Data protection
This privacy policy informs you about the nature, scope, and purpose of the processing of personal data (hereinafter referred to as “data”) in the course of providing our services, as well as within our online offering and the associated websites, functions, and content, and external online presences, such as our social media profiles (hereinafter collectively referred to as “online offering”). Regarding the terminology used, such as “processing” or “controller,” we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
Controller
Schertz Consulting GbR
Claus Schertz
Zum Rockenhübel 33
66589 Merchweiler
Phone: 0160 / 99070862
Email: [email protected]
Controller: Claus Schertz
Types of processed data
Inventory data (e.g., personal master data, names, addresses)
Contact data (e.g., email, phone numbers)
Content data (e.g., text input, photographs, videos)
Usage data (e.g., visited websites, interest in content, access times)
Meta/communication data (e.g., device information, IP addresses)
Categories of data subjects
Visitors and users of the online offering (hereinafter we also refer to the data subjects collectively as “users”).
Purpose of processing
Provision of the online offering, its functions, and content
Responding to contact inquiries and communication with users
Security measures
Reach measurement/marketing
Terminology used
“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 one or more specific factors expressing the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” means any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data.
“Pseudonymization” means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
“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, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
“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.
“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Relevant legal bases
In accordance with Art. 13 GDPR, we inform you of the legal bases of our data processing. If the legal basis is not mentioned in the privacy policy, the following applies:
The legal basis for obtaining consents is Art. 6(1)(a) and Art. 7 GDPR;
The legal basis for processing to perform our services and carry out contractual measures as well as respond to inquiries is Art. 6(1)(b) GDPR;
The legal basis for processing to fulfill our legal obligations is Art. 6(1)(c) GDPR;
In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6(1)(d) GDPR serves as the legal basis.
The legal basis for processing to carry out a task that is in the public interest or in the exercise of official authority vested in the controller is Art. 6(1)(e) GDPR.
The legal basis for processing to safeguard our legitimate interests is Art. 6(1)(f) GDPR.
The processing of data for purposes other than those for which it was collected is determined in accordance with Art. 6(4) GDPR.
The processing of special categories of data (pursuant to Art. 9(1) GDPR) is determined in accordance with Art. 9(2) GDPR.
Security measures
We take appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, the implementation costs, and the nature, scope, circumstances, and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as access, input, transfer, availability, and separation of the data. We have also implemented procedures to ensure the exercise of data subject rights, data deletion, and responses to data threats. Furthermore, we consider the protection of personal data already during the development or selection of hardware, software, and procedures, according to the principle of data protection by design and by default.
Cooperation with processors, joint controllers, and third parties
If, in the course of our processing, we disclose data to other persons and companies (processors, joint controllers, or third parties), transmit it to them, or otherwise grant them access to the data, this is done only on the basis of legal permission (e.g., if the transfer of data to third parties, such as payment service providers, is necessary for the performance of a contract), if users have consented, if a legal obligation provides for this, or based on our legitimate interests (e.g., when using agents, web hosts, etc.).
If we disclose or transmit data to other companies within our corporate group or otherwise grant them access, this is done primarily for administrative purposes as a legitimate interest and additionally on a legal basis in accordance with legal requirements.
Transfers to third countries
If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA), or the Swiss Confederation), or if this occurs in the context of the use of third-party services or disclosure or transfer of data to other persons or companies, this is done only if it is necessary for the fulfillment of our (pre)contractual obligations, based on your consent, due to a legal obligation, or based on our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special conditions of Art. 44 ff. GDPR are met. That is, the processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection equivalent to that of the EU, or compliance with officially recognized special contractual obligations.
Rights of data subjects
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.
You have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you, in accordance with legal requirements.
In accordance with the legal requirements, you have the right to request that relevant data be deleted without undue delay, or alternatively, to request a restriction of the processing of the data.
You have the right to request to receive the data concerning you, which you have provided to us, in accordance with legal requirements and to request its transmission to other controllers.
In accordance with legal requirements, you also have the right to lodge a complaint with the competent supervisory authority.
Right of withdrawal
You have the right to revoke consents granted with effect for the future.
Right to object
You may object to the future processing of data concerning you at any time in accordance with legal requirements. The objection may in particular be made against processing for direct marketing purposes.
