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Liability Notice: The following template has been prepared by a lawyer (Dr. jur. Schwenke, LL.M. commercial (UoA), Certified Data Protection Auditor (DSA-TÜV) Certified Data Protection Officer (TÜV Süd) ) in accordance with the typical requirements of an online shop. However, you should only use the template after careful review and adaptation to your specific business model. The following template therefore contains additional notes that you must observe and red passages that you must review and, if necessary, adapt. Please remove the notes after editing. If in doubt, seek legal advice. Copyright: You may use the template within the domain/website as long as your Marketpress license is valid for it. Distribution to third parties, including customers (e.g., as a developer), is not permitted.

Privacy Policy

Introduction

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes, and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, 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.

Last updated: XX.XX.20XX

Please specify the date of the privacy policy.

Table of Contents

Controller

First name, last name / Company
Street, house number
Postal code, city
Country

Email address: Your email address

Phone: Your phone number (optional)

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

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

Contact Data Protection Officer

First name, last name / Company
Street, house number
Postal code, city
Country

Note: Only the email address is mandatory; the other details are optional. Data protection officers must only be specified if they have been appointed. An appointment is required under § 38 BDSG-Neu from 20 employees who process personal data (which practically includes an email inbox), onwards.

Overview of Processing Operations

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

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

Types of Data Processed

  • Inventory data (e.g., names, addresses).
  • Content data (e.g., entries in online forms).
  • Contact data (e.g., email, phone numbers).
  • Meta/communication data (e.g., device information, IP addresses).
  • Usage data (e.g., websites visited, interest in content, access times).
  • Location data (information on the geographical position of a device or person).
  • Contract data (e.g., subject matter of contract, term, customer category).
  • Payment data (e.g., bank details, invoices, payment history).

Categories of Data Subjects

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

Purposes of Processing

  • Assessment of creditworthiness.
  • Provision of our online offering and user-friendliness.
  • Evaluation of visitor actions.
  • Office and organizational procedures.
  • Cross-device tracking (cross-device processing of user data for marketing purposes).
  • Direct marketing (e.g., by email or post).
  • Interest-based and behavioral marketing.
  • Contact requests and communication.
  • Conversion measurement (measuring the effectiveness of marketing measures).
  • Profiling (creating user profiles).
  • Remarketing.
  • Reach measurement (e.g., access statistics, recognition of returning visitors).
  • Security measures.
  • Tracking (e.g., interest/behavioral profiling, use of cookies).
  • Provision of contractual services and customer service.
  • Management and response to inquiries.
  • Audience building (determining target groups relevant for marketing purposes or other content delivery).

Automated Decisions in Individual Cases

  • Credit information (decision based on a credit assessment).

Relevant Legal Bases

In the following, we share the legal bases of the General Data Protection Regulation (GDPR) on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence and registered office. Should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6(1)(a) GDPR) – The data subject has given consent to the processing of their personal data for one or more specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6(1)(c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 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.

Security Measures

We take appropriate technical and organizational measures in accordance with 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 varying likelihood and severity of the risk to the rights and freedoms of natural persons, 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 of, disclosure of, ensuring availability of, and segregation of data. Furthermore, we have established procedures to ensure the exercise of data subject rights, deletion of data, and responses to data threats. In addition, we take the protection of personal data into account as early as the development or selection of hardware, software, and procedures in accordance with the principle of data protection through technology design and through data protection-friendly default settings.

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

Note: Remove the reference to encryption if your offering is not encrypted. However, delivering the website via https should be considered mandatory.

Transmission and Disclosure of Personal Data

In the course of our processing of personal data, it may occur that the data is transmitted to other entities, companies, legally independent organizational units, or persons, or that it is disclosed to them. Recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks, or providers of services and content that are integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data 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 if the processing takes place in the context of the use of third-party services or the disclosure or transmission of data to other persons, entities, or companies, this is done only in accordance with legal requirements.

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

Use of Cookies

Cookies are small text files or other storage markers 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 content accessed, or functions used in an online offering. Cookies can also be used for various purposes, such as for the functionality, security, and convenience of online offerings, as well as for the creation of analyses of visitor flows.

Notes on consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, except where this is not required by law. Consent is not necessary, in particular, if the storage and reading of information, including cookies, is absolutely necessary to provide users with a telemedia service (i.e., our online offering) that they have expressly requested. The revocable consent is clearly communicated to users and contains information on the respective cookie use.

