Privacy Policy

Preamble

With the following privacy policy we would like to inform you which types of your personal data (hereinafter also abbreviated as “data”) we process for which purposes and in which scope. The privacy statement 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 services”).

The terms used are not gender-specific.

Last Update: 7. August 2022

Table of contents

Controller

Carsten Radatz
Jacobsstraße 15
30449 Hannover
Germany

E-mail address: mail@3mmWargaming.com

Legal Notice: https://www.3mmWargaming.com/legal-notice

Overview of processing operations

The following table summarises the types of data processed, the purposes for which they are processed and the concerned data subjects.

Categories of Processed Data

  • Inventory data.
  • Payment Data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta/communication data.
  • Event Data (Facebook).

Categories of Data Subjects

  • Customers.
  • Prospective customers.
  • Communication partner.
  • Users.

Purposes of Processing

  • Provision of contractual services and customer support.
  • Contact requests and communication.
  • Security measures.
  • Direct marketing.
  • Web Analytics.
  • Affiliate Tracking.
  • Managing and responding to inquiries.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Authentication processes.
  • Provision of our online services and usability.
  • Information technology infrastructure.

Legal Bases for the Processing

In the following, you will find an overview of the legal basis of the GDPR on which we base the processing of personal data. Please note that in addition to the provisions of the GDPR, national data protection provisions of your or our country of residence or domicile may apply. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Article 6 (1) (a) GDPR) – The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  • Performance of a contract and prior requests (Article 6 (1) (b) GDPR) – Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legitimate Interests (Article 6 (1) (f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

In addition to the data protection regulations of the General Data Protection Regulation, national regulations apply to data protection in Germany. This includes in particular the Law on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special provisions on the right to access, the right to erase, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated individual decision-making, including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (§ 26 BDSG), in particular with regard to the establishment, execution or termination of employment relationships as well as the consent of employees. Furthermore, data protection laws of the individual federal states may apply.

Security Precautions

We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, transmission, securing and separation of the data. In addition, we have established procedures to ensure that data subjects’ rights are respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and service providers, in accordance with the principle of privacy by design and privacy by default.

Masking of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not necessary, the IP address is shortened (also referred to as “IP masking”). In this process, the last two digits or the last part of the IP address after a full stop are removed or replaced by wildcards. The masking of the IP address is intended to prevent the identification of a person by means of their IP address or to make such identification significantly more difficult.

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

Transmission of Personal Data

In the context of our processing of personal data, it may happen that the data is transferred to other places, companies or persons or that it is disclosed to them. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are embedded in a website. In such a case, the legal requirements will be respected and in particular corresponding contracts or agreements, which serve the protection of your data, will be concluded with the recipients of your data.

Data Processing in Third Countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third party services or disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements.

Subject to express consent or transfer required by contract or law, we process or have processed the data only in third countries with a recognised level of data protection, on the basis of special guarantees, such as a contractual obligation through so-called standard protection clauses of the EU Commission or if certifications or binding internal data protection regulations justify the processing (Article 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).

Erasure of data

The data processed by us will be erased in accordance with the statutory provisions as soon as their processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or they are not required for the purpose). If the data is not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data will be restricted and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons or for which storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person. In the context of our information on data processing, we may provide users with further information on the deletion and retention of data that is specific to the respective processing operation.

Use of Cookies

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

Information on consent: We use cookies in accordance with the statutory provisions. Therefore, we obtain prior consent from users, except when it is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is strictly necessary in order to provide an information society service explicitly requested by the subscriber or user. The revocable consent will be clearly communicated to the user and will contain the information on the respective cookie use.

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

Retention period: With regard to the retention period, a distinction is drawn between the following types of cookies:

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

General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also file an objection to processing in accordance with the legal requirements in Article 21 GDPR. Users can also declare their objection by means of the settings of their browser, e.g. by deactivating the use of cookies (whereby this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes, can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.Cookie Settings/ Opt-Out:

Change privacy settings Privacy settings history Revoke consents
  • Processed data types: Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of Processing: Provision of our online services and usability.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Processing Cookie Data on the Basis of Consent: We use a cookie management solution in which users’ consent to the use of cookies, or the procedures and providers mentioned in the cookie management solution, can be obtained, managed and revoked by the users. The declaration of consent is stored so that it does not have to be retrieved again and the consent can be proven in accordance with the legal obligation. Storage can take place server-sided and/or in a cookie (so-called opt-out cookie or with the aid of comparable technologies) in order to be able to assign the consent to a user or and/or his/her device. Subject to individual details of the providers of cookie management services, the following information applies: The duration of the storage of the consent can be up to two years. In this case, a pseudonymous user identifier is formed and stored with the date/time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and used end device.
  • Real Cookie Banner: Cookie-Consent Manager; Service provider: devowl.io GmbH, Tannet 12, 94539 Grafling, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://devowl.io/de/wordpress-real-cookie-banner/; Privacy Policy: https://devowl.io/de/datenschutzerklaerung/.

Payment Procedure

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

The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e. we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the terms and conditions and data protection information of the payment service providers.

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

  • Processed data types: Inventory data (e.g. names, addresses); Payment Data (e.g. bank details, invoices, payment history); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Customers; Prospective customers.
  • Purposes of Processing: Provision of contractual services and customer support.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Further information on processing methods, procedures and services used:

  • PayPal: Payment-Service-Provider (technical integration of online-payment-methods) (e.g. PayPal, PayPal Plus, Braintree, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Website: https://www.paypal.com; Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

Provision of online services and web hosting

We process user data in order to be able to provide them with our online services. For this purpose, we process the IP address of the user, which is necessary to transmit the content and functions of our online services to the user’s browser or terminal device.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of Processing: Provision of our online services and usability; Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.).); Security measures.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Provision of online offer on rented hosting space: For the provision of our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also referred to as a “web hoster”); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
  • Collection of Access Data and Log Files: The access to our online services is logged in the form of so-called “server log files”. Server log files may include the address and name of the web pages and files accessed, the date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a general rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the stability and optimal load balancing of the servers; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Retention period: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.
  • ALL-INKL: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: ALL-INKL.COM – Neue Medien Münnich, Inhaber: René Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://all-inkl.com/; Privacy Policy: https://all-inkl.com/datenschutzinformationen/; Data Processing Agreement: Provided by the service provider.

Registration, Login and User Account

Users can create a user account. Within the scope of registration, the required mandatory information is communicated to the users and processed for the purposes of providing the user account on the basis of contractual fulfilment of obligations. The processed data includes in particular the login information (name, password and an e-mail address).

Within the scope of using our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user’s protection against misuse and other unauthorized use. This data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.

Users may be informed by e-mail of information relevant to their user account, such as technical changes.

  • Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of Processing: Provision of contractual services and customer support; Security measures; Managing and responding to inquiries; Provision of our online services and usability.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Registration with pseudonyms: Users may use pseudonyms as user names instead of real names; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
  • Users’ profiles are public: Users’ profiles are publicly visible and accessible; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
  • Deletion of data after termination: If users have terminated their user account, their data relating to the user account will be deleted, subject to any legal permission, obligation or consent of the users; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
  • No obligation to retain data: It is the responsibility of the users to secure their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Community Functions

The community functions provided by us allow users to engage in conversations and other forms of interaction with each other. Please note that the use of the community functions is only permitted in compliance with the applicable legal situation, our terms and guidelines and the rights of other users and third parties.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of Processing: Provision of contractual services and customer support; Security measures.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Further information on processing methods, procedures and services used:

  • User contributions are public: The posts and content created by users are publicly visible and accessible; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
  • Storage of data for security purposes: The posts and other entries of the users are processed for the purposes of the community and conversation functions and, subject to legal obligations or legal permission, are not disclosed to third parties. An obligation to disclosure may arise in particular in the case of unlawful posts for the purposes of legal prosecution. We would like to point out that, in addition to the content of the posts, their time and the IP address of the user are also stored. This is done in order to be able to take appropriate measures to protect other users and the community; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
  • Right to delete content and information: The deletion of posts, content or information provided by users is permissible to the extent necessary after proper consideration if there are concrete indications that they could represent a violation of legal regulations, our provisions or the rights of third parties; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
  • Restricted deletion of posts: Out of consideration for other users, the user’s contributions to conversations remain stored even after termination and account deletion, so that conversations, comments, advice and similar communications do not lose their meaning or become inverted.This ensures that conversations, comments, advice or similar communication between and among users do not lose their meaning or become inverted. User names will be deleted or pseudonymised if they were not already pseudonyms.Users can request the complete deletion of their posts at any time; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
  • Protection of own data: Users decide for themselves what data they disclose about themselves within our online services. For example, when users provide personal information or participate in conversations. We ask users to protect their data and to publish personal data only with caution and only to the extent necessary. In particular, we ask users to note that they must protect their login credentials in particular and use secure passwords (preferably long and random combinations of characters); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Single Sign-on Authentication

