Gamesright

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gamesright
An der Alster 6
20099 Hamburg

[email protected]

Phone: 040 / 237 24 33 749
Fax: 040 / 81 987 28 7

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Privacy Policy

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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. This 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 the "online offering").

The terms used are not gender specific.

As of: 20 August 2024

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Table of Contents

Responsible

Gamesright GmbH
An der Alster 6
20099 Hamburg

Persons authorized to represent: Jan Beuck

E-mail address: [email protected]

Imprint: https://gamesright.de/impressum/

Overview of processing

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

Types of data processed

  • Inventory data.
  • Payment details.
  • Contact details.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication and procedural data.
  • Event data (Facebook).
  • Log data.
  • Credit data.

Categories of data subjects

  • Service recipient and client.
  • Employees.
  • Interested persons.
  • communication partner.
  • users.
  • Business and contractual partners.
  • Third parties.

Purposes of processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Security measures.
  • direct marketing.
  • Reach measurement.
  • Tracking.
  • Office and organizational procedures.
  • Remarketing.
  • Conversion measurement.
  • Target group formation.
  • Organisational and administrative procedures.
  • Content Delivery Network (CDN).
  • Firewalls.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offering and user-friendliness.
  • Assessment of creditworthiness and credit rating.
  • Information technology infrastructure.
  • Financial and payment management.
  • Public relations.
  • Sales promotion.
  • Business processes and business procedures.

Relevant legal bases

Relevant legal bases under the GDPR: Below you will find an overview of the GDPR legal bases on which we process personal data. Please note that in addition to the GDPR regulations, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases apply 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 his or her consent to the processing of personal data concerning him or her for one or more specific purposes.
  • Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Article 6 paragraph 1 sentence 1 lit. c) GDPR) – Processing is necessary to fulfill a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) – processing is necessary to safeguard the legitimate interests of the controller or of a third party, provided that the interests or fundamental rights and freedoms of the data subject which require protection of personal data do not override them.

National data protection regulations in Germany: In addition to the data protection provisions of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Federal Data Protection Act (BDSG). The BDSG contains, in particular, special provisions on the right to information, the right to erasure, the right of objection, the processing of special categories of personal data, processing for other purposes, and transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of individual federal states may apply.

Reference to the validity of GDPR and Swiss DSG: This privacy policy serves to provide information in accordance with both the Swiss Data Protection Act (DPA) and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that, due to their broader geographical application and clarity, the terms used in the GDPR are used. In particular, instead of the terms "processing" of "personal data," "overriding interest," and "particularly sensitive personal data" used in the Swiss Data Protection Act, 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 Data Protection Act within the scope of the Swiss Data Protection Act.

Security 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, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.

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 the access, input, and transfer of data, ensuring its availability, and segregation. Furthermore, we have established procedures that ensure the exercise of data subjects' rights, the deletion of data, and responses to data threats. Furthermore, we consider the protection of personal data right from the development and selection of hardware, software, and processes in accordance with the principle of data protection, through technology design, and through data protection-friendly default settings.

Securing online connections with TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. If a website is secured by an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

Transmission of personal data

As part of our processing of personal data, it may happen that this data is transmitted to or disclosed to other bodies, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

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 the processing takes place as part of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies, this will only take place 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 only take place if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 (2) (c) GDPR), express consent or in the case of contractually or legally required transfer (Art. 49 (1) GDPR). We will also inform you of the basis for third-country transfers from the individual providers in the third country, with the adequacy decisions taking precedence. Information on third country transfers 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 USA as secure within the framework of the adequacy decision of July 10, 2023. The list of certified companies as well as further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). As part of the data protection information, we inform you which service providers we use are certified under the Data Privacy Framework.

General information on data storage and deletion

We delete personal data that we process in accordance with legal requirements as soon as the underlying consent is revoked or there are no further legal grounds for processing. This applies to cases where the original processing purpose no longer applies or the data is no longer needed. Exceptions to this rule exist if legal obligations or special interests require longer retention or archiving of the data.

In particular, data that must be retained for commercial or tax law reasons or whose storage is necessary for legal proceedings or to protect the rights of other natural or legal persons must be archived accordingly.

Our privacy policy contains additional information on the retention and deletion of data that applies specifically to certain processing operations.

If there are multiple details regarding the retention period or deletion period for a given date, the longest period always applies.

If a period does not explicitly begin on a specific date and is at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the period is the effective date of the termination or other termination of the legal relationship.

We process data that is no longer stored for the originally intended purpose but due to legal requirements or other reasons only for the reasons that justify its storage.

Further information on processing procedures, methods and services:

  • Storage and deletion of data: The following general deadlines apply to storage and archiving under German law:
    • 10 years – retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets as well as the work instructions and other organizational documents, accounting documents and invoices required for their understanding (Section 147 (3) in conjunction with Section 1 Nos. 1, 4 and 4a AO, Section 14b (1) UStG, Section 257 (1) Nos. 1 and 4, Section 4 HGB).
    • 6 years – Other business documents: received commercial or business letters, reproductions of sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g. hourly wage slips, operating statements, calculation documents, price labels, but also payroll documents insofar as they are not already accounting documents and cash register slips (Section 147 (3) in conjunction with Section 1 Nos. 2, 3, 5 AO, Section 257 (1) Nos. 2 and 3, Paragraph 4 HGB).
    • 3 years – Data required to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and standard industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Rights of the data subjects

Rights of the data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

  • Right of objection: You have the right to object at any time to the processing of personal data concerning you based on Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct marketing.
  • Right of revocation for consent: You have the right to revoke your consent at any time.
  • Right of providing information: 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 statutory requirements.
  • Right to rectification: In accordance with the statutory provisions, you have the right to request that the data concerning you be completed or that inaccurate data concerning you be corrected.
  • Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to request that data concerning you be deleted immediately or, alternatively, to request that the processing of the data be restricted in accordance with the statutory provisions.
  • Right to data portability: You have the right to receive the 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 transmitted to another controller.
  • Complaint to the supervisory authority: In accordance with the statutory provisions 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 habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

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 framework of contractual and comparable legal relationships and related measures and with regard to communication with the contractual partners (or pre-contractually), for example to answer inquiries.

We use this data to fulfill our contractual obligations. This includes, in particular, the obligation to provide the agreed services, any update obligations, and remedy in the event of warranty and other service disruptions. Furthermore, we use the data to protect our rights and for the purposes of the administrative tasks associated with these obligations, as well as for corporate organization. Furthermore, we process the data based on our legitimate interests in proper and efficient business management and in security measures to protect our contractual partners and our business operations from misuse and the endangerment of their data, secrets, information, and rights (e.g., the involvement of telecommunications, transport, and other auxiliary services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Within the framework of applicable law, we only pass on contractual partners' data to third parties to the extent necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed of other forms of processing, such as for marketing purposes, in this privacy policy.

We will inform our contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.

We delete data after the expiration of statutory warranty and similar obligations, i.e., generally after four years, unless the data is stored in a customer account, e.g., for as long as it must be retained for legal archiving reasons (e.g., for tax purposes, usually ten years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications and generally after the end of the order.

  • Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); contact data (e.g., postal and email addresses or telephone numbers); contract data (e.g., contract subject matter, term, customer category); usage data (e.g., page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
  • Affected people: Service recipients and clients; interested parties; business and contractual partners.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; communication; office and organizational procedures; organizational and administrative procedures; business processes and management procedures. Conversion measurement (measurement of the effectiveness of marketing measures).
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Legal obligation (Art. 6 (1) (c) GDPR); Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing procedures, methods and services:

  • Data analysis: We process the data of our customers and clients to enable them to perform data analysis, evaluation, and consulting, as well as provide related services. The required information includes the information needed for analysis, evaluation, and billing, as well as contact information for necessary coordination. To the extent we receive access to information from end customers, employees, or other persons, we process it in accordance with legal and contractual requirements. Legal basis: Contractual fulfillment 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 S. 1 lit. f) GDPR).
  • Financial services: We process our customers' data to enable them to provide advice, brokerage, and conclude financial transactions and related services. The required information is marked as such within the scope of the advisory, brokerage, or similar contract and includes the information needed for service provision and billing, as well as contact information for any follow-up consultations. To the extent we receive access to information from customers or other persons, we process it in accordance with legal and contractual requirements. Legal basis: Contractual fulfillment 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 S. 1 lit. f) GDPR).
  • Mediation services: We process the information provided by interested parties within the scope of the brokerage request for the purposes of establishing, implementing and, if necessary, terminating a contract for the brokerage of offers from providers of the products or services requested by them.

