PRIVACY POLICY

PREAMBLE

WITH THE FOLLOWING PRIVACY POLICY, WE WOULD LIKE TO INFORM YOU ABOUT WHAT TYPES OF 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 PROVIDING OUR SERVICES AND, IN PARTICULAR, ON OUR WEBSITES, IN MOBILE APPLICATIONS, AND WITHIN EXTERNAL ONLINE PRESENCES, SUCH AS OUR SOCIAL MEDIA PROFILES (HEREINAFTER COLLECTIVELY REFERRED TO AS "ONLINE OFFERING").

THE TERMS USED ARE NOT GENDER-SPECIFIC.

AS OF FEBRUARY 13, 2024

TABLE OF CONTENTS


  • PREAMBLE

  • RESPONSIBLE

  • OVERVIEW OF PROCESSING

  • RELEVANT LEGAL BASIS

  • SECURITY

  • TRANSFER OF PERSONAL DATA

  • INTERNATIONAL DATA TRANSFERS

  • DELETION OF DATA

  • RIGHTS OF DATA SUBJECTS

  • USE OF COOKIES

  • BUSINESS SERVICES

  • PROVIDERS AND SERVICES USED IN THE COURSE OF BUSINESS

  • PAYMENT PROCEDURES

  • PROVISION OF THE ONLINE OFFERING AND WEB HOSTING

  • REGISTRATION, LOGIN, AND USER ACCOUNT

  • CONTACT AND INQUIRY MANAGEMENT

  • NEWSLETTERS AND ELECTRONIC NOTIFICATIONS

  • ADVERTISING COMMUNICATION VIA EMAIL, POST, FAX, OR TELEPHONE

  • WEB ANALYSIS, MONITORING, AND OPTIMIZATION

  • ONLINE MARKETING

  • PRESENCE ON SOCIAL NETWORKS (SOCIAL MEDIA)

  • PLUGINS AND EMBEDDED FUNCTIONS AND CONTENT

  • MODIFICATION AND UPDATING OF THE PRIVACY POLICY

  • DEFINITION OF TERMS

RESPONSIBLE

LOUIS KUIPER

AN DER HOREBURG 21

21079 HAMBURG

EMAIL ADDRESS: SUPPORT@CALA-BAS.COM

TELEPHONE: 004915154962626

LEGAL NOTICE: HTTPS://CALA-BAS.COM/PAGES/IMPRINT

OVERVIEW OF PROCESSING

THE FOLLOWING OVERVIEW SUMMARIZES THE TYPES OF DATA PROCESSED AND THE PURPOSES FOR WHICH THEY ARE PROCESSED, AND REFERS TO THE DATA SUBJECTS.

TYPES OF DATA PROCESSED

  • INVENTORY DATA.

  • PAYMENT DATA.

  • CONTACT DATA.

  • CONTENT DATA.

  • CONTRACT DATA.

  • USAGE DATA.

  • META, COMMUNICATION, AND PROCEDURAL DATA.

  • EVENT DATA (FACEBOOK).

CATEGORIES OF DATA SUBJECTS

  • CUSTOMERS.

  • PROSPECTIVE CUSTOMERS.

  • COMMUNICATION PARTNERS.

  • USERS.

  • BUSINESS AND CONTRACTUAL PARTNERS.

PURPOSES OF PROCESSING

  • PROVISION OF CONTRACTUAL SERVICES AND FULFILLMENT OF CONTRACTUAL OBLIGATIONS.

  • CONTACT REQUESTS AND COMMUNICATION.

  • SECURITY MEASURES.

  • DIRECT MARKETING.

  • REACH MEASUREMENT.

  • TRACKING.

  • OFFICE AND ORGANIZATIONAL PROCEDURES.

  • CONVERSION MEASUREMENT.

  • TARGET GROUP FORMATION.

  • MANAGEMENT AND RESPONSE TO INQUIRIES.

  • FEEDBACK.

  • MARKETING.

  • PROFILES WITH USER-RELATED INFORMATION.

  • PROVISION OF OUR ONLINE OFFERING AND USER-FRIENDLINESS.

  • INFORMATION TECHNOLOGY INFRASTRUCTURE.

RELEVANT LEGAL BASES

RELEVANT LEGAL BASES UNDER THE GDPR: BELOW YOU WILL FIND AN OVERVIEW OF THE LEGAL BASES OF THE GDPR ON WHICH WE PROCESS PERSONAL DATA. PLEASE NOTE THAT, IN ADDITION TO THE PROVISIONS OF THE GDPR, NATIONAL DATA PROTECTION REGULATIONS MAY APPLY IN YOUR OR OUR COUNTRY OF RESIDENCE OR REGISTERED OFFICE. IF MORE SPECIFIC LEGAL BASES ARE APPLICABLE IN INDIVIDUAL CASES, WE WILL INFORM YOU OF THESE IN THE PRIVACY POLICY.


  • CONSENT (ART. 6 PARA. 1 SENTENCE 1 LIT. A) GDPR) - THE DATA SUBJECT HAS GIVEN CONSENT TO THE PROCESSING OF PERSONAL DATA CONCERNING HIM OR HER FOR ONE OR MORE SPECIFIC PURPOSES.

  • CONTRACT FULFILLMENT AND PRE-CONTRACTUAL INQUIRIES (ART. 6 PARA. 1 SENTENCE 1 LIT. B) GDPR) - PROCESSING IS NECESSARY FOR THE PERFORMANCE OF A CONTRACT TO WHICH THE DATA SUBJECT IS PARTY OR IN ORDER TO TAKE STEPS AT THE REQUEST OF THE DATA SUBJECT PRIOR TO ENTERING INTO A CONTRACT.

  • LEGAL OBLIGATION (ART. 6 PARA. 1 SENTENCE 1 LIT. C) GDPR) - PROCESSING IS NECESSARY FOR COMPLIANCE WITH A LEGAL OBLIGATION TO WHICH THE CONTROLLER IS SUBJECT.

  • LEGITIMATE INTERESTS (ART. 6 PARA. 1 SENTENCE 1 LIT. F) GDPR) - PROCESSING IS NECESSARY FOR THE PURPOSES OF THE LEGITIMATE INTERESTS PURSUED BY THE CONTROLLER OR BY A THIRD PARTY, EXCEPT WHERE SUCH INTERESTS ARE OVERRIDDEN BY THE INTERESTS OR FUNDAMENTAL RIGHTS AND FREEDOMS OF THE DATA SUBJECT WHICH REQUIRE PROTECTION OF PERSONAL DATA.

NATIONAL DATA PROTECTION REGULATIONS IN GERMANY: IN ADDITION TO THE DATA PROTECTION REGULATIONS OF THE GDPR, NATIONAL REGULATIONS ON DATA PROTECTION APPLY IN GERMANY. THESE INCLUDE, IN PARTICULAR, THE FEDERAL DATA PROTECTION ACT (BUNDESDATENSCHUTZGESETZ – BDSG). THE BDSG CONTAINS, IN PARTICULAR, SPECIAL PROVISIONS ON THE RIGHT TO INFORMATION, THE RIGHT TO ERASURE, THE RIGHT TO OBJECT, THE PROCESSING OF SPECIAL CATEGORIES OF PERSONAL DATA, PROCESSING FOR OTHER PURPOSES AND TRANSFER, AS WELL AS AUTOMATED DECISION-MAKING IN INDIVIDUAL CASES, INCLUDING PROFILING. FURTHERMORE, STATE DATA PROTECTION LAWS OF THE INDIVIDUAL FEDERAL STATES MAY APPLY.

RELEVANT LEGAL BASIS UNDER SWISS DATA PROTECTION LAW: IF YOU ARE LOCATED IN SWITZERLAND, WE PROCESS YOUR DATA ON THE BASIS OF THE FEDERAL ACT ON DATA PROTECTION (IN SHORT, THE "SWISS DSG"). THIS ALSO APPLIES IF OUR PROCESSING OF YOUR DATA OTHERWISE AFFECTS YOU IN SWITZERLAND AND YOU ARE AFFECTED BY THE PROCESSING. THE SWISS DSG DOES NOT GENERALLY REQUIRE (UNLIKE, FOR EXAMPLE, THE GDPR) THAT A LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA BE SPECIFIED. WE ONLY PROCESS PERSONAL DATA IF THE PROCESSING IS LAWFUL, CARRIED OUT IN GOOD FAITH, AND PROPORTIONATE (ART. 6 (1) AND (2) OF THE SWISS DSG). FURTHERMORE, WE ONLY COLLECT PERSONAL DATA FOR SPECIFIC PURPOSES THAT ARE APPARENT TO THE DATA SUBJECT AND ONLY PROCESS IT IN A MANNER THAT IS COMPATIBLE WITH THESE PURPOSES (ART. 6 PARA. 3 OF THE SWISS DSG).

NOTE ON THE APPLICABILITY OF THE GDPR AND THE SWISS DSG: THIS PRIVACY POLICY SERVES TO PROVIDE INFORMATION IN ACCORDANCE WITH THE SWISS FEDERAL ACT ON DATA PROTECTION (SWISS DSG) AND THE GENERAL DATA PROTECTION REGULATION (GDPR). FOR THIS REASON, PLEASE NOTE THAT THE TERMS USED IN THE GDPR ARE USED DUE TO THEIR BROADER GEOGRAPHICAL APPLICATION AND COMPREHENSIBILITY. IN PARTICULAR, INSTEAD OF THE TERMS "PROCESSING" OF "PERSONAL DATA," "OVERRIDING INTEREST," AND "SENSITIVE PERSONAL DATA" USED IN THE SWISS DSG, THE TERMS "PROCESSING" OF "PERSONAL DATA," "LEGITIMATE INTEREST," AND "SPECIAL CATEGORIES OF DATA" USED IN THE GDPR ARE USED. HOWEVER, THE LEGAL MEANING OF THE TERMS WILL CONTINUE TO BE DETERMINED IN ACCORDANCE WITH THE SWISS DSG WITHIN THE SCOPE OF ITS APPLICABILITY.

SECURITY

WE TAKE APPROPRIATE TECHNICAL AND ORGANIZATIONAL MEASURES TO ENSURE A LEVEL OF PROTECTION APPROPRIATE TO THE RISK, TAKING INTO ACCOUNT THE STATE OF THE ART, THE COSTS OF IMPLEMENTATION, AND THE NATURE, SCOPE, CONTEXT, AND PURPOSES OF THE PROCESSING, AS WELL AS THE LIKELIHOOD AND SEVERITY OF THE 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 TO, INPUT, TRANSFER, AND BACKUP OF THE DATA AND ENSURING ITS AVAILABILITY AND SEPARATION. FURTHERMORE, WE HAVE ESTABLISHED PROCEDURES TO ENSURE THAT DATA SUBJECTS CAN EXERCISE THEIR RIGHTS, THAT DATA IS DELETED, AND THAT RESPONSES ARE PROVIDED IN THE EVENT OF A THREAT TO THE DATA. FURTHERMORE, WE TAKE THE PROTECTION OF PERSONAL DATA INTO ACCOUNT DURING THE DEVELOPMENT AND SELECTION OF HARDWARE, SOFTWARE, AND PROCEDURES IN ACCORDANCE WITH THE PRINCIPLE OF DATA PROTECTION, THROUGH TECHNOLOGY DESIGN AND DATA PROTECTION-FRIENDLY DEFAULT SETTINGS.

TLS/SSL ENCRYPTION (HTTPS): WE USE TLS/SSL ENCRYPTION TO PROTECT USER DATA TRANSMITTED VIA OUR ONLINE SERVICES. SECURE SOCKETS LAYER (SSL) IS THE STANDARD TECHNOLOGY FOR SECURING INTERNET CONNECTIONS BY ENCRYPTING THE DATA TRANSMITTED BETWEEN A WEBSITE OR APP AND A BROWSER (OR BETWEEN TWO SERVERS). TRANSPORT LAYER SECURITY (TLS) IS AN UPDATED AND MORE SECURE VERSION OF SSL. HYPER TEXT TRANSFER PROTOCOL SECURE (HTTPS) IS DISPLAYED IN THE URL WHEN A WEBSITE IS SECURED BY AN SSL/TLS CERTIFICATE.

TRANSFER OF PERSONAL DATA

IN THE COURSE 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 DISCLOSED TO THEM. THE RECIPIENTS OF THIS DATA MAY INCLUDE, FOR EXAMPLE, SERVICE PROVIDERS COMMISSIONED WITH IT TASKS OR PROVIDERS OF SERVICES AND CONTENT THAT ARE INTEGRATED INTO A WEBSITE. IN SUCH CASES, WE COMPLY WITH THE LEGAL REQUIREMENTS AND, IN PARTICULAR, CONCLUDE APPROPRIATE CONTRACTS OR AGREEMENTS WITH THE RECIPIENTS OF YOUR DATA TO ENSURE THAT YOUR DATA IS PROTECTED.

DATA TRANSFER WITHIN THE ORGANIZATION: WE MAY TRANSFER PERSONAL DATA TO OTHER ENTITIES WITHIN OUR ORGANIZATION OR GRANT THEM ACCESS TO THIS DATA. IF THIS TRANSFER IS FOR ADMINISTRATIVE PURPOSES, THE TRANSFER OF DATA IS BASED ON OUR LEGITIMATE BUSINESS AND ECONOMIC INTERESTS OR IS NECESSARY TO FULFILL OUR CONTRACTUAL OBLIGATIONS OR IF THE CONSENT OF THE DATA SUBJECT OR LEGAL PERMISSION HAS BEEN OBTAINED.

INTERNATIONAL DATA TRANSFERS

DATA PROCESSING IN THIRD COUNTRIES: IF WE PROCESS DATA IN A THIRD COUNTRY (I.E., OUTSIDE THE EUROPEAN UNION (EU) OR THE EUROPEAN ECONOMIC AREA (EEA)) OR IF PROCESSING TAKES PLACE IN THE CONTEXT OF USING THIRD-PARTY SERVICES OR DISCLOSING OR TRANSFERRING DATA TO OTHER PERSONS, BODIES, OR COMPANIES, THIS WILL ONLY BE DONE IN ACCORDANCE WITH THE LEGAL REQUIREMENTS. IF THE LEVEL OF DATA PROTECTION IN THE THIRD COUNTRY HAS BEEN RECOGNIZED BY MEANS OF AN ADEQUACY DECISION (ART. 45 GDPR), THIS SERVES AS THE BASIS FOR THE DATA TRANSFER. OTHERWISE, DATA TRANSFERS WILL ONLY TAKE PLACE IF THE LEVEL OF DATA PROTECTION IS OTHERWISE ENSURED, IN PARTICULAR THROUGH STANDARD CONTRACTUAL CLAUSES (ART. 46 (2) LIT. C) GDPR), EXPRESS CONSENT OR IN THE CASE OF CONTRACTUAL OR LEGALLY REQUIRED TRANSFERS (ART. 49 (1) GDPR). IN ADDITION, WE WILL INFORM YOU OF THE BASIS FOR THIRD-COUNTRY TRANSFERS FOR THE INDIVIDUAL PROVIDERS FROM THE THIRD COUNTRY, WHEREBY THE ADEQUACY DECISIONS TAKE PRECEDENCE AS THE BASIS. INFORMATION ON TRANSFERS TO THIRD COUNTRIES AND EXISTING ADEQUACY DECISIONS CAN BE FOUND IN THE INFORMATION PROVIDED BY THE EU COMMISSION: HTTPS://COMMISSION.EUROPA.EU/LAW/LAW-TOPIC/DATA-PROTECTION/INTERNATIONAL-DIMENSION-DATA-PROTECTION_EN?PREFLANG=DE.