Notes on data protection legal bases: The data protection legal basis on which we process users’ personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is the declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g., in the business operation of our online offering and improvement of its usability) or, if this is done in the context of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We clarify the purposes for which we process cookies in the course of this privacy policy or as part of our consent and processing procedures.

Storage duration: With regard to the storage duration, 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 end device (e.g., browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved, or preferred content can be displayed directly when the user visits a website again. Likewise, the data of users collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information on the type and storage duration of cookies (e.g., as part of obtaining consent), users should assume that cookies are permanent and the storage duration can be up to two years.

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

Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which users’ consent to the use of cookies, or the processing and providers mentioned in the cookie consent management procedure, is obtained and managed and revoked by users. The consent declaration is stored so that the query does not have to be repeated and the consent can be proven in accordance with the legal obligation. The storage can be server-side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following notes apply: The duration of storage of consent can be up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g., which categories of cookies and/or service providers), and the browser, system, and end device used.

Cookie Settings/Opt-Out Options:

If you use a cookie consent banner (which is recommended), you can enter the option to call it up here (e.g., link or a so-called [shortcode] that is automatically converted into a button/link by your software).

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

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

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

Commercial and Business Services

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

We process this data to fulfill our contractual obligations, to safeguard our rights, and for the purposes of the administrative tasks associated with this information as well as business organization. We only disclose the data of contractual partners to third parties within the framework of applicable law to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations or with the consent of the data subjects (e.g., to participating telecommunications, transport, and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Contractual partners will be informed about further forms of processing, e.g., for marketing purposes, within the scope of this privacy policy.

We inform contractual partners which data is required for the aforementioned purposes before or during data collection, e.g., in online forms, through special marking (e.g., colors) or symbols (e.g., asterisks, etc.), or personally.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e., generally after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal reasons of archiving (e.g., for tax purposes, generally 10 years). We delete data disclosed to us as part of an order by the contractual partner in accordance with the specifications of the order, generally after the end of the order.

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

Customer account: Contractual partners can create an account within our online offering (e.g., customer or user account, referred to as “customer account”). If registration of a customer account is required, contractual partners 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. As part of registration and subsequent logins and use of the customer account, we store the IP addresses of customers along with the access times in order to prove registration and prevent any misuse of the customer account.

If customers have canceled their customer account, the data concerning the customer account will be deleted, subject to their retention being required for legal reasons. It is the responsibility of customers to secure their data upon termination of the customer account.

Business analyses and market research: For business reasons and to be able to recognize market trends, wishes of contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc., whereby the group of data subjects may include contractual partners, prospective customers, customers, visitors, and users of our online offering.

The analyses are carried out for the purpose of business evaluations, marketing, and market research (e.g., to determine customer groups with different characteristics). Where available, we can take into account the profiles of registered users along with their information, e.g., on services used. The analyses serve us alone and are not disclosed externally unless they are anonymous analyses with aggregated, i.e., anonymized values. Furthermore, we respect the privacy of users and process the data for analysis purposes as pseudonymously as possible and, where feasible, anonymously (e.g., as aggregated data).

Shop and e-commerce: We process the data of our customers to enable them to select, purchase, or order the selected products, goods, and related services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, freight forwarding, and shipping companies, to carry out the delivery or execution to our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is identified as such in the context of the order or comparable purchase process and includes the information required for delivery or provision and billing as well as contact information in order to be able to hold any consultations.

  • Types of data processed: Inventory data (e.g., names, addresses), payment data (e.g., bank details, invoices, payment history), contact data (e.g., email, phone numbers), contract data (e.g., subject matter of contract, term, customer category), usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
  • Data subjects: Prospective customers, business and contractual partners, customers.
  • Purposes of processing: Provision of contractual services and customer service, contact requests and communication, office and organizational procedures, management and response to inquiries, security measures, evaluation of visitor actions, interest-based and behavioral marketing, profiling (creating user profiles).
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legal obligation (Art. 6(1)(c) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

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

Payment Service Providers

In the context 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 payment service providers in addition to banks and credit institutions (collectively “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. This means that 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. This transmission is for the purpose of identity and credit checks. In this regard, we refer to the terms and conditions and privacy notices of the payment service providers.

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

  • Types of data processed: Inventory data (e.g., names, addresses), payment data (e.g., bank details, invoices, payment history), contract data (e.g., subject matter of contract, term, 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 service.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Services and Service Providers Used:

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

Credit Assessment

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

We process the information received from the credit agencies about the statistical probability of payment default as part of a proper discretionary decision on the establishment, performance, and termination of the contractual relationship. We reserve the right to refuse payment on account or other advance payment in the event of a negative result of the credit check.