    We use the contact details of interested parties to specify their inquiry using the agreed or otherwise permitted communication channel (e.g., telephone or email) and to suggest suitable providers or offers based on the specified inquiry. Furthermore, we may ask interested parties at a later date, in accordance with legal requirements, questions about the success of our brokerage services.

    We process the data of both interested parties and providers to fulfill our contractual obligations, to link the enquiry submitted to us by interested parties with the offers of providers that match them and to forward them to the appropriate providers or to suggest the providers.

    We may log the entries in the online form submitted by interested parties in order to be able to prove the existence of the contractual relationship and the consent of the interested parties in accordance with legal accountability obligations (Article 5 (2) GDPR). This information will be stored for a period of three to four years in case we need to prove the original request (e.g., to be able to prove the authorization to contact the interested party). Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).

Business processes and procedures

Personal data of service recipients and clients – including customers, clients, or in special cases, clients, patients, business partners, and other third parties – is processed within the framework of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relationships. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting, and project management.

The collected data serves to fulfill contractual obligations and streamline operational processes. This includes processing business transactions, managing customer relationships, optimizing sales strategies, and ensuring internal accounting and financial processes. In addition, the data supports the protection of the controller's rights and supports administrative tasks and the organization of the company.

Personal data may be transferred to third parties if this is necessary to fulfill the stated purposes or legal obligations. After the expiration of statutory retention periods or if the purpose of processing no longer applies, the data will be deleted. This also includes data that must be stored for longer periods due to tax and legal documentation requirements.

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as details of authorship or time of creation); contract data (e.g. subject matter of the contract, term, customer category); protocol data (e.g. log files relating to logins or the retrieval of data or access times); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); creditworthiness data (e.g. credit score obtained, estimated probability of default, risk classification based on this, historical payment behaviour). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
  • Affected people: Service recipients and clients; interested parties; communication partners; business and contractual partners; third parties; users (e.g., website visitors, users of online services); employees (e.g., employees, applicants, temporary workers, and other staff).
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; office and organizational procedures; business processes and management procedures; communication; marketing; sales promotion; public relations; assessment of creditworthiness and credit rating; financial and payment management. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.).)
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Legitimate interests (Art. 6 (1) (f) GDPR); Legal obligation (Art. 6 (1) (c) GDPR).

Further information on processing procedures, methods and services:

  • Contact management and contact maintenance: Procedures required for organizing, maintaining, and securing contact information (e.g., setting up and maintaining a central contact database, regularly updating contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, backing up and restoring contact information, training employees in the effective use of contact management software, regularly reviewing communication history, and adapting contact strategies); Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
  • General payment transactions: Procedures required for the execution of payment transactions, the monitoring of bank accounts and the control of payment flows (e.g. preparation and verification of transfers, processing of direct debit transactions, checking of account statements, monitoring of incoming and outgoing payments, direct debit management, account reconciliation, cash management); Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
  • Accounting, accounts payable, accounts receivable: Procedures required for the recording, processing and control of business transactions in the area of accounts payable and accounts receivable accounting (e.g. preparation and checking of incoming and outgoing invoices, monitoring and management of open items, execution of payment transactions, processing of dunning procedures, account reconciliation within the scope of receivables and payables, accounts payable and accounts receivable accounting); Legal basis: Contractual fulfillment 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 S. 1 lit. f) GDPR).
  • Financial accounting and taxes: Procedures required for the recording, administration and control of financially relevant business transactions as well as for the calculation, reporting and payment of taxes (e.g., account allocation and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, processing of dunning procedures, account reconciliation, tax advice, preparation and filing of tax returns, processing of tax matters); Legal basis: Contractual fulfillment 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 S. 1 lit. f) GDPR).
  • Marketing, advertising and sales promotion: Procedures required within the framework of marketing, advertising and sales promotion (e.g. market analysis and target group identification, development of marketing strategies, planning and implementation of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade fair participation, customer loyalty programs, sales promotion measures, performance measurement and optimization of marketing activities, budget management and cost control); Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
  • Public relations: Procedures required within the framework of public relations (e.g. development and implementation of communication strategies, planning and implementation of PR campaigns, preparation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organization of press conferences and public events, crisis communication, creation of content for social media and company websites, management of corporate branding); Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Provision of the online offer and web hosting

We process user data 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 device.

  • Types of data processed: Usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and process data (e.g., IP addresses, time information, identification numbers, persons involved); protocol data (e.g., log files relating to logins or data retrieval or access times). Content data (e.g., textual or visual messages and contributions, as well as related information, such as authorship or time of creation).
  • Affected people: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); security measures. Content Delivery Network (CDN).
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Provision of online offering on rented storage space: To provide our online service, we use storage space, computing capacity and software that we rent from a corresponding server provider (also called “web host”) or obtain from other sources; Legal basis: Legitimate interests (Article 6 (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." These server log files may include the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, the referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. These server log files may be used for security purposes, e.g., to prevent server overload (particularly in the case of abusive attacks, so-called DDoS attacks), and to ensure server capacity utilization and stability. Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that needs to be retained for evidentiary purposes is exempt from deletion until the respective incident has been finally resolved.
  • Content Delivery Network: We use a content delivery network (CDN). A CDN is a service that enables faster and more secure delivery of online content, especially large media files such as graphics or program scripts, using regionally distributed servers connected via the Internet. Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
  • WordPress.com: Hosting and software for the creation, provision and operation of websites, blogs and other online offerings; Service provider: Aut O'Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR); Website: https://wordpress.com; Privacy Policy: https://automattic.com/de/privacy/; Data processing agreement: https://wordpress.com/support/data-processing-agreements/. Basis for third country transfers: Data Privacy Framework (DPF).
  • Cloudflare: Content Delivery Network (CDN) – a service that enables the faster and more secure delivery of online content, particularly large media files such as graphics or program scripts, using regionally distributed servers connected via the Internet; Service provider: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA; Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR); Website: https://www.cloudflare.com; Privacy Policy: https://www.cloudflare.com/privacypolicy/; Data processing agreement: https://www.cloudflare.com/cloudflare-customer-dpa/. Basis for third country transfers: Data Privacy Framework (DPF).
  • Namecheap: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: Namecheap Inc., 4600 East Washington Street, Suite 305, Phoenix, AZ 85034, USA; Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR); Website: https://www.namecheap.com; Privacy Policy: https://www.namecheap.com/legal/general/privacy-policy/. Data processing agreement: https://www.namecheap.com/legal/universal/data-processing-addendum/.
  • Lightspeed Cache: Caching and load optimization – features that store certain web page content so that it loads faster on repeated visits. This reduces loading times and improves the user experience. Service provider: Execution on servers and/or computers under your own data protection responsibility; Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR). Website: https://wordpress.org/plugins/litespeed-cache/.
  • JSDelivr: Content Delivery Network (CDN), which helps deliver media and files quickly and efficiently, especially under high load; Service provider: ProspectOne, Królewska 65A/1, 30-081, Kraków, Poland; Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR); Website: https://www.jsdelivr.com. Privacy Policy: https://www.jsdelivr.com/terms/privacy-policy.
  • WPRocket: Caching and load optimization – features that store certain web page content so that it loads faster on repeated visits. This reduces loading times and improves the user experience. Service provider: SAS WP MEDIA, Address: 4 rue de la République, 69001 LYON, France; Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR); Website: https://wp-rocket.me/de/; Privacy Policy: https://wp-rocket.me/privacy-policy/. Additional Information: Operation within your own hosting environment.

Use of cookies

Cookies are small text files or other storage devices that store and retrieve information from end devices. For example, they can 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 in an online offering. Cookies can also be used for various purposes, such as ensuring the functionality, security, and convenience of online offerings, as well as creating analyses of visitor flows.