Cookies and right to object to direct advertising
“Cookies” are small files that are stored on users’ devices. Different information can be stored within cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit within an online offering. Temporary cookies, or “session cookies” or “transient cookies,” are cookies that are deleted after a user leaves the online offering and closes their browser. For example, the content of a shopping cart in an online store or a login status can be stored in such a cookie. “Permanent” or “persistent” cookies remain stored even after the browser is closed. For example, a login status can be saved when users visit after several days. Likewise, user interests can be stored in such a cookie, which are used for reach measurement or marketing purposes. “Third-party cookies” are cookies that are offered by providers other than the controller who operates the online offering (otherwise, if it is only their cookies, they are referred to as “first-party cookies”).
We may use temporary and permanent cookies and provide information about this within our privacy policy.
If users do not want cookies stored on their device, they are asked to disable the corresponding option in their browser’s system settings. Stored cookies can be deleted in the system settings of the browser. Excluding cookies may lead to functional limitations of this online offering.
A general objection to the use of cookies used for online marketing purposes can be declared for many of the services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be prevented by disabling them in the browser settings. Please note that not all functions of this online offering may then be usable.
Deletion of data
The data we process is deleted or its processing restricted in accordance with legal requirements. Unless explicitly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any legal retention obligations.
If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means 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.
Changes and updates to the privacy policy
We ask you to regularly inform yourself about the content of our privacy policy. We adapt the privacy policy as soon as the changes in the data processing we carry out make this necessary. We will inform you as soon as such changes require your cooperation (e.g., consent) or other individual notification.
Business-related processing
Additionally, we process
Contract data (e.g., subject matter of the contract, term, customer category)
Payment data (e.g., bank details, payment history)
of our customers, interested parties, and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising, and market research.
Order processing in the online shop and customer account
We process our customers’ data in the context of order processes in our online shop in order to enable them to select and order the chosen products and services, as well as their payment and delivery or execution.
The processed data includes inventory data, communication data, contract data, payment data, and the data subjects include our customers, interested parties, and other business partners. The processing is carried out for the purpose of providing contractual services in the context of operating an online shop, billing, delivery, and customer service. In this context, we use session cookies to store the contents of the shopping cart and permanent cookies to store the login status.
Processing is carried out to fulfill our services and execute contractual measures (e.g., processing of order transactions) and to the extent that it is legally required (e.g., legally required archiving of business transactions for commercial and tax purposes). The information marked as required is necessary for the conclusion and fulfillment of the contract. We disclose data to third parties only in the context of delivery, payment, or within the framework of legal authorizations and obligations, as well as based on our legitimate interests, about which we inform you in the context of this privacy policy (e.g., to legal and tax advisors, financial institutions, freight companies, and authorities).
Users can optionally create a user account in which they can particularly view their orders. As part of the registration, users are informed of the required mandatory information. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data in relation to the user account will be deleted, subject to its retention being necessary for commercial or tax law reasons. Information in the customer account remains until its deletion with subsequent archiving in the case of a legal obligation or our legitimate interests (e.g., in the event of legal disputes). It is the responsibility of users to secure their data before the end of the contract in the event of termination.
As part of the registration and re-registrations as well as the use of our online services, we store the IP address and the time of the respective user action. Storage is based on our legitimate interests as well as those of users in protection against misuse and other unauthorized use. A transfer of this data to third parties does not take place in principle, unless it is necessary to pursue our claims as a legitimate interest or there is a legal obligation to do so.
Deletion takes place after the expiration of legal warranty and comparable obligations; the necessity of retention of the data is reviewed every three years; in the case of legal archiving obligations, deletion takes place after their expiration.
Agency services
We process our clients’ data within the scope of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/advice or maintenance, implementation of campaigns and processes/handling, server administration, data analysis/advice services, and training services.
In doing so, we process inventory data (e.g., customer master data such as names or addresses), contact data (e.g., email, phone numbers), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter of the contract, term), payment data (e.g., bank account, payment history), usage and metadata (e.g., as part of the evaluation and measurement of marketing measures). We generally do not process special categories of personal data unless they are components of commissioned processing. The data subjects include our clients, prospects as well as their clients, users, website visitors, or employees, and third parties. The purpose of the processing is the provision of contractual services, billing, and our customer service. The legal bases of the processing are Art. 6 para. 1 lit. b GDPR (contractual services), Art. 6 para. 1 lit. f GDPR (analysis, statistics, optimization, security measures). We process data that is necessary for the establishment and fulfillment of contractual services and indicate the necessity of their provision unless this is evident to the data subjects. Disclosure to external parties only takes place if it is required within the framework of an order. When processing data provided to us by the client within an order, we act in accordance with the client’s instructions and the legal requirements of commissioned processing pursuant to Art. 28 GDPR and do not process the data for any other purposes than those specified in the order.