EU-US TRANS-ATLANTIC DATA PRIVACY FRAMEWORK: WITHIN THE FRAMEWORK OF THE SO-CALLED "DATA PRIVACY FRAMEWORK" (DPF), THE EU COMMISSION HAS ALSO RECOGNIZED THE LEVEL OF DATA PROTECTION FOR CERTAIN COMPANIES FROM THE US AS SECURE WITHIN THE FRAMEWORK OF THE ADEQUACY DECISION OF JULY 10, 2023. THE LIST OF CERTIFIED COMPANIES AND FURTHER INFORMATION ON THE DPF CAN BE FOUND ON THE WEBSITE OF THE US DEPARTMENT OF COMMERCE AT HTTPS://WWW.DATAPRIVACYFRAMEWORK.GOV/ (IN ENGLISH). WE WILL INFORM YOU IN OUR PRIVACY POLICY WHICH SERVICE PROVIDERS WE USE THAT ARE CERTIFIED UNDER THE DATA PRIVACY FRAMEWORK.

DISCLOSURE OF PERSONAL DATA ABROAD: IN ACCORDANCE WITH THE SWISS DATA PROTECTION ACT (DSG), WE ONLY DISCLOSE PERSONAL DATA ABROAD IF ADEQUATE PROTECTION OF THE PERSONS CONCERNED IS GUARANTEED (ART. 16 SWISS DSG). IF THE FEDERAL COUNCIL HAS NOT DETERMINED THAT ADEQUATE PROTECTION EXISTS (LIST: HTTPS://WWW.BJ.ADMIN.CH/BJ/DE/HOME/STAAT/DATENSCHUTZ/INTERNATIONALES/ANERKENNUNG-STAATEN.HTML), WE TAKE ALTERNATIVE SECURITY MEASURES. THESE MAY INCLUDE INTERNATIONAL AGREEMENTS, SPECIFIC GUARANTEES, DATA PROTECTION CLAUSES IN CONTRACTS, STANDARD DATA PROTECTION CLAUSES APPROVED BY THE FEDERAL DATA PROTECTION AND INFORMATION COMMISSIONER (FDPIC) OR INTERNAL DATA PROTECTION REGULATIONS APPROVED IN ADVANCE BY THE FDPIC OR A COMPETENT DATA PROTECTION AUTHORITY IN ANOTHER COUNTRY.

ACCORDING TO ART. 16 OF THE SWISS DSG, EXCEPTIONS TO THE DISCLOSURE OF DATA ABROAD MAY BE PERMITTED IF CERTAIN CONDITIONS ARE MET, INCLUDING THE CONSENT OF THE DATA SUBJECT, CONTRACT PERFORMANCE, PUBLIC INTEREST, PROTECTION OF LIFE OR PHYSICAL INTEGRITY, DATA MADE PUBLIC, OR DATA FROM A REGISTER PROVIDED FOR BY LAW. THESE DISCLOSURES ARE ALWAYS MADE IN ACCORDANCE WITH LEGAL REQUIREMENTS.

DELETION OF DATA

THE DATA WE PROCESS WILL BE DELETED IN ACCORDANCE WITH LEGAL REQUIREMENTS AS SOON AS THE CONSENT FOR PROCESSING IS REVOKED OR OTHER PERMISSIONS EXPIRE (E.G., IF THE PURPOSE FOR PROCESSING THIS DATA NO LONGER APPLIES OR IT IS NO LONGER NECESSARY FOR THE PURPOSE). IF THE DATA IS NOT DELETED BECAUSE IT IS REQUIRED FOR OTHER AND LEGALLY PERMISSIBLE PURPOSES, ITS PROCESSING WILL BE RESTRICTED 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. WITHIN THE SCOPE OF OUR DATA PROTECTION INFORMATION, WE CAN PROVIDE USERS WITH FURTHER INFORMATION ON THE DELETION AND STORAGE OF DATA THAT APPLIES SPECIFICALLY TO THE RESPECTIVE PROCESSING PROCESS.

RIGHTS OF DATA SUBJECTS

RIGHTS OF DATA SUBJECTS UNDER THE GDPR: 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 AT ANY TIME, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU WHICH IS BASED ON ART. 6 PARA. 1 LIT. E OR F GDPR; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. IF THE PERSONAL DATA CONCERNING YOU IS PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR SUCH MARKETING; THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING.

  • RIGHT TO WITHDRAW CONSENT: YOU HAVE THE RIGHT TO WITHDRAW YOUR CONSENT 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 THE LEGAL REQUIREMENTS.

  • RIGHT TO RECTIFICATION: YOU HAVE THE RIGHT TO REQUEST THE COMPLETION OF DATA CONCERNING YOU OR THE RECTIFICATION OF INACCURATE DATA CONCERNING YOU IN ACCORDANCE WITH THE STATUTORY PROVISIONS.

  • RIGHT TO ERASURE AND RESTRICTION OF PROCESSING: IN ACCORDANCE WITH LEGAL REQUIREMENTS, YOU HAVE THE RIGHT TO REQUEST THAT DATA RELATING TO YOU BE DELETED IMMEDIATELY OR, ALTERNATIVELY, TO REQUEST THAT THE PROCESSING OF SUCH DATA BE RESTRICTED IN ACCORDANCE WITH LEGAL REQUIREMENTS.

  • RIGHT TO DATA PORTABILITY: YOU HAVE THE RIGHT TO RECEIVE DATA RELATING TO YOU THAT YOU HAVE PROVIDED TO US IN A STRUCTURED, COMMONLY USED AND MACHINE-READABLE FORMAT OR TO REQUEST THAT IT BE TRANSFERRED TO ANOTHER CONTROLLER.

  • COMPLAINT TO A SUPERVISORY AUTHORITY: IN ACCORDANCE WITH LEGAL REQUIREMENTS AND WITHOUT PREJUDICE TO ANY OTHER ADMINISTRATIVE OR JUDICIAL REMEDY, YOU ALSO HAVE THE RIGHT TO LODGE A COMPLAINT WITH A DATA PROTECTION SUPERVISORY AUTHORITY, IN PARTICULAR A SUPERVISORY AUTHORITY IN THE MEMBER STATE IN WHICH YOU USUALLY RESIDE, THE SUPERVISORY AUTHORITY OF YOUR WORKPLACE OR THE PLACE OF THE ALLEGED INFRINGEMENT, IF YOU BELIEVE THAT THE PROCESSING OF PERSONAL DATA RELATING TO YOU VIOLATES THE GDPR.

RIGHTS OF DATA SUBJECTS UNDER THE SWISS DSG: 

AS A DATA SUBJECT, YOU HAVE THE FOLLOWING RIGHTS UNDER THE PROVISIONS OF THE SWISS DSG:

  • RIGHT TO INFORMATION: YOU HAVE THE RIGHT TO REQUEST CONFIRMATION AS TO WHETHER PERSONAL DATA CONCERNING YOU IS BEING PROCESSED AND TO RECEIVE THE INFORMATION NECESSARY TO ENABLE YOU TO EXERCISE YOUR RIGHTS UNDER THIS LAW AND TO ENSURE TRANSPARENT DATA PROCESSING.

  • RIGHT TO DATA DISCLOSURE OR TRANSFER: YOU HAVE THE RIGHT TO REQUEST THE DISCLOSURE OF YOUR PERSONAL DATA THAT YOU HAVE PROVIDED TO US IN A COMMONLY USED ELECTRONIC FORMAT.

  • RIGHT TO RECTIFICATION: YOU HAVE THE RIGHT TO REQUEST THE RECTIFICATION OF INACCURATE PERSONAL DATA CONCERNING YOU.

  • RIGHT TO OBJECT, ERASURE, AND DESTRUCTION: YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR DATA AND TO REQUEST THAT YOUR PERSONAL DATA BE ERASED OR DESTROYED.

USE OF COOKIES

COOKIES ARE SMALL TEXT FILES OR OTHER STORAGE NOTES THAT STORE INFORMATION ON END DEVICES AND READ INFORMATION FROM END DEVICES. FOR EXAMPLE, TO STORE THE LOGIN STATUS IN A USER ACCOUNT, THE CONTENTS OF A SHOPPING CART IN AN E-SHOP, THE CONTENT ACCESSED OR THE FUNCTIONS USED OF AN ONLINE OFFER. COOKIES CAN ALSO BE USED FOR VARIOUS PURPOSES, E.G., FOR THE FUNCTIONALITY, SECURITY, AND CONVENIENCE OF ONLINE OFFERS, AS WELL AS FOR ANALYZING VISITOR TRAFFIC. 

INFORMATION ON CONSENT: WE USE COOKIES IN ACCORDANCE WITH LEGAL REQUIREMENTS. WE THEREFORE OBTAIN PRIOR CONSENT FROM USERS, UNLESS THIS IS NOT REQUIRED BY LAW. CONSENT IS NOT REQUIRED IN PARTICULAR IF THE STORAGE AND RETRIEVAL OF INFORMATION, INCLUDING COOKIES, IS ABSOLUTELY NECESSARY TO PROVIDE USERS WITH A TELEMEDIA SERVICE (I.E., OUR ONLINE OFFERING) THAT THEY HAVE EXPRESSLY REQUESTED. STRICTLY NECESSARY COOKIES GENERALLY INCLUDE COOKIES WITH FUNCTIONS THAT SERVE TO DISPLAY AND ENABLE THE ONLINE OFFER, LOAD BALANCING, SECURITY, STORAGE OF USER PREFERENCES AND SELECTIONS, OR SIMILAR PURPOSES RELATED TO THE PROVISION OF THE MAIN AND ANCILLARY FUNCTIONS OF THE ONLINE OFFER REQUESTED BY USERS. THE REVOCABLE CONSENT IS CLEARLY COMMUNICATED TO USERS AND CONTAINS INFORMATION ABOUT THE RESPECTIVE USE OF COOKIES.

INFORMATION ON THE LEGAL BASIS FOR DATA PROTECTION: THE LEGAL BASIS ON WHICH WE PROCESS USERS' PERSONAL DATA WITH THE HELP OF COOKIES DEPENDS ON WHETHER WE ASK USERS FOR THEIR CONSENT. IF USERS CONSENT, THE LEGAL BASIS FOR PROCESSING THEIR DATA IS THE CONSENT THEY HAVE GIVEN. OTHERWISE, THE DATA PROCESSED USING COOKIES IS PROCESSED ON THE BASIS OF OUR LEGITIMATE INTERESTS (E.G., IN THE COMMERCIAL OPERATION OF OUR ONLINE OFFERING AND THE IMPROVEMENT OF ITS USABILITY) OR, IF THIS IS DONE IN THE CONTEXT OF FULFILLING OUR CONTRACTUAL OBLIGATIONS, IF THE USE OF COOKIES IS NECESSARY TO FULFILL OUR CONTRACTUAL OBLIGATIONS. WE EXPLAIN THE PURPOSES FOR WHICH WE PROCESS COOKIES IN THIS PRIVACY POLICY OR AS PART OF OUR CONSENT AND PROCESSING PROCESSES.

STORAGE DURATION: WITH REGARD TO THE STORAGE DURATION, THE FOLLOWING TYPES OF COOKIES ARE DISTINGUISHED:

  • TEMPORARY COOKIES (ALSO KNOWN AS SESSION COOKIES): TEMPORARY COOKIES ARE DELETED AT THE LATEST AFTER A USER LEAVES AN ONLINE OFFER AND CLOSES THEIR END DEVICE (E.G., BROWSER OR MOBILE APPLICATION).

  • PERMANENT COOKIES: PERMANENT COOKIES REMAIN STORED EVEN AFTER THE END DEVICE IS CLOSED. THIS ALLOWS, FOR EXAMPLE, THE LOGIN STATUS TO BE STORED OR PREFERRED CONTENT TO BE DISPLAYED DIRECTLY WHEN THE USER REVISITS A WEBSITE. THE USER DATA COLLECTED WITH THE HELP OF COOKIES CAN ALSO BE USED TO MEASURE REACH. UNLESS WE PROVIDE USERS WITH EXPLICIT INFORMATION ABOUT THE TYPE AND STORAGE DURATION OF COOKIES (E.G., WHEN 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 (SO-CALLED "OPT-OUT"): USERS CAN REVOKE THEIR CONSENT AT ANY TIME AND OBJECT TO PROCESSING IN ACCORDANCE WITH THE LEGAL REQUIREMENTS. TO DO THIS, USERS CAN, AMONG OTHER THINGS, RESTRICT THE USE OF COOKIES IN THEIR BROWSER SETTINGS (ALTHOUGH THIS MAY ALSO RESTRICT THE FUNCTIONALITY OF OUR ONLINE OFFERING). OBJECTION TO THE USE OF COOKIES FOR ONLINE MARKETING PURPOSES CAN ALSO BE DECLARED VIA THE WEBSITES HTTPS://OPTOUT.ABOUTADS.INFO AND HTTPS://WWW.YOURONLINECHOICES.COM/.

  • TYPES OF DATA PROCESSED: USAGE DATA (E.G., WEBSITES VISITED, INTEREST IN CONTENT, ACCESS TIMES).

  • DATA SUBJECTS: USERS (E.G., WEBSITE VISITORS, USERS OF ONLINE SERVICES).

  • PURPOSES OF PROCESSING: PROVISION OF OUR ONLINE OFFERING AND USER-FRIENDLINESS.

  • LEGAL BASIS: LEGITIMATE INTERESTS (ART. 6 PARA. 1 SENTENCE 1 LIT. F) GDPR). CONSENT (ART. 6 PARA. 1 SENTENCE 1 LIT. A) GDPR).

FURTHER INFORMATION ON PROCESSING PROCESSES, PROCEDURES, AND SERVICES:

  • PROCESSING OF COOKIE DATA BASED ON CONSENT: WE USE A CONSENT MANAGEMENT PROCEDURE: PROCEDURE FOR OBTAINING, LOGGING, MANAGING, AND REVOKING CONSENT, IN PARTICULAR FOR THE USE OF COOKIES AND SIMILAR TECHNOLOGIES FOR STORING, READING, AND PROCESSING INFORMATION ON USERS' END DEVICES, AS WELL AS FOR PROCESSING THIS INFORMATION, WITHIN THE FRAMEWORK OF WHICH USERS' CONSENT TO THE USE OF COOKIES OR THE CONSENT MANAGEMENT PROCEDURE IS OBTAINED. PROCEDURE FOR OBTAINING, LOGGING, MANAGING, AND REVOKING CONSENT, IN PARTICULAR FOR THE USE OF COOKIES AND SIMILAR TECHNOLOGIES FOR STORING, READING, AND PROCESSING INFORMATION ON USERS' END DEVICES AND THEIR PROCESSING. THE DECLARATION OF CONSENT IS STORED SO THAT IT DOES NOT HAVE TO BE REQUESTED AGAIN AND SO THAT CONSENT CAN BE VERIFIED IN ACCORDANCE WITH LEGAL REQUIREMENTS. STORAGE MAY TAKE PLACE ON THE SERVER AND/OR IN A COOKIE (A SO-CALLED OPT-IN COOKIE OR USING COMPARABLE TECHNOLOGIES) IN ORDER TO BE ABLE TO ASSIGN THE CONSENT TO A USER OR THEIR DEVICE. SUBJECT TO INDIVIDUAL INFORMATION PROVIDED BY THE PROVIDERS OF COOKIE MANAGEMENT SERVICES, THE FOLLOWING APPLIES: THE CONSENT MAY BE STORED FOR UP TO TWO YEARS. A PSEUDONYMOUS USER IDENTIFIER IS CREATED AND STORED TOGETHER WITH THE TIME OF CONSENT, INFORMATION ON THE SCOPE OF CONSENT (E.G., WHICH CATEGORIES OF COOKIES AND/OR SERVICE PROVIDERS) AND THE BROWSER, SYSTEM, AND DEVICE USED; LEGAL BASIS: CONSENT (ART. 6 PARA. 1 SENTENCE 1 LIT. A) GDPR).

