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Privacy Policy
As of March 16th, 2025
Preamble
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 “online offering”).
The terms used are not gender-specific.
The English language version of this data privacy information valid at the time of the conclusion of the contract is decisive.
In the event of revocation, the legality of the data processing up to the time of revocation is not affected. CuraPalma may cancel any orders dependent on this at the customer’s expense.
Table of Contents
- Preamble
- Person responsible
- Overview of processing
- Relevant legal bases
- Security measures
- Transmission of personal data
- International data transfers
- General information on data storage and deletion
- Rights of data subjects
- Business services
- Business processes and procedures
- Use of online platforms for offer and sales purposes
- Payment methods
- Provision of the online service and web hosting
- Use of cookies
- Registration, login and user account
- Newsletters and electronic notifications
- Advertising communication via email, post, fax or telephone
- Web analysis, monitoring and optimization
- Online marketing
- Presence in social networks (Social Media)
- Plug-ins and embedded functions and content
- Change and update
- Definitions of terms
Person responsible
Mag. Renate Reingrabner
Florianiplatz 8
7141 Podersdorf am See
Email Address: renate.reingrabner@curapalma.eu
Imprint: CuraPalma.eu
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.
- Location data.
- Contact details.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and procedural data.
- Log data.
Categories of data subjects
- Service recipient and client.
- Employees.
- Interested parties.
- Communication partner.
- Users.
- Business and contractual partners.
- Third parties.
- Customers.
Purposes of processing
- Provision of contractual services and fulfillment of contractual obligations.
- Communication.
- Security measures.
- Direct marketing.
- Reach measurement.
- Tracking.
- Office and organizational procedures.
- Conversion measurement.
- Target group formation.
- Organizational and administrative procedures.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online offering and user-friendliness.
- Information technology infrastructure.
- Financial and payment management.
- Public relations.
- Sales promotion.
- Business processes and business procedures.
Relevant legal bases
Relevant legal bases under the DSGVO / GDPR: Below you will find an overview of the legal bases under the DSGVO / GDPR on which we process personal data. Please note that in addition to the provisions of the DSGVO / GDPR, 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 (Article 6 (1) (a) DSGVO / GDPR) – The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
- Contractual performance and pre-contractual inquiries (Article 6 (1) (b) DSGVO / GDPR) – Processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.
- Legal obligation (Article 6 (1) (c) DSGVO / GDPR) – Processing is necessary to fulfill a legal obligation to which the controller is subject.
- Legitimate interests (Article 6 (1) (f) DSGVO / GDPR) – processing is necessary to protect the legitimate interests of the controller or a third party, provided that the interests, fundamental rights and freedoms of the data subject which require protection of personal data do not override them.
National data protection regulations in Austria: In addition to the data protection regulations of the DSGVO / GDPR, national data protection regulations apply in Austria. These include, in particular, the Federal Act on the Protection of Natural Persons with regard to the Processing of Personal Data (Data Protection Act – DSG). The Data Protection Act contains, in particular, special provisions on the right to information, the right to rectification or erasure, the processing of special categories of personal data, processing for other purposes and transmission, and automated decision-making in individual cases.
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 transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs as part of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies (which can be identified by the postal address of the respective provider or if the data transfer to third countries is expressly referred to in the data protection declaration), this is always done in accordance with the legal requirements.
For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission dated July 10, 2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and establish contractual obligations to protect your data.
This dual safeguard ensures comprehensive protection of your data: The DPF forms the primary layer of protection, while the standard contractual clauses serve as an additional safeguard. Should changes occur within the framework of the DPF, the standard contractual clauses act as a reliable fallback option. This ensures that your data always remains adequately protected, even in the event of any political or legal changes.
For each service provider, we will inform you whether they are certified under the Data Privacy Framework and whether they have standard contractual clauses in place. Further information on the Data Privacy Framework and a list of certified companies can be found on the U.S. Department of Commerce website at https://www.dataprivacyframework.gov/ .
Appropriate security measures apply to data transfers to other third countries, in particular standard contractual clauses, explicit consent, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found in the EU Commission’s information offering: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.