Single Sign-On” or “Single Sign-On Authentication or Logon” are procedures that allow users to log in to our online services using a user account with a provider of Single Sign-On services (e.g. a social network). The prerequisite for Single Sign-On Authentication is that users are registered with the respective Single Sign-On provider and enter the required access data in the online form provided for this purpose, or are already logged in with the Single Sign-On provider and confirm the Single Sign-On login via the button.

Authentication takes place directly with the respective single sign-on provider. Within the scope of such authentication, we receive a user ID with the information that the user is logged in with the respective single sign-on provider under this user ID and an ID that cannot be used for other purposes (so-called “user handle”). Whether we receive further data depends solely on the single sign-on procedure used, the data releases selected as part of authentication and also which data users have released in the privacy or other settings of the user account with the single sign-on provider. Depending on the single sign-on provider and the user’s choice, there can be different data, usually the e-mail address and the user name. The password entered by the single sign-on provider as part of the single sign-on procedure is neither visible to us nor is it stored by us.

Users are requested to note that their data stored with us can be automatically compared with their user account with the single sign-on provider, but this is not always possible or actual. If, for example, the e-mail addresses of users change, users must change these manually in their user account with us.

We can use single sign-on authentication, provided that it has been agreed with users in the context of pre-fulfillment or fulfilment of the contract, in the context of consent processing and otherwise use it on the basis of our legitimate interests and the interests of users in an effective and secure authentication system.

Should users decide to no longer want to use the link of their user account with the Single Sign-On provider for the Single Sign-On procedure, they must remove this link within their user account with the Single Sign-On provider. If users wish to delete their data from us, they must cancel their registration with us.

  • Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses); Event Data (Facebook) (“Event Data” is data that can be transmitted from us to Facebook, e.g. via Facebook pixels (via apps or other means) and relates to persons or their actions; the data includes, for example, information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.; Event data is processed for the purpose of creating target groups for content and advertising information (Custom Audiences); Event Data does not include the actual content (such as written comments), login information, and Contact Information (such as names, email addresses, and phone numbers). Event Data is deleted by Facebook after a maximum of two years, the Custom Audiences created from them with the deletion of our Facebook account).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of Processing: Provision of contractual services and customer support; Security measures; Authentication processes.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Facebook Single-Sign-On: Authentication service of the platform Facebook; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Data Processing Agreement: https://www.facebook.com/legal/terms/dataprocessing; Standard Contractual Clauses (Safeguarding the level of data protection when processing data in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum.
  • Google Single-Sign-On: Authentication service; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.google.com; Privacy Policy: https://policies.google.com/privacy; Opt-Out: Settings for the Display of Advertisements: https://adssettings.google.com/authenticated.
  • Instagram Single-Sign-On: Authentication service – We are jointly responsible (so-called “joint-controllership”) with Meta Platforms Ireland Limited for the collection or receipt as part of a transmission (but not the further processing) of Event Data that Facebook collects or receives as part of a transmission for the following purposes using the Facebook single sign-on registration procedures that are implemented on our online services: a) displaying content advertising information that matches users’ presumed interests; b) delivering commercial and transactional messages (e.g. b) delivering commercial and transactional messages (e.g., addressing users via Facebook Messenger); c) improving ad delivery and personalizing features and content (e.g., improving recognition of which content or advertising information is believed to be of interest to users). We have entered into a special agreement with Facebook (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum), which specifically addresses the security measures that Facebook must take (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to comply with the rights of data subjects (i.e., users can, for example, submit information access or deletion requests directly to Facebook). Note: If Facebook provides us with measurements, analyses and reports (which are aggregated, i.e. do not contain information on individual users and are anonymous to us), then this processing is not carried out within the scope of joint responsibility, but on the basis of a DPA (“Data Processing Terms”, https://www.facebook.com/legal/terms/dataprocessing), the “Data Security Conditions” (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of Standard Contractual Clauses (“Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to access to information, erasure, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy.
  • Twitter Single-Sign-On: Authentication service; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, parent company: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://twitter.com; Privacy Policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data will only be processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this privacy policy.

  • Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses); Contract data (e.g. contract object, duration, customer category).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of Processing: Provision of contractual services and customer support; Feedback (e.g. collecting feedback via online form); Provision of our online services and usability; Security measures; Contact requests and communication; Managing and responding to inquiries.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Consent (Article 6 (1) (a) GDPR).

Further information on processing methods, procedures and services used:

  • Comment subscriptions: When users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests. This is done for our safety, if someone leaves illegal contents (insults, forbidden political propaganda, etc.) in comments and contributions. In this case, we ourselves can be prosecuted for the comment or contribution and are therefore interested in the author’s identity. Furthermore, we reserve the right to process user data for the purpose of spam detection on the basis of our legitimate interests. On the same legal basis, in the case of surveys, we reserve the right to store the IP addresses of users for the duration of the surveys and to use cookies in order to avoid multiple votes. The personal information provided in the course of comments and contributions, any contact and website information as well as the content information will be stored permanently by us until the user objects; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
  • Comment subscriptions: Follow-up comments can be subscribed to by users with their consent. Users will receive a confirmation email to verify that they are the owner of the email address entered. Users can unsubscribe from current comment subscriptions at any time. The confirmation email will contain information on the cancellation options. For the purposes of proving the users’ consent, we store the time of registration along with the users’ IP address and delete this information when users unsubscribe from the subscription. You can cancel the receipt of our subscription at any time, i.e. revoke your consent. We may store the unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to provide evidence of prior consent. The processing of these data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of a consent is confirmed at the same time; Legal Basis: Consent (Article 6 (1) (a) GDPR).
  • WordPress emojis and smilies: WordPress emojis and smilies – Within our WordPress blog, graphic emojis (or smilies), i.e. small graphic files that express feelings, that are obtained from external servers, are used for the efficient integration of content elements. Here the providers of the servers collect the IP addresses of the users. This is necessary so that the emoji files can be transmitted to the browsers of the users; Service provider: Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://automattic.com; Privacy Policy: https://automattic.com/privacy.
  • Akismet Anti-Spam Checking: Akismet Anti-Spam Checking – We use the “Akismet” service on the basis of our legitimate interests. With the help of Akismet, comments from real people are distinguished from spam comments. All comments are sent to a server in the USA, where they are analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data will be stored beyond that time. This information includes the name entered, the e-mail address, the IP address, the comment content, the referrer, information about the browser used, the computer system and the time of the entry. Users are welcome to use pseudonyms, or to refrain from entering their name or email address. You can completely prevent the transmission of data by not using our comment system. That is a pity, but unfortunately we do not see any alternatives that work just as effectively; Service provider: Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://automattic.com; Privacy Policy: https://automattic.com/privacy.
  • Gravatar Profile Pictures: Profile Pictures – We use the service Gravatar within our on-line offer and in particular in the Blog. Gravatar is a service where users can register and store profile pictures and their e-mail addresses. If users leave contributions or comments with the respective e-mail address on other online presences (especially in blogs), their profile pictures can be displayed next to the contributions or comments. For this purpose, the e-mail address provided by the users is transmitted to Gravatar in encrypted form for the purpose of checking whether a profile is stored for it. This is the only purpose of transmitting the email address and it will not be used for other purposes, but deleted thereafter. The use of Gravatar is based on our legitimate interests, as we use Gravatar to offer authors of contributions and comments the opportunity to personalize their contributions with a profile picture. By displaying the images, Gravatar knows the IP address of the user, as this is necessary for communication between a browser and an online service. If users do not want a user image linked to their e-mail address to appear in the comments at Gravatar, they should use an e-mail address which is not stored at Gravatar for commenting. We would also like to point out that it is also possible to use an anonymous e-mail address or no e-mail address at all if users do not wish their own e-mail address to be sent to Gravatar. Users can completely prevent the transmission of data by not using our comment system; Service provider: Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://automattic.com; Privacy Policy: https://automattic.com/privacy.

Contact and Inquiry Management

When contacting us (e.g. via contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

The response to the contact inquiries as well as the management of contact and inquiry data in the context of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to respond to (pre)contractual inquiries and otherwise on the basis of legitimate interests in responding to the inquiries and maintaining user or business relationships.

  • Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
  • Purposes of Processing: Provision of contractual services and customer support; Contact requests and communication; Managing and responding to inquiries; Feedback (e.g. collecting feedback via online form); Provision of our online services and usability.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Contact form: When users contact us via our contact form, e-mail or other communication channels, we process the data provided to us in this context to process the communicated request. For this purpose, we process personal data in the context of pre-contractual and contractual business relationships to the extent necessary for their fulfillment and otherwise on the basis of our legitimate interests as well as the interests of the communication partners in responding to the concerns and our legal archiving requirements; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Communication via Messenger

We use messenger services for communication purposes and therefore ask you to observe the following information regarding the functionality of the messenger services, encryption, use of the metadata of the communication and your objection options.

You can also contact us by alternative means, e.g. telephone or e-mail. Please use the contact options provided to you or use the contact options provided within our online services.

In the case of encryption of content (i.e. the content of your message and attachments), we point out that the communication content (i.e. the content of the message and attachments) is encrypted end-to-end. This means that the content of the messages is not visible, not even by the messenger service providers themselves. You should always use a current version of the messenger service with activated encryption, so that the encryption of the message contents is guaranteed.

However, we would like to point out to our communication partners that although messenger service providers do not see the content, they can find out that and when communication partners communicate with us and process technical information on the communication partner’s device used and, depending on the settings of their device, also location information (so-called metadata).

Information on Legal basis: If we ask communication partners for permission before communicating with them via messenger services, the legal basis of our processing of their data is their consent. Otherwise, if we do not request consent and you contact us, for example, voluntarily, we use messenger services in our dealings with our contractual partners and as part of the contract initiation process as a contractual measure and in the case of other interested parties and communication partners on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners for communication via messenger services. We would also like to point out that we do not transmit the contact data provided to us to the messenger service providers for the first time without your consent.

Withdrawal, objection and deletion: You can withdraw your consent or object to communication with us via messenger services at any time. In the case of communication via messenger services, we delete the messages in accordance with our general data retention policy (i.e. as described above after the end of contractual relationships, archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information provided by the communication partners, if no reference to a previous conversation is to be expected and there are no legal obligations to store the messages to prevent their deletion.

Reservation of reference to other means of communication: Finally, we would like to point out that we reserve the right, for reasons of your safety, not to answer inquiries about messenger services. This is the case if, for example, internal contractual matters require special secrecy or if an answer via the messenger services does not meet the formal requirements. In such cases we refer you to more appropriate communication channels.

  • Processed data types: Contact data (e.g. e-mail, telephone numbers); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
  • Purposes of Processing: Contact requests and communication; Direct marketing (e.g. by e-mail or postal).
  • Legal Basis: Consent (Article 6 (1) (a) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Web Analysis, Monitoring and Optimization

Web analysis is used to evaluate the visitor traffic on our website and may include the behaviour, interests or demographic information of users, such as age or gender, as pseudonymous values. With the help of web analysis we can e.g. recognize, at which time our online services or their functions or contents are most frequently used or requested for repeatedly, as well as which areas require optimization.

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

Unless otherwise stated below, profiles, i.e. data aggregated for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and read from it. The information collected includes, in particular, websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed.

Unless otherwise stated below, profiles, that is data summarized for a usage process or user, may be created for these purposes and stored in a browser or terminal device (so-called “cookies”) or similar processes may be used for the same purpose. The information collected includes, in particular, websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data or profiles to us or to the providers of the services we use, these may also be processed, depending on the provider.

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

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of Processing: Web Analytics (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (Creating user profiles).
  • Security measures: IP Masking (Pseudonymization of the IP address).
  • Legal Basis: Consent (Article 6 (1) (a) GDPR).

