Disclaimer: The sample below has been prepared by a lawyer (Dr. jur. Schwenke, LL.M. commercial (UoA), Certified Data Protection Auditor (DSA-TÜV), Certified Data Protection Officer (TÜV Süd)) according to the typical requirements of an online shop. However, you should only use the pattern after careful consideration and adaptation to your specific business model. The following sample therefore contains additional information that you must observe and red passages that you must check and adjust if necessary. Please remove the notices after editing. If in doubt, seek legal advice. Copyright: You may use the design within the domain/website as long as your Marketpress license applies to it. Disclosure to third parties, including customers (e.g. as developers) is not permitted.

Privacy policy

Introduction

With the following privacy policy, we would like to inform you about which types of your personal data (hereinafter also 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 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 (hereinafter collectively referred to as “online offer”).

The terms used are not gender-specific.

Status: XX.XX.20XX

Please indicate the status of the privacy policy.

Outline

Person in charge

First name, surname / company
Street, house no.
Postcode, City
Land

E-mail address: Your e-mail address

Telephone: Your phone number (optional)

Imprint: URL of your imprint (optional, but recommended)

Notes: For sole proprietors, please use the term “owner” and not “managing director”.

Contact Data Protection Officer

First name, surname / company
Street, house no.
Postcode, City
Land

Note: Only the e-mail address is mandatory, the other information is optional. Data protection officers only need to be specified if they have been appointed. An order is acc. § 38 BDSG-Neu already from 20 employees who process personal data (for which an e-mail inbox is practically sufficient).

Overview of processing operations

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

Note: The following information includes the typical processed data and categories of data subjects (these themselves as well as the explanations in the brackets are for clarification only and can be adapted or deleted).

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 geographical 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 data subjects

  • Business and contractual partners.
  • Interested parties.
  • Communication.
  • Customers.
  • Users (e.g. website visitors, users of online services).

Purposes of processing

  • Assessment of creditworthiness and creditworthiness.
  • Provision of our online offer and user-friendliness.
  • Visit 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 post).
  • Interest-based and behavioral marketing.
  • Contact requests and communication.
  • Conversion measurement (measurement of the effectiveness of marketing measures).
  • Profiling (creation of user profiles).
  • Remarketing.
  • Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures.
  • Tracking (e.g. interest/behavioural profiling, use of cookies).
  • Provision of contractual services and customer service.
  • Managing and responding to requests.
  • Target group formation (determination of target groups relevant for marketing purposes or other output of content).

Automated decisions on a case-by-case basis

  • Credit report (decision based on a credit check).

Relevant legal bases

In the following, we inform you of the legal basis of the General Data Protection Regulation (GDPR), on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, the national data protection regulations in your or our country of residence and domicile may apply. Furthermore, if more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 para. 1 p. 1 lit . a. GDPR) – The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or purposes.
  • Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO) – 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 taken at the request of the data subject.
  • Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO) – The processing is necessary for compliance with a legal obligation to which the person responsible is subject.
  • Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR) – 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 measures

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

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, safeguarding of availability and their separation. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data and reactions to the threat to the data. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

SSL encryption (https): In order to protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Note: Remove the encryption notice if your offer is not encrypted. However, delivery of the website via https is to be regarded as mandatory.

Transfer and disclosure of personal data

In the context of our processing of personal data, it may happen that the data is transferred to other bodies, companies, legally independent organizational units or persons or that it is disclosed to them. The recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect 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, bodies or companies, this will only be done in accordance with the legal requirements.

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

Use of cookies

Cookies are small text files or other storage notes that store information on end devices and read information from the end devices. For example, to save the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed or the functions used in an online offer. Cookies can also be used for various purposes, e.g. for the purposes of functionality, security and comfort of online offers as well as the creation of analyses of visitor flows.

Notes on consent: We use cookies in accordance with the statutory provisions. Therefore, we obtain prior consent from users, unless this is not required by law. In particular, consent is not necessary if the storage and reading of information, including cookies, is absolutely necessary in order to provide users with a telemedia service (i.e. our online offer) that they expressly request. The revocable consent is clearly communicated to the users and contains the information on the respective use of cookies.

Notes on legal bases under data protection law: The legal basis under data protection law on which we process users’ personal data with the help of cookies depends on whether we ask users for their consent. If the users consent, the legal basis for the processing of their data is the declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and improvement of its usability) or, if this is done in the context of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We will explain the purposes for which the cookies are processed by us in the course of this privacy policy or in the context of our consent and processing processes.