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:
- Retention and deletion of data: The following general periods apply to retention and archiving under Austrian law:
- 10 years – retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting documents and invoices as well as all necessary work instructions and other organizational documents (Federal Tax Code (BAO §132), Commercial Code (UGB §§190-212)).
- 6 years – Other business documents: Received commercial or business letters, copies of sent commercial or business letters, and other documents, provided they are relevant for tax purposes. These include, for example, hourly wage slips, operating statements, calculation documents, price labels, and payroll documents, provided they are not already accounting documents and cash register slips (Federal Tax Code (BAO §132), Commercial Code (UGB §§190-212)).
- 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 common industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 1478, 1480 ABGB).
Rights of data subjects
Rights of data subjects under the DSGVO / GDPR: As a data subject, you are entitled to various rights under the DSGVO / GDPR, which arise in particular from Articles 15 to 21 DSGVO / 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) DSGVO / 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 to withdraw consent: You have the right to withdraw consent at any time.
- Right to information: You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with the legal requirements.
- Right to rectification: You have the right, in accordance with the statutory provisions, to request that the data concerning you be completed or that inaccurate data concerning you be corrected.
- Right to erasure and restriction of processing: You have the right, in accordance with the statutory provisions, to demand that data concerning you be erased immediately or, alternatively, to demand 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 a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you violates the provisions of the DSGVO / 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, etc.), 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); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
- Data subjects: Service recipients and clients; interested parties; business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; security measures; communication; office and organizational procedures; organizational and administrative procedures. Business processes and operational procedures.
- 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) DSGVO / GDPR); Legal obligation (Art. 6 (1) (c) DSGVO / GDPR); Legitimate interests (Art. 6 (1) (f) DSGVO / GDPR).
Further information on processing procedures, methods and services:
- Online shop, order forms, e-commerce and delivery: We process our customers’ data to enable them to select, purchase, or order the selected products, goods, and related services, as well as to 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 required for delivery, provision, and billing, as well as contact information for any possible follow-up. Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) DSGVO / 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 passed on to third parties if this is necessary to fulfil the stated purposes or legal obligations.
- Types of data processed: Inventory data (e.g. full name, home address, contact information, customer number, Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses); Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as authorship details); 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 ); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, parties involved ). Protocol data (e.g. log files relating to logins or the retrieval of data ).
- Affected persons: Service recipients and clients; interested parties; communication partners; business and contractual partners; customers; third parties; users (e.g. website visitors, users of ). Employees (e.g. employees, applicants, temporary workers and others ).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; office and organizational procedures; business processes and commercial procedures; security measures; provision of our online offering and user-friendliness; communication; marketing; sales promotion; public relations; financial and payment management. Information technology infrastructure (operation and provision of information systems and technical devices (computers, ).
- 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) DSGVO / GDPR); legitimate interests (Art. 6 (1) (f) DSGVO / GDPR); legal obligation (Art. 6 (1) (c) DSGVO / GDPR).
Further information on processing procedures, methods and services:
- Contact management and contact maintenance: Procedures that are necessary for the organization, maintenance and security of contact information (e.g. setting up and maintaining a central contact database, regular updates to contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, carrying out backups and restores of contact details, training employees in effective ; Legal bases: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) DSGVO / GDPR), legitimate interests (Art. 6 (1) (f) DSGVO / GDPR).
- Customer account: Customers can create an account within our online offering (e.g., customer or user account, or “customer account” for short). If registration of a customer account is required, customers will be informed of this, as well as the information required for registration. Customer accounts are not public and cannot be indexed by search engines. During registration, as well as subsequent logins and use of the customer account, we store the customer’s IP addresses along with the access times in order to verify registration and prevent any misuse of the customer account. If the customer account is terminated, the customer account data will be deleted after the termination date, unless it is retained for purposes other than providing the customer account or must be retained for legal reasons (e.g., internal storage of customer data, order processes, or invoices). It is the customer’s responsibility to back up their data upon termination of the customer account; Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) DSGVO / GDPR), legitimate interests (Art. 6 (1) (f) DSGVO / GDPR).
