Introduction
With the following privacy policy, we aim to inform you about the types of personal data (hereinafter referred to as “data”) we process, for what purposes, and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (collectively referred to as the “online offering”). The terms used are not gender-specific.
Status: October 20, 2024 Table of Contents
- Introduction
- Controller
- Overview of Processing Activities
- Relevant Legal Bases
- Security Measures
- Transmission and Disclosure of Personal Data
- Data Processing in Third Countries
- Use of Cookies
- Commercial and Business Services
- Payment Service Providers
- Provision of the Online Offering and Web Hosting
- Blogs and Publication Media
- Contacting Us
- Cloud Services
- Online Marketing
- Affiliate Programs and Affiliate Links
- Plugins and Embedded Functions and Content
- Deletion of Data
- Changes and Updates to the Privacy Policy
- Rights of Data Subjects
- Definitions of Terms
Controller
DK Social Technologies Unternehmergesellschaft (haftungsbeschränkt)
Authorized Representative: Daniel Kling
Email Address: dk@dk-social-technologies.com
Phone: 017630100992
Imprint: [Imprint]Overview of Processing Activities
The following overview summarizes the types of data processed, 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., text inputs, photographs, videos).
- Contact data (e.g., email, phone numbers).
- Meta/communication data (e.g., device information, IP addresses).
- Usage data (e.g., visited websites, interest in content, access times).
- Social data (data subject to social secrecy (§ 35 SGB I) and processed, e.g., by social insurance institutions, social welfare authorities, or pension authorities).
- Location data (data indicating the location of an end user’s device).
- Contract data (e.g., contract subject, term, customer category).
- Payment data (e.g., bank details, invoices, payment history).
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- Affiliate Tracking: In the context of affiliate tracking, links through which referring websites direct users to websites with product or other offers are logged. The operators of the respective referring websites may receive a commission if users follow these so-called affiliate links and subsequently take advantage of the offers (e.g., purchase goods or use services). For this purpose, it is necessary for providers to track whether users who are interested in certain offers subsequently take advantage of them at the instigation of the affiliate links. Therefore, for the functionality of affiliate links, it is necessary that they are supplemented with certain values that become part of the link or are otherwise stored, e.g., in a cookie. These values include, in particular, the source website (referrer), the time, an online identifier of the operator of the website where the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as tracking-specific values such as advertising material ID, partner ID, and categorizations.
- Evaluation of Visitor Actions: “Evaluation of visitor actions” (English “conversion tracking”) refers to a method by which the effectiveness of marketing measures can be determined. Typically, a cookie is stored on the users’ devices within the websites where the marketing measures take place and then retrieved again on the target website. For example, we can track whether the ads we placed on other websites were successful.
- Content Delivery Network (CDN): A “Content Delivery Network” (CDN) is a service that enables the content of an online offering, particularly large media files such as graphics or program scripts, to be delivered faster and more securely using regionally distributed servers connected via the internet.
- IP Masking: “IP masking” refers to a method in which the last octet, i.e., the last two digits of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing methods, particularly in online marketing.
- Interest-Based and Behavioral Marketing: Interest-based and/or behavioral marketing refers to the process of predetermining users’ potential interests in ads and other content as accurately as possible. This is done based on information about their previous behavior (e.g., visiting certain websites and staying on them, purchasing behavior, or interaction with other users), which is stored in a so-called profile. Cookies are generally used for these purposes.
- Conversion Measurement: Conversion measurement is a method by which the effectiveness of marketing measures can be determined. Typically, a cookie is stored on the users’ devices within the websites where the marketing measures take place and then retrieved again on the target website. For example, we can track whether the ads we placed on other websites were successful.
- Personal Data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie), or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
- Profiling: “Profiling” means any form of automated processing of personal data that involves using personal data to evaluate certain personal aspects relating to a natural person (depending on the type of profiling, this includes information concerning age, gender, location data, and movement data, interaction with websites and their content, purchasing behavior, social interactions with other people) to analyze, evaluate, or predict them (e.g., interests in certain content or products, click behavior on a website, or location). Cookies and web beacons are often used for profiling purposes.