Storage period: With regard to the storage period, a distinction is made between the following types of cookies:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his device (e.g. browser or mobile application).
  • Persistent cookies: Permanent cookies remain stored even after the device has been closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the user data collected with the help of cookies can be used to measure reach. Unless we provide users with explicit information on the type and storage period of cookies (e.g. in the context of obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke your consent or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection by means of the settings of your browser, e.g. by deactivating the use of cookies (although this may also limit the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be made by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ . In addition, you can receive further objection notices in the context of the information on the service providers and cookies used.

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

Cookie settings/opt-out options:

If you use a cookie consent banner (which is recommended), you can enter the option of calling it up at this point (e.g. [Shortcode]link or a so-called , which is automatically converted into a button by your software).

Notes on the processing of cookie data on the basis of consent: You should only leave this option (and otherwise delete it) if you obtain a “real” opt-in, i.e. the consent of the user to the use of cookies (e.g. with so-called “cookie consent / consent / opt-in banners” or as part of a registration procedure).

Since, according to the ECJ, a cookie opt-in is usually necessary when using marketing tools frequently used in e-commerce (e.g. Google Analytics or Facebook pixels), this option is preselected.

This means that until users have given their consent, they do not use cookies (and do not use third-party services within your websites, which in turn use cookies). At most, the use of necessary cookies that are expected by users is permissible, such as a shopping cart function in the online shop or local reach measurement with the Matomo tool.

Commercial and business services

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

We process this data to fulfill our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as the entrepreneurial organization. Within the framework of 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 with the consent of the persons concerned (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.

We inform the contractual partners which data is required for the aforementioned purposes before or in the context of 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 statutory warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g. as long as it must be kept for legal reasons of archiving (e.g. for tax purposes usually 10 years). Data that has been disclosed to us by the contractual partner within the scope of an order will be deleted in accordance with the specifications of the order, in principle after the end of the order.

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

Customer account: Contractual partners can create an account within our online offer (e.g. customer or user account, or “customer account” for short). If the registration of a customer account is required, contractual partners will be informed of this as well as the information required for registration. The customer accounts are not public and cannot be indexed by search engines. As part of the registration as well as subsequent logins and uses of the customer account, we store the IP addresses of the customers together with the access times in order to be able 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 their retention being required for legal reasons. It is the responsibility of the customer to back up their data in the event of termination of the customer account.

Economic analyses and market research: For business reasons and in order to be able to recognize market trends, wishes of contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc., whereby contractual partners, interested parties, customers, visitors and users of our online offer may fall into the group of data subjects.

The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we may, if available, take into account the profiles of registered users together with their details, e.g. on services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarised, i.e. anonymised values. Furthermore, we take into account the privacy of the users and process the data for 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 for 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 purchase process and includes the information required for delivery, provision and billing 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).
  • Affected persons: 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, administration and response to inquiries, security measures, visit action evaluation, interest-based and behavioral marketing, profiling (creation of user profiles).
  • Legal bases: Fulfillment of the contract and pre-contractual inquiries (Art. 6 para. 1 S. 1 lit. b. GDPR), legal obligation (Art. 6 para. 1 S. 1 lit. c. GDPR), legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Note: Please remove the passage about the customer account or analysis of the customer data if you do not offer a customer account or do not analyze the data of your customers as described.

Payment

Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the persons concerned efficient and secure payment options and, in addition to banks and credit institutions, use other payment service providers for this purpose (collectively “payment service providers”).

The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, sum 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 about the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. For this purpose, we refer to the terms and conditions and the data protection notices of the payment service providers.

Payment transactions are subject to the terms and conditions and data protection notices of the respective payment service providers, which can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and assertion of revocation, information and other data subject rights.

  • Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), 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).
  • Affected persons: Customers, prospects.
  • Purposes of processing: Provision of contractual services and customer service.
  • Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. GDPR), legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Services used and service providers:

Otherwise, adjust the list of services and providers as needed.

Creditworthiness check

If we make advance payments or take comparable economic risks (e.g. when ordering on account), we reserve the right to obtain identity and creditworthiness information for the purpose of assessing the credit risk on the basis of mathematical-statistical procedures from service companies specializing in this field (credit agencies) in order to protect our legitimate interests.

We process the information received from the credit agencies on the statistical probability of a payment default as part of an appropriate discretionary decision on the establishment, implementation and termination of the contractual relationship. In the event of a negative result of the credit check, we reserve the right to refuse payment on account or any other advance payment.