- General payment transactions: Procedures required for carrying out payment transactions, monitoring bank accounts and controlling payment flows (e.g. creating and checking transfers, processing direct debits, checking account statements, monitoring ; Legal bases: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) DSGVO / GDPR), legitimate interests (Art. 6 (1) (f) DSGVO / GDPR).
- Accounting, accounts payable, accounts receivable: Procedures required for recording, processing, and controlling business transactions in the area of accounts payable and accounts receivable accounting (e.g. creation and checking of incoming and outgoing invoices, monitoring and management of open items, execution of payment transactions, processing of dunning procedures, account reconciliation – This text area must be activated with a premium license. – ; Legal bases: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) DSGVO / GDPR), legal obligation (Art. 6 (1) (c) DSGVO / GDPR), legitimate interests (Art. 6 (1) (f) DSGVO / 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 assignment and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, processing of dunning procedures, account reconciliation, ; Legal bases: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) DSGVO / GDPR), Legal obligation (Art. 6 (1) (c) DSGVO / GDPR), Legitimate interests (Art. 6 (1) (f) DSGVO / GDPR).
- Marketing, advertising and sales promotion: Procedures that are necessary within the framework of marketing, advertising and sales promotion (e.g. market analysis and target group determination, 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, ; Legal basis: Legitimate interests (Art. 6 (1) (f) DSGVO / GDPR).
- Economic analyses and market research: To fulfill business purposes and to identify market trends and the wishes of contractual partners and users, the available data on business transactions, contracts, inquiries, etc. are analyzed. Data subjects may include contractual partners, interested parties, customers, visitors, and users of the controller’s online offering. The analyses are carried out for the purposes of business evaluations, marketing, and market research (e.g., to determine customer groups with different characteristics). Profiles of registered users, where available, along with their information on the services used, are taken into account. The analyses serve the sole purpose of the controller and are not disclosed externally, unless they are anonymous analyses with summarized, i.e., anonymized values. Furthermore, user privacy is taken into account; the data is processed pseudonymously for analysis purposes wherever possible and, where feasible, anonymized (e.g., as summarized data). Legal basis: legitimate interests (Art. 6 (1) (f) DSGVO / GDPR).
- Public relations: Procedures that are 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, preparation of ; Legal basis: Legitimate interests (Art. 6 (1) (f) DSGVO / GDPR).
Use of online platforms for offer and sales purposes
We offer our services on online platforms operated by other service providers. In this context, the privacy policies of the respective platforms apply in addition to our privacy policy. This applies in particular with regard to the execution of the payment process and the methods used on the platforms for reach measurement and interest-based marketing.
- 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); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
- Affected persons: Service recipients and clients. Business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; marketing. Business processes and operational procedures.
- 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) DSGVO / GDPR). Legitimate interests (Art. 6 (1) (f) DSGVO / GDPR).
Further information on processing procedures, methods and services:
- eBay: Online marketplace for e-commerce; Service provider: eBay Marketplaces GmbH, Helvetiastrasse 15/17, 3005 Bern, Switzerland; Legal basis: Legitimate interests (Art. 6 (1) (f) DSGVO / GDPR); Website: https://www.ebay.de/ ; Privacy policy: https://www.ebay.de/help/policies/member-behavior-policies/datenschutzerklrung?id=4260 . Data processing agreement: Provided by the service provider.
- Etsy: Online marketplace for e-commerce; Service provider: Etsy, Inc., 55 Washington Street, Suite 712, Brooklyn, NY 11201, USA; Legal basis: Legitimate interests (Art. 6 (1) (f) DSGVO / GDPR); Website: https://www.etsy.com/de . Privacy policy: https://www.etsy.com/de/legal/privacy/?ref=ftr .
- Shopify: Platform through which e-commerce services are offered and carried out. The services and processes carried out in connection with them include, in particular, online shops, websites, their offers and content, community elements, purchase and payment transactions, customer communication, as well as analysis and marketing. Service provider: Shopify International Limited, Victoria Buildings, 2nd Floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland. Legal basis: Legitimate interests (Art. 6 (1) (f) DSGVO / GDPR). Website: https://www.shopify.com/de/ . Privacy policy: https://www.shopify.com/de/legal/datenschutz .
