Privacy Policy
Effective: July 3, 2023
Table of Contents
- Responsible Entity
- Contact Data Protection Officer
- Overview of Processing
- Relevant Legal Bases
- Security Measures
- Transmission of Personal Data
- International Data Transfers
- Deletion of Data
- Use of Cookies
- Business Services
- Use of Online Platforms for Offer and Distribution Purposes
- Payment Procedures
- Provision of Online Services and Web Hosting
- Registration, Login and User Account
- Blogs and Publication Media
- Contact and Inquiry Management
- Communication via Messenger
- Newsletters and Electronic Notifications
- Advertising Communication via Email, Mail, Fax or Telephone
- Contests and Competitions
- Surveys and Questionnaires
- Web Analysis, Monitoring and Optimization
- Online Marketing
- Affiliate Programs and Affiliate Links
- Offering of an Affiliate Program
- Customer Reviews and Rating Procedures
- Presence in Social Networks (Social Media)
- Plugins and Embedded Functions and Content
- Management, Organization and Utility Tools
- Changes and Updates to the Privacy Policy
- Rights of the Data Subjects
- Definitions of Terms
1. Responsible Entity
Green Balcony UG (limited liability)
Herbartstraße 16A
14057 Berlin, Germany
Authorized Representatives: Bruno Schubert
Phone: +49 (0)30 23963890
Email: info@greenbalcony.com
Imprint: https://www.greenbalcony.com/l/contact
2. Contact Data Protection Officer
info@greenbalcony.com
3. Overview of Processing
The following overview summarizes the types of data processed, the purposes of their processing, and refers to the affected persons.
Types of Processed Data
-> Inventory Data.
-> Payment Data.
-> Location Data.
-> Contact Data.
-> Content Data.
-> Contract Data.
-> Usage Data.
-> Meta-, Communication and Procedure Data.
-> Event Data (Facebook).
Categories of Affected Persons
-> Customers.
-> Prospects.
-> Communication Partners.
-> Users.
-> Contest and Competition Participants.
-> Business and Contractual Partners.
-> Participants.
Purposes of Processing
-> Provision of Contractual Services and Customer Service.
-> Contact Inquiries and Communication.
-> Security Measures.
-> Direct Marketing.
-> Reach Measurement.
-> Tracking.
-> Office and Organizational Procedures.
-> Conversion Measurement.
-> Affiliate Tracking.
-> Management and Response to Inquiries.
-> Conducting Contests and Competitions.
-> Feedback.
-> Marketing.
-> Profiles with User-Related Information.
-> Provision of Our Online Services and User-Friendliness.
-> Information Technology Infrastructure.
4. Relevant Legal Bases
Below is an overview of the legal bases of the 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. If more specific legal bases are relevant in individual cases, we will inform you of these in the privacy policy.
-> Consent (Article 6 (1) sentence 1 lit. a GDPR) - The data subject has given consent to the processing of their personal data for one or more specific purposes.
-> Contract performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b GDPR) - The processing is necessary for the performance of a contract to which the data subject is a party, or for the execution of pre-contractual measures taken at the data subject's request.
-> Legal obligation (Article 6 (1) sentence 1 lit. c GDPR) - The processing is necessary for compliance with a legal obligation to which the controller is subject.
-> Legitimate interests (Article 6 (1) sentence 1 lit. f GDPR) - The processing is necessary to protect the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, prevail.
In addition to the GDPR's data protection provisions, national data protection regulations apply in Germany. This includes, in particular, the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG), which contains special regulations on the right to access, the right to deletion, the right to object, the processing of special categories of personal data, processing for other purposes, and transmission, as well as automated decision-making in individual cases including profiling. Furthermore, state data protection laws of the individual federal states may apply.
5. Security Measures
In accordance with legal requirements and taking into account the state of the art, the costs of implementation, and the nature, scope, circumstances, and purposes of processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of security appropriate to the risk.
These measures particularly include ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access to, input of, transfer of, securing of availability of, and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to data compromise. In addition, we consider the protection of personal data in the development or selection of hardware, software, and procedures, in accordance with the principle of data protection through technology design and through privacy-friendly default settings.