Further information on processing methods, procedures and services used:

  • Google Analytics 4: We use Google Analytics to perform user analysis 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 an end device in order to recognize which content users have accessed within one or various usage processes, which search terms they have used, have accessed again or have interacted with our online services. Likewise, the time of use and its duration are stored, as well as the sources of users referring to our online services and technical aspects of their end devices and browsers. In the process, pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used. In Analytics, higher level geographic location data is provided by collecting the following metadata based on IP search: “city” (and the derived latitude and longitude of the city), “continent”, “country”, “region”, “subcontinent” (and the ID-based equivalents). To ensure the protection of user data in the EU, Google receives and processes all user data via domains and servers within the EU. The IP address of users is not logged and is shortened by the last two digits by default. The shortening of the IP address takes place on EU servers for EU users. In addition, all sensitive data collected from users in the EU is deleted before it is collected via EU domains and servers; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://marketingplatform.google.com/intl/en/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Standard Contractual Clauses (Safeguarding the level of data protection when processing data in third countries): https://business.safety.google/adsprocessorterms; Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the Display of Advertisements: https://adssettings.google.com/authenticated; Further Information: https://privacy.google.com/businesses/adsservices (Types of processing and data processed).
  • No collection of detailed location and device data (Google Analytics function): No detailed location and device data is recorded (further information: https://support.google.com/analytics/answer/12017362).

Affiliate-Programms und Affiliate-Links

Within our online services, we include so-called affiliate links or other references (which for example may include search forms, widgets or discount codes) to the offers and services of third parties (collectively referred to as “affiliate links”). When users follow affiliate links or subsequently take advantage of offers, we may receive commission or other benefits (collectively referred to as “commission”) from these third parties.

In order to be able to track whether the users have followed the offers of an affiliate link used by us, it is necessary for the respective third party to know that the users have followed an affiliate link used within our online services. The assignment of affiliate links to the respective business transactions or other actions (e.g., purchases) serves the sole purpose of commission settlement and is removed as soon as it is no longer required for this purpose.

For the purposes of the aforementioned affiliate link assignment, the affiliate links may be supplemented by certain values that may be a component of the link or otherwise stored, for example, in a cookie. The values may include in particular the source website (referrer), time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer and an online identifier of the user.

Information on legal basis: If we ask the users for their consent to the use of third party providers, the legal basis of the processing is consent. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Processed data types: Contract data (e.g. contract object, duration, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses); Inventory data (e.g. names, addresses); Payment Data (e.g. bank details, invoices, payment history).
  • Data subjects: Users (e.g. website visitors, users of online services); Customers.
  • Purposes of Processing: Affiliate Tracking; Provision of contractual services and customer support.
  • Legal Basis: Consent (Article 6 (1) (a) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Profiles 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 may entail risks for users, e.g. by making it more difficult to enforce users’ rights.

In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the associated interests of users. The user profiles can then be used, for example, to place advertisements within and outside the networks which are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer, in which the user’s usage behaviour and interests are stored. Furthermore, data can be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective networks or will become members later on).

For a detailed description of the respective processing operations and the opt-out options, please refer to the respective data protection declarations and information provided by the providers of the respective networks.

Also in the case of requests for information and the exercise of rights of data subjects, we point out that these can be most effectively pursued with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, please do not hesitate to contact us.

  • Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of Processing: Contact requests and communication; Feedback (e.g. collecting feedback via online form); Marketing.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy.
  • Facebook-Seiten: Profiles within the social network Facebook – We are jointly responsible (so called “joint controller”) with Meta Platforms Ireland Limited for the collection (but not the further processing) of data of visitors to our Facebook page. This data includes information about the types of content users view or interact with, or the actions they take (see “Things that you and others do and provide” in the Facebook Data Policy: https://www.facebook.com/policy), and information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie information; see “Device Information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How we use this information?” Facebook also collects and uses information to provide analytics services, known as “page insights,” to site operators to help them understand how people interact with their pages and with 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 regulates in particular the security measures that Facebook must observe and in which Facebook has agreed to fulfill the rights of the persons concerned (i.e. users can send information access or deletion requests directly to Facebook). The rights of users (in particular to access to information, erasure, objection and complaint to the competent 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); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Standard Contractual Clauses (Safeguarding the level of data protection when processing data in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Further Information: Joint Controllership Agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data. The joint controllership is limited to the collection and transfer of the data to Meta Platforms Ireland Limited, a company located in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
  • Pinterest: Social network; Service provider: Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.pinterest.com; Privacy Policy: https://about.pinterest.com/de/privacy-policy; Further Information: Pinterest Data Sharing Addendum (EXHIBIT A): https://business.pinterest.com/de/pinterest-advertising-services-agreement/.
  • Twitter: Social network; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, parent company: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Privacy Policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
  • YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Privacy Policy: https://policies.google.com/privacy; Opt-Out: https://adssettings.google.com/authenticated.