- Google Merchant: Platform through which e-commerce services are offered and carried out. Service provider: Google LLC , 1600 Amphitheatre Parkway Mountain View, CA 94043 United States Legal basis: Legitimate interests (Art. 6 (1) (f) DSGVO / GDPR). Website: https://www.google.com/ . Privacy policy: https://policies.google.com/privacy?hl=en-US
Payment methods
Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the data subjects efficient and secure payment options and, in addition to banks and credit institutions, we use other service providers for this purpose (collectively “payment service providers”).
The data processed by the payment service providers includes inventory data such as name and address, bank details such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, amount, and recipient-related information. This information is required to process the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account- or credit card-related information, only information confirming or rejecting the payment. Under certain circumstances, the payment service providers may transmit the data to credit agencies. This transmission is for the purpose of identity and credit checks. For more information, please refer to the terms and conditions and the privacy policy of the payment service providers.
Payment transactions are subject to the terms and conditions and privacy policy of the respective payment service providers, which are available on the respective websites or transaction applications. We also refer to these for further information and to assert your rights of withdrawal, information, and other data subjects.
- 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); 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); 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).
- Data subjects: Service recipients and clients; business and contractual partners; interested parties; users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; business processes and administrative procedures; feedback (e.g., collecting feedback via online form).
- 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) DSGVO / GDPR). Legitimate interests (Art. 6 (1) (f) DSGVO / GDPR).
Further information on processing procedures, methods and services:
- Amazon Payments: Payment services (technical connection of online payment methods); Service provider: Amazon Payments Europe SCA, 38 avenue JF Kennedy, L-1855 Luxembourg; Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) DSGVO / GDPR); Website: https://pay.amazon.de/ . Privacy policy: https://pay.amazon.de/help/201212490 .
- American Express: Payment services (technical connection of online payment methods); Service provider: American Express Europe SA, Theodor-Heuss-Allee 112, 60486 Frankfurt am Main, Germany; Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) DSGVO / GDPR); Website: https://www.americanexpress.com/de/ . Privacy policy: https://www.americanexpress.com/de-de/firma/legal/datenschutz-center/online-datenschutzerklarung/ .
- Apple Pay: Payment services (technical connection of online payment methods); Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) DSGVO / GDPR); Website: https://www.apple.com/de/apple-pay/ . Privacy policy: https://www.apple.com/legal/privacy/de-ww/ .
- Flattr: Flattr – online payment and donation service; Service provider: Flattr AB, Box 4111, 203 12 Malmö, Sweden; Legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) DSGVO / GDPR); Website: https://flattr.com/ . Privacy policy: https://flattr.com/privacy .
- Google Pay: Payment services (technical connection of online payment methods); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) DSGVO / GDPR); Website: https://pay.google.com/intl/de_de/about/ . Privacy policy: https://policies.google.com/privacy .
- Klarna: Payment services (technical connection of online payment methods); Service provider: Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden; Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) DSGVO / GDPR); Website: https://www.klarna.com/de . Privacy policy: https://www.klarna.com/de/datenschutz .
- Mastercard: Payment services (technical connection of online payment methods); Service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) DSGVO / GDPR); Website: https://www.mastercard.de/de-de.html . Privacy policy: https://www.mastercard.de/de-de/datenschutz.html .
- PayPal: Payment services (technical connection of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à rl et Cie, SCA, 22-24 Boulevard Royal, L-2449 Luxembourg; Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) DSGVO / GDPR); Website: https://www.paypal.com/de . Privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full .
- Stripe: Payment services (technical connection of online payment methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) DSGVO / GDPR); Website: https://stripe.com ; Privacy Policy: https://stripe.com/de/privacy . Basis for third-country transfers: Data Privacy Framework (DPF), Data Privacy Framework (DPF).
- Visa: Payment services (technical connection of online payment methods); Service provider: Visa Europe Services Inc., London branch, 1 Sheldon Square, London W2 6TT, GB; Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) DSGVO / GDPR); Website: https://www.visa.de . Privacy policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html .
Provision of the online service 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).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online services and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
- 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) DSGVO / GDPR).