TLS encryption (https): To protect your data transmitted via our online service, we use TLS encryption. You can recognize such encrypted connections by the prefix https:// in your browser's address bar.
6. Transmission of Personal Data
In the course of processing personal data, it may happen that the data is transferred to other bodies, companies, legally independent organizational units, or persons, or disclosed to them. Recipients of this data may include, for example, service providers tasked with IT tasks or providers of services and content integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements, which serve the protection of your data, with the recipients of your data.
Data transfer within the organization: We may transfer personal data to other entities within our organization or grant them access to this data. If this transfer is for administrative purposes, the transfer of data is based on our legitimate business and economic interests or takes place if it is necessary for the fulfillment of our contractual obligations or if consent of the data subjects or a legal permission exists.
7. International Data Transfers
If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of using third-party services or the disclosure or transfer of data to other persons, bodies, or companies, this only occurs in accordance with legal requirements.
Subject to express consent or contractually or legally required transmission, we process or allow the data to be processed only in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, the existence of certifications, or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).
8. Deletion of Data
The data we process will be deleted in accordance with legal requirements as soon as their consent allowed for processing is revoked or other permissions cease to apply (e.g., if the purpose of processing this data has ceased to apply or they are not required for the purpose). If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons or whose storage is necessary to assert, exercise, or defend legal claims or to protect the rights of another natural or legal person.
Our privacy notices may also contain further information on the retention and deletion of data, which take precedence for the respective processing operations.
9. Use of Cookies
Cookies are small text files or other storage markers that store information on end devices and read information from these devices. For example, they are used to store login status in a user account, shopping cart contents in an e-shop, accessed content, or used functions of an online offer. Cookies can also be used for various purposes, such as for the functionality, security, and comfort of online offers, as well as the creation of visitor flow analyses.
Consent Notice: We use cookies in compliance with legal regulations. Therefore, we obtain prior consent from users, except where such consent is not legally required. Consent is particularly unnecessary if the storage and reading of information, including cookies, are absolutely necessary to provide a telemedia service explicitly desired by the users (i.e., our online offer). Essential cookies typically include those with functions for displaying and operating the online offer, load balancing, security, storing user preferences and selections, or similar purposes associated with providing the main and ancillary functions of the online offer requested by users. The revocable consent is clearly communicated to the 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 using cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed with cookies are processed on the basis of our legitimate interests (e.g., in a commercial operation of our online offer and its usability improvement) or if it occurs within the scope of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We clarify the purposes for which cookies are processed by us in the course of this privacy policy or within our consent and processing processes.
Storage Duration: Regarding storage duration, the following types of cookies are distinguished:
-> Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user leaves an online offer and closes their end device (e.g., browser or mobile application).
-> Permanent cookies: Permanent cookies remain stored even after closing the end device. For example, login status can be saved or preferred content can be displayed directly when the user revisits a website. User data collected with cookies can also be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., during consent acquisition), users should assume that cookies are permanent and the storage duration can be up to two years.
General Notes on Revocation and Objection (so-called "Opt-Out"): Users can revoke their given consents at any time and object to processing in accordance with legal requirements. Among other things, users can restrict the use of cookies in their browser settings (which may, however, also limit the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.
Cookie settings / objection possibility:
https://www.greenbalcony.com/l/cookiepolicy
-> Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR); Consent (Art. 6 para. 1 sentence 1 lit. a GDPR).
Additional Notes on Processing Processes, Procedures, and Services:
-> Processing of Cookie Data Based on Consent: We implement a cookie consent management procedure, within which users' consents to the use of cookies or the processes and providers mentioned in the cookie consent management procedure are obtained, managed, and revoked by the users. The declaration of consent is stored to avoid repeating the query and to be able to prove the consent according to the legal obligation. Storage can occur server-side and/or in a cookie (so-called opt-in cookie, or using comparable technologies) to be able to assign the consent to a user or their device. Subject to individual information about the providers of cookie management services, the following notes apply: The duration of consent storage can be up to two years. A pseudonymous user identifier is formed and stored along 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 used end device; Legal Bases: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR).