- Reach Measurement: Reach measurement (also referred to as web analytics) is used to evaluate the visitor flows of an online offering and may include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, website owners can, for example, recognize when visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
- Remarketing: “Remarketing” or “retargeting” refers to noting, for example, for advertising purposes, which products a user was interested in on a website in order to remind the user of these products on other websites, e.g., in advertisements.
- Tracking: “Tracking” refers to the ability to track user behavior across multiple online offerings. Typically, behavioral and interest information is stored in cookies or on the servers of the tracking technology providers with regard to the online offerings used (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
- Controller: “Controller” means the natural or legal person, authority, institution, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data.
- Processing: “Processing” means any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and encompasses practically any handling of data, be it collection, evaluation, storage, transmission, or deletion.
Categories of Data Subjects
- Employees (e.g., employees, applicants, former employees).
- Business and contractual partners.
- Prospects.
- Communication partners.
- Customers.
- Users (e.g., website visitors, users of online services).
Purposes of Processing
- Affiliate tracking.
- Provision of our online offering and user-friendliness.
- Evaluation of visitor actions.
- Office and organizational procedures.
- Content Delivery Network (CDN).
- Feedback (e.g., collecting feedback via online forms).
- Interest-based and behavioral marketing.
- Contact requests and communication.
- Conversion measurement (measuring the effectiveness of marketing measures).
- Profiling (creating user profiles).
- Remarketing.
- Reach measurement (e.g., access statistics, recognition of returning visitors).
- Security measures.
- Tracking (e.g., interest/behavioral profiling, use of cookies).
- Contractual services and support.
- Management and response to inquiries.
Relevant Legal Bases
Below, we outline the legal bases of the General Data Protection Regulation (GDPR) on which we process personal data. Please note that, in addition to the GDPR provisions, national data protection regulations in your or our country of residence or domicile may apply. Should more specific legal bases apply in individual cases, we will inform you of these in the privacy policy.- Consent (Art. 6(1)(a) GDPR) – The data subject has given consent to the processing of their personal data for one or more specific purposes.
- Contract performance and pre-contractual inquiries (Art. 6(1)(b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract.
- Legal obligation (Art. 6(1)(c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Vital interests (Art. 6(1)(d) GDPR) – Processing is necessary to protect the vital interests of the data subject or another natural person.
- Legitimate interests (Art. 6(1)(f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject.
National Data Protection Regulations in Germany: In addition to the GDPR, national data protection regulations in Germany apply, particularly the Federal Data Protection Act (BDSG). The BDSG includes specific 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, transmission, and automated decision-making in individual cases, including profiling. It also regulates data processing for employment purposes (§ 26 BDSG), particularly regarding the establishment, execution, or termination of employment relationships and employee consent. Additionally, state data protection laws of individual federal states may apply.Security Measures
We implement appropriate technical and organizational measures to ensure a level of protection appropriate to the risk, in accordance with legal requirements, taking into account the state of the art, implementation costs, and the nature, scope, circumstances, and purposes of the processing, as well as the varying likelihood and severity of risks to the rights and freedoms of natural persons. These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, availability, and separation of data. We have also established procedures to ensure the exercise of data subjects’ rights, the deletion of data, and responses to data threats. Furthermore, we consider data protection in the development or selection of hardware, software, and processes in accordance with the principle of data protection by design and default. IP Address Truncation: Where possible or where storage of the IP address is not necessary, we truncate or have your IP address truncated. In the case of IP address truncation, also referred to as “IP masking,” the last octet (i.e., the last two digits of an IP address) is deleted (the IP address in this context is an identifier individually assigned to an internet connection by the online access provider). The truncation of the IP address is intended to prevent or significantly hinder the identification of a person based on their IP address. SSL Encryption (https): To protect your data transmitted via our online offering, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in your browser’s address bar.Transmission and Disclosure of Personal Data
In the course of our processing of personal data, it may happen that the data is transmitted to or disclosed to other entities, companies, legally independent organizational units, or persons. Recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers tasked with IT operations, or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data to protect your data.Data Processing in Third Countries
If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if processing occurs in the context of using third-party services or disclosing or transferring data to other persons, entities, or companies, this is done only in accordance with legal requirements. Subject to explicit consent or contractually or legally required transfer, we process or have data processed only in third countries with a recognized level of data protection, including US processors certified under the “Privacy Shield,” or based on special guarantees, such as contractual obligations through so-called standard contractual clauses of the EU Commission, certifications, or binding internal data protection regulations (Art. 44–49 GDPR, EU Commission information page: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).Use of Cookies
Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after their visit to an online offering. Stored information may include, for example, language settings on a website, login status, a shopping cart, or the point at which 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 using pseudonymous online identifiers, also referred to as “user IDs”). The following cookie types and functions are distinguished:- Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user leaves an online offering and closes their browser.
- Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved, or preferred content can be displayed directly when the user revisits a website. Likewise, user interests used for reach measurement or marketing purposes may be stored in such a cookie.
- First-party cookies: First-party cookies are set by us.
- Third-party cookies: Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
- Necessary (also: essential or strictly necessary) cookies: Cookies may be strictly necessary for the operation of a website (e.g., to store logins or other user inputs or for security reasons).
- Statistical, marketing, and personalization cookies: Cookies are also generally used for reach measurement and when a user’s interests or behavior (e.g., viewing certain content, using functions, etc.) are stored in a user profile on individual websites. Such profiles are used to display content to users that corresponds to their potential interests. This process is also referred to as “tracking,” i.e., tracking the potential interests of users. If we use cookies or tracking technologies, we will inform you separately in our privacy policy or when obtaining consent.
Notes on Legal Bases: The legal basis on which we process your personal data using cookies depends on whether we ask for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed using cookies is processed based on our legitimate interests (e.g., in the business operation of our online offering and its improvement) or if the use of cookies is necessary to fulfill our contractual obligations. Storage Duration: Unless we provide you with explicit information about the storage duration of permanent cookies (e.g., in the context of a so-called cookie opt-in), please assume that the storage duration can be up to two years. General Notes on Revocation and Objection (Opt-Out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke your consent or object to the processing of your data using cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection through your browser settings, e.g., by deactivating the use of cookies (which may also restrict the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared through various services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. Additionally, you can receive further objection notices in the context of the information about the service providers and cookies used. Processing of Cookie Data Based on Consent: Before we process or have data processed in the context of using cookies, we ask users for their consent, which can be revoked at any time. Before consent is given, only cookies that are strictly necessary for the operation of our online offering may be used. Processed Data Types: Usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
Data Subjects: Users (e.g., website visitors, users of online services).
Legal Bases: Consent (Art. 6(1)(a) GDPR), Legitimate Interests (Art. 6(1)(f) GDPR).Commercial and Business Services
We process data of our contractual and business partners, e.g., customers and prospects (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 respond to inquiries. We process this data to fulfill our contractual obligations, secure our rights, and for the purposes of administrative tasks associated with this information and business organization. We only disclose the data of contractual partners to third parties within the framework of applicable law to the extent necessary for the aforementioned purposes or to fulfill legal obligations or with the consent of the data subjects (e.g., to involved telecommunications, transport, and other auxiliary services, subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Contractual partners will be informed about further processing forms, e.g., for marketing purposes, within this privacy policy. We inform contractual partners about which data is necessary for the aforementioned purposes before or during data collection, e.g., in online forms, through special markings (e.g., colors) or symbols (e.g., asterisks), or personally. We delete the data after the expiry of statutory warranty and comparable obligations, i.e., generally after four years, unless the data is stored in a customer account, e.g., for as long as it must be retained for legal archiving reasons (e.g., typically 10 years for tax purposes). Data disclosed to us by the contractual partner in the context of an order is deleted in accordance with the specifications of the order, generally after the end of the order. If we use third-party providers or platforms to provide our services, the terms and conditions and privacy notices of the respective third-party providers or platforms apply in the relationship between the users and the providers. Economic Analyses and Market Research: For business reasons and to identify market trends and the wishes of contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc., whereby the group of data subjects may include contractual partners, prospects, customers, visitors, and users of our online offering. The analyses are conducted for the purpose of business evaluations, marketing, and market research (e.g., to determine customer groups with different characteristics). Where available, we may consider the profiles of registered users along with their information, e.g., on services used. The analyses serve solely our purposes and are not disclosed externally unless they are anonymous analyses with aggregated, i.e., anonymized, values. Furthermore, we take the privacy of users into account and process the data for analysis purposes as pseudonymously as possible and, where feasible, anonymously (e.g., as aggregated data). Further Information on Commercial Services: We process the data of our customers and clients (collectively referred to as “customers”) to enable them to select, acquire, or commission the chosen services or works as well as related activities, and their payment and delivery or execution. The required information is identified as such in the context of concluding an order, purchase, or comparable contract and includes the information needed for service provision and billing as well as contact information to hold any consultations. Processed Data Types: Inventory data (e.g., names, addresses), payment data (e.g., bank details, invoices, payment history), contact data (e.g., email, phone numbers), contract data (e.g., contract subject, term, customer category), usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
Data Subjects: Prospects, business and contractual partners, customers.