Plugins and embedded functions and content

Within our online services, we integrate functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may, for example, be graphics, videos or city maps (hereinafter uniformly referred to as “Content”).

The integration always presupposes that the third-party providers of this content process the IP address of the user, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents or functions. We strive to use only those contents, whose respective offerers use the IP address only for the distribution of the contents. Third parties may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring websites, visit times and other information about the use of our website, as well as may be linked to such information from other sources.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses); Event Data (Facebook) (“Event Data” is data that can be transmitted from us to Facebook, e.g. via Facebook pixels (via apps or other means) and relates to persons or their actions; the data includes, for example, information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.; Event data is processed for the purpose of creating target groups for content and advertising information (Custom Audiences); Event Data does not include the actual content (such as written comments), login information, and Contact Information (such as names, email addresses, and phone numbers). Event Data is deleted by Facebook after a maximum of two years, the Custom Audiences created from them with the deletion of our Facebook account).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of Processing: Provision of our online services and usability; Provision of contractual services and customer support; Marketing; Profiles with user-related information (Creating user profiles).
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Consent (Article 6 (1) (a) GDPR).

Further information on processing methods, procedures and services used:

  • Facebook plugins and contents: Facebook Social Plugins and contents – This can include content such as images, videos or text and buttons with which users can share content from this online service within Facebook. The list and appearance of the Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/ – We are jointly responsible (so-called “joint-controllership”) with Meta Platforms Ireland Limited for the collection or transmission (but not further processing) of “Event Data” that Facebook collects or receives as part of a transmission using the Facebook Social Plugins that run on our website for the following purposes: a) displaying content advertising information that matches users’ presumed interests; b) delivering commercial and transactional messages (e.g. b) delivering commercial and transactional messages (e.g., addressing users via Facebook Messenger); c) improving ad delivery and personalizing features and content (e.g., improving recognition of which content or advertising information is believed to be of interest to users). We have entered into a special agreement with Facebook (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum), which specifically addresses the security measures that Facebook must take (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to comply with the rights of data subjects (i.e., users can, for example, submit information access or deletion requests directly to Facebook). Note: If Facebook provides us with measurements, analyses and reports (which are aggregated, i.e. do not contain information on individual users and are anonymous to us), then this processing is not carried out within the scope of joint responsibility, but on the basis of a DPA (“Data Processing Terms”, https://www.facebook.com/legal/terms/dataprocessing/update), the “Data Security Conditions” (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of Standard Contractual Clauses (“Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to access to information, erasure, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy.
  • Font Awesome (Provision on own server): Display of fonts and symbols; Service provider: The Font Awesome icons are hosted on our server, no data is transmitted to the provider of Font Awesome; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
  • Google Fonts (Provision on own server): Obtaining fonts (“Google Fonts”) for the purpose of a user-friendly appearance of our online services; Service provider: The Google Fonts are hosted on our server, no data is transmitted to Google; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
  • Instagram plugins and contents: Instagram plugins and contents – This can include content such as images, videos or text and buttons with which users can share content from this online service within Instagram . – We are jointly responsible (so-called “joint-controllership”) with Meta Platforms Ireland Limited for the collection or transmission (but not further processing) of “Event Data” that Facebook collects or receives as part of a transmission using Instagram functions that run on our website for the following purposes: a) displaying content advertising information that matches users’ presumed interests; b) delivering commercial and transactional messages (e.g. b) delivering commercial and transactional messages (e.g., addressing users via Facebook Messenger); c) improving ad delivery and personalizing features and content (e.g., improving recognition of which content or advertising information is believed to be of interest to users). We have entered into a special agreement with Facebook (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum), which specifically addresses the security measures that Facebook must take (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to comply with the rights of data subjects (i.e., users can, for example, submit information access or deletion requests directly to Facebook). Note: If Facebook provides us with measurements, analyses and reports (which are aggregated, i.e. do not contain information on individual users and are anonymous to us), then this processing is not carried out within the scope of joint responsibility, but on the basis of a DPA (“Data Processing Terms”, https://www.facebook.com/legal/terms/dataprocessing/update), the “Data Security Conditions” (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of Standard Contractual Clauses (“Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to access to information, erasure, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy.
  • Pinterest plugins and contents: Pinterest plugins and contents- This can include content such as images, videos or text and buttons with which users can share content from this online service within Pinterest; Service provider: Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.pinterest.com; Privacy Policy: https://about.pinterest.com/de/privacy-policy.
  • reCAPTCHA: We integrate the “reCAPTCHA” function to be able to recognise whether entries (e.g. in online forms) are made by humans and not by automatically operating machines (so-called “bots”). The data processed may include IP addresses, information on operating systems, devices or browsers used, language settings, location, mouse movements, keystrokes, time spent on websites, previously visited websites, interactions with ReCaptcha on other websites, possibly cookies and results of manual recognition processes (e.g. answering questions asked or selecting objects in images). The data processing is based on our legitimate interest to protect our online services from abusive automated crawling and spam; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, , parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.google.com/recaptcha/; Privacy Policy: https://policies.google.com/privacy; Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the Display of Advertisements: https://adssettings.google.com/authenticated.
  • Twitter plugins and contents: Twitter plugins and buttons – This can include content such as images, videos or text and buttons with which users can share content from this online service within Twitter; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, parent company: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://twitter.com; Privacy Policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
  • YouTube-Videos: Video content; ouTube videos are integrated via a special domain (recognizable by the component “youtube-nocookie”) in the so-called ” enhanced data protection mode”, whereby no cookies on user activities are collected in order to personalise the video playback. Nevertheless, information on the user’s interaction with the video (e.g. remembering the last playback point) may be stored; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, , parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy.