10. Business Services
We process data of our contractual and business partners, e.g., customers and prospects (collectively referred to as "contractual partners"), within the scope of contractual and comparable legal relationships as well as associated measures and within the scope of communication with the contractual partners (or pre-contractual), e.g., to answer inquiries.
We process these data to fulfill our contractual obligations. This includes, in particular, the obligations to provide the agreed services, any update obligations, and remedies for warranty and other service disruptions. Furthermore, we process the data to protect our rights and for the purposes of the administrative tasks associated with these obligations and the business organization. In addition, we process the data based on our legitimate interests in proper and business-economic management and in security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information, and rights (e.g., involving telecommunications, transport, and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers, or financial authorities). Within the scope of the applicable law, we only disclose the data of contractual partners to third parties to the extent necessary for the aforementioned purposes or for the fulfillment of legal obligations. Further forms of processing, e.g., for marketing purposes, are informed to contractual partners within this privacy policy
Which data are necessary for the aforementioned purposes, we inform the contractual partners before or during the data collection, e.g., in online forms, by special marking (e.g., colors) or symbols (e.g., asterisks or similar), or personally.
We delete the data after the expiry of legal warranty and comparable obligations, i.e., generally after 4 years, unless the data are stored in a customer account, e.g., as long as they must be stored for legal archiving reasons. The legal retention period for tax-relevant documents as well as for commercial books, inventories, opening balance sheets, annual financial statements, work instructions necessary for understanding these documents, and other organizational documents and booking vouchers is ten years, and for received commercial and business letters and copies of sent commercial and business letters is six years. The period begins at the end of the calendar year in which the last entry in the book was made, the inventory, opening balance sheet, annual financial statement, or management report was prepared, the commercial or business letter was received or sent, or the booking voucher was created, or the recording was made, or the other documents were created.
To the extent that we use third-party providers or platforms to provide our services, the terms and conditions and privacy notices of the respective third-party providers or platforms apply in relation to the users.
-> Processed data types: Inventory data (e.g., names, addresses); Payment data (e.g., bank details, invoices, payment history); Contact data (e.g., email, telephone numbers); Contract data (e.g., subject matter of the contract, duration, customer category); Usage data (e.g., visited websites, interest in content, access times); Meta-, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
-> Affected Persons: Customers; Prospects; Business and contractual partners.
-> Purposes of processing: Provision of contractual services and customer service; Security measures; Contact inquiries and communication; Office and organizational procedures; Administration and response to inquiries.
-> Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
Additional Notes on Processing Processes, Procedures, and Services:
-> Customer Account: Customers can create an account within our online offer (e.g., customer or user account, briefly "customer account"). If the registration of a customer account is required, customers are informed of this as well as the information required for registration. Customer accounts are not public and cannot be indexed by search engines. During registration as well as subsequent logins and use of the customer account, we store the IP addresses of the customers along with the access times to prove the registration and prevent possible misuse of the customer account. If the customer account is terminated, the data of the customer account will be deleted after the termination date, unless they are kept for other purposes than providing the customer account or for legal reasons (e.g., internal storage of customer data, order processes, or invoices). It is the responsibility of the customers to secure their data upon termination of the customer account; Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR).
-> Shop and E-Commerce: We process the data of our customers to enable them to select, purchase, or order the chosen products, goods, and associated services, as well as their payment and delivery, or execution. If necessary for the execution of an order, we use service providers, especially postal, forwarding, and shipping companies, to carry out the delivery or execution to our customers. For processing payment transactions, we use the services of banks and payment service providers. The required data are marked as such within the order or comparable purchase process and include the data necessary for delivery, or provision and billing as well as contact information to be able to hold any consultation; Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR).
11. Use of Online Platforms for Offering and Distribution Purposes
We offer our services on online platforms operated by other service providers. In this context, in addition to our privacy notices, the privacy notices of the respective platforms apply, especially regarding the execution of payment processes and the procedures used on the platforms for reach measurement and interest-based marketing.
-> Types of Processed Data: 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., contract subject, duration, customer category); Usage Data (e.g., websites visited, interest in content, access times); Meta/Communication and Procedure Data (e.g., IP addresses, time information, identification numbers, consent status).