The decision on whether we provide advance payment is made in accordance with Art. 22 GDPR solely on the basis of an automated decision in individual cases, which our software makes based on the information from the credit agency.

If we obtain express consent from contractual partners, the legal basis for the credit information and the transmission of the customer’s data to the credit agencies is consent. If no consent is obtained, the credit information is based on our legitimate interests in the default security of our payment claims.

  • Types of data processed: Inventory data (e.g., names, addresses), payment data (e.g., bank details, invoices, payment history), contact data (e.g., email, phone numbers), contract data (e.g., subject matter of contract, term, customer category).
  • Data subjects: Customers, prospective customers.
  • Purposes of processing: Assessment of creditworthiness.
  • Legal bases: Consent (Art. 6(1)(a) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
  • Automated decisions in individual cases: Credit information (decision based on a credit assessment).

Services and Service Providers Used:

Note: Remove the passage on credit assessment if you do not conduct credit assessments. Review and change the list of service providers as needed. The assessment of a customer’s creditworthiness is permissible if there is otherwise a risk of payment default, i.e., if the goods are delivered without payment having been received (i.e., if the customer chooses to purchase on account). No risk of payment default exists, however, if the customer chooses, for example, the advance payment option or makes payment via third-party providers such as PayPal.

It should also be noted that obtaining an automatic credit report constitutes “automated decisions in individual cases” pursuant to Art. 22 GDPR, i.e., a legal decision without human involvement. This is permissible if the customer has consented or if this decision is necessary for the conclusion of the contract. Whether the decision is necessary has not yet been conclusively clarified, but is widely held to be the case, including by the author of this template.

However, if you wish to exclude any risk, you should obtain consent. Consent also becomes necessary if the credit information is already used to decide whether the “on account” option should be displayed at all. This is because it could have been that the customer would have chosen advance payment or PayPal anyway and the credit check would not have been necessary. Such consent could, for example, read as follows:

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

Provision of the Online Offering and Web Hosting

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

The data processed as part of the provision of the hosting offering may include all information relating to users of our online offering that arises in the course of use and communication. This regularly includes the IP address, which is necessary to deliver the content of online offerings to browsers, and all entries made within our online offering or from websites.

Email sending and hosting: The web hosting services we use also include the sending, receiving, and storage of emails. For these purposes, the addresses of recipients and senders as well as other information concerning email sending (e.g., the providers involved) and the contents of the respective emails are processed. The aforementioned data may also be processed for the purposes of spam detection. Please note that emails on the internet are generally not sent encrypted. As a rule, emails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of emails between the sender and receipt on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, 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 rule, IP addresses and the requesting provider.

The server log files can be used, on the one hand, for security purposes, e.g., to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and, on the other hand, to ensure the utilization of the servers and their stability.

  • Types of data processed: Content data (e.g., entries in online forms), usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Note: If not already done: Please ask the respective web hosts for a so-called “data processing agreement” (or “Data Processing Agreement”). This is legally required because the host collects personal data of website visitors on your behalf.

Contact

When contacting us (e.g., via contact form, email, phone, or via social media), 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 contact requests 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.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, phone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partners, prospects.
  • Purposes of processing: Contact requests and communication, management and response to inquiries.
  • Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).

Services and service providers used:

Note: If third-party CRM systems are used, their providers should be named. Please adapt this information or remove the specified service provider. In addition, data processing agreements (or “Data Processing Agreements”) must be concluded with the providers. If the providers process users’ data in a third country, special safeguards must be in place (e.g., Standard Contractual Clauses).

Newsletters and electronic notifications

We send newsletters, emails and other electronic notifications (hereinafter “newsletters”) only with the recipients’ consent or on the basis of a legal permission. If the contents of the newsletter are specifically described as part of the subscription process, they are decisive for users’ consent. Otherwise, our newsletters contain information about our services and about us.

To subscribe to our newsletters, it is generally sufficient to provide your email address. However, we may ask you to provide a name for personal addressing in the newsletter, or further information if this is required for the purposes of the newsletter.

Double opt-in procedure: Subscription to our newsletter generally takes place using the so-called double opt-in procedure. This means that after subscribing, you will receive an email asking you to confirm your subscription. This confirmation is necessary to prevent anyone from subscribing with third-party email addresses. Newsletter subscriptions are logged in order to be able to prove the subscription process in accordance with legal requirements. This includes storing the time of subscription and confirmation as well as the IP address. Changes to your data stored with the mailing service provider are also logged.

