads for statistical and market research purposes by seeing if users have been redirected to our website after clicking on a Facebook ad (so-called “conversion measurement”).
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information about the geographical location of a device or a person).
- Persons affected: users (e.g. website visitors, users of online services), interested parties.
- Purposes of processing: Tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, visit action evaluation, interest-based and behavioral marketing, profiling (creating user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors), targeting (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking
- Security measures: IP masking (pseudonymization of the IP address).
- Legal bases: Consent (Art. 6 sec. 1 p. 1 lit. a. GDPR), legitimate interests (Art. 6 sec. 1 p. 1 lit. f. GDPR).
- Possibility of opposition (opt-out): We refer to the data protection notices of the respective providers and the possible objections to the providers (so-called “opt-out”). Unless an explicit opt-out option has been specified, you may switch off cookies in your browser settings. However, this may limit the functions of our online offer. We therefore also recommend the following opt-out options, which are offered in summary to specific areas:a) Europe: https://www.youronlinechoices.eu.
(b) Canada: https://www.youradchoices.ca/choices.
(c) USA: https://www.aboutads.info/choices.
(d) Across the territorial basis: https://optout.aboutads.info.
Services and service providers used:
- Google Tag Manager: Google Tag Manager is a solution that allows us to manage so-called website tags from an interface and thus integrate other services into our online offering. The Tag Manager itself (which implements the tags) does not process any personal data of the users. With regard to the processing of users’ personal data, reference is made to the following information on the Google services. Service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy.
- Google Analytics: Online marketing and web analysis; Service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for displaying advertisements: https://adssettings.google.com/authenticated.
- Google Ads and Conversion Measurement: We use the online marketing process “Google Ads” to place ads on the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a suspected interest in the ads. We also measure the conversion of the ads. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page with a so-called “conversion tracking tag”. However, we do not receive any information that can be used to identify users. Service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy.
- Google Ad Manager: We use the “Google Marketing Platform” (and services such as “Google Ad Manager”) to place ads on the Google advertising network (e.g., in search results, in videos, on websites, etc.). The Google Marketing Platform is characterized by the fact that ads are displayed in real time based on the presumed interests of the users. This allows us to display ads for and within our online offering in a more targeted way, in order to present users only with ads that potentially correspond to their interests. If, for example, a user is shown advertisements for products for which he has been interested in other online offers, this is called “remarketing”. Service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy.
- Facebook pixels: Service providers: https://www.facebook.com, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Opt-out: https://www.facebook.com/settings?tab=ads.
Social media presences
We maintain online presences within social networks and process users’ 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 users’ data can be processed outside the European Union. This can create risks for users, as this could, for example, make it more difficult to enforce users’ rights.
Furthermore, users’ data within social networks are usually processed for market research and advertising purposes. For example, user profiles can be created based on the user behaviour and the resulting interests of the users. The user profiles can in turn be used to display advertisements inside and outside the networks, for example, which presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the user’s usage behaviour and the interests of the users are stored. Furthermore, data may also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
For a detailed description of the respective processing methods and the opt-out, we refer to the data protection declarations and information of the operators of the respective networks.
We would also like to point out that these can be asserted most effectively by the providers in the case of requests for information and the assertion of data subjects’ rights. Only the providers have access to the data of the users and can take direct action and provide information. If you still need help, you can contact us.
- Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Persons affected: users (e.g. website visitors, users of online services).
- Purposes of processing: Contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, range measurement (e.g. access statistics, detection of returning visitors).
- Legal bases: Eligible interests (Art. 6 sec. 1 p. 1 lit. f. GDPR).
Services and service providers used:
- Instagram: Social network; Service provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy.
- Facebook: Social network; Service provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Opt-out: Ad settings: https://www.facebook.com/settings?tab=ads; Additional information on data protection: Agreement on the joint processing of personal data on Facebook pages: https://www.facebook.com/legal/terms/page_controller_addendum, Privacy Noticefor Facebook Pages: https://www.facebook.com/legal/terms/information_about_page_insights_data.
- LinkedIn: Social network; Service providers: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Twitter: Social network; Service providers: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Privacy Policy: https://twitter.com/de/privacy, (Settings) https://twitter.com/personalization.
- YouTube: Social network; Service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Privacy Policy: https://policies.google.com/privacy; Opt-out: https://adssettings.google.com/authenticated.
- Xing: Social network; Service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Website: https://www.xing.de; Privacy Policy: https://privacy.xing.com/de/datenschutzerklaerung.