Further information on processing procedures, methods and services:
- Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity, and software that we rent from a corresponding server provider (also called a “web host”) or obtain from other sources; legal basis: legitimate interests (Art. 6 (1) (f) DSGVO / GDPR).
- Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files.” 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, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. Server log files may be used for security purposes, e.g., to prevent server overload (particularly in the case of abusive attacks, so-called DDoS attacks), and to ensure server utilization and stability; legal basis: legitimate interests (Art. 6 (1) (f) DSGVO / 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 will not be deleted until the incident in question has been finally resolved.
- 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 (Art. 6 Para. 1 S. 1 lit. f) DSGVO / 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), standard contractual clauses (provided by the service provider), Data Privacy Framework (DPF) standard contractual clauses (provided by the service provider).
- WooCommerce.com: Hosting and software for the creation, provision and operation of webshops together with WordPress; Service provider: WooCommerce Ireland Ltd., Grand Canal Dock, 25 Herbert Pl; Dublin, D02 AY86; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) DSGVO / GDPR); Website: https://woocommerce.com/ ; Privacy policy: https://woocommerce.com/document/subscriptions/gdpr/ ; Data processing agreement: https://wordpress.com/support/data-processing-agreements/ . Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (provided by the service provider), Data Privacy Framework (DPF) standard contractual clauses (provided by the service provider).
- Hostinger.de: Hosting of WordPress, WooCommerce and other PlugIns for hosting services, VPS services, Email services, domain services, website builder, Hostinger Horizons; Service provider: Hostinger International Ltd. 61 Lordou Vironos str., 6023 Larnaca, Cyprus; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) DSGVO / GDPR); Website: https://hostinger.de ; Privacy policy: https://www.hostinger.com/de/legal ; Data processing agreement: https://www.hostinger.com/de/legal/dpa . Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (provided by the service provider), Data Privacy Framework (DPF) standard contractual clauses (provided by the service provider).
Use of cookies
The term “cookies” refers to functions that store information on users’ end devices and read it from them. Cookies can also be used for a variety of purposes, such as ensuring the functionality, security, and convenience of online services, as well as creating analyses of visitor flows. We use cookies in accordance with legal regulations. Where necessary, we obtain users’ consent in advance. If consent is not required, we rely on our legitimate interests. This applies when storing and reading information is essential to providing expressly requested content and functions. This includes saving settings and ensuring the functionality and security of our online service. Consent can be revoked at any time. We provide clear information about the scope of cookies and which cookies are used.
Notes on data protection law: Whether we process personal data using cookies depends on consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and processes.
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 to measure reach. 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 that the storage period can be 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 the legal requirements, including by using 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).
- Data subjects: Users (e.g. website visitors, users of online services).
- Legal basis: Legitimate interests (Art. 6 (1) (f) DSGVO / GDPR). Consent (Art. 6 (1) (a) DSGVO / 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, in particular 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 be able 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 on 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 (Art. 6 (1) (a) DSGVO / GDPR).
Registration, login and user account
Users can create a user account. During registration, users are provided with the required mandatory information and processed for the purpose of providing the user account based on contractual obligations. The processed data includes, in particular, login information (username, password, and an email address).
When you use our registration and login functions, as well as your user account, we store your IP address and the time of each user action. This storage is based on our legitimate interests and those of the users in protecting against misuse and other unauthorized use. This data will generally not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users may be informed by email about events relevant to their user account, such as technical changes.
- 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); log data (e.g., log files relating to logins or data retrieval or access times).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; security measures; organizational and administrative procedures; provision of our online offering and user-friendliness.
- Retention and deletion: Deletion in accordance with the information in the “General Information on Data Storage and Deletion” section. Deletion after termination.
- Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) DSGVO / GDPR). Legitimate interests (Art. 6 (1) (f) DSGVO / GDPR).
Further information on processing procedures, methods and services:
- Registration with real name: Due to the nature of our community, we ask users to use our services only using their real names. This means that the use of pseudonyms is not permitted. Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) DSGVO / GDPR).
- User profiles are not public: User profiles are not publicly visible or accessible.
- Deletion of data after termination: If users have terminated their user account, their data relating to the user account will be deleted, subject to legal permission, obligation, or consent of the user; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) DSGVO / GDPR).