  • CONSENTMO: CONSENT MANAGEMENT: PROCEDURE FOR OBTAINING, LOGGING, MANAGING, AND REVOKING CONSENT, IN PARTICULAR FOR THE USE OF COOKIES AND SIMILAR TECHNOLOGIES FOR STORING, READING, AND PROCESSING INFORMATION ON USERS' END DEVICES AND FOR PROCESSING SUCH INFORMATION; SERVICE PROVIDER: CONSENTMO LTD., PROF. GEORGI BRADISTILOV 4, ENTR. A, 4TH FLOOR, 112660079 SOFIA, BULGARIA; LEGAL BASIS: LEGITIMATE INTERESTS (ART. 6 PARA. 1 SENTENCE 1 LIT. F) GDPR); WEBSITE: HTTPS://WWW.CONSENTMO.COM/; PRIVACY POLICY: HTTPS://WWW.CONSENTMO.COM/PRIVACY-POLICY-TERMS-OF-SERVICE/DE. BASIS FOR THIRD-COUNTRY TRANSFER: EU-US DATA PRIVACY FRAMEWORK (DPF).

BUSINESS SERVICES

WE PROCESS DATA OF OUR CONTRACTUAL AND BUSINESS PARTNERS, E.G., CUSTOMERS AND INTERESTED PARTIES (COLLECTIVELY REFERRED TO AS "CONTRACTUAL PARTNERS") WITHIN THE SCOPE OF CONTRACTUAL AND COMPARABLE LEGAL RELATIONSHIPS AND ASSOCIATED MEASURES AND WITHIN THE SCOPE OF COMMUNICATION WITH THE CONTRACTUAL PARTNERS (OR PRE-CONTRACTUALLY), E.G., TO RESPOND TO INQUIRIES.

WE PROCESS THIS DATA TO FULFILL OUR CONTRACTUAL OBLIGATIONS. THESE INCLUDE, IN PARTICULAR, OBLIGATIONS TO PROVIDE THE AGREED SERVICES, ANY UPDATE OBLIGATIONS, AND REMEDIES IN THE EVENT OF WARRANTY AND OTHER SERVICE DISRUPTIONS. IN ADDITION, WE PROCESS THE DATA TO PROTECT OUR RIGHTS AND FOR THE PURPOSES OF ADMINISTRATIVE TASKS ASSOCIATED WITH THESE OBLIGATIONS AND FOR COMPANY ORGANIZATION. FURTHERMORE, WE PROCESS THE DATA ON THE BASIS OF OUR LEGITIMATE INTERESTS IN PROPER AND ECONOMICAL BUSINESS MANAGEMENT AND IN SECURITY MEASURES TO PROTECT OUR CONTRACTUAL PARTNERS AND OUR BUSINESS OPERATIONS FROM MISUSE, ENDANGERMENT OF THEIR DATA, SECRETS, INFORMATION, AND RIGHTS (E.G., FOR THE INVOLVEMENT OF TELECOMMUNICATIONS, TRANSPORT, AND OTHER AUXILIARY SERVICES, AS WELL AS SUBCONTRACTORS, BANKS, TAX AND LEGAL ADVISORS, PAYMENT SERVICE PROVIDERS, OR FINANCIAL AUTHORITIES). WITHIN THE SCOPE OF APPLICABLE LAW, WE ONLY PASS ON THE DATA OF CONTRACTUAL PARTNERS TO THIRD PARTIES TO THE EXTENT THAT THIS IS NECESSARY FOR THE AFOREMENTIONED PURPOSES OR TO FULFILL LEGAL OBLIGATIONS. CONTRACTUAL PARTNERS WILL BE INFORMED ABOUT FURTHER FORMS OF PROCESSING, E.G., FOR MARKETING PURPOSES, WITHIN THE SCOPE OF THIS PRIVACY POLICY.

WE WILL INFORM CONTRACTUAL PARTNERS OF THE DATA REQUIRED FOR THE AFOREMENTIONED PURPOSES BEFORE OR DURING DATA COLLECTION, E.G., IN ONLINE FORMS, BY MEANS OF SPECIAL MARKINGS (E.G., COLORS) OR SYMBOLS (E.G., ASTERISKS OR SIMILAR), OR IN PERSON.

WE DELETE THE DATA AFTER EXPIRY OF STATUTORY WARRANTY AND COMPARABLE OBLIGATIONS, I.E., GENERALLY AFTER 4 YEARS, UNLESS THE DATA IS STORED IN A CUSTOMER ACCOUNT, E.G., AS LONG AS IT MUST BE RETAINED FOR ARCHIVING PURPOSES FOR LEGAL REASONS. THE STATUTORY RETENTION PERIOD IS TEN YEARS FOR DOCUMENTS RELEVANT TO TAX LAW, AS WELL AS FOR COMMERCIAL BOOKS, INVENTORIES, OPENING BALANCE SHEETS, ANNUAL FINANCIAL STATEMENTS, WORK INSTRUCTIONS AND OTHER ORGANIZATIONAL DOCUMENTS AND ACCOUNTING DOCUMENTS NECESSARY FOR UNDERSTANDING THESE DOCUMENTS, AND SIX YEARS FOR COMMERCIAL AND BUSINESS LETTERS RECEIVED AND COPIES OF COMMERCIAL AND BUSINESS LETTERS SENT. THE PERIOD BEGINS AT THE END OF THE CALENDAR YEAR IN WHICH THE LAST ENTRY IN THE BOOK WAS MADE, THE INVENTORY, OPENING BALANCE SHEET, ANNUAL FINANCIAL STATEMENTS OR MANAGEMENT REPORT WAS PREPARED, THE COMMERCIAL OR BUSINESS LETTER WAS RECEIVED OR SENT, OR THE ACCOUNTING DOCUMENT WAS CREATED, OR THE RECORD WAS MADE OR THE OTHER DOCUMENTS WERE CREATED.

INSOFAR AS WE USE THIRD-PARTY PROVIDERS OR PLATFORMS TO PROVIDE OUR SERVICES, THE TERMS AND CONDITIONS AND PRIVACY POLICIES OF THE RESPECTIVE THIRD-PARTY PROVIDERS OR PLATFORMS APPLY IN THE RELATIONSHIP BETWEEN THE USERS AND THE PROVIDERS.

  • TYPES OF DATA PROCESSED: INVENTORY DATA (E.G., NAMES, ADDRESSES); PAYMENT DATA (E.G., BANK DETAILS, INVOICES, PAYMENT HISTORY); CONTACT DATA (E.G., EMAIL, 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, AND PROCESS DATA (E.G., IP ADDRESSES, TIME DATA, IDENTIFICATION NUMBERS, CONSENT STATUS).

  • DATA SUBJECTS: CUSTOMERS; INTERESTED PARTIES. BUSINESS AND CONTRACTUAL PARTNERS.

  • PURPOSES OF PROCESSING: PROVISION OF CONTRACTUAL SERVICES AND FULFILLMENT OF CONTRACTUAL OBLIGATIONS; SECURITY MEASURES; CONTACT REQUESTS AND COMMUNICATION; OFFICE AND ORGANIZATIONAL PROCEDURES. MANAGEMENT AND RESPONSE TO INQUIRIES.

  • LEGAL BASIS: CONTRACT FULFILLMENT AND PRE-CONTRACTUAL INQUIRIES (ART. 6 PARA. 1 SENTENCE 1 LIT. B) GDPR); LEGAL OBLIGATION (ART. 6 PARA. 1 SENTENCE 1 LIT. C) GDPR). LEGITIMATE INTERESTS (ART. 6 PARA. 1 SENTENCE 1 LIT. F) GDPR).

FURTHER INFORMATION ON PROCESSING PROCEDURES, PROCESSES, AND SERVICES:

  • CUSTOMER ACCOUNT: CUSTOMERS CAN CREATE AN ACCOUNT WITHIN OUR ONLINE OFFERING (E.G., CUSTOMER OR USER ACCOUNT, "CUSTOMER ACCOUNT" FOR SHORT). IF THE REGISTRATION OF A CUSTOMER ACCOUNT IS REQUIRED, CUSTOMERS WILL BE INFORMED OF THIS AND OF THE INFORMATION REQUIRED FOR REGISTRATION. CUSTOMER ACCOUNTS ARE NOT PUBLIC AND CANNOT BE INDEXED BY SEARCH ENGINES. DURING REGISTRATION AND SUBSEQUENT LOGINS AND USE OF THE CUSTOMER ACCOUNT, WE STORE THE IP ADDRESSES OF CUSTOMERS ALONG WITH THE TIMES OF ACCESS IN ORDER TO VERIFY REGISTRATION AND PREVENT ANY MISUSE OF THE CUSTOMER ACCOUNT. IF THE CUSTOMER ACCOUNT HAS BEEN TERMINATED, THE DATA IN THE CUSTOMER ACCOUNT WILL BE DELETED AFTER THE TERMINATION DATE, UNLESS IT IS STORED FOR PURPOSES OTHER THAN PROVISION IN THE CUSTOMER ACCOUNT OR MUST BE RETAINED FOR LEGAL REASONS (E.G., INTERNAL STORAGE OF CUSTOMER DATA, ORDER PROCESSES, OR INVOICES). IT IS THE RESPONSIBILITY OF CUSTOMERS TO BACK UP THEIR DATA WHEN TERMINATING THEIR CUSTOMER ACCOUNT; LEGAL BASIS: FULFILLMENT OF THE CONTRACT AND PRE-CONTRACTUAL INQUIRIES (ART. 6 PARA. 1 SENTENCE 1 LIT. B) GDPR).

  • ONLINE SHOP, ORDER FORMS, E-COMMERCE, AND DELIVERY: WE PROCESS OUR CUSTOMERS' DATA TO ENABLE THEM TO SELECT, PURCHASE, OR ORDER THE SELECTED PRODUCTS, GOODS, AND RELATED SERVICES, AS WELL AS TO ENABLE PAYMENT AND DELIVERY OR EXECUTION. IF NECESSARY FOR THE EXECUTION OF AN ORDER, WE USE SERVICE PROVIDERS, IN PARTICULAR POSTAL, SHIPPING, AND DELIVERY COMPANIES, TO CARRY OUT THE DELIVERY OR EXECUTION TO OUR CUSTOMERS. WE USE THE SERVICES OF BANKS AND PAYMENT SERVICE PROVIDERS TO PROCESS PAYMENT TRANSACTIONS. THE NECESSARY INFORMATION IS IDENTIFIED AS SUCH DURING THE ORDERING OR COMPARABLE PURCHASING PROCESS AND INCLUDES THE INFORMATION REQUIRED FOR DELIVERY OR PROVISION AND BILLING, AS WELL AS CONTACT INFORMATION SO THAT WE CAN CONSULT WITH YOU IF NECESSARY; LEGAL BASIS: FULFILLMENT OF THE CONTRACT AND PRE-CONTRACTUAL INQUIRIES (ART. 6 PARA. 1 SENTENCE 1 LIT. B) GDPR).

PROVIDERS AND SERVICES USED IN THE COURSE OF BUSINESS

WITHIN THE SCOPE OF OUR BUSINESS ACTIVITIES, WE USE ADDITIONAL SERVICES, PLATFORMS, INTERFACES, OR PLUG-INS FROM THIRD-PARTY PROVIDERS (HEREINAFTER REFERRED TO AS "SERVICES") IN COMPLIANCE WITH LEGAL REQUIREMENTS. THEIR USE IS BASED ON OUR INTERESTS IN THE PROPER, LAWFUL, AND ECONOMICAL MANAGEMENT OF OUR BUSINESS OPERATIONS AND INTERNAL ORGANIZATION.

  • TYPES OF DATA PROCESSED: INVENTORY DATA (E.G., NAMES, ADDRESSES); PAYMENT DATA (E.G., BANK DETAILS, INVOICES, PAYMENT HISTORY); CONTACT DETAILS (E.G., EMAIL, PHONE NUMBERS); CONTENT DATA (E.G., ENTRIES IN ONLINE FORMS); CONTRACT DATA (E.G., SUBJECT MATTER OF THE CONTRACT, TERM, CUSTOMER CATEGORY).

  • DATA SUBJECTS: CUSTOMERS; INTERESTED PARTIES; USERS (E.G., WEBSITE VISITORS, USERS OF ONLINE SERVICES). BUSINESS AND CONTRACTUAL PARTNERS.

  • PURPOSES OF PROCESSING: PROVISION OF CONTRACTUAL SERVICES AND FULFILLMENT OF CONTRACTUAL OBLIGATIONS. OFFICE AND ORGANIZATIONAL PROCEDURES.

  • LEGAL BASIS: LEGITIMATE INTERESTS (ART. 6 PARA. 1 SENTENCE 1 LIT. F) GDPR).

FURTHER INFORMATION ON PROCESSING OPERATIONS, PROCEDURES, AND SERVICES:

  • BILLBEE: ORDER PROCESSING, PAYMENT RECONCILIATION, INVENTORY MANAGEMENT, AND CUSTOMER DATA MANAGEMENT; SERVICE PROVIDER: BILLBEE GMBH, AROLSER STRASSE 10, 34477 TWISTETAL, GERMANY; LEGAL BASIS: LEGITIMATE INTERESTS (ART. 6 PARA. 1 SENTENCE 1 LIT. F) GDPR); WEBSITE: HTTPS://WWW.BILLBEE.IO/. PRIVACY POLICY: HTTPS://WWW.BILLBEE.IO/DATENSCHUTZ/.

PAYMENT PROCEDURES

WITHIN THE FRAMEWORK OF CONTRACTUAL AND OTHER LEGAL RELATIONSHIPS, BASED ON LEGAL OBLIGATIONS OR OTHERWISE ON THE BASIS OF OUR LEGITIMATE INTERESTS, WE OFFER THE DATA SUBJECTS EFFICIENT AND SECURE PAYMENT OPTIONS AND USE ADDITIONAL SERVICE PROVIDERS FOR THIS PURPOSE IN ADDITION TO BANKS AND CREDIT INSTITUTIONS (COLLECTIVELY REFERRED TO AS "PAYMENT SERVICE PROVIDERS").

THE DATA PROCESSED BY THE PAYMENT SERVICE PROVIDERS INCLUDES INVENTORY DATA, SUCH AS NAME AND ADDRESS, BANK DETAILS, SUCH AS ACCOUNT NUMBERS OR CREDIT CARD NUMBERS, PASSWORDS, TANS, AND CHECKSUMS, AS WELL AS CONTRACT, SUM, AND RECIPIENT-RELATED INFORMATION. THIS INFORMATION IS NECESSARY TO CARRY OUT THE TRANSACTIONS. HOWEVER, THE DATA ENTERED IS ONLY PROCESSED AND STORED BY THE PAYMENT SERVICE PROVIDERS. THIS MEANS THAT WE DO NOT RECEIVE ANY ACCOUNT OR CREDIT CARD INFORMATION, BUT ONLY INFORMATION CONFIRMING OR DENYING THE PAYMENT. UNDER CERTAIN CIRCUMSTANCES, THE DATA MAY BE TRANSFERRED BY THE PAYMENT SERVICE PROVIDERS TO CREDIT AGENCIES. THE PURPOSE OF THIS TRANSFER IS TO VERIFY IDENTITY AND CREDITWORTHINESS. IN THIS REGARD, WE REFER YOU TO THE TERMS AND CONDITIONS AND PRIVACY POLICY OF THE PAYMENT SERVICE PROVIDERS.