Notes on consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users unless it is not required by law. Permission is particularly unnecessary if the storage and retrieval of information, including cookies, is absolutely necessary to provide users with a telemedia service they have expressly requested (i.e., our online offering). The revocable consent will be clearly communicated to users and will contain information about the respective cookie usage.

Notes on data protection legal bases: The data protection basis on which we process users' personal data with the help of cookies depends on whether we ask them for their consent. If users accept, the legal basis for the use of their data is their declared consent. Otherwise, the data used with the help of 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 occurs as part of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We explain the purposes for which we use cookies in the course of this privacy policy or as part of our consent and processing procedures.

Storage period: With regard to the storage period, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their device (e.g. browser or mobile application).
  • Persistent cookies: Persistent cookies remain stored even after the device is closed. For example, the login status can be saved and preferred content can be displayed directly when the user visits a website again. Likewise, the user data collected using cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., when obtaining consent), they should assume that they are permanent and can be stored for up to two years.

General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also object to processing in accordance with legal requirements, including through the privacy settings of their browser.

  • Types of data processed: Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
  • Affected people: Users (e.g. website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR). Consent (Art. 6 Para. 1 Clause 1 Letter a) GDPR).

Further information on processing procedures, methods and services:

  • Processing of cookie data based on consent: We use a consent management solution that obtains users' consent to the use of cookies or to the procedures and providers named within the consent management solution. This procedure is used to obtain, log, manage, and revoke consent, particularly with regard to the use of cookies and similar technologies used to store, read, and process information on users' end devices. As part of this procedure, users' consent is obtained for the use of cookies and the associated processing of information, including the specific processing operations and providers named in the consent management procedure. Users also have the option of managing and revoking their consent. Consent declarations are saved to avoid repeated queries and to provide evidence of consent in accordance with legal requirements. The data is stored on the server and/or in a cookie (so-called opt-in cookie) or using similar technologies in order to be able to assign consent to a specific user or their device. Unless specific information is available about the providers of consent management services, the following general information applies: Consent is stored for up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information about the scope of consent (e.g., relevant categories of cookies and/or service providers), and information about the browser, system, and device used. Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR).
  • Compliance: Consent management: procedures 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; Service provider: Execution on servers and/or computers under your own data protection responsibility; Website: https://complianz.io/; Privacy Policy: https://complianz.io/legal/. Additional Information: An individual user ID, language, types of consent and the time of their submission are stored on the server and in the cookie on the user's device.

Contact and inquiry management

When you contact us (e.g. by post, contact form, email, telephone or via social media) as well as within the framework of existing user and business relationships, the information provided by the person making the inquiry will be processed to the extent necessary to answer the contact inquiries and any requested measures.

  • Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and contributions as well as related information, such as authorship or time of creation); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and process data (e.g., IP addresses, time information, identification numbers, persons involved).
  • Affected people: Communication partners; service recipients and clients. Users (e.g., website visitors, users of online services).
  • Purposes of processing: Communication; organizational and administrative procedures; feedback (e.g., collecting feedback via online forms). Provision of our online offering and user-friendliness.
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR). Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR).

Further information on processing procedures, methods and services:

  • Contact form: When you contact us via our contact form, by email, or other communication channels, we process the personal data you provide to respond to and process your request. This typically includes information such as your name, contact information, and, if applicable, other information provided to us that is necessary for appropriate processing. We use this data exclusively for the stated purpose of establishing contact and communication. Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
  • Elementor: Creation of online forms, collection and storage of the associated user input; Service provider: Elementor Ltd., 40 Tuval St, Ramat Gan, Israel; Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR); Website: https://elementor.com/features/form-builder/; Privacy Policy: https://elementor.com/about/privacy/; Data processing agreement: https://elementor.com/terms/cloud-toc/elementor-data-processing-agreement/; Basis for third country transfers: Adequacy decision (Israel). Additional Information: https://elementor.com/trust/.

Cloud services

We use software services accessible via the Internet and running on the servers of their providers (so-called "cloud services", also referred to as "software as a service") for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with specific recipients or publication of content and information).

Within this framework, personal data may be processed and stored on the providers' servers if it is part of communication processes with us or is otherwise processed by us as set out in this privacy policy. This data may include, in particular, user master data and contact details, data on transactions, contracts, other processes, and their contents. The providers of cloud services also process usage data and metadata, which they use for security purposes and to optimize their services.

If we use cloud services to provide forms, documents, and content to other users or publicly accessible websites, the providers may store cookies on users' devices for web analysis purposes or to remember users' settings (e.g., in the case of media control).

  • Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and contributions as well as related information, such as authorship or time of creation); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and process data (e.g., IP addresses, time information, identification numbers, persons involved).
  • Affected people: Interested parties; communication partners; business and contractual partners. Users (e.g., website visitors, users of online services).
  • Purposes of processing: Office and organizational procedures; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.). Provision of our online offering and user-friendliness.
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

Newsletters and electronic notifications

We send newsletters, emails, and other electronic notifications (hereinafter "newsletters") exclusively with the recipient's consent or based on a legal basis. If the newsletter content is mentioned when registering for the newsletter, this content determines the user's consent. Providing your email address is usually sufficient to register for our newsletter. However, in order to offer you a personalized service, we may ask for your name so that we can address you personally in the newsletter or for additional information if this is necessary for the purpose of the newsletter.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove previously given consent. The processing of this data is limited to the purpose of potentially defending against claims. An individual request for deletion is possible at any time, provided that the previous consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address on a block list (so-called "block list") for this purpose alone.

The registration process is logged based on our legitimate interests for the purpose of demonstrating its proper execution. If we commission a service provider to send emails, this is done based on our legitimate interests in an efficient and secure delivery system.

Contents:

Information about us, our services, promotions and offers.

  • Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved); usage data (e.g., page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
  • Affected people: communication partner.
  • Purposes of processing: Direct marketing (e.g. by email or post).
  • Storage and deletion: 3 years – Contractual claims (AT) (Data required to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries based on previous business experience and standard industry practices, will be stored for the regular statutory limitation period of three years (§§ 1478, 1480 ABGB).) 10 years – Contractual claims (CH) (Data required to consider potential compensation claims or similar contractual claims and rights, as well as to process related inquiries based on previous business experience and standard industry practices, will be stored for the statutory limitation period of ten years, unless a shorter period of five years applies, which is applicable in specific cases (Art. 127, 130 OR)).
  • Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR). Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
  • Opt-out option: 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 by using one of the contact options listed above, preferably email.

Further information on processing procedures, methods and services:

Web analysis, monitoring and optimization

Web analytics (also known as "reach measurement") is used to evaluate visitor traffic to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. Reach analysis allows us, for example, to determine when our online offering or its features or content are most frequently used, or to encourage reuse. It also allows us to understand which areas require optimization.

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

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 then read out. The data collected includes, in particular, websites visited and the 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, the processing of location data is also possible.

In addition, users' IP addresses are stored. However, we use an IP masking process (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no real user data (such as email addresses or names) is stored for web analysis, A/B testing, and optimization; instead, pseudonyms are used. 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 purpose of the respective processes.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-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., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and process data (e.g., IP addresses, time information, identification numbers, persons involved); inventory data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers). Content data (e.g., textual or visual messages and contributions as well as related information, such as authorship or time of creation).
  • Affected people: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g., access statistics, recognition of recurring visitors); profiles with user-related information (creation of user profiles); provision of our online offering and user-friendliness; security measures; firewall. Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.).).
  • Storage and deletion: Deletion as described in the "General Information on Data Storage and Deletion" section. Cookies are stored for up to two years (unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR). Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Further information on processing procedures, methods 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 identify which content users have accessed within one or more usage processes, which search terms they have used, accessed these again, or interacted with our online offering. The time and duration of use are also stored, as are the sources of users who refer to our online offering and technical aspects of their devices and browsers.
    This involves creating pseudonymous profiles of users with information from their use of different devices, and cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics does provide rough geographic 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 counterparts). For EU traffic, IP address data is used solely for this derivation of geolocation data before being immediately deleted. 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 the traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Article 6 (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 third country transfers: Data Privacy Framework (DPF); Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for displaying advertisements: https://myadcenter.google.com/personalizationoff. Additional Information: https://business.safety.google/adsservices/ (Types of processing and data processed).
  • Google Tag Manager: We use Google Tag Manager, a software from Google that allows us to centrally manage so-called website tags via a user interface. Tags are small code elements on our website that are used to record and analyze visitor activity. This technology helps us improve our website and the content offered on it. Google Tag Manager itself does not create user profiles, does not store cookies with user profiles, and does not perform any independent analyses. Its function is limited to simplifying and making the integration and management of tools and services that we use on our website more efficient. Nevertheless, when Google Tag Manager is used, the user's IP address is transmitted to Google; this is necessary for technical reasons in order to implement the services we use. Cookies may also be set in the process. However, this data processing only occurs if services are integrated via Tag Manager. For more detailed information about these services and their data processing, please refer to the further sections of this privacy policy; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Data processing agreement:
    https://business.safety.google/adsprocessorterms. Basis for third country transfers: Data Privacy Framework (DPF).
  • WP Armour: Anti-spam filter that blocks spam bots; Service provider: Execution on servers and/or computers under your own data protection responsibility. Website: https://wordpress.org/plugins/honeypot/.