In accordance with Art. 22 GDPR, the decision as to whether we make advance payments is made solely on the basis of an automated decision in the individual case, which our software makes on the basis of the information provided by the credit agency.

If we obtain the express consent of contractual partners, the legal basis for the credit report and the transmission of the customer’s data to the credit agencies is consent. If no consent is obtained, the credit report is carried out on the basis of our legitimate interests in the reliability of our payment claims.

  • 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).
  • Affected persons: Customers, prospects.
  • Purposes of processing: Assessment of creditworthiness and creditworthiness.
  • Legal bases: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).
  • Automated decisions in individual cases: Credit report (decision based on a credit check).

Services used and service providers:

Note: Remove the credit check passage if you are not performing a credit check. If necessary, review and modify the list of service providers. The creditworthiness of a customer is permitted if there is otherwise a risk of non-payment, i.e. if the goods are delivered without payment having been received (i.e. if the customer chooses to purchase on account). On the other hand, there is no threat of non-payment if, for example, the customer chooses the prepayment option or makes the payment via third-party providers, such as PayPal.

It should also be noted that obtaining an automatic credit report is an “automated decisions in individual cases” acc. Art. 22 GDPR, i.e. a legal decision without human intervention. This is permissible if the customer has consented or if this decision is necessary for the conclusion of the contract. Whether the decision is necessary has not yet been conclusively clarified, but is often taken for granted, including by the author of this model.

However, if you want to eliminate any risk, you should obtain consent. Consent is also necessary if the credit report is already used to decide whether the option “on account” should be displayed. Because it could have been that the customer would have opted for prepayment or PayPal anyway and the credit check would not have been necessary. Such consent could, for example, be as follows:

 I agree that a credit check will be carried out in order to decide in an automated procedure (Art. 22 GDPR) whether the option of purchase on account is offered. Further information on the credit check, the credit agencies used and the procedure as well as the possibilities of objection can be found in our [Link]privacy policy[/Link].

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 services and technical maintenance services.

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

E-mail sending and hosting: The web hosting services we use also include sending, receiving and storing e-mails. For these purposes, the addresses of the recipients and senders as well as other information regarding the sending of e-mails (e.g. the providers involved) and 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 on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received (unless a so-called end-to-end encryption method is used). Therefore, we cannot assume any responsibility for the transmission path of the e-mails between the sender and receipt on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the websites and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

On the one hand, 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).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Legal bases: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Note: If you have not already done so: Please ask the respective web hosts for a so-called “order processing agreement” (or “data processing agreement”). This is required by law because the hoster collects personal data of website visitors for you.

Contact

When contacting us (e.g. via contact form, e-mail, telephone or via social media), the information of the inquiring persons will be processed insofar as this is necessary to answer the contact requests and any requested measures.

The answering of contact inquiries within the framework of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of the legitimate interests in answering the inquiries.

  • 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).
  • Affected persons: Communication partners, interested parties.
  • Purposes of processing: Contact requests and communication, management and response to requests.
  • Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. GDPR), legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Services used and service providers:

  • Contact: If users contact us via our contact form, e-mail or other communication channels, we process the data provided to us in this context to process the communicated request. For this purpose, we process personal data within the framework of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfillment and otherwise on the basis of our legitimate interests as well as the interests of the communication partners in answering the concerns and our statutory retention obligations.
  • 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/; Standard contractual clauses (ensuring the level of data protection when processing in third countries): https://www.helpscout.com/company/legal/dpa/; Data Processing Agreement: https://www.helpscout.com/company/legal/dpa/.

Note: If third-party CRM systems are used, their providers should be named. Adjust this information or remove the specified service provider. Furthermore, order processing agreements (or “data processing agreements”) must be concluded with the providers. If the providers process the data of the users in the third country, special guarantees must be in place (e.g. standard contractual clauses).

Newsletters and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter referred to as “newsletters”) only with the consent of the recipient or a legal permission. Insofar as the contents of the newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. In addition, our newsletters contain information about our services and us.

In order to subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name for the purpose of addressing you personally in the newsletter, or other information if this is necessary for the purposes of the newsletter.

Double opt-in procedure: The registration for our newsletter is always carried out in a so-called double opt-in procedure. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can register with other people’s e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the time of registration and confirmation as well as the IP address. Changes to your data stored with the shipping service provider are also logged.

Deletion and restriction of processing: We may store the unsubscribed 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 against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the e-mail address in a blacklist for this purpose alone.