Purposes of Processing: Contractual services and support, contact inquiries and communication, office and organizational procedures, management and response to inquiries, evaluation of visitor actions, interest-based and behavioral marketing, profiling (creating user profiles).
Legal Bases: Contract performance and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legal obligation (Art. 6(1)(c) GDPR), Legitimate Interests (Art. 6(1)(f) GDPR).Payment Service Providers
In the context of contractual and other legal relationships, due to legal obligations or otherwise based on our legitimate interests, we offer data subjects efficient and secure payment options and use additional payment service providers besides banks and credit institutions (collectively referred to as “payment service providers”). The data processed by payment service providers includes inventory data, such as name and address, bank data, such as account or credit card numbers, passwords, TANs, and checksums, as well as contract, total, and recipient-related information. This information is necessary to carry out the transactions. However, the entered data is processed and stored only by the payment service providers. This means we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. In some cases, the data may be transmitted by the payment service providers to credit agencies for identity and credit checks. We refer to the terms and conditions and privacy notices of the payment service providers in this regard. The terms and conditions and privacy notices of the respective payment service providers, accessible within their respective websites or transaction applications, apply to payment transactions. We also refer to these for further information and the assertion of revocation, information, and other data subject rights. Processed Data Types: Inventory data (e.g., names, addresses), payment data (e.g., bank details, invoices, payment history), contract data (e.g., contract subject, term, customer category), usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
Data Subjects: Customers, prospects.
Purposes of Processing: Contractual services and support.
Legal Bases: Contract performance and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate Interests (Art. 6(1)(f) GDPR). Services and Service Providers Used:- PayPal: Payment services and solutions (e.g., PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Website: https://www.paypal.com/de; Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
Provision of the Online Offering and Web Hosting
To provide our online offering securely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers they manage) the online offering can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space, and database services, as well as security and technical maintenance services. The data processed in the context of providing the hosting offering may include all information relating to the users of our online offering that arises during use and communication. This regularly includes the IP address, which is necessary to deliver the content of online offerings to browsers, and all entries made within our online offering or on websites. Email Sending and Hosting: The web hosting services we use also include the sending, receiving, and storage of emails. For these purposes, the addresses of recipients and senders, as well as further information regarding email transmission (e.g., the providers involved) and the contents of the respective emails, are processed. The aforementioned data may also be processed for SPAM detection purposes. Please note that emails on the internet are generally not sent encrypted. As a rule, emails are encrypted during transport but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore assume no responsibility for the transmission path of emails between the sender and the recipient on our server. Collection of Access Data and Log Files: We (or our web hosting provider) collect data on every access to the server (so-called server log files). Server log files may include the address and name of the accessed websites and files, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. Server log files may be used for security purposes, e.g., to prevent server overload (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure server utilization and stability. Content Delivery Network: We use a Content Delivery Network (CDN). A CDN is a service that enables the content of an online offering, particularly large media files such as graphics or program scripts, to be delivered faster and more securely using regionally distributed servers connected via the internet. Processed Data Types: Content data (e.g., text inputs, photographs, videos), usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
Data Subjects: Users (e.g., website visitors, users of online services).
Purposes of Processing: Content Delivery Network (CDN).