Plugins and embedded functions as well as content
We incorporate functional and content elements from the servers of their respective providers (hereinafter referred to as “Third Parties”) in our online offering. These may include graphics, videos, social media buttons, and posts (hereinafter referred to as “Content”).
The integration always presupposes that the third parties of this content process the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content or functions. We make every effort to use only those content whose respective providers use the IP address only for the delivery of the content. 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 can also be stored in cookies on the user’s device and may include, among other things, technical information about the browser and operating system, websites to be referenced, the time of visit as well as other information on the use of our online offer, as well as to be linked to such information from other sources.
Notes on legal bases: If we ask the users for their consent to the use of the third-party providers, the legal basis for the processing of data is the consent. Otherwise, the data of the users will be 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 draw your attention to the information on the use of cookies in this privacy policy.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographical location of a device or person), content data (e.g. entries in online forms), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
- Persons affected: Users (e.g. website visitors, users of online services), communication partners.
- Purposes of processing: Provision of our online offer and user-friendliness, provision of contractual services and customer service, contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), interest-based and behavioural marketing, profiling (creating user profiles), security measures, management and response of enquiries.
- Legal bases: Eligible interests (Art. 6 sec. 1 p. 1 lit. f. GDPR), consent (Art. 6 abs. 1 p. 1 lit. a. GDPR), performance of the contract and pre-contractual enquiries (Art. 6 abs. 1 p. 1 lit. (b. GDPR).
Services and service providers used:
- Facebook plugins and content: Facebook Social Plugins and Content – This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online offer within Facebook. The list and appearance of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/; Service provider: https://www.facebook.com, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Opt-out: Ad settings: https://www.facebook.com/settings?tab=ads.
- Google Fonts: We include the fonts (“Google Fonts”) of the provider Google, whereby the data of the users are used solely for the purpose of displaying the fonts in the user’s browser. The integration is based on our legitimate interests in a technically safe, maintenance-free and efficient use of fonts, their uniform presentation and taking into account possible licensing restrictions for their integration. Service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy.
- Google Maps: We include the maps of the “Google Maps” service of the provider Google. The data processed may include, in particular, IP addresses and location data of the users, but these may not be collected without their consent (usually carried out within the framework of the settings of their mobile devices); Service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://cloud.google.com/maps-platform; Privacy Policy: https://policies.google.com/privacy; Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for displaying advertisements: https://adssettings.google.com/authenticated.
- ReCaptcha: We include the “ReCaptcha” function for the detection of bots, e.g. when entering online forms. The user’s behavioral information (e.g. mouse movements or queries) is evaluated in order to distinguish people from bots. Service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://www.google.com/recaptcha/; Privacy Policy: https://policies.google.com/privacy; Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for displaying advertisements: https://adssettings.google.com/authenticated.
- Twitter plugins and content: Twitter plugins and buttons – This may include content such as images, videos or texts and buttons with which users can share content from this online offer within Twitter. Service providers: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Website: https://twitter.com/de; Privacy policy: https://twitter.com/de/privacy.
- YouTube videos: video content; Service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for displaying advertisements: https://adssettings.google.com/authenticated.
Deletion of data
The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permission is omitted (e.g. if the purpose of the processing of this data has ceased or they are not necessary for the purpose).
Unless the data is deleted because it is necessary for other and legally permissible purposes, their processing will be limited to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.
Further information on the deletion of personal data can also be made within the framework of the individual data protection notices of this data protection declaration.
Modification and updating of the Privacy Policy
We kindly ask you to keep up to know regularly about the content of our privacy policy. We will adjust the Privacy Policy as soon as the changes to the data processing we perform make this necessary. We will inform you as soon as the changes require an act of participation on your part (e.g. consent) or any other individual notification.
If we provide addresses and contact information of companies and organizations in this Privacy Policy, please note that the addresses may change over time and ask you to check the information before contacting them.
Rights of data subjects
As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:
- Right to object: For reasons arising from your particular situation, you have the right to object at any time to the processing of personal data concerning you, which is subject to Article 6(4) of the Year. 1 lit. e or f GDPR to object; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising; this also applies to profiling in so far as it is related to such direct marketing.
- Right of withdrawal in case of consent: You have the right to revoke consents given at any time.
- Right of access: You have the right to request confirmation as to whether the data in question is being processed and for information about this data as well as for further information and copy of the data in accordance with the legal requirements.
- Right to correction: In accordance with the law, you have the right to request the completion of the data concerning you or the correction of the inaccurate data concerning you.
- Right to erasure and restriction of processing: In accordance with the statutory requirements, you have the right to request that you delete data concerning you immediately or, alternatively, to request a restriction on the processing of the data in accordance with the statutory requirements.
- Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request their transmission to another controller.
- Complaint to supervisory authority: You also have the right, in accordance with the legal requirements, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, workplace or place of alleged infringement, if you believe that the processing of personal data concerning you is in breach of the GDPR.
Definitions
This section provides an overview of the terms used in this Privacy Policy. Many of the terms are taken from the law and are defined above all in Article 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended for understanding. The terms are sorted alphabetically.
- Visit action evaluation: “Conversion Tracking” means a method of determining the effectiveness of marketing activities. As a rule, a cookie is stored on the users’ devices within the websites on which the marketing measures are carried out and then retrieved again on the destination website. For example, we can track whether the ads we run on other websites were successful).
- Credit information: Automated decisions are based on automatic data processing without human intervention (e.g. in the case of an automatic rejection of a purchase on account, an online credit application or an online application procedure without any human intervention. Under Article 22 GDPR, such automated decisions are only permitted if interested parties agree, if they are necessary for the performance of the contract or if national laws permit such decisions.
- Cross-Device Tracking: Cross-device tracking is a form of tracking in which user behaviour al-interest information is collected across devices in so-called profiles by assocising an online identifier to users. This allows user information to be analyzed for marketing purposes, regardless of browsers or devices used (e.g. mobile phones or desktop computers). For most providers, the online ID is not associated with clear data, such as names, postal addresses, or e-mail addresses.
- IP Masking: IP masking is a method in which the last octet, i.e. the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing methods, especially in online marketing
- Interest-based and behavioral marketing: Interest- and/or behavioral marketing is referred to when potential interests of users in advertisements and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behaviour (e.g. visiting certain websites and staying on them, buying behaviour or interaction with other users), which are stored in a so-called profile. Cookies are usually used for these purposes.
- Conversion measurement: Conversion measurement is a method by which the effectiveness of marketing measures can be determined. As a rule, a cookie is stored on the users’ devices within the websites on which the marketing measures are carried out and then retrieved again on the destination website. For example, we can track whether the ads we run on other websites were successful.
- Personal data: “Personal Data” means any information relating to an identified or identifiable natural person (‘the data subject’); Identifiable is a natural person who can be identified directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more specific characteristics that are an expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
- Profiling: ‘Profiling’ means any type of automated processing of personal data that consists in the use of such personal data to analyse certain personal aspects relating to a natural person (depending on the type of profiling, this includes information relating to age, gender, location data and movement data, interaction with websites and their content, purchasing behaviour, social interactions with other people). , or to predict them (e.g. interests in specific content or products, click-through behavior on a website or where you are). Cookies and web beacons are often used for profiling purposes.
- Range measurement: The range measurement (also referred to as web analytics) is used to evaluate the visitor flows of an online offer and may include the behaviour or interests of visitors in certain information, such as the content of websites. With the help of the range analysis, website owners can, for example, recognize the time at which visitors visit their website and what content they are interested in. This allows them, for example, to better adapt the contents of the website to the needs of their visitors. For the purposes of range analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more accurate analyses of the use of an online offer.
- Remarketing: “Remarketing” or “retargeting” is referred to when, for example, for advertising purposes, it is noted which products a user has been interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
- Location data: Location data arises when a mobile device (or other device with the technical requirements of a location determination) connects to a radio cell, a WLAN or similar technical intermediaries and functions of location determination. Location data is used to indicate which geographically identifiable position of the earth the respective device is located. Location data, for example, can be used to represent map functions or other location-dependent information.
- Tracking: “Tracking” is called when the behaviour of users can be tracked across multiple online offers. As a rule, with regard to the online offers used, behavioural and interest information is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
- Responsible: ‘Responsible person’ means the natural or legal person, authority, body or other body which decides, alone or jointly with others, on the purposes and means of the processing of personal data.
- Processing: “Processing” means any operation or series of operations carried out with or without the help of automated procedures in connection with personal data. The term goes far and covers virtually every use of data, be it the collection, the evaluating, the saving, the transmission or the deletion.
- Target group formation: Target groups (or “Custom Audiences”) are defined when target groups are designated for advertising purposes, e.g. displayof advertisements. For example, based on a user’s interest in certain products or topics on the Internet, it can be concluded that that user is interested in advertisements for similar products or the online shop in which he viewed the products. “Lookalike Audiences” (or similar audiences) are referred to when the content deemed appropriate is displayed to users whose profiles or interests are presumed to correspond to the users to whom the profiles were created. For the purposes of the formation of Custom Audiences and Lookalike Audiences, cookies and web beacons are usually used.
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