The registration process is recorded on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system.

Notes on legal bases: The newsletter is sent on the basis of the consent of the recipient or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of advertising to existing customers. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration procedure is recorded on the basis of our legitimate interests in order to prove that it has been carried out in accordance with the law.

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

Analysis and performance measurement: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from their server. 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 initially collected.

This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. 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 purpose of using a user-friendly and secure newsletter system that serves both our business interests and the expectations of the users.

Unfortunately, it is not possible to revoke the performance measurement separately, in which case the entire newsletter subscription must be cancelled or objected to.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
  • Affected persons: Communication.
  • Purposes of processing: Direct marketing (e.g. by e-mail or post).
  • Legal bases: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).
  • Possibility of objection (opt-out): You can unsubscribe from our newsletter at any time, i.e. revoke your consent or object .dem further receipt. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or you can otherwise use one of the contact options given above, preferably e-mail.

Services used and service providers:

Please delete the passage Newsletter if you do not send newsletters. Otherwise, adjust the list of services and providers as well as the information on the content of the newsletter and the performance measurement if necessary.

Web analysis, monitoring and optimization

Web analysis (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offer and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the reach analysis, we can recognize, for example, at what time our online offer or its functions or content are most frequently used or invite reuse. We can also understand which areas need optimization.

In addition to web analysis, we can also use test procedures, e.g. to test and optimize different versions of our online offer or its components.

For these purposes, so-called user profiles can be created and stored in a file (so-called “cookie”) or similar procedures can be used for the same purpose. This information may include, for example, content viewed, websites visited and elements used there 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, depending on the provider.

The IP addresses of the users are also collected. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimization, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, user data 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).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Range measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behavioural profiling, use of cookies), visit action evaluation, profiling (creation of user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Services used and service providers:

Please delete the passage web analysis, monitoring and optimization if you do not use web analysis, monitoring and optimization tools on your website. Adjust the list of services and providers as needed.

Online marketing

We process personal data for online marketing purposes, 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 the potential interests of users and the measurement of their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which the information about the user relevant for the presentation of the aforementioned content 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 collected. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that we, as well as the providers of the online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can later generally also be read out on other websites that use the same online marketing process and analyzed for the purpose 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 links the profiles of the users with the aforementioned information. Please note that users can make additional agreements with the providers, e.g. by giving their consent as part of the registration process.

As a matter of principle, we only have access to summarized information about the success of our advertisements. However, within the framework 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 the conclusion of a contract with us. The conversion measurement is used solely to analyze the success of our marketing measures.

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

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, user data 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 position of a device or person).
  • Affected persons: 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 behavioural marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors), target group formation (determination of target groups relevant for marketing purposes or other output of content), Cross-device tracking (cross-device processing of user data for marketing purposes).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).
  • Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the possibilities of objection (so-called “opt-out”) given to the providers. If no explicit opt-out option has been specified, you have the option of switching off cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore also recommend the following opt-out options, which are offered in summary for the respective areas:a) Europe: https://www.youronlinechoices.eu.
    (b) Canada: https://www.youradchoices.ca/choices.
    c) USA: https://www.aboutads.info/choices.
    (d) Multi-territorial: https://optout.aboutads.info.

Services used and service providers:

  • Facebook pixels and custom audiences: With the help of the Facebook pixel (or comparable functions, for the transmission of event data or contact information by means of interfaces in apps), it is possible for Facebook to determine the visitors to our online offer as a target group for the display of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those users on Facebook and within the services of the partners cooperating with Facebook (so-called “Audience Network” https://www.facebook.com/audiencenetwork/ ) that have also shown an interest in our online offer or that have certain characteristics (e.g. interest in certain topics or products that can be seen from the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of the users and do not have a harassing effect. With the help of the Facebook pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion measurement”); Service Provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Standard contractual clauses (ensuring the level of data protection when processing in third countries): The “Facebook-EU Data Transfer Addendum” (https://www.facebook.com/legal/EU_data_transfer_addendum) in the case of order processing by Facebook as the basis for the processing of event data of EU citizens in the USA and the inclusion in the “Facebook Platform Terms of Use” (https://developers.facebook.com/terms) with regard to the independent processing of event data by Facebook in the context of ad placement; Further information: The “Data Processing Conditions” (https://www.facebook.com/legal/terms/dataprocessing/update) with regard to event data that Facebook processes on behalf of companies in order to provide companies with reports and analytics; Furthermore, the “Addendum for Controllers” applies as an agreement on joint responsibility (Art. 26 para. 1 p. 3 GDPR), which is decisive in the case of the independent processing of event data by Facebook for the purposes of targeting and improving and securing Facebook products.
  • 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, 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 users. This allows us to display advertisements for and within our online offer in a more targeted manner in order to present users only with advertisements that potentially correspond to their interests. If, for example, a user is shown advertisements for products in which he or she has shown interest on other online offers, 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; Further information: Types of processing as well as data processed: https://privacy.google.com/businesses/adsservices; Data Processing Terms for Google Advertising Products: Information about the services Data processing terms between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms; if Google acts as a processor, data processing terms for Google advertising products and standard contractual clauses for third country transfers of data: https://business.safety.google/adsprocessorterms.
  • Google Ads and Conversion Measurement: We use the online marketing process “Google Ads” to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads (so-called “conversion”). 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 ourselves do not receive any information that can be used to identify users; 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; Further information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices; Data processing terms for Google advertising products: Information about the services Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.