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

The logging of the subscription procedure is carried out on the basis of our legitimate interests for the purpose of proving that it was properly carried out. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure mailing system.

Information on legal bases: Newsletters are sent on the basis of the recipients’ consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, insofar as and to the extent that this is legally permitted, e.g. in the case of advertising to existing customers. If we commission a service provider to send emails, this is done on the basis of our legitimate interests. The registration procedure is recorded on the basis of our legitimate interests in order to prove that it was carried out in compliance with the law.

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

Analysis and performance measurement: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a mailing service provider, from its server. As part of this retrieval, technical information is collected first, such as information about the browser and your system, as well as your IP address and the time of retrieval.

This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behaviour, on the basis of their retrieval locations (which can be determined with the help of the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor, if used, that of the mailing service provider to monitor individual users. Rather, the evaluations help us to recognise our users’ reading habits and adapt our content to them, or to send different content according to our users’ interests.

The evaluation of the newsletter and performance measurement are carried out—subject to the users’ explicit consent—on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves both our business interests and users’ expectations.

Unfortunately, separate withdrawal of consent for performance measurement is not possible; in this case, the entire newsletter subscription must be cancelled or objected to.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, phone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g. by email or post).
  • Legal bases: Consent (Art. 6(1) sentence 1 lit. a GDPR), legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).
  • Right to object (opt-out): You may cancel receipt of our newsletter at any time, i.e. withdraw your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you may otherwise use one of the contact options provided above, preferably email.

Services and service providers used:

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

Web analytics, monitoring and optimisation

Web analytics (also referred to as “reach measurement”) is used to evaluate visitor flows on our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognise at what times our online offering or its functions or content are used most frequently or invite reuse. We can also identify which areas require optimisation.

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

For these purposes, so-called user profiles may be created and stored in a file (so-called “cookie”) or similar procedures with the same purpose may be used. This information may include, for example, content viewed, websites visited and elements used there, and technical information such as the browser used, the computer system used, and information on usage times. If users have consented to the collection of their location data, this may also be processed depending on the provider.

Users’ IP addresses are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored as part of web analytics, A/B testing and optimisation, but rather pseudonyms. This means that neither we nor the providers of the software used know the users’ actual identity, but only the information stored in their profiles for the purposes of the respective procedures.

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

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • 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-/behaviour-based profiling, use of cookies), evaluation of visit actions, profiling (creation of user profiles).
  • Security measures: IP masking (pseudonymisation of the IP address).
  • Legal bases: Consent (Art. 6(1) sentence 1 lit. a GDPR), legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).

Services and service providers used:

  • etracker: Web analytics/reach measurement; service provider: etracker GmbH, Erste Brunnenstraße 1 20459 Hamburg, Germany; website: https://www.etracker.com; privacy policy: https://www.etracker.com/datenschutz/; data processing agreement: https://www.etracker.com/av-vertrag/.; right to object (opt-out): https://www.etracker.de/privacy?et=[PLEASE-INSERT-YOUR-Account-ID].
  • Matomo (without cookies): Matomo is a privacy-friendly web analytics software that is used without cookies and in which returning users are recognised using a so-called “digital fingerprint” that is stored anonymously and changed every 24 hours; with the “digital fingerprint”, user movements within our online offering are recorded using pseudonymised IP addresses in combination with browser settings on the user side in such a way that it is not possible to draw conclusions about the identity of individual users. The user data collected as part of the use of Matomo is processed only by us and is not shared with third parties.

Please delete the web analytics, monitoring and optimisation section if you do not use any web analytics, monitoring and optimisation tools on your website. Adjust the list of services and providers as needed. Note: Matomo is declared in the version without cookies.

Online marketing

We process personal data for the purposes of online marketing, which may include, in particular, the marketing of advertising space or the display of advertising and other content (collectively referred to as “content”) based on users’ potential interests, as well as measuring its effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which the information relevant for displaying the aforementioned content is stored about the user. This information may include, for example, content viewed, websites visited, online networks used, as well as communication partners and technical information such as the browser used, the computer system used, and information on usage times. If users have consented to the collection of their location data, this may also be processed.

Users’ IP addresses are also stored. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored as part of online marketing procedures, but rather pseudonyms. This means that neither we nor the providers of the online marketing procedures know the users’ actual identity, but only the information stored in their profiles.