Legal Bases: Legitimate Interests (Art. 6(1)(f) GDPR).Blogs and Publication Media
We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data is 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 further information, we refer to the information on the processing of visitors to our publication medium within this privacy policy. 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 unlawful content in comments or contributions (e.g., insults, prohibited political propaganda, etc.). In such cases, we may be held liable for the comment or contribution and are therefore interested in the identity of the author. Furthermore, we reserve the right, based on our legitimate interests, to process user information for spam detection. On the same legal basis, we reserve the right to store users’ IP addresses for the duration of surveys and to use cookies to prevent multiple votes. The personal information provided in the context of comments and contributions, including contact and website information as well as content-related information, is stored by us permanently until the user objects. Processed Data Types: Inventory data (e.g., names, addresses), contact data (e.g., email, phone numbers), content data (e.g., text inputs, photographs, videos), usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
Data Subjects: Users (e.g., website visitors, users of online services).
Purposes of Processing: Contractual services and support, feedback (e.g., collecting feedback via online forms), security measures, management and response to inquiries.
Legal Bases: Contract performance and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate Interests (Art. 6(1)(f) GDPR), Consent (Art. 6(1)(a) GDPR), Protection of vital interests (Art. 6(1)(d) GDPR).Contacting Us
When contacting us (e.g., via contact form, email, phone, or social media), the data of the inquiring persons is processed to the extent necessary to respond to the contact inquiries and any requested measures. The response to contact inquiries in the context of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to respond to (pre)contractual inquiries and otherwise based on legitimate interests in responding to the inquiries. Processed Data Types: Inventory data (e.g., names, addresses), contact data (e.g., email, phone numbers), content data (e.g., text inputs, photographs, videos).
Data Subjects: Communication partners.
Purposes of Processing: Contact inquiries and communication.
Legal Bases: Contract performance and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate Interests (Art. 6(1)(f) GDPR).Cloud Services
We use software services accessible via the internet and executed 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, email sending, spreadsheets and presentations, exchange of documents, content, and information with specific recipients, or publication of websites, forms, or other content and information, as well as chats and participation in audio and video conferences. In this context, personal data may be processed and stored on the providers’ servers to the extent that these are part of communication processes with us or are otherwise processed by us as set out in this privacy policy. These data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes, and their contents. Cloud service providers also process usage data and metadata used by them 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 web analytics purposes or to remember users’ settings (e.g., in the case of media control). Notes on Legal Bases: If we ask for consent to use cloud services, the legal basis for processing is consent. Furthermore, their use may be part of our (pre)contractual services, provided that the use of cloud services has been agreed upon in this context. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient and secure administrative and collaboration processes). Processed Data Types: Inventory data (e.g., names, addresses), contact data (e.g., email, phone numbers), content data (e.g., text inputs, photographs, videos), usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
Data Subjects: Customers, employees (e.g., employees, applicants, former employees), prospects, communication partners.
Purposes of Processing: Office and organizational procedures.
Legal Bases: Consent (Art. 6(1)(a) GDPR), Contract performance and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate Interests (Art. 6(1)(f) GDPR).Online Marketing
We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the display of promotional and other content (collectively referred to as “content”) based on the potential interests of users and the measurement of its effectiveness. For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which information about the user relevant to the presentation of the aforementioned content is stored. This information may include, for example, viewed content, visited websites, used online networks, as well as 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 may also be processed. The IP addresses of users are also stored. However, we use available IP-masking procedures (i.e., pseudonymization by truncating the IP address) to protect users. Generally, in the context of online marketing procedures, no clear user data (such as email addresses or names) is stored, 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 means of similar procedures. These cookies can generally also be read later on other websites that use the same online marketing procedure, analyzed for the purpose of displaying content, and supplemented with further data and stored on the server of the online marketing procedure provider. Exceptionally, clear data can be assigned to the profiles. This is the case, for example, if users are members of a social network whose online marketing procedure we use, and the network links the users’ profiles with the aforementioned information. Please note that users can make additional agreements with the providers, e.g., through consent during registration. We generally only receive 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 conclusion with us. The conversion measurement is used solely to analyze the success of our marketing measures. Unless otherwise stated, please assume that cookies used are stored for a period of two years. Notes on Legal Bases: If we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economic, and user-friendly services). In this context, we also refer you to the information on the use of cookies in this privacy policy. Target Group Formation with Google Analytics: We use Google Analytics to display ads placed within Google’s and its partners’ advertising services only to users who have shown an interest in our online offering or who have specific characteristics (e.g., interests in certain topics or products determined based on the websites visited) that we transmit to Google (so-called “Remarketing” or “Google Analytics Audiences”). With the help of Remarketing Audiences, we also want to ensure that our ads correspond to the potential interests of users. Processed Data Types: Usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses), location data (data indicating the location of an end user’s device), social data (data subject to social secrecy (§ 35 SGB I) and processed, e.g., by social insurance institutions, social welfare authorities, or pension authorities).