PAYMENT TRANSACTIONS ARE SUBJECT TO THE TERMS AND CONDITIONS AND PRIVACY POLICIES OF THE RESPECTIVE PAYMENT SERVICE PROVIDERS, WHICH CAN BE ACCESSED ON THEIR RESPECTIVE WEBSITES OR TRANSACTION APPLICATIONS. WE ALSO REFER YOU TO THESE FOR FURTHER INFORMATION AND TO ASSERT YOUR RIGHTS OF WITHDRAWAL, INFORMATION, AND OTHER RIGHTS AS A DATA SUBJECT.

  • 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, AND PROCESS DATA (E.G., IP ADDRESSES, TIME STAMPS, IDENTIFICATION NUMBERS, CONSENT STATUS); CONTACT DATA (E.G., EMAIL, TELEPHONE NUMBERS).

  • DATA SUBJECTS: CUSTOMERS. PROSPECTIVE CUSTOMERS.

  • PURPOSES OF PROCESSING: PROVISION OF CONTRACTUAL SERVICES AND FULFILLMENT OF CONTRACTUAL OBLIGATIONS.

  • LEGAL BASIS: CONTRACT FULFILLMENT AND PRE-CONTRACTUAL INQUIRIES (ART. 6 PARA. 1 SENTENCE 1 LIT. B) GDPR).

FURTHER INFORMATION ON PROCESSING PROCESSES, PROCEDURES, AND SERVICES:

PROVISION OF ONLINE SERVICES AND WEB HOSTING

WE PROCESS USER DATA IN ORDER TO PROVIDE THEM WITH OUR ONLINE SERVICES. FOR THIS PURPOSE, WE PROCESS THE USER'S IP ADDRESS, WHICH IS NECESSARY TO TRANSMIT THE CONTENT AND FUNCTIONS OF OUR ONLINE SERVICES TO THE USER'S BROWSER OR END DEVICE.

  • TYPES OF DATA PROCESSED: USAGE DATA (E.G., WEBSITES VISITED, INTEREST IN CONTENT, ACCESS TIMES); META, COMMUNICATION, AND PROCESS DATA (E.G., IP ADDRESSES, TIME STAMPS, IDENTIFICATION NUMBERS, CONSENT STATUS); INVENTORY DATA (E.G., NAMES, ADDRESSES); PAYMENT DATA (E.G., BANK DETAILS, INVOICES, PAYMENT HISTORY); CONTACT DATA (E.G., EMAIL, TELEPHONE NUMBERS); CONTRACT DATA (E.G., SUBJECT MATTER OF THE CONTRACT, TERM, CUSTOMER CATEGORY).

  • DATA SUBJECTS: USERS (E.G., WEBSITE VISITORS, USERS OF ONLINE SERVICES). CUSTOMERS.

  • PURPOSES OF PROCESSING: PROVISION OF OUR ONLINE OFFERING AND USER-FRIENDLINESS; IT INFRASTRUCTURE (OPERATION AND PROVISION OF INFORMATION SYSTEMS AND TECHNICAL EQUIPMENT (COMPUTERS, SERVERS, ETC.)); SECURITY MEASURES. PROVISION OF CONTRACTUAL SERVICES AND FULFILLMENT OF CONTRACTUAL OBLIGATIONS.

  • LEGAL BASIS: LEGITIMATE INTERESTS (ART. 6 PARA. 1 SENTENCE 1 LIT. F) GDPR).

FURTHER INFORMATION ON PROCESSING PROCESSES, PROCEDURES, AND SERVICES:

  • PROVISION OF ONLINE SERVICES ON RENTED STORAGE SPACE: TO PROVIDE OUR ONLINE SERVICES, WE USE STORAGE SPACE, COMPUTING CAPACITY, AND SOFTWARE THAT WE RENT OR OTHERWISE OBTAIN FROM AN APPROPRIATE SERVER PROVIDER (ALSO KNOWN AS A "WEB HOST"). LEGAL BASIS: LEGITIMATE INTERESTS (ART. 6 PARA. 1 SENTENCE 1 LIT. F) GDPR).

  • COLLECTION OF ACCESS DATA AND LOG FILES: ACCESS TO OUR ONLINE OFFERING IS LOGGED IN THE FORM OF 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. THE SERVER LOG FILES CAN BE USED FOR SECURITY PURPOSES, E.G., TO PREVENT SERVER OVERLOAD (ESPECIALLY IN THE CASE OF MALICIOUS ATTACKS, SO-CALLED DDOS ATTACKS) AND TO ENSURE SERVER CAPACITY AND STABILITY. LEGAL BASIS: LEGITIMATE INTERESTS (ART. 6 PARA. 1 SENTENCE 1 LIT. F) GDPR). DELETION OF DATA: LOG FILE INFORMATION IS STORED FOR A MAXIMUM PERIOD OF 30 DAYS AND THEN DELETED OR ANONYMIZED. DATA THAT MUST BE RETAINED FOR FURTHER STORAGE FOR EVIDENCE PURPOSES IS EXCLUDED FROM DELETION UNTIL THE RESPECTIVE INCIDENT HAS BEEN FINALLY CLARIFIED.

  • SHOPIFY: PLATFORM THROUGH WHICH E-COMMERCE SERVICES ARE OFFERED AND PERFORMED. THE SERVICES AND PROCESSES CARRIED OUT IN CONNECTION WITH THEM INCLUDE, IN PARTICULAR, ONLINE SHOPS, WEBSITES, THEIR OFFERS AND CONTENT, COMMUNITY ELEMENTS, PURCHASE AND PAYMENT PROCESSES, CUSTOMER COMMUNICATION, AND ANALYSIS AND MARKETING; SERVICE PROVIDER: SHOPIFY INTERNATIONAL LIMITED, VICTORIA BUILDINGS, 2ND FLOOR, 1-2 HADDINGTON ROAD, DUBLIN 4, D04 XN32, IRELAND; LEGAL BASIS: LEGITIMATE INTERESTS (ART. 6 PARA. 1 SENTENCE 1 LIT. F) GDPR); WEBSITE: HTTPS://WWW.SHOPIFY.COM/DE/. PRIVACY POLICY: HTTPS://WWW.SHOPIFY.COM/DE/LEGAL/DATENSCHUTZ.

REGISTRATION, LOGIN, AND USER ACCOUNT

USERS CAN CREATE A USER ACCOUNT. DURING REGISTRATION, USERS ARE INFORMED OF THE REQUIRED MANDATORY INFORMATION, WHICH IS PROCESSED FOR THE PURPOSE OF PROVIDING THE USER ACCOUNT ON THE BASIS OF CONTRACTUAL OBLIGATIONS. THE DATA PROCESSED INCLUDES, IN PARTICULAR, LOGIN INFORMATION (USER NAME, PASSWORD, AND EMAIL ADDRESS).

WHEN YOU USE OUR REGISTRATION AND LOGIN FUNCTIONS AND YOUR USER ACCOUNT, WE STORE YOUR IP ADDRESS AND THE TIME OF THE RESPECTIVE USER ACTION. THIS DATA IS STORED ON THE BASIS OF OUR LEGITIMATE INTERESTS AND THOSE OF THE USERS IN PROTECTING AGAINST MISUSE AND OTHER UNAUTHORIZED USE. THIS DATA WILL NOT BE PASSED ON TO THIRD PARTIES UNLESS IT IS NECESSARY TO PURSUE OUR CLAIMS OR THERE IS A LEGAL OBLIGATION TO DO SO.

USERS CAN BE INFORMED BY EMAIL ABOUT PROCESSES THAT ARE RELEVANT TO THEIR USER ACCOUNT, SUCH AS TECHNICAL CHANGES.

  • TYPES OF DATA PROCESSED: INVENTORY DATA (E.G., NAMES, ADDRESSES); CONTACT DATA (E.G., EMAIL, TELEPHONE NUMBERS); CONTENT DATA (E.G., ENTRIES IN ONLINE FORMS); META, COMMUNICATION, AND PROCESS DATA (E.G., IP ADDRESSES, TIME STAMPS, IDENTIFICATION NUMBERS, CONSENT STATUS).

  • DATA SUBJECTS: USERS (E.G., WEBSITE VISITORS, USERS OF ONLINE SERVICES).

  • PURPOSES OF PROCESSING: PROVISION OF CONTRACTUAL SERVICES AND FULFILLMENT OF CONTRACTUAL OBLIGATIONS; SECURITY MEASURES; MANAGEMENT AND RESPONSE TO INQUIRIES. PROVISION OF OUR ONLINE OFFERING AND USER-FRIENDLINESS.

  • LEGAL BASIS: CONTRACT FULFILLMENT AND PRE-CONTRACTUAL INQUIRIES (ART. 6 PARA. 1 SENTENCE 1 LIT. B) GDPR). LEGITIMATE INTERESTS (ART. 6 PARA. 1 SENTENCE 1 LIT. F) GDPR).

FURTHER INFORMATION ON PROCESSING OPERATIONS, PROCEDURES, AND SERVICES:

  • REGISTRATION WITH REAL NAMES: DUE TO THE NATURE OF OUR COMMUNITY, WE ASK USERS TO ONLY USE OUR SERVICES UNDER THEIR REAL NAMES. THIS MEANS THAT THE USE OF PSEUDONYMS IS NOT PERMITTED; LEGAL BASIS: FULFILLMENT OF CONTRACT AND PRE-CONTRACTUAL INQUIRIES (ART. 6 PARA. 1 SENTENCE 1 LIT. B) GDPR).

  • DELETION OF DATA AFTER TERMINATION: IF USERS HAVE TERMINATED THEIR USER ACCOUNT, THEIR DATA RELATING TO THE USER ACCOUNT WILL BE DELETED, SUBJECT TO LEGAL PERMISSION, OBLIGATION, OR CONSENT OF THE USERS; LEGAL BASIS: FULFILLMENT OF CONTRACT AND PRE-CONTRACTUAL INQUIRIES (ART. 6 PARA. 1 SENTENCE 1 LIT. B) GDPR).

  • NO OBLIGATION TO RETAIN DATA: IT IS THE RESPONSIBILITY OF USERS TO BACK UP THEIR DATA BEFORE THE END OF THE CONTRACT UPON TERMINATION. WE ARE ENTITLED TO IRRETRIEVABLY DELETE ALL USER DATA STORED DURING THE CONTRACT PERIOD; LEGAL BASIS: FULFILLMENT OF THE CONTRACT AND PRE-CONTRACTUAL INQUIRIES (ART. 6 PARA. 1 SENTENCE 1 LIT. B) GDPR).

CONTACT AND INQUIRY MANAGEMENT

WHEN YOU CONTACT US (E.G., BY MAIL, CONTACT FORM, EMAIL, TELEPHONE, OR VIA SOCIAL MEDIA) AND WITHIN THE SCOPE OF EXISTING USER AND BUSINESS RELATIONSHIPS, THE INFORMATION PROVIDED BY THE INQUIRING PERSONS WILL BE PROCESSED TO THE EXTENT NECESSARY TO RESPOND TO THE CONTACT INQUIRIES AND ANY REQUESTED MEASURES.

  • TYPES OF DATA PROCESSED: CONTACT DETAILS (E.G., EMAIL, TELEPHONE NUMBERS); CONTENT DATA (E.G., ENTRIES IN ONLINE FORMS); USAGE DATA (E.G., WEBSITES VISITED, INTEREST IN CONTENT, ACCESS TIMES); META, COMMUNICATION, AND PROCESS DATA (E.G., IP ADDRESSES, TIME STAMPS, IDENTIFICATION NUMBERS, CONSENT STATUS).

  • DATA SUBJECTS: COMMUNICATION PARTNERS.

  • PURPOSES OF PROCESSING: CONTACT REQUESTS AND COMMUNICATION; MANAGEMENT AND RESPONSE TO INQUIRIES; FEEDBACK (E.G., COLLECTION OF FEEDBACK VIA ONLINE FORM). PROVISION OF OUR ONLINE OFFERING AND USER-FRIENDLINESS.

  • LEGAL BASIS: LEGITIMATE INTERESTS (ART. 6 PARA. 1 SENTENCE 1 LIT. F) GDPR). CONTRACT FULFILLMENT AND PRE-CONTRACTUAL INQUIRIES (ART. 6 PARA. 1 SENTENCE 1 LIT. B) GDPR).

FURTHER INFORMATION ON PROCESSING OPERATIONS, PROCEDURES, AND SERVICES:

  • CONTACT FORM: IF USERS CONTACT US VIA OUR CONTACT FORM, EMAIL, OR OTHER COMMUNICATION CHANNELS, WE PROCESS THE DATA PROVIDED IN THIS CONTEXT TO PROCESS THE REQUEST. LEGAL BASIS: CONTRACT FULFILLMENT AND PRE-CONTRACTUAL INQUIRIES (ART. 6 PARA. 1 SENTENCE 1 LIT. B) GDPR), LEGITIMATE INTERESTS (ART. 6 PARA. 1 SENTENCE 1 LIT. F) GDPR).

NEWSLETTERS AND ELECTRONIC NOTIFICATIONS

WE SEND NEWSLETTERS, EMAILS, AND OTHER ELECTRONIC NOTIFICATIONS (HEREINAFTER REFERRED TO AS "NEWSLETTERS") ONLY WITH THE CONSENT OF THE RECIPIENT OR WITH LEGAL PERMISSION. IF THE CONTENT OF THE NEWSLETTER IS SPECIFICALLY DESCRIBED WHEN REGISTERING FOR THE NEWSLETTER, IT IS DECISIVE FOR THE CONSENT OF THE USER. OTHERWISE, OUR NEWSLETTERS CONTAIN INFORMATION ABOUT OUR SERVICES AND ABOUT US.

TO SUBSCRIBE TO OUR NEWSLETTERS, IT IS GENERALLY SUFFICIENT TO PROVIDE YOUR EMAIL ADDRESS. HOWEVER, WE MAY ASK YOU TO PROVIDE A NAME FOR PERSONALIZATION IN THE NEWSLETTER OR OTHER INFORMATION IF THIS IS NECESSARY FOR THE PURPOSES OF THE NEWSLETTER.

DOUBLE OPT-IN PROCEDURE: REGISTRATION FOR OUR NEWSLETTER IS ALWAYS CARRIED OUT USING A DOUBLE OPT-IN PROCEDURE. THIS MEANS THAT AFTER REGISTERING, YOU WILL RECEIVE AN EMAIL ASKING YOU TO CONFIRM YOUR REGISTRATION. THIS CONFIRMATION IS NECESSARY TO PREVENT ANYONE FROM REGISTERING WITH SOMEONE ELSE'S EMAIL ADDRESS. NEWSLETTER REGISTRATIONS ARE LOGGED IN ORDER TO BE ABLE TO PROVE THE REGISTRATION PROCESS IN ACCORDANCE WITH LEGAL REQUIREMENTS. THIS INCLUDES STORING THE TIME OF REGISTRATION AND CONFIRMATION AS WELL AS THE IP ADDRESS. ANY CHANGES TO YOUR DATA STORED BY THE MAILING SERVICE PROVIDER ARE ALSO LOGGED.

DELETION AND RESTRICTION OF PROCESSING: WE MAY STORE THE UNSUBSCRIBED EMAIL ADDRESSES FOR UP TO THREE YEARS BASED ON OUR LEGITIMATE INTERESTS BEFORE DELETING THEM IN ORDER TO BE ABLE TO PROVE THAT CONSENT WAS PREVIOUSLY GIVEN. 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 EVENT OF OBLIGATIONS TO PERMANENTLY COMPLY WITH OBJECTIONS, WE RESERVE THE RIGHT TO STORE THE EMAIL ADDRESS IN A BLOCK LIST (SO-CALLED "BLOCK LIST") FOR THIS PURPOSE ONLY.