The information in the profiles is generally stored in cookies or by means of similar procedures. These cookies can later generally also be read on other websites that use the same online marketing procedure and analysed for the purpose of displaying content, as well as supplemented with further data and stored on the server of the online marketing procedure provider.

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

As a rule, we only receive access to aggregated information about the success of our advertisements. However, as part of so-called conversion measurement, we can check which of our online marketing procedures led to a so-called conversion, i.e. for example, to the conclusion of a contract with us. Conversion measurement is used solely to analyse the success of our marketing measures.

Unless otherwise stated, please assume that cookies used are stored for a period of two years.

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

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographical position of a device or a person).
  • Data subjects: Users (e.g. website visitors, users of online services), prospective customers.
  • Purposes of processing: Tracking (e.g. interest-/behaviour-based profiling, use of cookies), remarketing, evaluation of visit actions, interest-based and behaviour-based marketing, profiling (creation of user profiles), conversion measurement (measuring the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors), audience building (determining target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes).
  • Security measures: IP masking (pseudonymisation of the IP address).
  • Legal bases: Consent (Art. 6(1) sentence 1 lit. a GDPR), legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).
  • Right to object (opt-out): We refer to the privacy notices of the respective providers and the opt-out options specified for the providers (so-called “opt-out”). If no explicit opt-out option has been provided, you may, firstly, disable cookies in your browser settings. However, this may restrict functions of our online offering. We therefore additionally recommend the following opt-out options, which are offered in summary for the respective regions:a) Europe: https://www.youronlinechoices.eu.
    b) Canada: https://www.youradchoices.ca/choices.
    c) USA: https://www.aboutads.info/choices.
    d) Cross-region: https://optout.aboutads.info.

Services and service providers used:

  • Google Tag Manager: Google Tag Manager is a solution that allows us to manage so-called website tags via an interface and thus integrate other services into our online offering (reference is made to further information in this privacy policy). With the Tag Manager itself (which implements the tags), no user profiles are created and no cookies are stored. Google only learns the user’s IP address, which is necessary to run Google Tag Manager; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy; data processing agreement: https://business.safety.google/adsprocessorterms; further information: types of processing and data processed: https://privacy.google.com/businesses/adsservices; data processing terms for Google advertising products and Standard Contractual Clauses for third-country transfers of data: https://business.safety.google/adsprocessorterms.
  • Google Analytics: Reach measurement and web analytics; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com/intl/de/about/analytics/; privacy policy: https://policies.google.com/privacy; right to object (opt-out): opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of ads: https://adssettings.google.com/authenticated; data processing agreement: https://business.safety.google/adsprocessorterms/; further information: types of processing and data processed: https://privacy.google.com/businesses/adsservices; data processing terms for Google advertising products and Standard Contractual Clauses for third-country transfers of data: https://business.safety.google/adsprocessorterms.
  • Google Ads and conversion measurement: We use the online marketing procedure “Google Ads” to place ads in the Google advertising network (e.g. in search results, in videos, on websites, etc.) so that they are shown to users who are presumed to have an interest in the ads. We also measure the conversion of the ads. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page tagged with a so-called “conversion tracking tag”. However, we do not receive any information that could be used to identify users; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website:https://marketingplatform.google.com; privacy policy:https://policies.google.com/privacy; further information: types of processing and data processed: https://privacy.google.com/businesses/adsservices; data processing terms for Google advertising products: information on the services, data processing terms between controllers and Standard Contractual Clauses for third-country transfers of data: https://business.safety.google/adscontrollerterms.
  • Google Ad Manager: We use the “Google Marketing Platform” (and services such as “Google Ad Manager”) to place ads in the Google advertising network (e.g. in search results, in videos, on websites, etc.). The Google Marketing Platform is characterised by the fact that ads are displayed in real time based on presumed user interests. This allows us to display ads for and within our online offering in a more targeted manner, in order to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products they were interested in on other online offerings, this is referred to as “remarketing”; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy; further information: types of processing and data processed: https://privacy.google.com/businesses/adsservices; data processing terms for Google advertising products: information on the services, data processing terms between controllers and Standard Contractual Clauses for third-country transfers of data: https://business.safety.google/adscontrollerterms; if Google acts as a processor, data processing terms for Google advertising products and Standard Contractual Clauses for third-country transfers of data: https://business.safety.google/adsprocessorterms.
  • Facebook Pixel and audience building (Custom Audiences): With the help of the Facebook Pixel (or comparable functions for transmitting event data or contact information via interfaces in apps), Facebook is able, on the one hand, to determine visitors to our online offering as a target group for the display of ads (so-called “Facebook Ads”). Accordingly, we use the Facebook Pixel to display the Facebook Ads placed by us only to those users on Facebook and within the services of Facebook’s cooperating partners (so-called “Audience Network” https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offering or who have certain characteristics (e.g. interest in certain topics or products that can be inferred from the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook Pixel, we also want to ensure that our Facebook Ads correspond to users’ potential interests and do not appear annoying. With the help of the Facebook Pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion measurement”); service provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; website: https://www.facebook.com; privacy policy: https://www.facebook.com/about/privacy; Standard Contractual Clauses (ensuring an adequate level of data protection when processing in third countries): the “Facebook EU Data Transfer Addendum” (https://www.facebook.com/legal/EU_data_transfer_addendum) applies in the case of processing by Facebook as the basis for processing event data of EU citizens in the USA and the inclusion in the “Facebook Platform Terms” (https://developers.facebook.com/terms) with regard to Facebook’s independent processing of event data in the context of ad placement; further information: the “Data Processing Terms” (https://www.facebook.com/legal/terms/dataprocessing/update) apply with regard to event data that Facebook processes on behalf of businesses in order to provide reports and analyses; furthermore, the “Controller Addendum” applies as an agreement on joint controllership (Art. 26(1) sentence 3 GDPR), which is relevant in the case of Facebook’s independent processing of event data for the purposes of targeting as well as improving and securing Facebook products.