We delete the data after the expiry of statutory warranty and comparable obligations. The necessity of retaining the data is reviewed every three years; in the case of statutory archiving obligations, deletion takes place after their expiry (6 years under § 257 para. 1 HGB, 10 years under § 147 para. 1 AO). In the case of data disclosed to us within the framework of an order by the client, we delete the data in accordance with the specifications of the order, in principle after the end of the order.
Therapeutic services and coaching
We process the data of our clients and interested parties and other clients or contractual partners (collectively referred to as "clients") in accordance with Art. 6 para. 1 lit. b GDPR to provide them with our contractual or pre-contractual services. The type, scope, and purpose, and necessity of the data processing are determined according to the underlying contractual relationship. The processed data includes, in principle, inventory and master data of the clients (e.g., name, address, etc.), as well as contact data (e.g., email address, telephone, etc.), contract data (e.g., services used, fees, names of contact persons, etc.), and payment data (e.g., bank details, payment history, etc.).
As part of our services, we may also process special categories of data pursuant to Art. 9 para. 1 GDPR, in particular information about the health of the clients, possibly with reference to their sex life or sexual orientation, ethnic origin, or religious or ideological beliefs. For this, we obtain explicit consent from clients pursuant to Art. 6 para. 1 lit. a, Art. 7, and Art. 9 para. 2 lit. a GDPR, provided this is required, and otherwise process the special categories of data for purposes of health care on the basis of Art. 9 para. 2 lit. h GDPR, § 22 para. 1 no. 1 b BDSG.
If necessary for the fulfillment of the contract or legally required, we disclose or transmit the clients’ data in the context of communication with other professionals, typically or necessarily involved third parties, such as billing centers or comparable service providers, if this serves to provide our services pursuant to Art. 6 para. 1 lit. b GDPR, is legally required pursuant to Art. 6 para. 1 lit. c GDPR, is in our or the clients’ interest in an efficient and cost-effective health care provision as a legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR, or is necessary pursuant to Art. 6 para. 1 lit. d GDPR to protect vital interests of the clients or another natural person, or within the framework of consent pursuant to Art. 6 para. 1 lit. a, Art. 7 GDPR.
Data is deleted when it is no longer necessary for the fulfillment of contractual or legal duties of care and dealing with any warranty or comparable obligations, with the necessity of data retention reviewed every three years; otherwise, the statutory retention obligations apply.
Contractual services
We process the data of our contractual partners and interested parties as well as other clients, customers, clients, or contractual partners (uniformly referred to as "contractual partners") in accordance with Art. 6 para. 1 lit. b GDPR to provide them with our contractual or pre-contractual services. The processed data, the type, scope, purpose, and necessity of their processing are determined by the underlying contractual relationship.
The processed data includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g., email addresses and telephone numbers), as well as contract data (e.g., services used, contract contents, contractual communication, names of contact persons) and payment data (e.g., bank details, payment history).
We generally do not process special categories of personal data unless they are part of commissioned or contractual processing.
We process data that is necessary for the justification and fulfillment of the contractual services and point out the necessity of their disclosure unless this is obvious to the contractual partners. Disclosure to external persons or companies only takes place if required under the contract. When processing data provided to us within an order, we act in accordance with the instructions of the clients and legal requirements.
When using our online services, we may store the IP address and the time of the respective user action. Storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorized use. In principle, this data is not passed on to third parties unless it is necessary to pursue our claims according to Art. 6 para. 1 lit. f GDPR or there is a legal obligation according to Art. 6 para. 1 lit. c GDPR.
The data is deleted when it is no longer required for the fulfillment of contractual or statutory duties of care as well as dealing with any warranty or comparable obligations, whereby the necessity of data retention is reviewed every three years; otherwise, the statutory retention obligations apply.