-> Affected Persons: Customers.
-> Purposes of Processing: Provision of contractual services and customer service; Marketing.
-> Legal Bases: Contract Fulfillment and Pre-Contractual Inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR).
12. Payment Procedures
In the context of contractual and other legal relationships, due to legal obligations, or otherwise based on our legitimate interests, we offer affected persons efficient and secure payment options and employ banks and credit institutions as well as other service providers (collectively "Payment Service Providers").
The data processed by the Payment Service Providers includes Inventory Data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs, checksums, as well as contract, sum, and recipient-related information. These details are necessary to carry out the transactions. However, the data entered is processed and stored only by the Payment Service Providers. This means we do not receive any account or credit card-related information but only information with confirmation or negative notice of payment. The data may be transmitted by the Payment Service Providers to credit reporting agencies. This transmission aims to check identity and creditworthiness. For this purpose, we refer to the terms and conditions and the privacy notices of the Payment Service Providers.
The terms and conditions and privacy notices of the respective Payment Service Providers, which are available within their respective websites or transaction applications, apply to payment transactions. We also refer to these for further information and the assertion of revocation, information, and other data subject rights.
-> Types of Processed Data: Inventory Data (e.g., names, addresses); Payment Data (e.g., bank details, invoices, payment history); Contract Data (e.g., contract subject, duration, customer category); Usage Data (e.g., websites visited, interest in content, access times); Meta/Communication and Procedure Data (e.g., IP addresses, time information, identification numbers, consent status); Contact Data (e.g., email, phone numbers).
-> Affected Persons: Customers; Interested Parties.
-> Purposes of Processing: Provision of contractual services and customer service.
-> Legal Bases: Contract Fulfillment and Pre-Contractual Inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR).
Further Information on Processing Procedures, Methods, and Services:
-> Apple Pay: Payment services (technical integration of online payment methods); Service Provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal Bases: Contract Fulfillment and Pre-Contractual Inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR); Website: https://www.apple.com/de/apple-pay/; Privacy Policy: https://www.apple.com/legal/privacy/de-ww/.
-> Giropay: Payment services (technical integration of online payment methods); Service Provider: giropay GmbH, An der Welle 4, 60322 Frankfurt, Germany; Legal Bases: Contract Fulfillment and Pre-Contractual Inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR); Website: https://www.giropay.de; Privacy Policy: https://www.giropay.de/rechtliches/datenschutzerklaerung/.
-> Klarna: Payment services (technical integration of online payment methods); Service Provider: Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden; Legal Bases: Contract Fulfillment and Pre-Contractual Inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR); Website: https://www.klarna.com/de; Privacy Policy: https://www.klarna.com/de/datenschutz.
-> Mastercard: Payment services (technical integration of online payment methods); Service Provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; Legal Bases: Contract Fulfillment and Pre-Contractual Inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR); Website: https://www.mastercard.de/de-de.html; Privacy Policy: https://www.mastercard.de/de-de/datenschutz.html.
-> PayPal: Payment services (technical integration of online payment methods) (e.g., PayPal, PayPal Plus, Braintree); Service Provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal Bases: Contract Fulfillment and Pre-Contractual Inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR); Website: https://www.paypal.com/de; Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
-> Visa: Payment services (technical integration of online payment methods); Service Provider: Visa Europe Services Inc., Branch Office London, 1 Sheldon Square, London W2 6TT, GB; Legal Bases: Contract Fulfillment and Pre-Contractual Inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR); Website: https://www.visa.de; Privacy Policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html.
13. Provision of Online Services and Web Hosting
We process user data to provide our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or device.
-> Types of Processed Data: Usage Data (e.g., websites visited, interest in content, access times); Meta/Communication and Procedure Data (e.g., IP addresses, time information, identification numbers, consent status); Content Data (e.g., entries in online forms).
-> Affected Persons: Users (e.g., website visitors, users of online services).
-> Purposes of Processing: Provision of our online services and user-friendliness; Information Technology Infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); Security Measures.