Online marketing

We process personal data for the purpose of online marketing, which may include, in particular, the marketing of advertising space or the presentation of advertising and other content (collectively referred to as “content”) based on 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 (the so-called "cookie"), or similar processes are used to store user information relevant to the presentation of the aforementioned content. This may include, for example, content viewed, websites visited, online networks used, as well as communication partners and technical information, such as the browser used, the computer system used, as well as information on usage times and functions used. If users have consented to the collection of their location data, this may also be processed.

In addition, users' IP addresses are stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no real user data (such as email addresses or names) is stored as part of the online marketing process; instead, pseudonyms are used. This means that neither we nor the providers of the online marketing processes know the actual user identity, only the information stored in their profiles.

The statements in the profiles are usually stored in cookies or using similar processes. These cookies can generally also be read later on other websites that use the same online marketing process and analyzed for the purpose of displaying content, supplemented with additional data, and stored on the server of the online marketing process provider.

In exceptional cases, it is possible to assign clear data to profiles, primarily if, for example, the users are members of a social network whose online marketing methods we use and the network links the user profiles with the aforementioned information. Please note that users may enter into additional agreements with the providers, for example, by providing consent during registration.

We generally only receive access to aggregated information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. Conversion measurements are 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 basis: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-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.

Information on revocation and objection:

We refer to the privacy policies of the respective providers and the opt-out options provided for each provider. If no explicit opt-out option has been provided, you can disable cookies in your browser settings. However, this may limit the functionality of our online offering. We therefore recommend the following additional opt-out options, which are summarized for each area:

a) Europe: https://www.youronlinechoices.eu.

b) Canada: https://www.youradchoices.ca/choices.

c) United States: https://www.aboutads.info/choices.

d) Cross-regional: https://optout.aboutads.info.

  • Types of data processed: Content data (e.g., textual or visual messages and posts, as well as related information, such as authorship or time of creation); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and process data (e.g., IP addresses, time information, identification numbers, persons involved). Event data (Facebook) ("Event data" is information that is sent to the provider Meta, for example, via meta pixels (be it via apps or other channels) and relates to people or their actions. This data includes details about website visits, interactions with content and functions, app installations, and product purchases. The event data is processed with the aim of creating target groups for content and advertising messages (custom audiences). It is important to note that event data does not include actual content such as written comments, login information, or contact information such as names, email addresses, or phone numbers. "Event data" is deleted by Meta after a maximum of two years, and the target groups created from it disappear when our Meta user accounts are deleted.).
  • Affected people: 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); conversion measurement (measurement of the effectiveness of marketing measures); target group formation; marketing; profiles with user-related information (creation of user profiles); provision of our online offering and user-friendliness. Remarketing.
  • Storage and deletion: Deletion as described in the "General Information on Data Storage and Deletion" section. Cookies are stored for up to two years (unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR). Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Meta pixels and target group creation (custom audiences): With the help of the meta pixel (or comparable functions for transmitting event data or contact information via interfaces in apps), Meta is able to determine visitors to our online offering as a target group for the display of advertisements (so-called "meta ads"). Accordingly, we use the meta pixel to display the meta ads placed by us only to those users on Meta platforms and within the services of partners cooperating with Meta (so-called "Audience Network"). https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offering or who have certain characteristics (e.g. interest in certain topics or products that can be seen from the websites visited) that we transmit to Meta (so-called "custom audiences"). With the help of the meta pixel, we also want to ensure that our meta ads correspond to the potential interests of the users and do not appear annoying. With the help of the meta pixel, we can also understand the effectiveness of the meta ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a meta ad (so-called "conversion measurement"); Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/; Data processing agreement: https://www.facebook.com/legal/terms/dataprocessing; Basis for third country transfers: Data Privacy Framework (DPF); Additional Information: Event data of users, i.e. behavioral and interest information, are processed for the purposes of targeted advertising and target group formation on the basis of the agreement on joint responsibility (“Addition for Responsible Parties”, https://www.facebook.com/legal/controller_addendum). Joint controllership is limited to the collection and transmission 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 the transmission of data to its parent company, Meta Platforms, Inc., in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
  • Google Ad Manager: We use the "Google Ad Manager" service to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.). Google Ad Manager is characterized by the fact that ads are displayed in real time based on users' presumed interests. This allows us to display ads for our online offering to users who may have a potential interest in our offering or who have previously shown interest in it, as well as to measure the success of the ads. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF); Additional Information: Types of processing and data processed: https://business.safety.google/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 conditions for Google advertising products and standard contractual clauses for third-country transfers of data: https://business.safety.google/adsprocessorterms.
  • Google Ads and conversion measurement: Online marketing practices for the purpose of placing content and advertisements within the service provider's advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who are likely to be interested in the ads. We also measure the conversion of the ads, i.e., whether users have used them as an opportunity to interact with the ads and use the advertised offers (so-called conversions). However, we only receive anonymous information and no personal information about individual users. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR), legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Google's Business Data Responsibility website (how Google processes personal information): https://business.safety.google/privacy/ ; Basis for third country transfers: Data Privacy Framework (DPF); Additional Information: Types of processing and data processed: https://business.safety.google/adsservices/. Data processing conditions between controllers and standard contractual clauses for third country data transfers: https://business.safety.google/adscontrollerterms.
  • Google Adsense with personalized ads: We integrate the Google Adsense service, which enables personalized ads to be placed within our online offering. Google Adsense analyzes user behavior and uses this data to display targeted advertising tailored to the interests of our visitors. We receive financial compensation for each ad placement or other use of these ads. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF); Additional Information: Types of processing and data processed: https://business.safety.google/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.
  • Google Adsense with non-personalized ads: We use the Google Adsense service to display non-personalized ads on our website. These ads are not based on individual user behavior, but are selected based on general characteristics such as the page content or your approximate geographic location. We receive compensation for the display or other use of these ads. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF); Additional Information: Types of processing and data processed: https://business.safety.google/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.
  • Outbrain: Displaying personalized advertisements; Service provider: Outbrain United Kingdom Limited, 175 High Holborn, London WC1V 7AA, Great Britain; Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR); Website: https://www.outbrain.com; Privacy Policy: https://www.outbrain.com/privacy/. Deletion of data: The stored personal data will be deleted or anonymized after 13 months.
  • TabooLa: Providing functionality to display personalized advertising based on interest- and behavior-based information, including demographic characteristics, interests and browsing history of users, stored in user profiles; Service provider: Taboola, Inc. 16 Madison Square West 7th Floor New York, New York 10010, USA; Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR); Website: https://www.taboola.com/de; Privacy Policy: https://www.taboola.com/privacy-policy; Data processing agreement: Provided by the service provider; Basis for third country transfers: Standard Contractual Clauses (provided by the service provider); Deletion of data: Taboola retains user information collected directly for ad serving for a maximum of eighteen (18) months after the user's last interaction with the Taboola Services and anonymizes it by removing personal identifiers or aggregating the data. Taboola retains anonymous or aggregated data that cannot identify an individual or device and is used for reporting and analytics purposes as long as commercially necessary. Opt-out option: https://www.taboola.com/privacy-policy#user-choices-and-optout.
  • Facebook Conversions API: We use the �Conversions API� from Facebook. The Conversions API is an interface that sends event data from our servers directly to Facebook. The functionality and processing of data within the Conversions API corresponds to the functionality and processing within the scope of using the Facebook pixel, which is why we refer to the data protection information on the Facebook pixel and target group formation; Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR).
  • TikTok Pixels: Code that is loaded when a user visits our online offering and tracks the user's behavior and conversions and saves them in a profile (possible uses: measuring campaign performance, optimizing ad delivery, building custom and similar audiences). – We and TikTok are jointly responsible for the collection and transmission of event data as well as for measuring and creating insights reports (statistics) for profile owners. This event data includes information about the types of content 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 the user's profile, such as country or location. Data protection information on the processing of user data by TikTok can be found in TikTok's privacy policy: https://www.tiktok.com/legal/page/eea/privacy-policy/de. We have concluded a special joint controller agreement with TikTok, which specifically regulates the security measures TikTok must observe and in which TikTok has agreed to fulfill the rights of data subjects (i.e., users can, for example, submit information or deletion requests directly to TikTok). Users' rights (in particular, the right to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with TikTok. The joint controller agreement can be found in TikTok's "Jurisdiction Specific Terms": https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms.; 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: Consent (Article 6 (1) sentence 1 lit. a) GDPR); Website: https://ads.tiktok.com/help/article/tiktok-pixel; Privacy Policy: https://www.tiktok.com/legal/page/eea/privacy-policy/de. Basis for third country transfers: Standard Contractual Clauses (https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms).