THE REGISTRATION PROCESS IS LOGGED ON THE BASIS OF OUR LEGITIMATE INTERESTS FOR THE PURPOSE OF PROVING THAT IT HAS BEEN CARRIED OUT CORRECTLY. IF WE COMMISSION A SERVICE PROVIDER TO SEND EMAILS, THIS IS DONE ON THE BASIS OF OUR LEGITIMATE INTERESTS IN AN EFFICIENT AND SECURE MAILING SYSTEM.

CONTENTS:


INFORMATION ABOUT US, OUR SERVICES, PROMOTIONS, AND OFFERS.

  • TYPES OF DATA PROCESSED: INVENTORY DATA (E.G., NAMES, ADDRESSES); CONTACT DATA (E.G., EMAIL, TELEPHONE NUMBERS); META, COMMUNICATION, AND PROCESS DATA (E.G., IP ADDRESSES, TIME STAMPS, IDENTIFICATION NUMBERS, CONSENT STATUS); USAGE DATA (E.G., WEBSITES VISITED, INTEREST IN CONTENT, ACCESS TIMES).

  • DATA SUBJECTS: COMMUNICATION PARTNERS.

  • PURPOSES OF PROCESSING: DIRECT MARKETING (E.G., BY EMAIL OR POST).

  • LEGAL BASIS: CONSENT (ART. 6 PARA. 1 SENTENCE 1 LIT. A) GDPR).

  • RIGHT TO OBJECT (OPT-OUT): YOU CAN UNSUBSCRIBE FROM OUR NEWSLETTER AT ANY TIME, I.E. REVOKE YOUR CONSENT OR OBJECT TO FURTHER RECEIPT. YOU WILL FIND A LINK TO UNSUBSCRIBE FROM THE NEWSLETTER EITHER AT THE END OF EACH NEWSLETTER OR YOU CAN USE ONE OF THE CONTACT OPTIONS LISTED ABOVE, PREFERABLY EMAIL.

FURTHER INFORMATION ON PROCESSING, PROCEDURES, AND SERVICES:

  • MEASUREMENT OF OPENING AND CLICK RATES: THE NEWSLETTERS CONTAIN A SO-CALLED "WEB BEACON," I.E., A PIXEL-SIZED FILE THAT IS RETRIEVED FROM OUR SERVER OR, IF WE USE A MAILING SERVICE PROVIDER, FROM THEIR SERVER WHEN THE NEWSLETTER IS OPENED. DURING THIS RETRIEVAL, TECHNICAL INFORMATION SUCH AS INFORMATION ABOUT YOUR BROWSER AND YOUR SYSTEM, AS WELL AS YOUR IP ADDRESS AND THE TIME OF RETRIEVAL, IS COLLECTED. THIS INFORMATION IS USED TO IMPROVE OUR NEWSLETTER BASED ON TECHNICAL DATA OR THE TARGET GROUPS AND THEIR READING BEHAVIOR BASED ON THEIR LOCATION (WHICH CAN BE DETERMINED USING THE IP ADDRESS) OR THE ACCESS TIMES. THIS ANALYSIS ALSO INCLUDES DETERMINING WHETHER THE NEWSLETTERS ARE OPENED, WHEN THEY ARE OPENED, AND WHICH LINKS ARE CLICKED. THIS INFORMATION IS ASSIGNED TO THE INDIVIDUAL NEWSLETTER RECIPIENTS AND STORED IN THEIR PROFILES UNTIL THEY ARE DELETED. THE EVALUATIONS HELP US TO IDENTIFY THE READING HABITS OF OUR USERS AND TO ADAPT OUR CONTENT TO THEM OR TO SEND DIFFERENT CONTENT ACCORDING TO THE INTERESTS OF OUR USERS. THE MEASUREMENT OF OPENING RATES AND CLICK RATES, AS WELL AS THE STORAGE OF THE MEASUREMENT RESULTS IN THE USER PROFILES AND THEIR FURTHER PROCESSING, ARE BASED ON THE CONSENT OF THE USERS. UNFORTUNATELY, IT IS NOT POSSIBLE TO REVOKE THE PERFORMANCE MEASUREMENT SEPARATELY; IN THIS CASE, THE ENTIRE NEWSLETTER SUBSCRIPTION MUST BE CANCELED OR OBJECTED TO. IN THIS CASE, THE STORED PROFILE INFORMATION WILL BE DELETED; LEGAL BASIS: CONSENT (ART. 6 PARA. 1 SENTENCE 1 LIT. A) GDPR).

  • SENDING VIA SMS: ELECTRONIC NOTIFICATIONS CAN ALSO BE SENT AS SMS TEXT MESSAGES (OR WILL ONLY BE SENT VIA SMS IF THE AUTHORIZATION TO SEND, E.G., CONSENT, ONLY COVERS SENDING VIA SMS); LEGAL BASIS: CONSENT (ART. 6 PARA. 1 SENTENCE 1 LIT. A) GDPR).

ADVERTISING COMMUNICATION VIA EMAIL, POST, FAX, OR TELEPHONE

WE PROCESS PERSONAL DATA FOR THE PURPOSES OF ADVERTISING COMMUNICATION, WHICH MAY TAKE PLACE VIA VARIOUS CHANNELS, SUCH AS EMAIL, TELEPHONE, POST, OR FAX, IN ACCORDANCE WITH LEGAL REQUIREMENTS.

RECIPIENTS HAVE THE RIGHT TO REVOKE THEIR CONSENT AT ANY TIME OR TO OBJECT TO ADVERTISING COMMUNICATIONS AT ANY TIME.

AFTER REVOCATION OR OBJECTION, WE WILL STORE THE DATA NECESSARY TO PROVE THE PREVIOUS AUTHORIZATION FOR CONTACT OR SENDING FOR UP TO THREE YEARS AFTER THE END OF THE YEAR OF REVOCATION OR OBJECTION ON THE BASIS OF OUR LEGITIMATE INTERESTS. THE PROCESSING OF THIS DATA IS LIMITED TO THE PURPOSE OF A POSSIBLE DEFENSE AGAINST CLAIMS. ON THE BASIS OF THE LEGITIMATE INTEREST IN PERMANENTLY OBSERVING THE REVOCATION OR OBJECTION OF USERS, WE ALSO STORE THE DATA NECESSARY TO AVOID RENEWED CONTACT (E.G., DEPENDING ON THE COMMUNICATION CHANNEL, THE EMAIL ADDRESS, TELEPHONE NUMBER, NAME).

  • TYPES OF DATA PROCESSED: INVENTORY DATA (E.G., NAMES, ADDRESSES); CONTACT DETAILS (E.G., EMAIL, TELEPHONE NUMBERS).

  • DATA SUBJECTS: COMMUNICATION PARTNERS.

  • PURPOSES OF PROCESSING: DIRECT MARKETING (E.G., BY EMAIL OR POST).

  • LEGAL BASIS: CONSENT (ART. 6 PARA. 1 SENTENCE 1 LIT. A) GDPR). LEGITIMATE INTERESTS (ART. 6 PARA. 1 SENTENCE 1 LIT. F) GDPR).

WEB ANALYSIS, MONITORING, AND OPTIMIZATION

WEB ANALYSIS (ALSO KNOWN AS "REACH MEASUREMENT") IS USED TO EVALUATE THE VISITOR FLOWS OF OUR ONLINE OFFERING AND MAY INCLUDE BEHAVIOR, INTERESTS, OR DEMOGRAPHIC INFORMATION ABOUT VISITORS, SUCH AS AGE OR GENDER, AS PSEUDONYMOUS VALUES. WITH THE HELP OF REACH ANALYSIS, WE CAN, FOR EXAMPLE, IDENTIFY AT WHAT TIMES OUR ONLINE OFFERING OR ITS FUNCTIONS OR CONTENT ARE USED MOST FREQUENTLY OR INVITE REUSE. WE CAN ALSO IDENTIFY AREAS THAT REQUIRE OPTIMIZATION. 

IN ADDITION TO WEB ANALYSIS, WE MAY ALSO USE TEST PROCEDURES TO TEST AND OPTIMIZE DIFFERENT VERSIONS OF OUR ONLINE OFFERING OR ITS COMPONENTS, FOR EXAMPLE.

UNLESS OTHERWISE STATED BELOW, PROFILES, I.E., DATA SUMMARIZED FOR A USAGE PROCESS, MAY BE CREATED FOR THESE PURPOSES AND INFORMATION MAY BE STORED IN A BROWSER OR ON A DEVICE AND READ FROM IT. THE INFORMATION COLLECTED INCLUDES, IN PARTICULAR, WEBSITES VISITED AND ELEMENTS USED THERE, AS WELL AS TECHNICAL INFORMATION SUCH AS THE BROWSER USED, THE COMPUTER SYSTEM USED, AND INFORMATION ON USAGE TIMES. IF USERS HAVE CONSENTED TO THE COLLECTION OF THEIR LOCATION DATA BY US OR BY THE PROVIDERS OF THE SERVICES WE USE, LOCATION DATA MAY ALSO BE PROCESSED.

THE IP ADDRESSES OF USERS ARE ALSO STORED. HOWEVER, WE USE AN IP MASKING PROCEDURE (I.E., PSEUDONYMIZATION BY SHORTENING THE IP ADDRESS) TO PROTECT USERS. IN GENERAL, NO CLEAR DATA OF USERS (SUCH AS EMAIL ADDRESSES OR NAMES) IS STORED IN THE CONTEXT OF WEB ANALYSIS, A/B TESTING, AND OPTIMIZATION, BUT RATHER PSEUDONYMS. THIS MEANS THAT NEITHER WE NOR THE PROVIDERS OF THE SOFTWARE USED KNOW THE ACTUAL IDENTITY OF THE USERS, BUT ONLY THE INFORMATION STORED IN THEIR PROFILES FOR THE PURPOSES OF THE RESPECTIVE PROCEDURES.

  • TYPES OF DATA PROCESSED: USAGE DATA (E.G., WEBSITES VISITED, INTEREST IN CONTENT, ACCESS TIMES); META, COMMUNICATION, AND PROCESS DATA (E.G., IP ADDRESSES, TIME INFORMATION, IDENTIFICATION NUMBERS, CONSENT STATUS).

  • DATA SUBJECTS: USERS (E.G., WEBSITE VISITORS, USERS OF ONLINE SERVICES).

  • PURPOSES OF PROCESSING: REACH MEASUREMENT (E.G., ACCESS STATISTICS, RECOGNITION OF RETURNING VISITORS); PROFILES WITH USER-RELATED INFORMATION (CREATION OF USER PROFILES). PROVISION OF OUR ONLINE OFFERING AND USER-FRIENDLINESS.

  • SECURITY MEASURES: IP MASKING (PSEUDONYMIZATION OF THE IP ADDRESS).

  • LEGAL BASIS: CONSENT (ART. 6 PARA. 1 SENTENCE 1 LIT. A) GDPR).

FURTHER INFORMATION ON PROCESSING PROCEDURES, PROCESSES, AND SERVICES:

  • GOOGLE ANALYTICS: WE USE GOOGLE ANALYTICS TO MEASURE AND ANALYZE THE USE OF OUR ONLINE OFFERING BASED ON A PSEUDONYMOUS USER IDENTIFICATION NUMBER. THIS IDENTIFICATION NUMBER DOES NOT CONTAIN ANY UNIQUE DATA SUCH AS NAMES OR EMAIL ADDRESSES. IT IS USED TO ASSIGN ANALYSIS INFORMATION TO A DEVICE IN ORDER TO RECOGNIZE WHICH CONTENT USERS HAVE ACCESSED WITHIN ONE OR MORE USAGE SESSIONS, WHICH SEARCH TERMS THEY HAVE USED, WHICH CONTENT THEY HAVE ACCESSED AGAIN, OR HOW THEY HAVE INTERACTED WITH OUR ONLINE OFFERING. THE TIME OF USE AND DURATION OF USE ARE ALSO STORED, AS WELL AS THE SOURCES OF USERS WHO REFER TO OUR ONLINE OFFERING AND TECHNICAL ASPECTS OF THEIR END DEVICES AND BROWSERS. PSEUDONYMOUS USER PROFILES ARE CREATED USING INFORMATION FROM THE USE OF VARIOUS DEVICES, WHEREBY COOKIES MAY BE USED. GOOGLE ANALYTICS DOES NOT LOG OR STORE INDIVIDUAL IP ADDRESSES FOR EU USERS. HOWEVER, ANALYTICS PROVIDES ROUGH GEOGRAPHICAL LOCATION DATA BY DERIVING THE FOLLOWING METADATA FROM IP ADDRESSES: CITY (AND THE DERIVED LATITUDE AND LONGITUDE OF THE CITY), CONTINENT, COUNTRY, REGION, SUBCONTINENT (AND ID-BASED EQUIVALENTS). FOR EU DATA TRAFFIC, IP ADDRESS DATA IS USED EXCLUSIVELY FOR THIS DERIVATION OF GEOLOCATION DATA BEFORE BEING DELETED IMMEDIATELY. IT IS NOT LOGGED, IS NOT ACCESSIBLE, AND IS NOT USED FOR ANY OTHER PURPOSE. WHEN GOOGLE ANALYTICS COLLECTS MEASUREMENT DATA, ALL IP QUERIES ARE PERFORMED ON EU-BASED SERVERS BEFORE TRAFFIC IS FORWARDED TO ANALYTICS SERVERS FOR PROCESSING. SERVICE PROVIDER: GOOGLE IRELAND LIMITED, GORDON HOUSE, BARROW STREET, DUBLIN 4, IRELAND; LEGAL BASIS: CONSENT (ART. 6 PARA. 1 SENTENCE 1 LIT. A) GDPR); WEBSITE: HTTPS://MARKETINGPLATFORM.GOOGLE.COM/INTL/DE/ABOUT/ANALYTICS/; SECURITY MEASURES: IP MASKING (PSEUDONYMIZATION OF THE IP ADDRESS); PRIVACY POLICY: HTTPS://POLICIES.GOOGLE.COM/PRIVACY; DATA PROCESSING AGREEMENT: HTTPS://BUSINESS.SAFETY.GOOGLE/ADSPROCESSORTERMS/; BASIS FOR TRANSFER TO THIRD COUNTRIES: EU-US DATA PRIVACY FRAMEWORK (DPF), STANDARD CONTRACTUAL CLAUSES (HTTPS://BUSINESS.SAFETY.GOOGLE/ADSPROCESSORTERMS); OPT-OUT OPTION: OPT-OUT PLUGIN: HTTPS://TOOLS.GOOGLE.COM/DLPAGE/GAOPTOUT?HL=DE,  SETTINGS FOR THE DISPLAY OF ADVERTISING: HTTPS://MYADCENTER.GOOGLE.COM/PERSONALIZATIONOFF. FURTHER INFORMATION: HTTPS://BUSINESS.SAFETY.GOOGLE/ADSSERVICES/ (TYPES OF PROCESSING AND DATA PROCESSED).

ONLINE MARKETING

WE PROCESS PERSONAL DATA FOR ONLINE MARKETING PURPOSES, WHICH MAY INCLUDE, IN PARTICULAR, THE MARKETING OF ADVERTISING SPACE OR THE DISPLAY OF ADVERTISING AND OTHER CONTENT (COLLECTIVELY REFERRED TO AS "CONTENT") BASED ON THE POTENTIAL INTERESTS OF USERS AND THE MEASUREMENT OF ITS EFFECTIVENESS. 