-> Legal Bases: Legitimate Interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
Further Information on Processing Procedures, Methods, and Services:
-> Provision of Online Services on Rented Storage Space: For the provision of our online services, we use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding server provider (also known as a "web hoster"); Legal Bases: Legitimate Interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
-> Collection of Access Data and Log Files: Access to our online service is logged in the form of so-called "server log files." Server log files can include the address and name of the retrieved web pages and files, the date and time of retrieval, data volumes transferred, notification of successful retrieval, browser type along with version, the user's operating system, referrer URL (the previously visited page), and usually IP addresses and the requesting provider. Server log files can be used for security purposes, e.g., to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the utilization of the servers and their stability; Legal Bases: Legitimate Interests (Art. 6 para. 1 sentence 1 lit. f GDPR); Data Deletion: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is necessary for evidentiary purposes are exempted from deletion until the final clarification of the respective incident.
-> Email Sending and Hosting: The web hosting services we use also include the sending, receiving, and storing of emails. For these purposes, the addresses of recipients and senders as well as other information concerning the email sending (e.g., the participating providers) and the content of the respective emails are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that emails are generally not sent encrypted on the Internet. As a rule, emails are encrypted during transport, but (unless an end-to-end encryption method is used) not on the servers from which they are sent and received. Therefore, we cannot assume any responsibility for the transmission path of the emails between the sender and receipt on our server; Legal Bases: Legitimate Interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
-> Content Delivery Network: We use a "Content Delivery Network" (CDN). A CDN is a service that helps to deliver the content of an online service, especially large media files such as graphics or program scripts, faster and more securely with the help of regionally distributed and internet-connected servers; Legal Bases: Legitimate Interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
> STRATO: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacity); Service Provider: STRATO AG, Pascalstraße 10, 10587 Berlin, Germany; Legal Bases: Legitimate interests (Art. 6 para. 1 s. 1 lit. f GDPR); Website: https://www.strato.de; Privacy Policy: https://www.strato.de/datenschutz; Data Processing Agreement: Provided by the service provider.
14. Registration, Login, and User Account
Users can create a user account. During the registration process, users are informed of the required mandatory information and this data is processed for the purpose of providing the user account, based on contractual obligations. The data processed particularly includes login information (username, password, and an email address).
In the context of using our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. This storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorized use. This data is not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users may be informed by email about processes relevant to their user account, such as technical changes.
-> Types of Processed Data: Inventory data (e.g., names, addresses); Contact data (e.g., email, phone numbers); Content data (e.g., entries in online forms); Meta-, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
-> Affected Persons: Users (e.g., website visitors, users of online services).
-> Purposes of Processing: Provision of contractual services and customer service; Security measures; Administration and answering of inquiries; Provision of our online offer and user-friendliness.
-> Legal Bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 s. 1 lit. b GDPR); Legitimate interests (Art. 6 para. 1 s. 1 lit. f GDPR).
Additional Notes on Processing Methods, Procedures, and Services:
Registration with real names: Due to the nature of our community, we ask users to use our services using their real names. This means the use of pseudonyms is not permitted; Legal Bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 s. 1 lit. b GDPR).
15. Blogs and Publication Media
We use blogs or similar means of online communication and publication (hereafter "Publication Medium"). The data of the readers is processed only to the extent necessary for the presentation of the Publication Medium and the communication between authors and readers or for security reasons. For further information, we refer to the processing of visitors' data in our privacy policy.
-> Types of Processed Data: 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., visited websites, interest in content, access times); Meta-, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
-> Affected Persons: Users (e.g., website visitors, users of online services).
-> Purposes of Processing: Provision of contractual services and customer service; Feedback (e.g., collecting feedback via online form); Provision of our online offer and user-friendliness.
-> Legal Bases: Legitimate interests (Art. 6 para. 1 s. 1 lit. f GDPR).
16. Contact and Inquiry Management
When contacting us (e.g., via mail, contact form, email, phone, or via social media) and in the context of existing user and business relationships, the information provided by the inquiring persons is processed as far as this is necessary to answer the contact inquiries and any requested measures.
-> Types of Processed Data: Contact data (e.g., email, phone numbers); Content data (e.g., entries in online forms); Usage data (e.g., visited websites, interest in content, access times); Meta-, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
-> Affected Persons: Communication partners.