External payment service providers
We use external payment service providers through whose platforms users and we can carry out payment transactions (e.g., each with a link to the privacy policy, PayPal [https://www.paypal.com/de/webapps/mpp/ua/privacy-full], Klarna [https://www.klarna.com/de/datenschutz/], Skrill [https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/], Giropay [https://www.giropay.de/rechtliches/datenschutz-agb/], Visa [https://www.visa.de/datenschutz], Mastercard [https://www.mastercard.de/de-de/datenschutz.html], American Express [https://www.americanexpress.com/de/content/privacy-policy-statement.html]).
Within the scope of contract fulfillment, we use the payment service providers on the basis of Art. 6 para. 1 lit. b GDPR. Otherwise, we use external payment service providers on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR in order to offer our users effective and secure payment options.
The data processed by the payment service providers includes inventory data, such as name and address, bank details such as account numbers or credit card numbers, passwords, TANs, and checksums, as well as contract, sum, and recipient-related information. The information is necessary to carry out the transactions. However, the entered data is only processed and stored by the payment service providers. That means we do not receive account or credit card information, only information with confirmation or negative reporting of the payment. In some cases, the data may be transmitted by the payment service providers to credit agencies. This transmission aims at identity and credit checks. We refer to the terms and privacy policies of the respective payment service providers for this.
For payment transactions, the terms and conditions and the privacy policies of the respective payment service providers apply, which can be accessed from 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.
Administration, financial accounting, office organization, contact management
We process data within the scope of administrative tasks as well as the organization of our operations, financial accounting, and compliance with legal obligations, such as archiving. In this context, we process the same data that we process within the scope of providing our contractual services. The legal bases for processing are Art. 6 para. 1 lit. c GDPR and Art. 6 para. 1 lit. f GDPR. Data subjects affected by the processing include customers, interested parties, business partners, and website visitors. The purpose and our interest in processing lie in the administration, financial accounting, office organization, archiving of data—tasks that serve the maintenance of our business activities, the performance of our tasks, and the provision of our services. Data deletion with regard to contractual services and contractual communication corresponds to the information specified in these processing activities.
We disclose or transmit data to the tax authorities, consultants such as tax advisors or auditors, and other fee offices and payment service providers.
Furthermore, we store information about suppliers, organizers, and other business partners on the basis of our business interests, e.g., for the purpose of later contact. These mostly company-related data are stored permanently as a general rule.
Business analyses and market research
In order to operate our business economically, to identify market trends, customer and user preferences, we analyze the data available to us on business transactions, contracts, inquiries, etc. We process inventory data, communication data, contract data, payment data, usage data, and metadata based on Art. 6 para. 1 lit. f GDPR, with the data subjects including contractual partners, interested parties, customers, visitors, and users of our online offering.
The analyses are carried out for the purpose of business evaluations, marketing, and market research. In doing so, we can take into account the profiles of registered users, including data such as the services they have used. The analyses serve us to increase user-friendliness, optimize our offering, and improve business efficiency. The analyses are solely for our own use and are not disclosed externally unless they involve anonymous analyses with aggregated values.
If these analyses or profiles are personal, they will be deleted or anonymized upon user termination; otherwise, two years after the conclusion of the contract. In all other respects, overall business analyses and general trend determinations are created anonymously wherever possible.
Participation in affiliate programs
Within our online offering, we use industry-standard tracking measures based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offering) pursuant to Art. 6 para. 1 lit. f GDPR, to the extent that these are necessary for the operation of the affiliate system. Below, we inform users about the technical background.
The services offered by our contractual partners may also be advertised and linked on other websites (so-called affiliate links or after-buy systems, e.g., if links or services of third parties are offered after a contract is concluded). The operators of the respective websites receive a commission if users follow the affiliate links and then make use of the offers.
In summary, it is necessary for our online offering that we can track whether users who are interested in affiliate links and/or the products available with us subsequently take up the offers at the instigation of the affiliate links or our online platform. For this purpose, the affiliate links and our offerings are supplemented with certain values that are part of the link or otherwise set, e.g., in a cookie. These values include, in particular, the originating website (referrer), time, an online identifier of the website operator on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as tracking-specific values such as advertising material ID, partner ID, and categorizations.
The online identifiers of users we use are pseudonymous values. That means the online identifiers do not themselves contain personal data such as names or email addresses. They help us only to determine whether the same user who clicked on an affiliate link or was interested in an offer via our online offering has taken up the offer, i.e., for example, concluded a contract with the provider. However, the online identifier is personal to the extent that the partner company and also we have the online identifier together with other user data. Only in this way can the partner company inform us whether the user has taken up the offer and we, for example, can pay out the bonus.