Please delete the passage online marketing if you do not use online marketing tools on your website. Adjust the list of services and providers as needed. Please keep in mind that the use of marketing services on the website usually requires a cookie opt-in.

Presence in social networks (social media)

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

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

Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the resulting interests of the users. The user profiles can in turn be used, for example, to place advertisements inside and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer, in which the user’s usage behavior and interests are stored. Furthermore, data can also be stored in the usage 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 forms of processing and the possibilities of objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, 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).
  • Affected persons: 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, reach measurement (e.g. access statistics, recognition of returning visitors).
  • Legal bases: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Services used and service providers:

Adjust the list of social networks if necessary.

Plugins and embedded functions as well as content

We integrate functional and content elements into our online offer, which are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These can be, for example, graphics, videos or social media buttons as well as contributions (hereinafter uniformly referred to as “content”).

The integration always presupposes that the third-party providers of this content process the IP address of the users, as they would not be able to 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 only use 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 known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and operating system, websites to be referred to, the time of visit and other information about the use of our online offer, as well as being linked to such information from other sources.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, user data 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 position 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).
  • Affected persons: 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 (creation of user profiles), security measures, administration and answering of enquiries.
  • Legal bases: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR), consent (Art. 6 para. 1 S. 1 lit. a. GDPR), fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 S. 1 lit. b. GDPR).

Services used and service providers:

  • 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/ – We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt in the context of a transmission (but not the further processing) of “event data” that Facebook collects by means of the Facebook social plugins (and embedding functions for content) that are executed on our online offer or receives in the course of a transmission for the following purposes: a) display of content, as well as advertising information in line with the presumed interests of users; b) delivery of commercial and transactional messages (e.g. addressing users via Facebook Messenger); c) Improving ad delivery and personalizing features and content (e.g., improving the recognition of which content or advertising information is likely to match users’ interests). We have entered into a special agreement with Facebook (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum), which regulates, in particular, the security measures to be observed by Facebook (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with measurements, analyses and reports (which are aggregated, i.e. do not receive any information about individual users and are anonymous to us), then this processing is not carried out within the framework of joint responsibility, but on the basis of an order processing agreement (“Data Processing Terms”, https://www.facebook.com/legal/terms/dataprocessing) , the ‘Data Security Conditions’ (https://www.facebook.com/legal/terms/data_security_terms) as well as with regard to processing in the USA on the basis of standard contractual clauses (“Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service Provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/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 takes place on the basis of our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform presentation and taking into account possible licensing restrictions for their integration; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy.
  • Google Maps: We integrate the maps of the “Google Maps” service of the provider Google. The processed data may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually as part of the settings of their mobile devices); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 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 the display of advertisements: https://adssettings.google.com/authenticated.
  • reCAPTCHA: We integrate the “reCAPTCHA” function in order to be able to recognize whether entries (e.g. in online forms) are made by humans and not by automatically acting machines (so-called “bots”). The processed data may include IP addresses, information on operating systems, devices or browsers used, language settings, location, mouse movements, keystrokes, time spent on websites, previously visited websites, interactions with ReCaptcha on other websites, possibly cookies and results of manual recognition processes (e.g. answering questions asked or selecting objects in images); 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://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 the display of advertisements: https://adssettings.google.com/authenticated.
  • Twitter plugins and content: Twitter plugins and buttons – 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 Twitter; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, parent company: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Website:https://twitter.com/de; Privacy Policy:https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
  • YouTube videos: Video; 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://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 the display of advertisements: https://adssettings.google.com/authenticated.
  • Vimeo: Video; Service provider: Vimeo Inc., Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA; Website: https://vimeo.com; Privacy Policy: https://vimeo.com/privacy; Opt-Out: We would like to point out that Vimeo may use Google Analytics and refer to the privacy policy (https://policies.google.com/privacy) as well as the opt-out options for Google Analytics (https://tools.google.com/dlpage/gaoptout?hl=de) or Google’s settings for data use for marketing purposes (https://adssettings.google.com/).