- No obligation to retain data: It is the responsibility of the user to back up their data upon termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract. Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) DSGVO / GDPR).
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. Content:
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); metadata, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
- Data subjects: communication partners.
- Purposes of processing: Direct marketing (e.g. by email or post).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) DSGVO / GDPR).
- Opt-out: You can unsubscribe from our newsletter at any time, i.e., revoke your consent or object to further receipt. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or by using one of the contact options listed above, preferably email.
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 email, telephone, mail 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., 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 posts, as well as related information, such as authorship or time of creation).
- Data subjects: communication partners.
- Purposes of processing: Direct marketing (e.g., by email or post); marketing. Sales promotion.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal basis: Consent (Art. 6 (1) (a) DSGVO / GDPR). Legitimate interests (Art. 6 (1) (f) DSGVO / 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, 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 procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
- Data subjects: 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.
- Retention and Deletion: Deletion as described in the “General Information on Data Retention and Deletion” section. Cookies are retained 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 (Art. 6 (1) (a) DSGVO / GDPR). Legitimate interests (Art. 6 (1) (f) DSGVO / 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 recognize which content users have accessed within one or more usage processes, which search terms they 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.
Pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used for this purpose. 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 data traffic, the IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. It is not logged, is not accessible, and is not used for any other purposes. 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 (Art. 6 (1) (a) DSGVO / 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), Standard Contractual Clauses ( https://business.safety.google/adsprocessorterms ), Data Privacy Framework (DPF) Standard Contractual Clauses ( https://business.safety.google/adsprocessorterms ); Opt-out option: Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de , Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff . Further information: https://business.safety.google/adsservices/ (types of processing and data processed). - Google Tag Manager: We use Google Tag Manager, a tool from Google, to centrally manage so-called website tags via a user interface. Tags are small code elements on our website that are used, among other things, to measure and analyze visitor activity. This technology helps us improve our website and the services it offers. Google Tag Manager itself does not create user profiles, does not store cookies, and does not perform any independent analyses. It merely serves to make the integration of the tools and services we use for our website easier and more efficient. Nevertheless, when Google Tag Manager is used, the user’s IP address is transmitted to Google, which is technically necessary to run the various services we use. It is important to know that this data processing only takes place if services that require it are integrated via Tag Manager. For details about these services and how they process data, 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 (Art. 6 Para. 1 S. 1 lit. a) DSGVO / 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), Standard Contractual Clauses ( https://business.safety.google/adsprocessorterms ), Data Privacy Framework (DPF) Standard Contractual Clauses ( https://business.safety.google/adsprocessorterms ). Further information: https://business.safety.google/adsservices/ (types of processing and data processed). - Jetpack (WordPress Stats): Jetpack offers analysis functions for WordPress software;
Service provider: Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) DSGVO / GDPR); Website: https://automattic.com ; Privacy policy: https://automattic.com/privacy ; Data processing agreement: Provided by the service provider. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (Provided by the service provider), Data Privacy Framework (DPF) Standard Contractual Clauses (Provided by the service provider).
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 potential user interests and the measurement of its 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, but also 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, 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 bases: 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) Europa: https://www.youronlinechoices.eu.
b) Canada: https://www.youradchoices.ca/choices.
c) USA: https://www.aboutads.info/choices.
d) Cross-territory: https://optout.aboutads.info.
- 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).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest-/behavioral profiling, use of cookies); target group building; marketing; profiles with user-related information (creation of user profiles); conversion measurement (measurement of the effectiveness of marketing measures).
- Retention and Deletion: Deletion as described in the “General Information on Data Retention and Deletion” section. Cookies are retained 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 (Art. 6 (1) (a) DSGVO / GDPR). Legitimate interests (Art. 6 (1) (f) DSGVO / GDPR).
Further information on processing procedures, methods and services:
- Google Ads and conversion measurement: Online marketing methods for placing content and ads within the service provider’s advertising network (e.g., in search results, in videos, on websites, 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 (Art. 6 (1) (a) DSGVO / GDPR), Legitimate interests (Art. 6 (1) (f) DSGVO / GDPR); Website: https://marketingplatform.google.com ; Privacy policy: https://policies.google.com/privacy ; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/ . Data processing conditions between controllers and standard contractual clauses for third-country transfers of data: https://business.safety.google/adscontrollerterms .