Amazon affiliate program
Based on our legitimate interests (i.e., interest in the economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f GDPR), we are a participant in the Amazon EU affiliate program, which was designed to provide a medium for websites to earn advertising fees by placing advertisements and links to Amazon.de (so-called affiliate system). This means that as an Amazon partner, we earn from qualified purchases.
Amazon uses cookies to be able to trace the origin of the orders. Among other things, Amazon can recognize that you clicked on the partner link on this website and subsequently purchased a product from Amazon.
Further information on data usage by Amazon and options for objection can be found in the company's privacy policy:
https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010
Note: Amazon and the Amazon logo are trademarks of Amazon.com, Inc. or one of its affiliated companies.
Digistore24 affiliate program
Based on our legitimate interests (i.e., interest in the economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f GDPR), we are a participant in the affiliate program of Digistore24 GmbH, St.-Godehard-Straße 32, 31139 Hildesheim, Germany, which is designed to provide a medium for websites through which advertising fees can be earned by placing advertisements and links to Digistore24 (so-called affiliate system). Digistore24 uses cookies to be able to trace the origin of the contract conclusion. Among other things, Digistore24 can recognize that you clicked on the partner link on this website and subsequently made a contract conclusion at or through Digistore24.
Further information on data usage by Digistore24 and options for objection can be found in the company's privacy policy:
https://www.digistore24.com/page/privacyl
Privacy information in the application process
We process applicant data only for the purpose and within the scope of the application procedure in accordance with legal requirements. Applicant data is processed to fulfill our (pre)contractual obligations within the application procedure in accordance with Art. 6 para. 1 lit. b GDPR, Art. 6 para. 1 lit. f GDPR if data processing becomes necessary for us, e.g., in the context of legal procedures (in Germany, § 26 BDSG also applies).
The application process requires that applicants provide us with the applicant data. Necessary applicant data are identified where we offer an online form, otherwise result from the job descriptions and generally include information about the person, postal and contact addresses, and the application documents such as cover letter, CV, and certificates. Applicants may also voluntarily provide additional information.
By submitting the application to us, applicants consent to the processing of their data for the purposes of the application process in accordance with the nature and scope set out in this privacy policy.
Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are voluntarily communicated as part of the application process, their processing is additionally carried out in accordance with Art. 9 para. 2 lit. b GDPR (e.g., health data, such as severe disability or ethnic origin). If special categories of personal data within the meaning of Art. 9 para. 1 GDPR are requested from applicants as part of the application process, their processing is additionally carried out in accordance with Art. 9 para. 2 lit. a GDPR (e.g., health data if they are necessary for the exercise of the profession).
If provided, applicants can submit their applications via an online form on our website. The data will be transmitted to us encrypted according to the state of the art.
Applicants can also send us their applications via email. However, please note that emails are generally not encrypted and applicants themselves must ensure encryption. We cannot therefore accept any responsibility for the transmission path of the application between the sender and receipt on our server and therefore recommend using an online form or postal submission instead. In addition to the online form and email, applicants can still send us their application by post.
The data provided by applicants may be further processed by us in the event of a successful application for the purposes of the employment relationship. Otherwise, if the application for a job posting is not successful, the data of the applicants will be deleted. The applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time.
Deletion takes place, subject to a legitimate withdrawal by the applicants, after a period of six months so that we can answer any follow-up questions about the application and meet our obligations under the Equal Treatment Act. Invoices for any travel expense reimbursement are archived in accordance with tax law requirements.
Registration function
Users can create a user account. As part of the registration, the required mandatory information is communicated to the users and processed based on Art. 6 para. 1 lit. b GDPR for the purpose of providing the user account. The processed data includes in particular the login information (name, password, and an email address). The data entered during registration will be used for the purpose of using the user account and its intended purpose.
Users may be informed by email about information relevant to their user account, such as technical changes. If users have terminated their user account, their data related to the user account will be deleted, subject to legal retention obligations. It is the responsibility of users to back up their data before the end of the contract in case of termination. We are entitled to irretrievably delete all user data stored during the contract term.
As part of the use of our registration and login functions and the use of the user account, we store the IP address and the time of the respective user action. Storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorized use. As a rule, this data is not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation according to Art. 6 para. 1 lit. c GDPR. IP addresses are anonymized or deleted at the latest after 7 days.