FOR THESE PURPOSES, SO-CALLED USER PROFILES ARE CREATED AND STORED IN A FILE (A SO-CALLED "COOKIE") OR SIMILAR PROCEDURES ARE USED TO STORE INFORMATION ABOUT THE USER THAT IS RELEVANT FOR THE PRESENTATION OF THE AFOREMENTIONED CONTENT. 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 AND FUNCTIONS USED. 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 SHORTENING THE IP ADDRESS) TO PROTECT USERS. IN GENERAL, NO CLEAR DATA OF USERS (SUCH AS EMAIL ADDRESSES OR NAMES) IS STORED WITHIN THE SCOPE OF ONLINE MARKETING PROCEDURES, BUT RATHER PSEUDONYMS. THIS MEANS THAT NEITHER WE NOR THE PROVIDERS OF THE ONLINE MARKETING PROCEDURES 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 USING SIMILAR METHODS. THESE COOKIES CAN LATER BE READ ON OTHER WEBSITES THAT USE THE SAME ONLINE MARKETING PROCESS, ANALYZED FOR THE PURPOSE OF DISPLAYING CONTENT, SUPPLEMENTED WITH FURTHER DATA, AND STORED ON THE SERVER OF THE ONLINE MARKETING PROCESS PROVIDER.

IN EXCEPTIONAL CASES, CLEAR DATA MAY BE ASSIGNED TO THE PROFILES. THIS IS THE CASE IF, FOR EXAMPLE, USERS ARE MEMBERS OF A SOCIAL NETWORK WHOSE ONLINE MARKETING METHODS WE USE AND THE NETWORK LINKS THE USERS' PROFILES WITH THE AFOREMENTIONED INFORMATION. PLEASE NOTE THAT USERS MAY HAVE ADDITIONAL AGREEMENTS WITH THE PROVIDERS, E.G., THROUGH CONSENT GIVEN DURING REGISTRATION.

WE GENERALLY ONLY HAVE ACCESS TO AGGREGATED INFORMATION ABOUT THE SUCCESS OF OUR ADVERTISEMENTS. HOWEVER, WE CAN USE SO-CALLED CONVERSION MEASUREMENTS TO CHECK WHICH OF OUR ONLINE MARKETING METHODS HAVE LED TO A SO-CALLED CONVERSION, I.E., FOR EXAMPLE, TO THE CONCLUSION OF A CONTRACT WITH US. CONVERSION MEASUREMENT IS USED SOLELY TO ANALYZE THE SUCCESS OF OUR MARKETING MEASURES.

UNLESS OTHERWISE STATED, PLEASE ASSUME THAT COOKIES USED WILL BE STORED FOR A PERIOD OF TWO YEARS.

  • TYPES OF DATA PROCESSED: USAGE DATA (E.G., WEBSITES VISITED, INTEREST IN CONTENT, ACCESS TIMES); META, COMMUNICATION, AND PROCESS DATA (E.G., IP ADDRESSES, TIME STAMPS, IDENTIFICATION NUMBERS, CONSENT STATUS); EVENT DATA (FACEBOOK) ("EVENT DATA" IS DATA THAT CAN BE TRANSMITTED BY US TO FACEBOOK, E.G. VIA FACEBOOK PIXELS (VIA APPS OR OTHER MEANS), AND RELATES TO INDIVIDUALS OR THEIR ACTIONS; THIS DATA INCLUDES, FOR EXAMPLE, INFORMATION ABOUT VISITS TO WEBSITES, INTERACTIONS WITH CONTENT, FUNCTIONS, INSTALLATION OF APPS, PURCHASES OF PRODUCTS, ETC.; EVENT DATA IS PROCESSED FOR THE PURPOSE OF CREATING TARGET GROUPS FOR CONTENT AND ADVERTISING INFORMATION (CUSTOM AUDIENCES); EVENT DATA DOES NOT INCLUDE THE ACTUAL CONTENT (SUCH AS COMMENTS POSTED), LOGIN INFORMATION, OR CONTACT INFORMATION (I.E., NO NAMES, EMAIL ADDRESSES, OR PHONE NUMBERS). EVENT DATA IS DELETED BY FACEBOOK AFTER A MAXIMUM OF TWO YEARS, AND THE TARGET GROUPS CREATED FROM IT ARE DELETED WHEN OUR FACEBOOK ACCOUNT IS DELETED.

  • DATA SUBJECTS: USERS (E.G., WEBSITE VISITORS, USERS OF ONLINE SERVICES).

  • PURPOSES OF PROCESSING: REACH MEASUREMENT (E.G., ACCESS STATISTICS, RECOGNITION OF RETURNING VISITORS); TRACKING (E.G., INTEREST/BEHAVIOR-BASED PROFILING, USE OF COOKIES); MARKETING; PROFILES WITH USER-RELATED INFORMATION (CREATION OF USER PROFILES); CONVERSION MEASUREMENT (MEASUREMENT OF THE EFFECTIVENESS OF MARKETING MEASURES); TARGET GROUP FORMATION. PROVISION OF OUR ONLINE OFFERING AND USER-FRIENDLINESS.

  • SECURITY MEASURES: IP MASKING (PSEUDONYMIZATION OF THE IP ADDRESS).

  • LEGAL BASIS: CONSENT (ART. 6 PARA. 1 SENTENCE 1 LIT. A) GDPR).

  • RIGHT TO OBJECT (OPT-OUT): WE REFER YOU TO THE PRIVACY POLICIES OF THE RESPECTIVE PROVIDERS AND THE OPTIONS FOR OBJECTING (KNOWN AS "OPT-OUT") SPECIFIED BY THE PROVIDERS. IF NO EXPLICIT OPT-OUT OPTION HAS BEEN SPECIFIED, YOU MAY DISABLE COOKIES IN YOUR BROWSER SETTINGS. HOWEVER, THIS MAY RESTRICT THE FUNCTIONALITY OF OUR ONLINE OFFERING. WE THEREFORE RECOMMEND THE FOLLOWING ADDITIONAL OPT-OUT OPTIONS, WHICH ARE SUMMARIZED AND GROUPED BY REGION: A) EUROPE: HTTPS://WWW.YOURONLINECHOICES.EU. B) CANADA: HTTPS://WWW.YOURADCHOICES.CA/CHOICES. C) USA: HTTPS://WWW.ABOUTADS.INFO/CHOICES. D) CROSS-REGIONAL: HTTPS://OPTOUT.ABOUTADS.INFO.

FURTHER INFORMATION ON PROCESSING, PROCEDURES, AND SERVICES:

  • FACEBOOK ADVERTISEMENTS: PLACEMENT OF ADVERTISEMENTS WITHIN THE FACEBOOK PLATFORM AND EVALUATION OF THE ADVERTISING RESULTS; SERVICE PROVIDER: META PLATFORMS IRELAND LIMITED, MERRION ROAD, DUBLIN 4, D04 X2K5, IRELAND; LEGAL BASIS: CONSENT (ART. 6 PARA. 1 SENTENCE 1 LIT. A) GDPR); WEBSITE: HTTPS://WWW.FACEBOOK.COM; PRIVACY POLICY: HTTPS://WWW.FACEBOOK.COM/ABOUT/PRIVACY; BASIS FOR TRANSFER TO THIRD COUNTRIES: EU-US DATA PRIVACY FRAMEWORK (DPF); RIGHT TO OBJECT (OPT-OUT): WE REFER TO THE DATA PROTECTION AND ADVERTISING SETTINGS IN THE USER'S PROFILE ON THE FACEBOOK PLATFORMS AND TO FACEBOOK'S CONSENT PROCEDURE AND CONTACT OPTIONS FOR EXERCISING INFORMATION AND OTHER DATA SUBJECT RIGHTS, AS DESCRIBED IN FACEBOOK'S PRIVACY POLICY; FURTHER INFORMATION: EVENT DATA OF USERS, I.E., BEHAVIORAL AND INTEREST INFORMATION, IS PROCESSED FOR THE PURPOSES OF TARGETED ADVERTISING AND TARGET GROUP FORMATION ON THE BASIS OF THE JOINT RESPONSIBILITY AGREEMENT ("ADDENDUM FOR CONTROLLERS," HTTPS://WWW.FACEBOOK.COM/LEGAL/CONTROLLER_ADDENDUM). JOINT RESPONSIBILITY IS LIMITED TO THE COLLECTION AND TRANSFER OF DATA TO META PLATFORMS IRELAND LIMITED, A COMPANY BASED IN THE EU. FURTHER PROCESSING OF THE DATA IS THE SOLE RESPONSIBILITY OF META PLATFORMS IRELAND LIMITED, IN PARTICULAR WITH REGARD TO THE TRANSFER OF DATA TO THE PARENT COMPANY META PLATFORMS, INC. IN THE USA (BASED ON THE STANDARD CONTRACTUAL CLAUSES CONCLUDED BETWEEN META PLATFORMS IRELAND LIMITED AND META PLATFORMS, INC.).

  • INSTAGRAM ADVERTISEMENTS: PLACEMENT OF ADVERTISEMENTS WITHIN THE INSTAGRAM PLATFORM AND EVALUATION OF THE ADVERTISING RESULTS; SERVICE PROVIDER: META PLATFORMS IRELAND LIMITED, MERRION ROAD, DUBLIN 4, D04 X2K5, IRELAND; LEGAL BASIS: CONSENT (ART. 6 PARA. 1 SENTENCE 1 LIT. A) GDPR); WEBSITE: HTTPS://WWW.INSTAGRAM.COM; PRIVACY POLICY: HTTPS://INSTAGRAM.COM/ABOUT/LEGAL/PRIVACY; BASIS FOR TRANSFER TO THIRD COUNTRIES: EU-US DATA PRIVACY FRAMEWORK (DPF); RIGHT TO OBJECT (OPT-OUT): WE REFER TO THE DATA PROTECTION AND ADVERTISING SETTINGS IN THE USER'S PROFILE ON THE INSTAGRAM PLATFORM AND IN INSTAGRAM'S CONSENT PROCEDURE AND INSTAGRAM'S CONTACT OPTIONS FOR EXERCISING INFORMATION AND OTHER DATA SUBJECT RIGHTS IN INSTAGRAM'S PRIVACY POLICY; FURTHER INFORMATION: EVENT DATA OF USERS, I.E. BEHAVIORAL AND INTEREST INFORMATION, IS PROCESSED FOR THE PURPOSES OF TARGETED ADVERTISING AND TARGET GROUP FORMATION ON THE BASIS OF THE JOINT RESPONSIBILITY AGREEMENT ("ADDENDUM FOR CONTROLLERS," HTTPS://WWW.FACEBOOK.COM/LEGAL/CONTROLLER_ADDENDUM). JOINT RESPONSIBILITY IS LIMITED TO THE COLLECTION AND TRANSFER OF DATA TO META PLATFORMS IRELAND LIMITED, A COMPANY BASED IN THE EU. FURTHER PROCESSING OF THE DATA IS THE SOLE RESPONSIBILITY OF META PLATFORMS IRELAND LIMITED, IN PARTICULAR WITH REGARD TO THE TRANSFER OF DATA TO THE PARENT COMPANY META PLATFORMS, INC. IN THE USA (BASED ON THE STANDARD CONTRACTUAL CLAUSES CONCLUDED BETWEEN META PLATFORMS IRELAND LIMITED AND META PLATFORMS, INC.).

PRESENCE ON SOCIAL NETWORKS (SOCIAL MEDIA)

WE MAINTAIN ONLINE PRESENCES WITHIN SOCIAL NETWORKS AND PROCESS USER DATA IN THIS CONTEXT IN ORDER TO COMMUNICATE WITH USERS ACTIVE THERE OR TO PROVIDE INFORMATION ABOUT US.

WE WOULD LIKE TO POINT OUT THAT USER DATA MAY BE PROCESSED OUTSIDE THE EUROPEAN UNION. THIS MAY ENTAIL RISKS FOR USERS, AS IT COULD, FOR EXAMPLE, MAKE IT MORE DIFFICULT TO ENFORCE THEIR RIGHTS.

FURTHERMORE, USER DATA WITHIN SOCIAL NETWORKS IS GENERALLY PROCESSED FOR MARKET RESEARCH AND ADVERTISING PURPOSES. FOR EXAMPLE, USAGE PROFILES CAN BE CREATED BASED ON THE USAGE BEHAVIOR AND RESULTING INTERESTS OF USERS. THE USAGE PROFILES CAN IN TURN BE USED, FOR EXAMPLE, TO PLACE ADVERTISEMENTS WITHIN AND OUTSIDE THE NETWORKS THAT ARE LIKELY TO CORRESPOND TO THE INTERESTS OF USERS. FOR THESE PURPOSES, COOKIES ARE USUALLY STORED ON THE USERS' COMPUTERS, IN WHICH THE USAGE BEHAVIOR AND INTERESTS OF THE USERS ARE STORED. FURTHERMORE, DATA MAY ALSO BE STORED IN THE USAGE PROFILES INDEPENDENTLY OF THE DEVICES USED BY THE USERS (IN PARTICULAR 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 OPTIONS FOR OBJECTION (OPT-OUT), WE REFER TO THE PRIVACY POLICIES AND INFORMATION PROVIDED BY THE OPERATORS OF THE RESPECTIVE NETWORKS.

IN THE EVENT OF REQUESTS FOR INFORMATION AND THE ASSERTION OF DATA SUBJECT RIGHTS, WE WOULD ALSO LIKE TO POINT OUT THAT THESE CAN BE MOST EFFECTIVELY ASSERTED WITH THE PROVIDERS. ONLY THE PROVIDERS HAVE ACCESS TO THE USER DATA AND CAN TAKE APPROPRIATE MEASURES AND PROVIDE INFORMATION DIRECTLY. HOWEVER, IF YOU REQUIRE ASSISTANCE, PLEASE CONTACT US.

  • TYPES OF DATA PROCESSED: CONTACT DATA (E.G., EMAIL, TELEPHONE NUMBERS); CONTENT DATA (E.G., ENTRIES IN ONLINE FORMS); USAGE DATA (E.G., WEBSITES VISITED, INTEREST IN CONTENT, ACCESS TIMES); META, COMMUNICATION, AND PROCESS DATA (E.G., IP ADDRESSES, TIME INFORMATION, IDENTIFICATION NUMBERS, CONSENT STATUS).

  • DATA SUBJECTS: USERS (E.G., WEBSITE VISITORS, USERS OF ONLINE SERVICES).

  • PURPOSES OF PROCESSING: CONTACT REQUESTS AND COMMUNICATION; FEEDBACK (E.G., COLLECTION OF FEEDBACK VIA ONLINE FORM). MARKETING.

  • LEGAL BASIS: LEGITIMATE INTERESTS (ART. 6 PARA. 1 SENTENCE 1 LIT. F) GDPR).

FURTHER INFORMATION ON PROCESSING PROCEDURES, METHODS, AND SERVICES:

  • INSTAGRAM: SOCIAL NETWORK; SERVICE PROVIDER: META PLATFORMS IRELAND LIMITED, MERRION ROAD, DUBLIN 4, D04 X2K5, IRELAND; LEGAL BASIS: LEGITIMATE INTERESTS (ART. 6 (1) (F) GDPR); WEBSITE: HTTPS://WWW.INSTAGRAM.COM; PRIVACY POLICY: HTTPS://INSTAGRAM.COM/ABOUT/LEGAL/PRIVACY. BASIS FOR TRANSFER TO THIRD COUNTRIES: EU-US DATA PRIVACY FRAMEWORK (DPF).