Customer reviews and rating processes

We participate in review and rating processes to evaluate, optimize, and promote our services. If users rate us via the participating rating platforms or processes or otherwise provide feedback, the providers' general terms and conditions of use and privacy policies also apply. Typically, the rating also requires registration with the respective providers.

To ensure that the reviewers have actually used our services, we transmit, with the customer's consent, the necessary data regarding the customer and the service used to the respective review platform (including name, email address, and order number or item number). This data is used solely to verify the user's authenticity.

  • Types of data processed: Contract data (e.g., subject matter of the contract, term, customer category); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
  • Affected people: Service recipients and clients. Users (e.g., website visitors, users of online services).
  • Purposes of processing: Feedback (e.g., collecting feedback via online form). Marketing.
  • Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

Presences 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 could pose risks for users, for example, because it could make it more difficult to enforce user rights.

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of users. These profiles may in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the users' interests. Therefore, cookies are generally stored on users' computers, in which the user behavior and interests are saved. Furthermore, user profiles can also store data independent of the devices used by users (particularly if they are members of the respective platforms and are logged in there).

For a detailed description of the respective processing methods and the options for 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 like to point out that these can be most effectively asserted with the providers. Only the latter have access to user data and can directly take appropriate measures and provide information. Should you still need assistance, please contact us.

  • Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and posts, as well as related information, such as authorship or time of creation); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and features).
  • Affected people: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Communication; feedback (e.g., collecting feedback via online form). Public relations.
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Instagram: Social network, allows sharing photos and videos, commenting and favorite posts, sending messages, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for third country transfers: Data Privacy Framework (DPF).
  • Facebook pages: Profiles within the social network Facebook – We, together with Meta Platforms Ireland Limited, are responsible for collecting (but not further processing) data from visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see "Things you and others do and provide" in the Facebook Data Policy). https://www.facebook.com/privacy/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/privacy/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 called "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 specific 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 fulfill the rights of those affected (i.e., users can, for example, submit information or deletion requests directly to Facebook). Users' rights (in particular the right to information, deletion, objection, and complaint to the responsible supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information on Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data). Joint controllership is limited to the collection and transmission 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 the transmission of data to its parent company, Meta Platforms, Inc., in the USA. Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for third country transfers: Data Privacy Framework (DPF).
  • LinkedIn: Social Network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not 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 users view or interact with, or the actions they take, as well as information about the devices users use (e.g., IP addresses, operating system, browser type, language settings, cookie data), and information from users' profiles, such as job function, country, industry, hierarchy level, company size, and employment status. Data protection information regarding LinkedIn's processing of user data 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 in particular regulates which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfil the rights of those affected (i.e. users can, for example, address information or deletion requests directly to LinkedIn). The rights of users (in particular the right to information, deletion, objection and complaint to the responsible supervisory authority) are not restricted by the agreements with LinkedIn. Joint controllership is limited to the collection of data by and transmission 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 transmission of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Basis for third country transfers: Data Privacy Framework (DPF). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • Snapchat: Social network, allows sharing photos and videos, commenting and favorite posts, sending messages, subscribing to profiles and pages; Service provider: Snap Inc., 3000 31st Street, Santa Monica, California 90405 USA; Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR); Website: https://www.snapchat.com/; Privacy Policy: https://www.snap.com/de-DE/privacy/privacy-policy. Basis for third country transfers: Standard Contractual Clauses (https://www.snap.com/en-US/terms/standard-contractual-clauses).
  • X: Social network; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR); Website: https://x.com. Privacy Policy: https://x.com/de/privacy.
  • YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR); Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF). Opt-out option: https://myadcenter.google.com/personalizationoff.

Plug-ins and embedded functions and content

We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may include, for example, graphics, videos, or city maps (hereinafter collectively referred to as "content").

Integration always requires that the third-party providers of this content process the user's IP address, as without an IP address they would not be able to send the content to their browser. The IP address is therefore required to display this content or functions. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, the time of visit and other information about the use of our online offering, but may also be linked to such information from other sources.

Notes on legal basis: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-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., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved). Event data (Facebook) ("Event data" is information that is sent to the provider Meta, for example, via meta pixels (be it via apps or other channels) and relates to people or their actions. This data includes details about website visits, interactions with content and functions, app installations, and product purchases. The event data is processed with the aim of creating target groups for content and advertising messages (custom audiences). It is important to note that event data does not include actual content such as written comments, login information, or contact information such as names, email addresses, or phone numbers. "Event data" is deleted by Meta after a maximum of two years, and the target groups created from it disappear when our Meta user accounts are deleted.).
  • Affected people: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and user-friendliness.
  • Storage and deletion: Deletion as described in the "General Information on Data Storage and Deletion" section. Cookies are stored for up to two years (unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).
  • Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR). Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Facebook plugins and content: Facebook social plugins and content – This may include content such as images, videos, or text, as well as buttons that allow users to share content from this website within Facebook. The list and appearance of 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 during transmission (but not the further processing) of "event data" that Facebook collects or receives during transmission using the Facebook social plugins (and content embedding functions) that are executed on our online offering for the following purposes: a) Displaying content and advertising information that corresponds to the presumed interests of users; b) Delivering commercial and transaction-related 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 presumably corresponds to the interests of users). We have concluded a special agreement with Facebook ("Addendum for Controllers"). https://www.facebook.com/legal/controller_addendum), which specifically regulates which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the data subject's rights (i.e., users can, for example, submit information or deletion requests directly to Facebook). Note: If Facebook provides us with measurements, analyses, and reports (which are aggregated, i.e., do not contain any information about individual users and are anonymous to us), then this processing does not take place within the framework of joint controllership, but on the basis of a data processing agreement ("Data Processing Conditions"). https://www.facebook.com/legal/terms/dataprocessing), the �Data Security Conditions� (https://www.facebook.com/legal/terms/data_security_terms) and with regard to processing in the USA on the basis of standard contractual clauses (“Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). Users' rights (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 (Article 6 (1) sentence 1 lit. a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for third country transfers: Data Privacy Framework (DPF).
  • Font Awesome (sourced from the provider�s server): Obtaining fonts (and symbols) for the purpose of technically secure, maintenance-free, and efficient use of fonts and symbols with regard to timeliness and loading times, their consistent presentation, and consideration of possible licensing restrictions. The font provider is informed of the user's IP address so that the fonts can be made available in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) is transmitted that is necessary for providing the fonts depending on the devices used and the technical environment. Service provider: Fonticons, Inc. ,6 Porter Road Apartment 3R, Cambridge, MA 02140, USA; Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR); Website: https://fontawesome.com/. Privacy Policy: https://fontawesome.com/privacy.