Contacting us
When contacting us (e.g., via contact form, email, phone, or social media), the user’s details are processed to handle the contact request and its processing in accordance with Art. 6 para. 1 lit. b (within the framework of contractual/pre-contractual relationships), Art. 6 para. 1 lit. f (other inquiries) GDPR. The user information may be stored in a Customer Relationship Management System ("CRM System") or comparable inquiry organization.
We delete inquiries if they are no longer necessary. We review the necessity every two years; furthermore, the statutory archiving obligations apply.
Newsletter
With the following information, we inform you about the contents of our newsletter as well as the registration, dispatch, and statistical evaluation procedures and your rights of objection. By subscribing to our newsletter, you agree to the receipt and the described procedures.
Content of the newsletter: We only send newsletters, emails, and other electronic notifications with promotional information (hereinafter "newsletter") with the consent of the recipients or a legal permission. If the contents of the newsletter are specifically described within the scope of a registration, they are decisive for the user’s consent. Otherwise, our newsletters contain information about our services and us.
Double opt-in and logging: Registration for our newsletter is carried out in a so-called double opt-in process. This means you will receive an email after registration asking you to confirm your registration. This confirmation is necessary so that no one can register with third-party email addresses. Newsletter registrations are logged in order to be able to prove the registration process in accordance with legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored with the dispatch service provider are also logged.
Registration data: To sign up for the newsletter, it is sufficient to provide your email address. Optionally, we ask you to provide a name for personal salutation in the newsletter.
The dispatch of the newsletter and the associated performance measurement are based on the consent of the recipients according to Art. 6 para. 1 lit. a, Art. 7 GDPR in conjunction with § 7 para. 2 no. 3 UWG or, if consent is not required, on our legitimate interests in direct marketing according to Art. 6 para. 1 lit. f GDPR in conjunction with § 7 para. 3 UWG.
The logging of the registration process is based on our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR. Our interest is focused on the use of a user-friendly and secure newsletter system that serves both our business interests and meets the expectations of the users and also allows us to prove consent.
Cancellation/revocation – You can cancel the receipt of our newsletter at any time, i.e., revoke your consent. You will find a link to unsubscribe from the newsletter at the end of each newsletter. We may store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before we delete them to prove previously given consent. The processing of this 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 consent is confirmed at the same time.
Newsletter – Mailing service provider
The newsletter is sent using the mailing service provider [NAME, ADDRESS, COUNTRY]. You can view the data protection provisions of the mailing service provider here: [LINK TO THE PRIVACY POLICY]. The mailing service provider is used based on our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR and a data processing agreement pursuant to Art. 28 para. 3 sentence 1 GDPR.
The mailing service provider may use the recipients' data in pseudonymous form, i.e., without assignment to a user, to optimize or improve their own services, e.g., for technical optimization of the delivery and the presentation of the newsletter or for statistical purposes. However, the mailing service provider does not use the data of our newsletter recipients to write to them themselves or to pass the data on to third parties.
Newsletter – Performance measurement
The newsletters contain a so-called “web beacon,” i.e., a pixel-sized file that is retrieved from our server or, if we use a mailing service provider, from their server when the newsletter is opened. During this retrieval, technical information is first collected, such as information about the browser and your system, as well as your IP address and the time of the retrieval.
This information is used to technically improve the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or access times. The statistical data collected also includes whether the newsletters are opened, when they are opened, and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our intention nor, if used, that of the mailing service provider, to observe individual users. The evaluations serve to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
Unfortunately, a separate revocation of the performance measurement is not possible; in this case, the entire newsletter subscription must be canceled.
Hosting and email dispatch
The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, email dispatch, security services, and technical maintenance services that we use for the operation of this online offering.
We, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties, and visitors to this online offering based on our legitimate interests in an efficient and secure provision of this online offering in accordance with Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of a data processing agreement).
Collection of access data and log files
We, or our hosting provider, collect data based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f GDPR about every access to the server on which this service is located (so-called server log files). Access data includes the name of the accessed website, file, date and time of access, amount of data transferred, notification of successful access, browser type including version, the user’s operating system, referrer URL (the previously visited page), IP address, and the requesting provider.
Log file information is stored for security reasons (e.g., to investigate abuse or fraud) for a maximum of 7 days and then deleted. Data that needs to be retained for evidence purposes is excluded from deletion until the respective incident is finally resolved.