- Google Adsense with personalized ads: We integrate the Google Adsense service, which enables personalized ads to be placed on our website. 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 (Art. 6 (1) (a) DSGVO / GDPR); Website: https://marketingplatform.google.com ; Privacy policy: https://policies.google.com/privacy ; Basis for third country transfers: Data Privacy Framework (DPF), Data Privacy Framework (DPF); Further 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 place 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 content of the page or your approximate geographical location. We receive compensation for displaying or otherwise using these ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 (1) (a) DSGVO / GDPR); Website: https://marketingplatform.google.com ; Privacy policy: https://policies.google.com/privacy ; Basis for third country transfers: Data Privacy Framework (DPF), Data Privacy Framework (DPF); Further 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 .
Presence in social networks (Social Media)
We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This 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 to place advertisements within and outside the networks that presumably correspond to the users’ interests. Therefore, cookies are generally stored on users’ computers to store user behavior and interests. 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 duration of visits, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and features).
- Data subjects: 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 (Art. 6 (1) (f) DSGVO / GDPR).
Further information on processing procedures, methods and services:
- Instagram: Social network, enables the sharing of photos and videos, commenting on 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 (Art. 6 Para. 1 S. 1 lit. f) DSGVO / GDPR); Website: https://www.instagram.com ; Privacy policy: https://privacycenter.instagram.com/policy/ . Basis for third country transfers: Data Privacy Framework (DPF), 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 users use (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 described in the Facebook Data Policy under “How do we use this information?” explains, Facebook also collects and uses information to provide analysis services, so-called “Page Insights,” for page operators so that they can gain insights into how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook (“Information about Page Insights,” 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, direct Facebook to requests for information or deletion). The rights of users (in particular 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 about 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 the 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 (Art. 6 (1) (f) DSGVO / GDPR). Website: https://www.facebook.com ; Privacy Policy: https://www.facebook.com/privacy/policy/ . Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum ), Data Privacy Framework (DPF) Standard Contractual Clauses ( https://www.facebook.com/legal/EU_data_transfer_addendum ).
- YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) DSGVO / GDPR); Privacy policy: https://policies.google.com/privacy ; Basis for third-country transfers: Data Privacy Framework (DPF), 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, since 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 bases: 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); location data (information on the geographical position of a device or person); 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).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offering and user-friendliness; reach measurement (e.g., access statistics, recognition of recurring visitors); tracking (e.g., interest-/behavior-based profiling, use of cookies); target group formation; marketing. Profiles with user-related information (creation of user profiles).
- Retention and Deletion: Deletion as described in the “General Information on Data Retention and Deletion” section. Cookies are retained 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 (Art. 6 (1) (a) DSGVO / GDPR). Legitimate interests (Art. 6 (1) (f) DSGVO / GDPR).
Further information on processing procedures, methods and services:
- Google Fonts (provision on our own server): Provision of font files for the purpose of a user-friendly presentation of our online offering; Service provider: The Google Fonts are hosted on our server; no data is transmitted to Google; Legal basis: Legitimate interests (Art. 6 (1) (f) DSGVO / GDPR).
- Google Fonts (obtained from Google servers): 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. This data may be processed on a server of the font provider in the USA. When visiting our online offering, users’ browsers send their browser HTTP requests to the Google Fonts Web API (i.e., a software interface for retrieving fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) from Google Fonts and then the fonts specified in the CCS. These HTTP requests include (1) the IP address used by the user to access the internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user agent, which describes the browser and operating system versions of website visitors, and the referring URL (i.e., the web page where the Google font should be displayed). IP addresses are neither logged nor stored on Google servers, and they are not analyzed. The Google Fonts Web API logs details of the HTTP requests (requested URL, user agent, and referring URL). Access to this data is limited and tightly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. The Google Fonts Web API requires the user agent to customize the font generated for each browser type. The user agent is logged primarily for debugging purposes and used to generate aggregated usage statistics that measure the popularity of font families. These aggregated usage statistics are published on the Google Fonts Analytics page. Finally, the referring URL is logged so that the data can be used for production maintenance and to generate an aggregated report on top integrations based on the number of font requests. Google states that it does not use any of the information collected by Google Fonts to build end-user profiles or target ads; service providers:Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) DSGVO / GDPR); Website: https://fonts.google.com/ ; Privacy policy: https://policies.google.com/privacy ; Basis for third country transfers: Data Privacy Framework (DPF), Data Privacy Framework (DPF). Further information: https://developers.google.com/fonts/faq/privacy?hl=de .