Change and update

We ask you to inform yourself regularly about the content of our privacy policy. We will adapt 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 your cooperation (e.g., consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting us.

Definitions

This section provides an overview of the terms used in this privacy policy. To the extent that the terms are defined by law, the legal definitions apply. The following explanations, however, are intended primarily to facilitate understanding.

  • Employees: Employees are people who are in an employment relationship, whether as employees, staff, or in similar positions. An employment relationship is a legal relationship between an employer and an employee, defined by an employment contract or agreement. It entails the employer's obligation to pay the employee remuneration while the employee performs their work. The employment relationship comprises various stages, including the inception of the employment contract, the implementation of the contract, during which the employee carries out their work, and the termination when the employment relationship ends, whether through notice, termination agreement, or otherwise. Employee data is all information relating to these individuals in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, vacation entitlements, health data, and performance appraisals.
  • Inventory data: Inventory data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar assignments. This data may include, among other things, personal and demographic information such as names, contact information (addresses, phone numbers, email addresses), dates of birth, and unique identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, institutions, or systems by enabling unambiguous assignment and communication.
  • Content Delivery Network (CDN): A “Content Delivery Network” (CDN) is a service that enables the faster and more secure delivery of online content, particularly large media files such as graphics or program scripts, using regionally distributed servers connected via the Internet.
  • Firewalls: A firewall is a security system that protects a computer network or an individual computer from unwanted network access.
  • Content data: Content data encompasses information generated during the creation, editing, and publication of all types of content. This category of data can include text, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the actual content itself; it also includes metadata that provides information about the content itself, such as tags, descriptions, author information, and publication dates.
  • Contact details: Contact data is essential information that enables communication with individuals or organizations. It includes, among other things, telephone numbers, postal addresses, and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.
  • Conversion measurement: Conversion measurement (also known as "visit action analysis") is a method used to determine the effectiveness of marketing measures. This typically involves storing a cookie on users' devices within the websites where the marketing measures are carried out and then retrieving it on the target website. For example, this allows us to understand whether the ads we place on other websites were successful.
  • Meta, communication and procedural data: Metadata, communication data, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Metadata, also known as data about data, includes information that describes the context, origin, and structure of other data. It can include details about file size, creation date, document author, and change histories. Communication data captures the exchange of information between users across different channels, such as email traffic, call logs, social media messages, and chat histories, including the people involved, timestamps, and transmission paths. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review events.
  • Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data encompasses a broad range of information, including how users use applications, which features they prefer, how long they stay on certain pages, and the paths they take through an application. Usage data can also include frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. Furthermore, usage data plays a crucial role in identifying trends, preferences, and potential problem areas within digital offerings.
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to 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, encompasses any type of automated processing of personal data consisting of the use of 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 relating to demographics, behavior, and interests, such as interaction with websites and their content, etc.). Cookies and web beacons are often used for profiling purposes.
  • Log data: Log data is information about events or activities logged on a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages, and other details about a system's usage or operation. Log data is often used to analyze system problems, conduct security monitoring, or compile performance reports.
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate visitor traffic to an online offering and can include visitor behavior or interest in specific information, such as website content. With the help of reach analysis, operators of online offerings can, for example, identify when users visit their websites and what content they are interested in. This allows them to, for example, better adapt website content to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
  • Remarketing: “Remarketing” or “retargeting” is the term used 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.
  • Tracking: "Tracking" occurs when user behavior can be tracked across multiple online offerings. Typically, behavioral and interest information related to the online offerings used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
  • Responsible: The “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of the processing of personal data.
  • Processing: "Processing" is any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, whether it involves collecting, analyzing, storing, transmitting, or deleting.
  • Contract data: Contract data is specific information relating to the formalization of an agreement between two or more parties. It documents the terms and conditions under which services or products are provided, exchanged, or sold. This data category is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data can include contract start and end dates, the type of agreed services or products, pricing agreements, payment terms, termination rights, renewal options, and special conditions or clauses. It serves as the legal basis for the relationship between the parties and is crucial for clarifying rights and obligations, enforcing claims, and resolving disputes.
  • Payment details: Payment data includes all information required to process payment transactions between buyers and sellers. This data is critical for e-commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction data, verification numbers, and billing information. Payment data may also include information about payment status, chargebacks, authorizations, and fees.
  • Target group formation: Custom audiences are defined when target groups are created for advertising purposes, e.g., displaying 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 they viewed the products. Lookalike audiences, on the other hand, are defined when 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 generally used to create custom audiences and lookalike audiences.

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. This 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 the "online offering").

The terms used are not gender specific.

As of: June 30, 2022

Created with Datenschutz-Generator.de by Dr. Thomas Schwenke

 

Table of Contents

 

Responsible

Attorney Hannes Beuck
Esplanade 41
20354 Hamburg

Authorized representatives:

Jan Beuck

E-mail address:

[email protected]

 

Contact Data Protection Officer

[email protected]

 

Overview of processing

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

 

Types of data processed

  • Inventory data.
  • Payment details.
  • Contact details.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta/communication data.

 

Categories of data subjects

  • Customers.
  • Employees.
  • Interested persons.
  • communication partner.
  • users.
  • Business and contractual partners.

 

Purposes of processing

  • Provision of contractual services and customer service.
  • Contact requests and communication.
  • Security measures.
  • direct marketing.
  • Reach measurement.
  • Tracking.
  • Office and organizational procedures.
  • Remarketing.
  • Conversion measurement.
  • Affiliate tracking.
  • Managing and responding to inquiries.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offering and user-friendliness.
  • Information technology infrastructure.

 

Relevant legal bases

Below you will find an overview of the GDPR legal bases on which we process personal data. Please note that in addition to the GDPR regulations, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases apply 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 his or her consent to the processing of personal data concerning him or her for one or more specific purposes.
  • Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is 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 to fulfill a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR) – Processing is necessary to protect the legitimate interests of the controller or of a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

In addition to the data protection provisions of the General Data Protection Regulation, national data protection regulations apply in Germany. These include, in particular, the Federal Data Protection Act (BDSG). The BDSG contains, in particular, special provisions on the right to information, the right to erasure, the right of objection, the processing of special categories of personal data, processing for other purposes, and transmission and automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (Section 26 BDSG), particularly with regard to the establishment, implementation, or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

 

Security 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, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.

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 the access, input, and transfer of data, ensuring its availability, and segregation. Furthermore, we have established procedures that ensure the exercise of data subjects' rights, the deletion of data, and responses to data threats. Furthermore, we consider the protection of personal data right from the development and selection of hardware, software, and processes in accordance with the principle of data protection, through technology design, and through data protection-friendly default settings.

SSL encryption (https): To protect the data you transmit via our online service, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in your browser's address bar.

 

Transmission of personal data

As part of our processing of personal data, it may happen that the data is transmitted to or disclosed to other bodies, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data 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 transmission 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 transmission, we process or have the data 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).

 

Deletion of data

The data we process will be deleted in accordance with legal requirements as soon as the consent to processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or it is no longer required for that purpose). If the data is not deleted because it is required for other 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 law reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.

As part of our privacy policy, we can provide users with further information on the deletion and retention of data that applies specifically to the respective processing operations.

 

Use of cookies

Cookies are small text files or other storage devices that store information on end devices and read information from end devices. For example, they can 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 in an online offering. Cookies can also be used for various purposes, such as improving the functionality, security, and convenience of online offerings, as well as creating analyses of visitor flows.

Notes on consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, unless this is not required by law. Consent is particularly unnecessary if the storage and retrieval of information, including cookies, is absolutely necessary to provide users with a telemedia service they have expressly requested (i.e., our online offering). The revocable consent will be clearly communicated to users and will contain information about the respective cookie usage.

Notes on data protection legal bases: The legal basis under data protection law for processing 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 their declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and improving its usability) or, if this occurs as part of the fulfillment of 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 the course of this data protection declaration or as part of our consent and processing procedures.