Google Analytics
We use Google Analytics, a web analysis service of Google LLC (“Google”), based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f GDPR). Google uses cookies. The information generated by the cookie about the use of the online offering by users is usually transmitted to a Google server in the USA and stored there.
Google is certified under the Privacy Shield agreement and thus offers a guarantee to comply with European data protection law:
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active
Google will use this information on our behalf to evaluate the use of our online offering by users, to compile reports on the activities within this online offering, and to provide us with further services associated with the use of this online offering and internet usage. In doing so, pseudonymous usage profiles of users may be created from the processed data.
We use Google Analytics only with IP anonymization enabled. This means that the IP address of users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user’s browser will not be merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent Google from collecting the data generated by the cookie and related to their use of the online offering and from processing this data by Google by downloading and installing the browser plug-in available at the following link:
http://tools.google.com/dlpage/gaoptout?hl=de
Further information on data usage by Google, settings, and opt-out options can be found in Google’s privacy policy:
https://policies.google.com/privacy
and in the settings for the display of advertisements by Google:
https://adssettings.google.com/authenticated
The personal data of users is deleted or anonymized after 14 months.
Google AdSense with personalized ads
We use the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”) on the basis of our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offering in accordance with Art. 6 para. 1 lit. f GDPR).
Google is certified under the Privacy Shield agreement and thus offers a guarantee to comply with European data protection law:
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active
We use the AdSense service, which enables advertisements to be integrated into our website and allows us to earn compensation for their display or other use. For these purposes, usage data such as clicks on ads and users’ IP addresses are processed, whereby the IP address is shortened by the last two digits. Therefore, the processing of the data of users is pseudonymized.
We use AdSense with personalized ads. In doing so, Google draws conclusions about the interests of users based on their visited websites or used apps and the user profiles thus created. Advertisers use this information to tailor their campaigns to those interests, which benefits both users and advertisers. Ads are considered personalized by Google when collected or known data determines or influences the ad selection. This includes, for example, previous search queries, activities, website visits, app usage, demographic and location information. In detail, this includes: demographic targeting, interest-based targeting, remarketing, and targeting on customer match lists and audience lists uploaded to DoubleClick Bid Manager or Campaign Manager.
Further information on data usage by Google, settings, and opt-out options can be found in Google’s privacy policy:
https://policies.google.com/technologies/ads
and in the settings for the display of advertisements by Google:
https://adssettings.google.com/authenticated
Facebook Pixel, Custom Audiences, and Facebook Conversion
Within our online offering, due to our legitimate interests in analysis, optimization, and the economic operation of our online offering, and for these purposes, the so-called "Facebook Pixel" of the social network Facebook is used, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”).
Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law:
https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active
With the help of the Facebook Pixel, it is possible for Facebook to determine the visitors of our online offering as a target group for the display of advertisements (so-called "Facebook Ads"). Accordingly, we use the Facebook Pixel to show Facebook Ads only to Facebook users who have shown an interest in our online offering or who have certain characteristics (e.g., interests in certain topics or products determined based on the visited websites) that we transmit to Facebook (so-called "Custom Audiences"). With the help of the Facebook Pixel, we also want to ensure that our Facebook Ads correspond to the potential interest of users and are not annoying. The Facebook Pixel also allows us to 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").
The processing of data by Facebook is carried out within the framework of Facebook’s data usage policy. Accordingly, general information on the display of Facebook Ads can be found in Facebook's data usage policy:
https://www.facebook.com/policy
Special information and details about the Facebook Pixel and how it works can be found in Facebook’s help section:
https://www.facebook.com/business/help/651294705016616
You can object to the collection by the Facebook Pixel and the use of your data for displaying Facebook Ads. To set what types of ads are shown to you within Facebook, you can visit the page set up by Facebook and follow the instructions there regarding settings for usage-based advertising:
https://www.facebook.com/settings?tab=ads
The settings are platform-independent, meaning they apply to all devices, such as desktop computers or mobile devices.
You can also object to the use of cookies for reach measurement and advertising purposes via the deactivation page of the Network Advertising Initiative:
http://optout.networkadvertising.org/
as well as via the US website:
http://www.aboutads.info/choices
or the European website:
http://www.youronlinechoices.com/uk/your-ad-choices/
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