  • FACEBOOK PAGES: PROFILES WITHIN THE FACEBOOK SOCIAL NETWORK; SERVICE PROVIDER: META PLATFORMS IRELAND LIMITED, MERRION ROAD, DUBLIN 4, D04 X2K5, IRELAND; LEGAL BASIS: LEGITIMATE INTERESTS (ART. 6 (1) (1) (F) GDPR); WEBSITE: HTTPS://WWW.FACEBOOK.COM; PRIVACY POLICY: HTTPS://WWW.FACEBOOK.COM/ABOUT/PRIVACY; BASIS FOR TRANSFER TO THIRD COUNTRIES: EU-US DATA PRIVACY FRAMEWORK (DPF), STANDARD CONTRACTUAL CLAUSES (HTTPS://WWW.FACEBOOK.COM/LEGAL/EU_DATA_TRANSFER_ADDENDUM); FURTHER INFORMATION: TOGETHER WITH META PLATFORMS IRELAND LIMITED, WE ARE RESPONSIBLE FOR THE COLLECTION (BUT NOT THE FURTHER PROCESSING) OF DATA FROM VISITORS TO OUR FACEBOOK PAGE (KNOWN AS A "FAN PAGE"). THIS DATA INCLUDES INFORMATION ABOUT THE TYPES OF CONTENT USERS VIEW OR INTERACT WITH, OR THE ACTIONS THEY TAKE (SEE "THINGS YOU AND OTHERS DO AND PROVIDE" IN THE FACEBOOK DATA POLICY: HTTPS://WWW.FACEBOOK.COM/POLICY), AS WELL AS INFORMATION ABOUT THE DEVICES USED BY USERS (E.G., IP ADDRESSES, OPERATING SYSTEM, BROWSER TYPE, LANGUAGE SETTINGS, COOKIE DATA; SEE "DEVICE INFORMATION" IN THE FACEBOOK DATA POLICY: HTTPS://WWW.FACEBOOK.COM/POLICY). AS EXPLAINED IN THE FACEBOOK DATA POLICY UNDER "HOW DO WE USE THIS INFORMATION?", FACEBOOK ALSO COLLECTS AND USES INFORMATION TO PROVIDE ANALYTICS SERVICES, KNOWN AS "PAGE INSIGHTS," TO PAGE OPERATORS SO THAT THEY CAN GAIN INSIGHTS INTO HOW PEOPLE INTERACT WITH THEIR PAGES AND THE CONTENT ASSOCIATED WITH THEM. WE HAVE ENTERED INTO A SPECIAL AGREEMENT WITH FACEBOOK ("PAGE INSIGHTS INFORMATION," HTTPS://WWW.FACEBOOK.COM/LEGAL/TERMS/PAGE_CONTROLLER_ADDENDUM), WHICH SPECIFICALLY REGULATES THE SECURITY MEASURES FACEBOOK MUST OBSERVE AND IN WHICH FACEBOOK HAS AGREED TO COMPLY WITH THE RIGHTS OF DATA SUBJECTS (I.E., USERS CAN, FOR EXAMPLE, SUBMIT REQUESTS FOR INFORMATION OR DELETION DIRECTLY TO FACEBOOK). THE RIGHTS OF USERS (IN PARTICULAR THE RIGHT TO INFORMATION, DELETION, OBJECTION, AND COMPLAINT TO THE COMPETENT SUPERVISORY AUTHORITY) ARE NOT RESTRICTED BY THE AGREEMENTS WITH FACEBOOK. FURTHER INFORMATION CAN BE FOUND IN THE "PAGE INSIGHTS INFORMATION" (HTTPS://WWW.FACEBOOK.COM/LEGAL/TERMS/INFORMATION_ABOUT_PAGE_INSIGHTS_DATA). JOINT RESPONSIBILITY IS LIMITED TO THE COLLECTION AND TRANSFER OF DATA TO META PLATFORMS IRELAND LIMITED, A COMPANY BASED IN THE EU. FURTHER PROCESSING OF THE DATA IS THE SOLE RESPONSIBILITY OF META PLATFORMS IRELAND LIMITED, WHICH IN PARTICULAR CONCERNS THE TRANSFER OF DATA TO THE PARENT COMPANY META PLATFORMS, INC. IN THE USA.

  • LINKEDIN: SOCIAL NETWORK; SERVICE PROVIDER: LINKEDIN IRELAND UNLIMITED COMPANY, WILTON PLACE, DUBLIN 2, IRELAND; LEGAL BASIS: LEGITIMATE INTERESTS (ART. 6 (1) (F) GDPR); WEBSITE: HTTPS://WWW.LINKEDIN.COM; PRIVACY POLICY: HTTPS://WWW.LINKEDIN.COM/LEGAL/PRIVACY-POLICY; BASIS FOR TRANSFER TO THIRD COUNTRIES: EU-US DATA PRIVACY FRAMEWORK (DPF), STANDARD CONTRACTUAL CLAUSES (HTTPS://LEGAL.LINKEDIN.COM/DPA); RIGHT TO OBJECT (OPT-OUT): HTTPS://WWW.LINKEDIN.COM/PSETTINGS/GUEST-CONTROLS/RETARGETING-OPT-OUT; FURTHER INFORMATION: TOGETHER WITH LINKEDIN IRELAND UNLIMITED COMPANY, WE ARE RESPONSIBLE FOR THE COLLECTION (BUT NOT THE FURTHER PROCESSING) OF VISITOR DATA FOR THE PURPOSE OF CREATING "PAGE INSIGHTS" (STATISTICS) FOR OUR LINKEDIN PROFILES. THIS DATA INCLUDES INFORMATION ABOUT THE TYPES OF CONTENT THAT USERS VIEW OR INTERACT WITH, OR THE ACTIONS THEY TAKE, AS WELL AS INFORMATION ABOUT THE DEVICES USED BY USERS (E.G., IP ADDRESSES, OPERATING SYSTEM, BROWSER TYPE, LANGUAGE SETTINGS, COOKIE DATA) AND INFORMATION FROM USERS' PROFILES, SUCH AS JOB TITLE, COUNTRY, INDUSTRY, HIERARCHY LEVEL, COMPANY SIZE, AND EMPLOYMENT STATUS. INFORMATION ON DATA PROTECTION FOR THE PROCESSING OF USER DATA BY LINKEDIN CAN BE FOUND IN LINKEDIN'S PRIVACY POLICY: HTTPS://WWW.LINKEDIN.COM/LEGAL/PRIVACY-POLICY WE HAVE ENTERED INTO A SPECIAL AGREEMENT WITH LINKEDIN IRELAND ("PAGE INSIGHTS JOINT CONTROLLER ADDENDUM (THE 'ADDENDUM')", HTTPS://LEGAL.LINKEDIN.COM/PAGES-JOINT-CONTROLLER-ADDENDUM), WHICH SPECIFICALLY REGULATES THE SECURITY MEASURES THAT LINKEDIN MUST OBSERVE AND IN WHICH LINKEDIN HAS AGREED TO COMPLY WITH THE RIGHTS OF DATA SUBJECTS (I.E., USERS CAN, FOR EXAMPLE, SUBMIT REQUESTS FOR INFORMATION OR DELETION DIRECTLY TO LINKEDIN). THE RIGHTS OF USERS (IN PARTICULAR THE RIGHT TO INFORMATION, DELETION, OBJECTION, AND COMPLAINT TO THE COMPETENT SUPERVISORY AUTHORITY) ARE NOT RESTRICTED BY THE AGREEMENTS WITH LINKEDIN. JOINT RESPONSIBILITY IS LIMITED TO THE COLLECTION OF DATA BY AND TRANSFER TO IRELAND UNLIMITED COMPANY, A COMPANY BASED IN THE EU. FURTHER PROCESSING OF THE DATA IS THE SOLE RESPONSIBILITY OF IRELAND UNLIMITED COMPANY, WHICH IN PARTICULAR CONCERNS THE TRANSFER OF DATA TO THE PARENT COMPANY LINKEDIN CORPORATION IN THE USA.

  • PINTEREST: SOCIAL NETWORK; SERVICE PROVIDER: PINTEREST EUROPE LIMITED, 2ND FLOOR, PALMERSTON HOUSE, FENIAN STREET, DUBLIN 2, IRELAND; LEGAL BASIS: LEGITIMATE INTERESTS (ART. 6 PARA. 1 SENTENCE 1 LIT. F) GDPR); WEBSITE: HTTPS://WWW.PINTEREST.COM. PRIVACY POLICY: HTTPS://POLICY.PINTEREST.COM/DE/PRIVACY-POLICY.

  • SNAPCHAT: SOCIAL NETWORK; SERVICE PROVIDER: SNAP INC., 3000 31ST STREET, SANTA MONICA, CALIFORNIA 90405 USA; LEGAL BASIS: LEGITIMATE INTERESTS (ART. 6 PARA. 1 SENTENCE 1 LIT. F) GDPR); WEBSITE: HTTPS://WWW.SNAPCHAT.COM/; PRIVACY POLICY: HTTPS://WWW.SNAP.COM/DE-DE/PRIVACY/PRIVACY-POLICY. BASIS FOR TRANSFER TO THIRD COUNTRIES: STANDARD CONTRACTUAL CLAUSES (HTTPS://WWW.SNAP.COM/EN-US/TERMS/STANDARD-CONTRACTUAL-CLAUSES).

  • TIKTOK: SOCIAL NETWORK/VIDEO PLATFORM; SERVICE PROVIDER: TIKTOK TECHNOLOGY LIMITED, 10 EARLSFORT TERRACE, DUBLIN, D02 T380, IRELAND, AND TIKTOK INFORMATION TECHNOLOGIES UK LIMITED, KALEIDOSCOPE, 4 LINDSEY STREET, LONDON, UNITED KINGDOM, EC1A 9HP; LEGAL BASIS: LEGITIMATE INTERESTS (ART. 6 PARA. 1 SENTENCE 1 LIT. F) GDPR); WEBSITE: HTTPS://WWW.TIKTOK.COM. PRIVACY POLICY: HTTPS://WWW.TIKTOK.COM/DE/PRIVACY-POLICY.

  • X: SOCIAL NETWORK; SERVICE PROVIDER: TWITTER INTERNATIONAL COMPANY, ONE CUMBERLAND PLACE, FENIAN STREET, DUBLIN 2 D02 AX07, IRELAND; LEGAL BASIS: LEGITIMATE INTERESTS (ART. 6 PARA. 1 SENTENCE 1 LIT. F) GDPR). PRIVACY POLICY: HTTPS://TWITTER.COM/PRIVACY, (SETTINGS: HTTPS://TWITTER.COM/PERSONALIZATION).

  • YOUTUBE: SOCIAL NETWORK AND VIDEO PLATFORM; SERVICE PROVIDER: GOOGLE IRELAND LIMITED, GORDON HOUSE, BARROW STREET, DUBLIN 4, IRELAND; LEGAL BASIS: LEGITIMATE INTERESTS (ART. 6 PARA. 1 SENTENCE 1 LIT. F) GDPR); PRIVACY POLICY: HTTPS://POLICIES.GOOGLE.COM/PRIVACY; BASIS FOR TRANSFER TO THIRD COUNTRIES: EU-US DATA PRIVACY FRAMEWORK (DPF). OPT-OUT OPTION: HTTPS://MYADCENTER.GOOGLE.COM/PERSONALIZATIONOFF.

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 BE GRAPHICS, VIDEOS, OR CITY MAPS (HEREINAFTER REFERRED TO UNIFORMLY AS "CONTENT").

THE INTEGRATION ALWAYS REQUIRES 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 TO DISPLAY THIS CONTENT OR THESE FUNCTIONS. WE ENDEAVOR TO USE ONLY 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. PIXEL TAGS CAN BE USED TO EVALUATE INFORMATION SUCH AS VISITOR TRAFFIC ON THE PAGES OF THIS WEBSITE. THE PSEUDONYMOUS INFORMATION MAY ALSO BE STORED IN COOKIES ON THE USER'S DEVICE AND MAY INCLUDE TECHNICAL INFORMATION ABOUT THE BROWSER AND OPERATING SYSTEM, REFERRING WEBSITES, TIME OF VISIT, AND OTHER INFORMATION ABOUT THE USE OF OUR ONLINE OFFERING, AND MAY BE LINKED TO SUCH INFORMATION FROM OTHER SOURCES.

  • TYPES OF DATA PROCESSED: USAGE DATA (E.G., WEBSITES VISITED, INTEREST IN CONTENT, ACCESS TIMES); META, COMMUNICATION, AND PROCESS DATA (E.G., IP ADDRESSES, TIME STAMPS, IDENTIFICATION NUMBERS, CONSENT STATUS); INVENTORY DATA (E.G., NAMES, ADDRESSES); CONTACT DATA (E.G., EMAIL, TELEPHONE NUMBERS); CONTENT DATA (E.G., ENTRIES IN ONLINE FORMS); EVENT DATA (FACEBOOK) ("EVENT DATA" IS DATA THAT CAN BE TRANSMITTED BY US TO FACEBOOK, E.G., VIA FACEBOOK PIXELS (VIA APPS OR OTHER MEANS), AND RELATES TO INDIVIDUALS OR THEIR ACTIONS; THIS DATA INCLUDES, FOR EXAMPLE, INFORMATION ABOUT VISITS TO WEBSITES, INTERACTIONS WITH CONTENT, FUNCTIONS, INSTALLATION OF APPS, PURCHASES OF PRODUCTS, ETC.; THE EVENT DATA IS PROCESSED FOR THE PURPOSE OF FORMING TARGET GROUPS FOR CONTENT AND ADVERTISING INFORMATION (CUSTOM AUDIENCES); EVENT DATA DOES NOT INCLUDE THE ACTUAL CONTENT (SUCH AS COMMENTS POSTED), LOGIN INFORMATION, OR CONTACT INFORMATION (I.E., NO NAMES, EMAIL ADDRESSES, OR PHONE NUMBERS). EVENT DATA IS DELETED BY FACEBOOK AFTER A MAXIMUM OF TWO YEARS, AND THE TARGET GROUPS CREATED FROM IT ARE DELETED WHEN WE DELETE OUR FACEBOOK ACCOUNT.

  • DATA SUBJECTS: USERS (E.G., WEBSITE VISITORS, USERS OF ONLINE SERVICES).

  • PURPOSES OF PROCESSING: PROVISION OF OUR ONLINE OFFERING AND USER-FRIENDLINESS; MARKETING. PROFILES WITH USER-RELATED INFORMATION (CREATION OF USER PROFILES).

  • LEGAL BASIS: CONSENT (ART. 6 PARA. 1 SENTENCE 1 LIT. A) GDPR). LEGITIMATE INTERESTS (ART. 6 PARA. 1 SENTENCE 1 LIT. F) GDPR).