Changes and Updates to the Privacy Policy

We kindly ask you to inform yourself regularly about the contents of our data protection declaration. We will adjust the privacy policy as changes in our data processing practices 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, we ask you to note that addresses may change over time and to verify the information before contacting us.

Rights of Data Subjects

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

  • Right to Object: You have the right, on grounds arising from your particular situation, to object at any time to the processing of your personal data which is based on letter (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right of withdrawal for consents: You have the right to revoke consents at any time.
  • Right of access: You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law.
  • Right to rectification: You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the incorrect data concerning you.
  • Right to Erasure and Right to Restriction of Processing: In accordance with the statutory provisions, you have the right to demand that the relevant data 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 data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
  • Complaint to the supervisory authority: In accordance with the law and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Supervisory authority competent for us:

Die Landesbeauftragte für den Datenschutz Niedersachsen
Barbara Thiel
Prinzenstraße 5
30159 Hannover
Telefon: 05 11/120-45 00
E-Mail: poststelle@lfd.niedersachsen.de
Homepage: https://www.lfd.niedersachsen.de

Terminology and Definitions

This section provides an overview of the terms used in this privacy policy. Many of the terms are drawn from the law and defined mainly in Article 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended above all for the purpose of comprehension. The terms are sorted alphabetically.

  • Affiliate Tracking: Affiliate tracking logs links that the linking websites use to refer users to websites with products or other offers. The owners of the respective linked websites can receive a commission if users follow these so-called “affiliate links” and subsequently take advantage of the offers (e.g. buy goods or use services). To this end, it is necessary for providers to be able to track whether users who are interested in certain offers subsequently follow the affiliate links. It is therefore necessary for the functionality of affiliate links that they are supplemented by certain values that become part of the link or are otherwise stored, e.g. in a cookie. The values include in particular the source website (referrer), time, an online identification of the owner of the website on which the affiliate link was located, an online identification of the respective offer, an online identifier of the user, as well as tracking specific values such as advertising media ID, partner ID and categorizations
  • Controller: “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Personal Data: “personal data” means any information relating to an identified or identifiable natural person (“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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Processing: The term “processing” covers a wide range and practically every handling of data, be it collection, evaluation, storage, transmission or erasure.
  • Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any kind of automated processing of personal data that consists of using these personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Web Analytics: Web Analytics serves the evaluation of visitor traffic of online services and can determine their behavior or interests in certain information, such as content of websites. With the help of web analytics, website owners, for example, can recognize at what time visitors visit their website and what content they are interested in. This allows them, for example, to optimize the content of the website to better meet the needs of their visitors. For purposes of web analytics, pseudonymous cookies and web beacons are frequently used in order to recognise returning visitors and thus obtain more precise analyses of the use of an online service.
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