Storage period: With regard to the storage period, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed his or her device (e.g. browser or mobile application).
  • Persistent cookies: Persistent cookies remain stored even after the device is 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 through cookies can be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g., when obtaining consent), users should assume that cookies are permanent and can be stored for up to two years.

General information on revocation and objection (opt-out): Users can revoke their consent at any time and also object to processing in accordance with the legal requirements of Art. 21 GDPR. Users can also declare their objection via their browser settings, e.g. by deactivating the use of cookies (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be made via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ be explained.

 

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 framework of contractual and comparable legal relationships as well as related measures and within the framework of communication with the contractual partners (or pre-contractually), e.g. to answer inquiries.

We process this data to fulfill our contractual obligations. This includes, in particular, the obligation to provide the agreed services, any update obligations, and remedy in the event of warranty and other service disruptions. Furthermore, we process the data to protect our rights and for the purposes of the administrative tasks associated with these obligations, as well as company organization. Furthermore, we process the data on the basis of our legitimate interests in proper and efficient business management and in security measures to protect our contractual partners and our business operations from misuse and the endangerment of their data, secrets, information, and rights (e.g., the involvement of telecommunications, transport, and other auxiliary services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Within the framework of applicable law, we only pass on contractual partners' data to third parties to the extent necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed of other forms of processing, e.g., for marketing purposes, within the framework of this privacy policy.

We will inform our contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.

We delete the data after statutory warranty and similar obligations have expired, i.e. generally after four years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal archiving 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, the work instructions necessary to understand these documents and other organizational documents and accounting documents, and six years for received commercial and business letters and reproductions of sent commercial and business letters. The period begins at the end of the calendar year in which the last entry was made in the book, 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, furthermore the recording was made or the other documents were created.

To the extent that 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 to the relationship between 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. contract subject, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Affected people: Customers; interested parties; business and contractual partners.
  • Purposes of processing: Provision of contractual services and customer service; security measures; contact requests and communication; office and organizational procedures; administration and response to inquiries.
  • Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Legal obligation (Art. 6 (1) (c) GDPR); Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing procedures, methods and services:

  • Shop and e-commerce: We process our customers' data to enable them to select, purchase, or order the selected products, goods, and related services, as well as to pay for and deliver them or execute them. If necessary to execute 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 within the order or similar purchase process and includes the information needed for delivery, provision, and billing, as well as contact information for any follow-up questions. Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).

 

Provision of the online offer and web hosting

In order to provide our online offering securely and efficiently, we utilize the services of one or more web hosting providers, from whose servers (or servers managed by them) the online offering can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space, and database services, as well as security and technical maintenance services.

The data processed in the context of providing the hosting service may include all information concerning the users of our online offering that arises during use and communication. This usually includes the IP address, which is necessary to deliver the content of online offerings to browsers, and all entries made within our online offering or on websites.

  • 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 people: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.).
  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Further information on processing procedures, methods and services:

  • 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). These server log files may include the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, the referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider.

    The server log files can be used for security purposes, e.g. to avoid overloading the servers (particularly in the case of abusive attacks, so-called DDoS attacks) and to ensure the utilization of the servers and their stability; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 lit. f. GDPR); Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that needs to be retained for evidentiary purposes is exempt from deletion until the respective incident has been finally resolved.

 

Contact and inquiry management

When you contact us (e.g. via contact form, email, telephone or via social media) as well as within the framework of existing user and business relationships, the information provided by the person making the inquiry will be processed to the extent necessary to answer the contact inquiries and any requested measures.

The answering of contact inquiries and the management of contact and inquiry data 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 inquiries and maintaining user or business relationships.

  • 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 data (e.g., device information, IP addresses).
  • Affected people: communication partner.
  • Purposes of processing: Provision of contractual services and customer service; contact requests and communication; administration and response to inquiries; feedback (e.g. collecting feedback via online form); provision of our online offering and user-friendliness.
  • Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing procedures, methods and services:

 

Cloud services

We use software services accessible via the Internet and running on the servers of their providers (so-called "cloud services", also referred to as "software as a service") for the following purposes: document storage and management, calendar management, email sending, spreadsheets and presentations, exchange of documents, content and information with specific recipients or publication of web pages, forms or other content and information as well as chats and participation in audio and video conferences.

Within this framework, personal data may be processed and stored on the providers' servers if it is part of communication processes with us or is otherwise processed by us as set out in this privacy policy. This data may include, in particular, user master data and contact details, data on transactions, contracts, other processes, and their contents. The providers of cloud services also process usage data and metadata, which they use for security purposes and to optimize their services.

If we use cloud services to provide forms, documents, and content to other users or publicly accessible websites, the providers may store cookies on users' devices for web analysis purposes or to remember users' settings (e.g., in the case of media control).

  • 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); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Affected people: Customers; employees (e.g. employees, applicants, former employees); interested parties; communication partners.
  • Purposes of processing: Office and organizational procedures; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.).).
  • Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Legitimate interests (Art. 6 (1) (f) GDPR).

 

Advertising communication via email, post, fax or telephone

We process personal data for the purposes of advertising communication, which can be carried out via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.

Recipients have the right to revoke consent given at any time or to object to advertising communication at any time.

After revocation or objection, we will store the data required to prove previous authorization for contacting or sending for up to three years after the end of the year of revocation or objection based on our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. Based on our legitimate interest in permanently respecting the user's revocation or objection, we also store the data required to avoid further 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 data (e.g. e-mail, telephone numbers).
  • Affected people: communication partner.
  • Purposes of processing: Direct marketing (e.g. by email or post).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

 

Web analysis, monitoring and optimization

Web analytics (also known as "reach measurement") is used to evaluate visitor traffic to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. Reach analysis allows us to determine, for example, when our online offering or its functions or content are most frequently used or encourage reuse. Likewise, we can understand which areas require optimization.

In addition to web analysis, we can also use testing procedures to, for example, test and optimize different versions of our online offering or its components.

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.

Users' IP addresses are also stored. However, we use an IP masking process (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no real user data (such as email addresses or names) is stored for web analysis, A/B testing, and optimization; instead, pseudonyms are used. 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 processes.

  • 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 people: 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); tracking (e.g. interest/behavior-related profiling, use of cookies); provision of our online offer and user-friendliness.
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Article 6 (1) sentence 1 lit. a. GDPR).

Further information on processing procedures, methods and services:

 

Online marketing

We process personal data for the purposes of online marketing, which may include, in particular, the marketing of advertising space or the presentation of advertising and other content (collectively referred to as “content”) based on 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 processes are used to store user information relevant to the presentation of the aforementioned content. This information may include, for example, content viewed, websites visited, online networks used, as well as communication partners and technical information such as the browser used, the computer system used, as well as information on usage times and functions used. If users have consented to the collection of their location data, this may also be processed.

Users' IP addresses are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no real user data (such as email addresses or names) is stored as part of the online marketing process; instead, pseudonyms are used. This means that neither we nor the providers of the online marketing process know the actual identity of the users, only the information stored in their profiles.

The information in profiles is usually stored in cookies or similar processes. These cookies can generally also be read later on other websites that use the same online marketing process, analyzed for the purpose of displaying content, and supplemented with additional data and stored on the server of the online marketing process provider.

In exceptional cases, clear data may be assigned to profiles. This is the case, for example, if users are members of a social network whose online marketing processes we use, and the network links the users' profiles with the aforementioned information. Please note that users may enter into additional agreements with the providers, e.g., by providing consent during registration.

We generally only receive access to aggregated information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes led to a so-called conversion, i.e., to the conclusion of a contract with us. Conversion measurements are 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.

  • 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 people: 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-related profiling, use of cookies); profiles with user-related information (creation of user profiles); provision of our online offer and user-friendliness; marketing.
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Article 6 (1) sentence 1 lit. a. GDPR).
  • Opt-out option: We refer to the privacy policies of the respective providers and the opt-out options provided for each provider. If no explicit opt-out option has been provided, you can disable cookies in your browser settings. However, this may limit the functionality of our online offering. We therefore recommend the following additional opt-out options, which are summarized for each area:

    a) Europe: https://www.youronlinechoices.eu.
    b) Canada: https://www.youradchoices.ca/choices.
    c) United States: https://www.aboutads.info/choices.
    d) Cross-regional: https://optout.aboutads.info.