Data Subjects: Users (e.g., website visitors, users of online services), prospects, customers, employees (e.g., employees, applicants, former employees), communication partners.
Purposes of Processing: Tracking (e.g., interest/behavioral profiling, use of cookies), remarketing, evaluation of visitor actions, interest-based and behavioral marketing, profiling (creating user profiles), conversion measurement (measuring the effectiveness of marketing measures), reach measurement (e.g., access statistics, recognition of returning visitors).
Security Measures: IP masking (pseudonymization of the IP address).
Legal Bases: Consent (Art. 6(1)(a) GDPR), Legitimate Interests (Art. 6(1)(f) GDPR).
Opt-Out Options: We refer to the privacy notices of the respective providers and the opt-out options provided for them (so-called “opt-out”). If no explicit opt-out option is specified, you can disable cookies in your browser settings, although this may restrict the functionality of our online offering. We therefore additionally recommend the following opt-out options, which are offered collectively for respective regions:
a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://www.youradchoices.ca/choices.
c) USA: https://www.aboutads.info/choices.
d) Cross-regional: https://optout.aboutads.info. Services and Service Providers Used:- Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offering. The Tag Manager itself (which implements the tags) does not process personal data of users. Regarding the processing of users’ personal data, reference is made to the information on Google services. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (ensuring data protection level when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- Google Analytics: Online marketing and web analytics; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (ensuring data protection level when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; Opt-Out: Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
- Google Ads and Conversion Measurement: We use the online marketing procedure “Google Ads” to place ads in the Google advertising network (e.g., in search results, videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads. Furthermore, we 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 tagged with a so-called “conversion tracking tag.” We ourselves do not receive any information with which users can be identified. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (ensuring data protection level when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- Google Ad Manager: We use the “Google Marketing Platform” (and services such as “Google Ad Manager”) to place ads in the Google advertising network (e.g., in search results, videos, on websites, etc.). The Google Marketing Platform is characterized by displaying ads in real-time based on presumed user interests. This allows us to display ads for and within our online offering more targeted to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products they were interested in on other online offerings, this is referred to as “remarketing.” Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (ensuring data protection level when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- Google Adsense with Personalized Ads: We use the Google Adsense service with personalized ads, through which ads are displayed within our online offering, and we receive payment for their display or other use. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (ensuring data protection level when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- Google Adsense with Non-Personalized Ads: We use the Google Adsense service with non-personalized ads, through which ads are displayed within our online offering, and we receive payment for their display or other use. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (ensuring data protection level when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
Affiliate Programs and Affiliate Links
We include so-called affiliate links or other references (which may include, e.g., search forms, widgets, or discount codes) to the offers and services of third-party providers in our online offering (collectively referred to as “affiliate links”). If users follow the affiliate links or subsequently take advantage of the offers, we may receive a commission or other benefits from these third-party providers (collectively referred to as “commission”). To track whether users have taken advantage of the offers of an affiliate link used by us, it is necessary for the respective third-party providers to know that the users followed an affiliate link used within our online offering. The assignment of affiliate links to the respective business transactions or other actions (e.g., purchases) serves solely the purpose of commission accounting and is canceled as soon as it is no longer necessary for this purpose. For the purposes of the aforementioned assignment of affiliate links, the affiliate links may be supplemented with certain values that are part of the link or otherwise stored, e.g., in a cookie. These values may include, in particular, the source website (referrer), the time, an online identifier of the operator of the website where the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer, and an online identifier of the user. Notes on Legal Bases: If we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Furthermore, their use may be part of our (pre)contractual services, provided that the use of third-party providers was agreed upon in this context. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economic, and user-friendly services). In this context, we also refer you to the information on the use of cookies in this privacy policy. Processed Data Types: Contract data (e.g., contract subject, term, customer category), usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
Data Subjects: Users (e.g., website visitors, users of online services).