FURTHER INFORMATION ON PROCESSING PROCESSES, PROCEDURES, AND SERVICES:

  • FACEBOOK PLUGINS AND CONTENT: FACEBOOK SOCIAL PLUGINS AND CONTENT – THIS MAY INCLUDE CONTENT SUCH AS IMAGES, VIDEOS, OR TEXT AND BUTTONS THAT ALLOW USERS TO SHARE CONTENT FROM THIS ONLINE OFFERING WITHIN FACEBOOK. THE LIST AND APPEARANCE OF FACEBOOK SOCIAL PLUGINS CAN BE VIEWED HERE: HTTPS://DEVELOPERS.FACEBOOK.COM/DOCS/PLUGINS/ - TOGETHER WITH META PLATFORMS IRELAND LIMITED, WE ARE JOINTLY RESPONSIBLE FOR THE COLLECTION OR RECEIPT IN THE CONTEXT OF A TRANSFER (BUT NOT THE FURTHER PROCESSING) OF "EVENT DATA" THAT FACEBOOK COLLECTS OR RECEIVES IN THE CONTEXT OF A TRANSFER FOR THE FOLLOWING PURPOSES USING THE FACEBOOK SOCIAL PLUGINS (AND CONTENT EMBEDDING FUNCTIONS) THAT ARE EXECUTED ON OUR ONLINE OFFERING:  A) DISPLAYING CONTENT AND ADVERTISING INFORMATION THAT CORRESPONDS TO THE PRESUMED INTERESTS OF USERS; B) DELIVERING COMMERCIAL AND TRANSACTION-RELATED MESSAGES (E.G., CONTACTING 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 BE OF INTEREST TO USERS). WE HAVE ENTERED INTO A SPECIAL AGREEMENT WITH FACEBOOK ("ADDENDUM FOR CONTROLLERS," HTTPS://WWW.FACEBOOK.COM/LEGAL/CONTROLLER_ADDENDUM), WHICH SPECIFICALLY REGULATES THE SECURITY MEASURES FACEBOOK MUST OBSERVE (HTTPS://WWW.FACEBOOK.COM/LEGAL/TERMS/DATA_SECURITY_TERMS) AND IN WHICH FACEBOOK HAS AGREED TO COMPLY WITH THE RIGHTS OF DATA SUBJECTS (I.E., USERS CAN, FOR EXAMPLE, SUBMIT INFORMATION OR DELETION REQUESTS DIRECTLY TO FACEBOOK). NOTE: IF FACEBOOK PROVIDES US WITH METRICS, ANALYTICS, AND REPORTS (WHICH ARE AGGREGATED, I.E., DO NOT CONTAIN ANY INFORMATION ABOUT INDIVIDUAL USERS AND ARE ANONYMOUS TO US), THIS PROCESSING IS NOT CARRIED OUT WITHIN THE SCOPE OF JOINT RESPONSIBILITY, BUT ON THE BASIS OF A DATA PROCESSING AGREEMENT ("DATA PROCESSING TERMS," HTTPS://WWW.FACEBOOK.COM/LEGAL/TERMS/DATAPROCESSING) , THE "DATA SECURITY TERMS" (HTTPS://WWW.FACEBOOK.COM/LEGAL/TERMS/DATA_SECURITY_TERMS) AND, 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 THE RIGHT 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, MERRION ROAD, DUBLIN 4, D04 X2K5, IRELAND; LEGAL BASIS: CONSENT (ART. 6 PARA. 1 SENTENCE 1 LIT. A) GDPR); WEBSITE: HTTPS://WWW.FACEBOOK.COM; PRIVACY POLICY: HTTPS://WWW.FACEBOOK.COM/PRIVACY/POLICY/. BASIS FOR THIRD COUNTRY TRANSFER: EU-US DATA PRIVACY FRAMEWORK (DPF).

  • INSTAGRAM PLUGINS AND CONTENT: INSTAGRAM PLUGINS AND CONTENT - THIS MAY INCLUDE CONTENT SUCH AS IMAGES, VIDEOS, OR TEXT AND BUTTONS THAT ALLOW USERS TO SHARE CONTENT FROM THIS ONLINE OFFERING WITHIN INSTAGRAM. - TOGETHER WITH META PLATFORMS IRELAND LIMITED, WE ARE JOINTLY RESPONSIBLE FOR THE COLLECTION OR RECEIPT IN THE CONTEXT OF A TRANSFER (BUT NOT THE FURTHER PROCESSING) OF "EVENT DATA" THAT FACEBOOK COLLECTS OR RECEIVES IN THE CONTEXT OF A TRANSFER FOR THE FOLLOWING PURPOSES USING INSTAGRAM FEATURES (E.G., CONTENT EMBEDDING FEATURES) THAT ARE EXECUTED ON OUR ONLINE OFFERING:  A) DISPLAYING CONTENT AND ADVERTISING INFORMATION THAT CORRESPONDS TO THE PRESUMED INTERESTS OF USERS; B) DELIVERING COMMERCIAL AND TRANSACTION-RELATED MESSAGES (E.G., CONTACTING 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 CORRESPOND TO THE INTERESTS OF USERS). WE HAVE ENTERED INTO A SPECIAL AGREEMENT WITH FACEBOOK ("ADDENDUM FOR CONTROLLERS," HTTPS://WWW.FACEBOOK.COM/LEGAL/CONTROLLER_ADDENDUM), WHICH SPECIFICALLY REGULATES THE SECURITY MEASURES FACEBOOK MUST OBSERVE (HTTPS://WWW.FACEBOOK.COM/LEGAL/TERMS/DATA_SECURITY_TERMS) AND IN WHICH FACEBOOK HAS AGREED TO COMPLY WITH THE RIGHTS OF DATA SUBJECTS (I.E., USERS CAN, FOR EXAMPLE, SUBMIT INFORMATION OR DELETION REQUESTS DIRECTLY TO FACEBOOK). NOTE: IF FACEBOOK PROVIDES US WITH METRICS, ANALYTICS, AND REPORTS (WHICH ARE AGGREGATED, I.E., DO NOT CONTAIN ANY INFORMATION ABOUT INDIVIDUAL USERS AND ARE ANONYMOUS TO US), THIS PROCESSING IS NOT CARRIED OUT WITHIN THE SCOPE OF JOINT RESPONSIBILITY, BUT ON THE BASIS OF A DATA PROCESSING AGREEMENT ("DATA PROCESSING TERMS," HTTPS://WWW.FACEBOOK.COM/LEGAL/TERMS/DATAPROCESSING) , THE "DATA SECURITY TERMS" (HTTPS://WWW.FACEBOOK.COM/LEGAL/TERMS/DATA_SECURITY_TERMS) AND, 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, MERRION ROAD, DUBLIN 4, D04 X2K5, IRELAND; LEGAL BASIS: LEGITIMATE INTERESTS (ART. 6 PARA. 1 SENTENCE 1 LIT. F) GDPR); WEBSITE: HTTPS://WWW.INSTAGRAM.COM. PRIVACY POLICY: HTTPS://INSTAGRAM.COM/ABOUT/LEGAL/PRIVACY/.

  • X PLUGINS AND CONTENT: PLUGINS AND BUTTONS OF THE "X" PLATFORM - THESE MAY INCLUDE, FOR EXAMPLE, CONTENT SUCH AS IMAGES, VIDEOS, OR TEXT AND BUTTONS THAT ALLOW USERS TO SHARE CONTENT FROM THIS ONLINE OFFERING WITHIN X; SERVICE PROVIDER: TWITTER INTERNATIONAL COMPANY, ONE CUMBERLAND PLACE, FENIAN STREET, DUBLIN 2 D02 AX07, IRELAND; LEGAL BASIS: LEGITIMATE INTERESTS (ART. 6 PARA. 1 SENTENCE 1 LIT. F) GDPR); WEBSITE: HTTPS://TWITTER.COM/DE; PRIVACY POLICY: HTTPS://TWITTER.COM/DE/PRIVACY, (SETTINGS: HTTPS://TWITTER.COM/PERSONALIZATION); DATA PROCESSING AGREEMENT: HTTPS://PRIVACY.TWITTER.COM/EN/FOR-OUR-PARTNERS/GLOBAL-DPA. BASIS FOR TRANSFER TO THIRD COUNTRIES: STANDARD CONTRACTUAL CLAUSES (HTTPS://PRIVACY.TWITTER.COM/EN/FOR-OUR-PARTNERS/GLOBAL-DPA).

  • YOUTUBE VIDEOS: VIDEO CONTENT; SERVICE PROVIDER: GOOGLE IRELAND LIMITED, GORDON HOUSE, BARROW STREET, DUBLIN 4, IRELAND; LEGAL BASIS: CONSENT (ART. 6 PARA. 1 SENTENCE 1 LIT. A) GDPR); WEBSITE: HTTPS://WWW.YOUTUBE.COM; PRIVACY POLICY: HTTPS://POLICIES.GOOGLE.COM/PRIVACY; BASIS FOR TRANSFER TO THIRD COUNTRIES: EU-US DATA PRIVACY FRAMEWORK (DPF). OPT-OUT OPTION: OPT-OUT PLUGIN: HTTPS://TOOLS.GOOGLE.COM/DLPAGE/GAOPTOUT?HL=DE, SETTINGS FOR THE DISPLAY OF ADVERTISEMENTS: HTTPS://MYADCENTER.GOOGLE.COM/PERSONALIZATIONOFF.

  • YOUTUBE VIDEOS: VIDEO CONTENT; YOUTUBE VIDEOS ARE INTEGRATED VIA A SPECIAL DOMAIN (RECOGNIZABLE BY THE COMPONENT "YOUTUBE-NOCOOKIE") IN THE SO-CALLED "EXTENDED DATA PROTECTION MODE," WHICH MEANS THAT NO COOKIES ARE COLLECTED ON USER ACTIVITIES TO PERSONALIZE THE VIDEO PLAYBACK. HOWEVER, INFORMATION ABOUT USER INTERACTION WITH THE VIDEO (E.G., REMEMBERING THE LAST PLAYBACK POSITION) MAY BE STORED; SERVICE PROVIDER: GOOGLE IRELAND LIMITED, GORDON HOUSE, BARROW STREET, DUBLIN 4, IRELAND; LEGAL BASIS: CONSENT (ART. 6 PARA. 1 SENTENCE 1 LIT. A) GDPR); WEBSITE: HTTPS://WWW.YOUTUBE.COM; PRIVACY POLICY: HTTPS://POLICIES.GOOGLE.COM/PRIVACY. BASIS FOR TRANSFER TO THIRD COUNTRIES: EU-US DATA PRIVACY FRAMEWORK (DPF).

CHANGES AND UPDATES TO THE PRIVACY POLICY

WE ASK YOU TO REGULARLY REVIEW THE CONTENT OF OUR PRIVACY POLICY. WE WILL AMEND THE PRIVACY POLICY AS SOON AS CHANGES TO THE DATA PROCESSING WE CARRY OUT MAKE THIS NECESSARY. WE WILL INFORM YOU AS SOON AS THE CHANGES REQUIRE ACTION ON YOUR PART (E.G., CONSENT) OR OTHER INDIVIDUAL NOTIFICATION.

IF WE PROVIDE ADDRESSES AND CONTACT INFORMATION FOR COMPANIES AND ORGANIZATIONS IN THIS PRIVACY POLICY, PLEASE NOTE THAT THESE ADDRESSES MAY CHANGE OVER TIME AND CHECK THE INFORMATION BEFORE CONTACTING THEM.

DEFINITION OF TERMS

THIS SECTION PROVIDES AN OVERVIEW OF THE TERMS USED IN THIS PRIVACY POLICY. WHERE THE TERMS ARE DEFINED BY LAW, THEIR LEGAL DEFINITIONS APPLY. THE FOLLOWING EXPLANATIONS ARE INTENDED PRIMARILY TO AID UNDERSTANDING.


  • CONVERSION MEASUREMENT: CONVERSION MEASUREMENT (ALSO REFERRED TO AS "VISIT ACTION EVALUATION") IS A PROCESS THAT CAN BE USED TO DETERMINE THE EFFECTIVENESS OF MARKETING MEASURES. TO DO THIS, A COOKIE IS USUALLY STORED ON THE USER'S DEVICE WITHIN THE WEBSITES ON WHICH THE MARKETING MEASURES ARE CARRIED OUT AND THEN RETRIEVED AGAIN ON THE TARGET WEBSITE. THIS ALLOWS US, FOR EXAMPLE, TO TRACK WHETHER THE ADVERTISEMENTS WE PLACE ON OTHER WEBSITES WERE SUCCESSFUL. 

  • PERSONAL DATA: "PERSONAL DATA" IS 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 ASSOCIATION WITH AN IDENTIFIER SUCH AS A NAME, AN IDENTIFICATION NUMBER, LOCATION DATA, AN ONLINE IDENTIFIER (E.G., A COOKIE) OR ONE OR MORE FACTORS SPECIFIC TO THE PHYSICAL, PHYSIOLOGICAL, GENETIC, MENTAL, ECONOMIC, CULTURAL, OR SOCIAL IDENTITY OF THAT NATURAL PERSON. 

  • PROFILES WITH USER-RELATED INFORMATION: THE PROCESSING OF "PROFILES WITH USER-RELATED INFORMATION," OR "PROFILES" FOR SHORT, INCLUDES ANY TYPE OF AUTOMATED PROCESSING OF PERSONAL DATA THAT CONSISTS OF USING THIS PERSONAL DATA TO ANALYZE, EVALUATE, OR PREDICT CERTAIN PERSONAL ASPECTS RELATING TO A NATURAL PERSON (DEPENDING ON THE TYPE OF PROFILING, THIS MAY INCLUDE DIFFERENT INFORMATION REGARDING DEMOGRAPHICS, BEHAVIOR, AND INTERESTS, SUCH AS INTERACTION WITH WEBSITES AND THEIR CONTENT, ETC.). COOKIES AND WEB BEACONS ARE OFTEN USED FOR PROFILING PURPOSES. 

  • REACH MEASUREMENT: REACH MEASUREMENT (ALSO KNOWN 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, OPERATORS OF ONLINE SERVICES CAN, FOR EXAMPLE, IDENTIFY AT WHAT TIME USERS VISIT THEIR WEBSITES AND WHAT CONTENT THEY ARE INTERESTED IN. THIS ENABLES THEM, FOR EXAMPLE, TO BETTER TAILOR THE CONTENT OF THEIR WEBSITES TO THE NEEDS OF THEIR VISITORS. PSEUDONYMOUS COOKIES AND WEB BEACONS ARE OFTEN USED FOR REACH ANALYSIS TO RECOGNIZE RETURNING VISITORS AND THUS OBTAIN MORE ACCURATE ANALYSES OF THE USE OF AN ONLINE SERVICE. 

  • TRACKING: "TRACKING" REFERS TO THE TRACKING OF USER BEHAVIOR ACROSS MULTIPLE ONLINE SERVICES. AS A RULE, BEHAVIORAL AND INTEREST INFORMATION RELATING TO THE ONLINE SERVICES USED IS STORED IN COOKIES OR ON THE SERVERS OF THE PROVIDERS OF THE TRACKING TECHNOLOGIES (KNOWN AS PROFILING). THIS INFORMATION CAN THEN BE USED, FOR EXAMPLE, TO DISPLAY ADVERTISEMENTS TO USERS THAT ARE LIKELY TO CORRESPOND TO THEIR INTERESTS. 

  • CONTROLLER: THE "CONTROLLER" IS THE NATURAL OR LEGAL PERSON, PUBLIC AUTHORITY, AGENCY, 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 COVERS VIRTUALLY EVERY TYPE OF DATA HANDLING, INCLUDING COLLECTION, EVALUATION, STORAGE, TRANSMISSION, AND DELETION. 

  • TARGET GROUP FORMATION: TARGET GROUP FORMATION (ALSO KNOWN AS "CUSTOM AUDIENCES") REFERS TO THE DETERMINATION OF TARGET GROUPS FOR ADVERTISING PURPOSES, E.G., THE DISPLAY 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 WHERE THEY VIEWED THE PRODUCTS. "LOOKALIKE AUDIENCES" (OR SIMILAR TARGET GROUPS) REFER TO USERS WHO ARE SHOWN CONTENT THAT IS DEEMED SUITABLE FOR THEM BECAUSE THEIR PROFILES OR INTERESTS ARE PRESUMED TO CORRESPOND TO THOSE OF THE USERS FOR WHOM THE PROFILES WERE CREATED. COOKIES AND WEB BEACONS ARE GENERALLY USED TO CREATE CUSTOM AUDIENCES AND LOOKALIKE AUDIENCES.