Please delete the passage Plugins and embedded functions as well as content if you do not use plugins or embedded functions as well as content within your website. Otherwise, adjust the list of services and providers if necessary.

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consent to processing is revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose).

If the data is not deleted because it is required for other and legally permissible purposes, its processing will be limited to these purposes. This means that the data will be 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 defense 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 found in the individual data protection notices of this data protection declaration.

Modification and updating of the privacy policy

We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (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 us.

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: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such advertising; this also applies to profiling to the extent that it is related to such direct marketing.
  • Right of revocation of consent: You have the right to revoke your consent at any time.
  • Right: You have the right to request confirmation as to whether the data in question is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the legal requirements, you have the right to request the completion of the data concerning you or the correction of incorrect data concerning you.
  • Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be deleted immediately or, alternatively, to demand a restriction of the processing of the data in accordance with the legal requirements.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transferred to another person responsible.
  • Complaint to the 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, your place of work or the place of the alleged infringement, if you believe that the processing of personal data concerning you violates the GDPR.

Definitions

This section provides you with 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 provide understanding. The terms are sorted alphabetically.

  • Visit Action Evaluation: “Conversion tracking” refers to a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the user’s devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, it allows us to track whether the ads we have placed on other websites have been successful).
  • Credit report: Automated decisions are based on automatic data processing without human intervention (e.g. in the case of an automatic refusal of a purchase on account, an online loan application or an online application process without any human intervention). According to Art. 22 GDPR, such automated decisions are only permissible if data subjects consent, if they are necessary for the performance of a contract or if national laws allow these decisions.
  • Cross-Device Tracking: Cross-device tracking is a form of tracking in which users’ behavioral and interest information is recorded across devices in so-called profiles by assigning an online identifier to the users. As a result, user information can usually be analyzed for marketing purposes, regardless of the browsers or devices used (e.g. mobile phones or desktop computers). For most providers, the online identifier is not linked to 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 procedures, especially in online marketing
  • Interest-based and behavioral marketing: Interest- and/or behavioral marketing is 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, purchasing behaviour or interaction with other users), which is stored in a so-called profile. Cookies are usually used for these purposes.
  • Conversion measurement: Conversion measurement is a procedure that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user’s devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, it allows us to track whether the ads we have placed on other websites have been successful.
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “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 to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiling: “Profiling” refers to any type of automated processing of personal data consisting of the use of such personal data to develop certain personal aspects relating to a natural person (depending on the type of profiling, this may include information regarding age, gender, location data and movement data, interaction with websites and their content, shopping behavior, social interactions with other people). analyze, evaluate or predict them (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Range measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offer and can include the behavior or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, see at what time visitors visit their website and what content they are interested in. This allows them, for example, to better adapt the content of the website to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Remarketing: One speaks of “remarketing” or “retargeting” when, for example, for advertising purposes, it is noted 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.
  • Location: Location data is generated when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, a WLAN or similar technical intermediaries and functions of location determination. Location data is used to indicate the geographically determinable position of the earth at which the respective device is located. Location data can be used, for example, to display map functions or other location-dependent information.
  • Tracking: “Tracking” is when the behavior of users can be traced across several online offers. As a rule, behavioral and interest information is stored in cookies or on servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
  • Person in charge: “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and encompasses practically every handling of data, be it collection, evaluation, storage, transmission or deletion.
  • Target group formation: Target group formation (or “custom audiences”) is when target groups are determined for advertising purposes, e.g. insertion of advertisements. For example, based on a user’s interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which he viewed the products. In turn, one speaks of “lookalike audiences” (or similar target groups) when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are usually used for the purpose of creating Custom Audiences and Lookalike Audiences.

10%

Willkommens-Rabatt 🎁

Jetzt unseren Newsletter abonnieren und einen 10%*-Gutschein sichern!

Gültig ohne Mindesteinkaufswert. 
Abmeldung jederzeit möglich.
Hinweise zum Datenschutz findest Du hier.