Purposes of Processing: Affiliate tracking.
Legal Bases: Consent (Art. 6(1)(a) GDPR), Contract performance and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate Interests (Art. 6(1)(f) GDPR). Services and Service Providers Used:- Amazon Affiliate Program: Amazon – Affiliate Program – Amazon and the Amazon logo are trademarks of Amazon.com, Inc. or one of its affiliates. Service provider: Amazon Europe Core S.à.r.l., Amazon EU S.à.r.l., Amazon Services Europe S.à.r.l., and Amazon Media EU S.à.r.l., all four located at 38, avenue John F. Kennedy, L-1855 Luxembourg, as well as Amazon Instant Video Germany GmbH, Domagkstr. 28, 80807 Munich (collectively “Amazon Europe”), parent company: Amazon.com, Inc., 2021 Seventh Ave, Seattle, Washington 98121, USA; Website: https://www.amazon.de; Privacy Policy: https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010; Privacy Shield (ensuring data protection level when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TOWQAA4&status=Active.
Plugins and Embedded Functions and Content
We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may include, for example, graphics, videos, or social media buttons and posts (hereinafter uniformly referred to as “content”). The integration always requires that the third-party providers of this content process the IP address of the users, as they could not send the content to their browser without the IP address. The IP address is therefore necessary for the presentation of this content or functions. We strive to use only such content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, among other things, technical information about the browser and operating system, referring websites, visit time, 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 use third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economic, and user-friendly services). In this context, we also refer you to the information on the use of cookies in this privacy policy. Processed Data Types: Usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
Data Subjects: Users (e.g., website visitors, users of online services).
Purposes of Processing: Provision of our online offering and user-friendliness, contractual services and support.
Legal Bases: Legitimate Interests (Art. 6(1)(f) GDPR). Services and Service Providers Used:- Font Awesome: Display of fonts and symbols; Service provider: Fonticons, Inc., 6 Porter Road Apartment 3R, Cambridge, MA 02140, USA; Website: https://fontawesome.com/; Privacy Policy: https://fontawesome.com/privacy.
- Google Fonts: We integrate the fonts (“Google Fonts”) of the provider Google, whereby the user’s data is used solely for the purpose of displaying the fonts in the user’s browser. The integration is based on our legitimate interests in a technically secure, maintenance-free, and efficient use of fonts, their uniform presentation, and consideration of possible licensing restrictions for their integration. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (ensuring data protection level when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
Deletion of Data
The data processed by us will be deleted in accordance with legal requirements as soon as the consents permitted for processing are revoked or other permissions cease to apply (e.g., if the purpose of processing this data has ceased or it is not necessary for the purpose). If the data is not deleted because it is required for other legally permissible purposes, its processing is restricted to these purposes. This means the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for the assertion, exercise, or defense of legal claims or to protect the rights of another natural or legal person. Further information on the deletion of personal data can also be provided in the context of the individual data protection notices of this privacy policy.Changes and Updates to the Privacy Policy
We ask you to regularly inform yourself about the content of our privacy policy. We will adjust the privacy policy as soon as changes in the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g., consent) or other individual notification. If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time, and we ask you to verify the information before contacting them.Rights of Data Subjects
As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:- Right to Object: You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on Art. 6(1)(e) or (f) GDPR, including profiling based on those provisions. Where 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 such marketing, which includes profiling to the extent that it is related to such direct marketing.
- Right to Withdraw Consent: You have the right to withdraw consents given at any time.
- Right to Information: You have the right to request confirmation as to whether data concerning you is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with legal requirements.
- Right to Rectification: You have the right, in accordance with legal requirements, to request the completion of data concerning you or the correction of inaccurate data concerning you.
- Right to Erasure and Restriction of Processing: You have the right, in accordance with legal requirements, to request that data concerning you be erased without delay or, alternatively, to request restriction of the processing of the data in accordance with legal requirements.
- Right to Data Portability: You have the right to receive data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format in accordance with legal requirements or to request its transmission to another controller.
- Right to Lodge a Complaint with a Supervisory Authority: You also have the right, in accordance with legal requirements, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you believe that the processing of personal data concerning you infringes the GDPR.
Definitions of Terms
This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined primarily in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are sorted alphabetically.
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