Please delete the online marketing section if you do not use any online marketing tools on your website. Adjust the list of services and providers as needed. Please note that the use of marketing services on the website generally requires cookie opt-in.

Presences on social networks (social media)

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

Please note that users’ data may be processed outside the European Union. This may result in risks for users, as it could, for example, make it more difficult to enforce users’ rights.

Furthermore, users’ data is generally processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on users’ usage behaviour and the interests resulting from it. The usage profiles can in turn be used, for example, to place ads within and outside the networks that presumably correspond to users’ interests. For these purposes, cookies are generally stored on users’ computers in which users’ usage behaviour and interests are stored. Furthermore, data may also be stored in the usage profiles independently of the devices used by users (in particular if users are members of the respective platforms and are logged in to them).

For a detailed description of the respective forms of processing and the opt-out options, we refer to the privacy policies and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we also point out that these can be asserted most effectively with the providers. Only the providers have access to users’ data and can take appropriate measures directly and provide information. If you nevertheless need assistance, you may contact us.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, phone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Contact requests and communication, tracking (e.g. interest-/behaviour-based profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
  • Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).

Services and service providers used:

  • Instagram: Social network; service provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; website: https://www.instagram.com; privacy policy: https://instagram.com/about/legal/privacy.
  • Facebook Pages: Profiles within the social network Facebook – Together with Facebook Ireland Ltd., we are jointly responsible for the collection (but not the further processing) of 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 actions they take (see “Things you and others do and provide” in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see “Device information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, so-called “Page Insights”, to page operators so that they can gain insights into how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook (“Page Insights Information”, https://www.facebook.com/legal/terms/page_controller_addendum), which in particular regulates which security measures Facebook must observe and in which Facebook has agreed to fulfil data subject rights (i.e. users can, for example, direct requests for information or deletion directly to Facebook). Users’ rights (in particular the right to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Page Insights Information” (https://www.facebook.com/legal/terms/information_about_page_insights_data); service provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; website: https://www.facebook.com; privacy policy: https://www.facebook.com/about/privacy; Standard Contractual Clauses (ensuring an adequate level of data protection when processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; further information: agreement on joint controllership: https://www.facebook.com/legal/terms/information_about_page_insights_data.
  • LinkedIn: Social network; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; website: https://www.linkedin.com; privacy policy: https://www.linkedin.com/legal/privacy-policy; Standard Contractual Clauses (ensuring an adequate level of data protection when processing in third countries): https://legal.linkedin.com/dpa; right to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out; data processing agreement: https://legal.linkedin.com/dpa.
  • 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; 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; privacy policy: https://policies.google.com/privacy; right to object (opt-out): https://adssettings.google.com/authenticated.
  • Xing: Social network; service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; website: https://www.xing.de; privacy policy: https://privacy.xing.com/de/datenschutzerklaerung.

Adjust the list of social networks as needed.