- Google Maps: We integrate maps from the “Google Maps” service provided by Google. The data processed may include, in particular, users’ IP addresses and location data. Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland. Legal basis: Consent (Art. 6 (1) (a) DSGVO / GDPR); Website: https://mapsplatform.google.com/ ; Privacy policy: https://policies.google.com/privacy . Basis for third-country transfers: Data Privacy Framework (DPF).
- YouTube videos: video content; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: consent (Art. 6 (1) (a) DSGVO / GDPR); website: https://www.youtube.com ; privacy policy: https://policies.google.com/privacy ; basis for third country transfers: Data Privacy Framework (DPF). Opt-out option: opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de ; settings for the display of advertisements: https://myadcenter.google.com/personalizationoff .
- YouTube videos: Videos stored on YouTube are embedded within our online offering. These YouTube videos are integrated via a special domain using the “youtube-nocookie” component in the so-called “extended data protection mode”. In “extended data protection mode”, until the video starts, only information such as your IP address and information about your browser and device can be stored on your device in cookies or using comparable processes that YouTube needs to display, control, and optimize the video. As soon as you play the videos, additional information can be processed by YouTube to analyze usage behavior, store it in your user profile, and personalize content and ads. Cookies can be stored for up to two years; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 (1) (a) DSGVO / GDPR); Website: https://www.youtube.com ; Privacy policy: https://policies.google.com/privacy ; Basis for third-country transfers: Data Privacy Framework (DPF), Data Privacy Framework (DPF). Further information: https://support.google.com/youtube/answer/171780?hl=de-DE#zippy=%2Cturn-on-privacy-enhanced-mode%2Cerweiterten-datenschutzmodus-aktivieren .
- Vimeo video player: Integration of a video player; Service provider: Vimeo Inc., Attention: Legal Department, 555 West 18th Street, New York, New York 10011, USA; Legal basis: Legitimate interests (Art. 6 (1) (f) DSGVO / GDPR); Website: https://vimeo.com ; Privacy policy: https://vimeo.com/privacy ; Data processing agreement: https://vimeo.com/enterpriseterms/dpa . Basis for third country transfers: Standard contractual clauses ( https://vimeo.com/enterpriseterms/dpa ), Standard contractual clauses ( https://vimeo.com/enterpriseterms/dpa ).
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 of terms
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 individuals who are employed, 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 performs their work, and the termination when the employment relationship ends, whether by 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 banking 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 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 but also includes metadata that provides information about the content itself, such as tags, descriptions, author information, and publication dates.
- Contact details: Contact details are essential information that enables communication with individuals or organizations. They include, 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.
- Metadata, communication data, 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 may 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, 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.
- 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, for security monitoring, or for generating 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 interests in certain 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 the content of the websites to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
- Location data: Location data is generated when a mobile device (or other device with the technical capabilities for location determination) connects to a cell tower, a Wi-Fi network, or similar technical means and functions for location determination. Location data is used to indicate the geographically identifiable position of the respective device on Earth. Location data can be used, for example, to display map functions or other location-dependent information.
- Tracking: “Tracking” refers to the tracking of user behavior 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.
- Controller: 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, whether or not by automated means. The term is broad and encompasses virtually every type of data handling, including collection, analysis, storage, transmission, or deletion.
- Contract data: Contract data is specific information related 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 data: 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 creation: Target group creation (English: “Custom Audiences”) refers to the creation of target groups for advertising purposes, e.g., the display of advertisements. For example, based on a user’s interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which they viewed the products. “Lookalike Audiences” (or similar target groups), on the other hand, refer to content deemed suitable and 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.
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