Further information on processing procedures, methods and services:

  • Facebook Pixel and target group creation (Custom Audiences): With the help of the Facebook pixel (or comparable functions for transmitting event data or contact information via interfaces in apps), Facebook is able to determine visitors to our online offering as a target group for the display of advertisements (so-called "Facebook Ads"). Accordingly, we use the Facebook pixel to display the Facebook ads we place only to users on Facebook and within the services of partners cooperating with Facebook (so-called "Audience Network"). https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offering or who 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 interests of users and do not appear annoying. 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; Legal basis: Consent (Article 6 (1) sentence 1 lit. a. GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Standard contractual clauses (ensuring data protection levels when processing in third countries): The “Facebook EU Data Transfer Supplement” (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 advertising; Additional Information: The �Data Processing Conditions� (https://www.facebook.com/legal/terms/dataprocessing/update) with regard to event data that Facebook processes on its behalf to provide companies with reports and analyses; Furthermore, the "Controller Addendum" is considered a joint controllership agreement (Article 26 (1) (3) GDPR), which is relevant in the case of Facebook's independent processing of event data for the purposes of targeting, improving, and securing Facebook products.

 

Affiliate programs and affiliate links

We integrate so-called affiliate links or other references (which may include, for example, search masks, widgets, or discount codes) to offers and services from third-party providers (collectively referred to as "affiliate links") into our online offering. If users follow the affiliate links or subsequently take advantage of the offers, we may receive a commission or other benefits from these third-party providers (collectively referred to as "commission").

In order to track whether users have taken advantage of the offers of an affiliate link we use, it is necessary for the respective third-party providers to know that users have followed an affiliate link used within our online offering. The assignment of the affiliate links to the respective business transactions or other actions (e.g., purchases) serves solely the purpose of commission settlement and is canceled as soon as it is no longer required for this purpose.

For the purposes of the aforementioned assignment of affiliate links, the affiliate links may be supplemented with certain values that are part of the link or can be stored otherwise, e.g., in a cookie. These values may include, in particular, the source website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer, and an online identifier of the user.

Notes on legal basis: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-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: 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 people: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Affiliate tracking.
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

 

Customer reviews and rating processes

We participate in review and rating processes to evaluate, optimize, and promote our services. If users rate us via the participating rating platforms or processes or otherwise provide feedback, the providers' general terms and conditions of use and privacy policies also apply. Typically, the rating also requires registration with the respective providers.

To ensure that the reviewers have actually used our services, we transmit, with the customer's consent, the necessary data regarding the customer and the service used to the respective review platform (including name, email address, and order number or item number). This data is used solely to verify the user's authenticity.

  • Types of data processed: 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 people: Customers; users (e.g. website visitors, users of online services).
  • Purposes of processing: Feedback (e.g. collecting feedback via online form); Marketing.
  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Further information on processing procedures, methods and services:

 

Presences in social networks (social media)

We maintain online presences within social networks and, in this context, process user data 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 could pose risks for users, for example, because it could 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, user profiles can be created based on user behavior and the resulting interests of the users. These user profiles can then be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are generally stored on users' computers in which the user behavior and interests are saved. Furthermore, user profiles can also store data independent of the devices used by the users (particularly if the users are members of the respective platforms and are logged in to them).

For a detailed description of the respective processing methods and the options for opting out, please refer to the privacy policies 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 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 directly take appropriate measures and provide information. If you still need 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 data (e.g., device information, IP addresses).
  • Affected people: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Contact requests and communication; feedback (e.g. collecting feedback via online form); marketing.
  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Further information on processing procedures, methods and services:

 

Management, organization and tools

We use services, platforms, and software from other providers (hereinafter referred to as "third-party providers") for the purposes of organizing, managing, planning, and providing our services. We comply with legal requirements when selecting third-party providers and their services.

In this context, personal data may be processed and stored on the servers of third-party providers. This may affect various data that we process in accordance with this privacy policy. This data may include, in particular, user master data and contact details, data on transactions, contracts, other processes, and their content.

If users are referred to third-party providers or their software or platforms as part of their communication, business, or other relationships with us, these third-party providers may process usage data and metadata for security purposes, service optimization, or marketing purposes. We therefore ask you to observe the privacy policies of the respective third-party providers.

  • 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); contract data (e.g., subject matter of the contract, term, customer category).
  • Affected people: Communication partners; users (e.g. website visitors, users of online services); interested parties; business and contractual partners.
  • Purposes of processing: Provision of contractual services and customer service; office and organizational procedures; contact requests and communication; reach measurement (e.g. access statistics, recognition of recurring visitors); remarketing; conversion measurement (measurement of the effectiveness of marketing measures); marketing; profiles with user-related information (creation of user profiles).
  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Further information on processing procedures, methods and services:

 

Changes and updates to the privacy policy

We ask you to inform yourself regularly about the content of our privacy policy. We will adapt 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 your cooperation (e.g., consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting us.

 

Rights of the data subjects

As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:

  • Right of objection: You have the right to object at any time to the processing of personal data concerning you based on Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct marketing.
  • Right of revocation for consent: You have the right to revoke your consent at any time.
  • Right of providing information: 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 statutory requirements.
  • Right to rectification: In accordance with the statutory provisions, you have the right to request that the data concerning you be completed or that inaccurate data concerning you be corrected.
  • Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to request that data concerning you be deleted immediately or, alternatively, to request that the processing of the data be restricted in accordance with the statutory provisions.
  • Right to data portability: You have the right to receive the 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 transmitted to another controller.
  • Complaint to the supervisory authority: In accordance with the statutory provisions 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 habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

 

Definitions

This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined primarily in Art. 4 GDPR. The legal definitions are binding. The following explanations, however, are primarily intended to facilitate understanding. The terms are sorted alphabetically.

  • Affiliate Tracking: As part of affiliate tracking, links that link websites to websites with product or other offers are logged. The operators of the respective linking websites can receive a commission if users follow these so-called affiliate links and subsequently take advantage of the offers (e.g., purchase goods or use services). To do this, it is necessary for the providers to be able to track whether users who are interested in certain offers subsequently take advantage of them as a result of the affiliate links. Therefore, for affiliate links to function properly, they must be supplemented with certain values that become part of the link or are stored elsewhere, e.g., in a cookie. These values include, in particular, the source website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as tracking-specific values, such as advertising material ID, partner ID, and categorizations.
  • Conversion measurement: Conversion measurement (also known as "visit action analysis") is a method used to determine the effectiveness of marketing measures. This typically involves storing a cookie on users' devices within the websites where the marketing measures are carried out and then retrieving it on the target website. For example, this allows us to understand whether the ads we place on other websites were 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. a cookie) or to 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 consisting of the use of 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 relating to 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 visitor traffic to an online offering and can include visitor behavior or interests in specific information, such as website content. With the help of reach analysis, website owners can, for example, identify when visitors visit their website and what content they are interested in. This allows them to, for example, better tailor website content to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
  • Remarketing: “Remarketing” or “retargeting” is the term used 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.
  • Tracking: "Tracking" occurs when user behavior can be tracked across multiple online offerings. Typically, behavioral and interest information related to the online offerings used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
  • Responsible: The “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of the processing of personal data.
  • Processing: "Processing" is any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, whether it involves collecting, analyzing, storing, transmitting, or deleting.
 
 

Imprint

Gamesright GmbH
Esplanade 41
20354 Hamburg

contact (at) gamesright.de

Please understand that we cannot offer telephone support.

District Court of Hamburg, HRB 175203
VAT identification number: not yet known
Authorized representative: Jan Beuck

In the event of a dispute regarding our contract, we will endeavor to resolve it amicably with you. Furthermore, we are not obligated to participate in dispute resolution proceedings and do not participate in dispute resolution proceedings before a consumer arbitration board.

The European Commission provides an online platform for out-of-court dispute resolution. The dispute resolution platform can be accessed via the following link:
http://ec.europa.eu/consumers/odr/