Plugins and embedded functions and content

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

Integration always requires that the third-party providers of this content process users’ IP addresses, as they could not otherwise send the content to users’ browsers without the IP address. The IP address is therefore required to display this content or functions. We endeavour to use only content whose respective providers use the IP address solely to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to 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 users’ devices and may include, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offering, and may also be linked with such information from other sources.

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

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographical position of a device or a person), content data (e.g. entries in online forms), inventory data (e.g. names, addresses), contact data (e.g. email, phone numbers).
  • Data subjects: Users (e.g. website visitors, users of online services), communication partners.
  • Purposes of processing: Provision of our online offering and user-friendliness, performance of contractual services and customer service, contact requests and communication, tracking (e.g. interest-/behaviour-based profiling, use of cookies), interest-based and behaviour-based marketing, profiling (creation of user profiles), security measures, administration and response to enquiries.
  • Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR), consent (Art. 6(1) sentence 1 lit. a GDPR), performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR).

Services and service providers used:

  • Facebook Plugins and Content: Facebook Social Plugins and content – This may include content such as images, videos, or text and buttons that allow users to share content from this online service within Facebook. The list and appearance of Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/ – We are jointly responsible with Facebook Ireland Ltd. for the collection or receipt in the context of a transmission (but not the further processing) of “Event Data” that Facebook collects by means of the Facebook Social Plugins (and embedding functions for content) that are executed on our online service, or receives in the context of a transmission for the following purposes: a) Display of content and advertising information that corresponds to the presumed interests of users; b) Delivery of commercial and transactional messages (e.g., addressing users via Facebook Messenger); c) Improvement of ad delivery and personalization of features and content (e.g., improving the recognition of which content or advertising information presumably corresponds to the interests of users). We have concluded a special agreement with Facebook (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum), which in particular regulates which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the rights of data subjects (i.e., users can, for example, direct requests for information or deletion directly to Facebook). Note: If Facebook provides us with metrics, analyses, and reports (which are aggregated, i.e., contain no information about individual users and are anonymous to us), this processing does not take place within the scope of joint responsibility, but rather on the basis of a data processing agreement (“Data Processing Terms”, https://www.facebook.com/legal/terms/dataprocessing), the “Data Security Terms” (https://www.facebook.com/legal/terms/data_security_terms) and with regard to processing in the USA on the basis of standard contractual clauses (“Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service Provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy.
  • Google Fonts: We integrate the fonts (“Google Fonts”) of the provider Google, whereby the data of users are used solely for the purpose of displaying the fonts in the users’ browser. The integration is based on our legitimate interests in a technically secure, maintenance-free, and efficient use of fonts, their uniform display, and taking into account possible licensing restrictions for their integration; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent Company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy.
  • Google Maps: We integrate the maps of the service “Google Maps” from the provider Google. The processed data may include, in particular, IP addresses and location data of users, which, however, are not collected without their consent (usually carried out within the settings of their mobile devices); Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent Company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://cloud.google.com/maps-platform; Privacy Policy: https://policies.google.com/privacy; Opt-Out Option: Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • reCAPTCHA: We integrate the “reCAPTCHA” function to be able to recognize whether inputs (e.g., in online forms) are made by humans and not by automatically acting machines (so-called “bots”). The processed data may include IP addresses, information about 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 or selecting objects in images); Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent Company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://www.google.com/recaptcha/; Privacy Policy: https://policies.google.com/privacy; Opt-Out Option: Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • Twitter Plugins and Content: Twitter plugins and buttons – This may include content such as images, videos, or text and buttons that allow users to 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; Website: https://twitter.com/de; Privacy Policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
  • YouTube Videos: Video content; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent Company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Opt-Out Option: Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • Vimeo: Video content; Service Provider: Vimeo Inc., Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA; Website: https://vimeo.com; Privacy Policy: https://vimeo.com/privacy; Opt-Out Option: We note that Vimeo may use Google Analytics and refer to the privacy policy (https://policies.google.com/privacy) as well as the opt-out options for Google Analytics (https://tools.google.com/dlpage/gaoptout?hl=de) or Google’s settings for data use for marketing purposes (https://adssettings.google.com/).

Please delete the section on plugins and embedded functions and content if you do not use any plugins or embedded functions and content within your website. Otherwise, adjust the list of services and providers as needed.

Deletion of Data

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

If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted to these purposes. That is, the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person.

Further information on the deletion of personal data may also be provided within the individual data protection notices of this privacy policy.

Amendment and Update of the Privacy Policy

We ask you to regularly inform yourself about the content of our privacy policy. We will adjust the privacy policy as soon as changes in the data processing we carry out make this necessary. We will inform you as soon as the changes require your participation (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 addresses may change over time and please verify the information before making contact.

Rights of Data Subjects

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

  • Right to Object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to Withdraw Consent: You have the right to withdraw consent at any time.
  • Right of Access: You have the right to request confirmation as to whether data concerning you is being processed and to access this data as well as further information and a copy of the data in accordance with legal requirements.
  • Right to Rectification: In accordance with legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
  • Right to Erasure and Restriction of Processing: In accordance with legal requirements, you have the right to request that data concerning you be erased without delay, or alternatively, in accordance with legal requirements, to request restriction of the processing of the data.
  • Right to Data Portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used, and machine-readable format in accordance with legal requirements, or to request its transmission to another controller.
  • Complaint to Supervisory Authority: You also have the right, in accordance with legal requirements, 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 infringes the GDPR.

Definitions of Terms

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

  • Conversion Tracking: “Conversion tracking” refers to a procedure that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the devices of users within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the advertisements we placed on other websites were successful.
  • Credit Assessment: Automated decisions are based on automatic data processing without human intervention (e.g., in the case of an automatic rejection of a purchase on account, an online credit application, or an online application process without any human intervention). Such automated decisions are only permissible under Article 22 of the GDPR if data subjects consent, if they are necessary for the performance of a contract, or if national laws permit such decisions.
  • Cross-Device Tracking: Cross-device tracking is a form of tracking in which behavioral and interest information of users is recorded across devices in so-called profiles by assigning an online identifier to users. This allows user information to be analyzed for marketing purposes, regardless of the browsers or devices used (e.g., mobile phones or desktop computers). For most providers, the online identifier is not linked to clear data such as names, postal addresses, or email addresses.
  • IP Masking: “IP masking” refers to a method in which the last octet, i.e., the last two numbers of an IP address, is deleted so that the IP address can no longer serve to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing procedures, particularly in online marketing.
  • Interest-Based and Behavioral Marketing: Interest-based and/or behavioral marketing refers to the practice of predetermining potential interests of users in advertisements and other content as precisely as possible. This is done on the basis of information about their previous behavior (e.g., visiting certain websites and staying on them, purchasing behavior, or interaction with other users), which is stored in a so-called profile. Cookies are usually used for these purposes.
  • Conversion Measurement: Conversion measurement is a procedure that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the devices of users within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the advertisements we placed on other websites were successful.
  • 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., cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
  • Profiling: “Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person (depending on the type of profiling, this includes information concerning age, gender, location data and movement data, interaction with websites and their content, purchasing behavior, social interactions with other people), to analyze or predict them (e.g., interests in certain content or products, click behavior on a website, or location). Cookies and web beacons are often used for profiling purposes.
  • Reach Measurement: Reach measurement (also referred to as web analytics) is used to evaluate visitor traffic to an online service and may include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, website owners can, for example, recognize at what time visitors visit their website and what content they are interested in. This allows them, for example, to better adapt the content of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis purposes to recognize returning visitors and thus obtain more accurate analyses of the use of an online service.
  • Remarketing: “Remarketing” or “retargeting” refers to the practice of noting, for advertising purposes, which products a user was interested in on a website in order to remind the user of these products on other websites, for example in advertisements.
  • Location Data: Location data is generated when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, a WLAN, or similar technical means and functions of location determination. Location data is used to indicate at which geographically determinable position on earth the respective device is located. Location data can, for example, be used to display map functions or other information dependent on a location.
  • Tracking: “Tracking” refers to the practice of tracking user behavior across multiple online services. As a rule, behavioral and interest information is stored in cookies or on servers of the providers of tracking technologies with regard to the online services used (so-called profiling). This information can then be used, for example, to display advertisements to users that presumably correspond to their interests.
  • 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.
  • Processing: “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically every handling of data, whether it be collection, evaluation, storage, transmission, or deletion.
  • Target Group Formation: Target group formation (or “Custom Audiences”) refers to the practice of determining target groups for advertising purposes, e.g., the display of advertisements. For example, it can be inferred from a user’s interest in certain products or topics on the internet that this user is interested in advertisements for similar products or the online shop in which he or she viewed the products. “Lookalike Audiences” (or similar target groups) refers to the practice of displaying content deemed suitable to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are usually used for the purposes of creating Custom Audiences and Lookalike Audiences.