-> Purposes of Processing: Contact inquiries and communication; Management and answering of inquiries; Feedback (e.g., collecting feedback via online form); Provision of our online offer and user-friendliness.
-> Legal Bases: Legitimate interests (Art. 6 para. 1 s. 1 lit. f GDPR); Contract performance and pre-contractual inquiries (Art. 6 para. 1 s. 1 lit. b GDPR).
Additional Notes on Processing Methods, Procedures, and Services:
-> Contact form: When users contact us via our contact form, email, or other communication channels, we process the data provided in this context to handle the communicated concern; Legal Bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 s. 1 lit. b GDPR), Legitimate interests (Art. 6 para. 1 s. 1 lit. f GDPR).
17. Communication via Messenger
We use messengers for communication purposes and therefore ask you to observe the following notes on the functionality of the messengers, encryption, use of the communication metadata, and your objection options.
You can also contact us via alternative means, e.g., telephone or email. Please use the contact options communicated to you or those within our online offer.
In the case of end-to-end encryption of content (i.e., the content of your message and attachments), we point out that the communication contents (i.e., the content of the message and attached images) are end-to-end encrypted. This means that the content of the messages is not visible, not even by the messenger providers themselves. You should always use a current version of the messengers with activated encryption to ensure the encryption of the message contents.
However, we additionally point out to our communication partners that although the providers of the messengers cannot see the content, they can find out that and when communication partners communicate with us as well as technical information on the device used by the communication partners and, depending on the settings of their device, also location information (so-called metadata).
Notes on Legal Bases: If we ask communication partners for permission before communicating with them via messenger, the legal basis of our processing of their data is their consent. Otherwise, if we do not ask for consent and you contact us, for example, on your own initiative, we use messengers in relation to our contractual partners as well as in the context of contract initiation as a contractual measure and in the case of other interested parties and communication partners on the basis of our legitimate interests in a fast and efficient communication and meeting the needs of our communication partners for communication via messengers. Furthermore, we would like to point out that we do not transmit the contact data provided to us to the messengers without your consent.
Revocation, objection, and deletion: You can revoke a given consent at any time.
-> Types of Processed Data: Contact data (e.g., email, phone numbers); Usage data (e.g., visited websites, interest in content); Meta-, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers).
-> Affected Persons: Communication partners.
-> Purposes of Processing: Contact inquiries and communication; Direct marketing (e.g., by email or postal).
-> Legal Bases: Consent (Art. 6 para. 1 s. 1 lit. a GDPR); Legitimate interests (Art. 6 para. 1 s. 1 lit. f GDPR).
18. Newsletter and Electronic Notifications
We send newsletters, emails, and other electronic notifications (hereinafter "Newsletter") only with the consent of the recipients or a legal permission. If the contents of the newsletter are concretely described within the framework of a registration for the newsletter, they are decisive for the consent of the users. Our newsletters contain information about our services and 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 address in the newsletter or other information if necessary for the purposes of the newsletter.
Double Opt-In Procedure: The registration for our newsletter is generally done in a so-called double opt-in procedure. 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 foreign email addresses. The registrations for the newsletter are logged to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address. Also, the changes to your data stored with the shipping service provider are logged.
Deletion and Limitation of Processing: We may store the unsubscribed email addresses for up to three years based on our legitimate interests before we delete them to prove a formerly given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided at the same time the former existence of a consent is confirmed. In the case of obligations to permanently observe objections, we reserve the right to store the email address for this purpose alone in a blocklist (so-called "blocklist").
Logging the registration process is based on our legitimate interests for the purpose of proving its proper course. If we hire a service provider to send emails, this is done based on our legitimate interests in an efficient and secure sending system.
Contents:
Information about us, our services, promotions, and offers.
-> Types of Processed Data: Inventory data (e.g., names, addresses); Contact data (e.g., email, phone numbers); Meta-, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status); Usage data (e.g., visited websites, interest in content, access times).
-> Affected Persons: Communication partners.
-> Purposes of Processing: Direct marketing (e.g., by email or postal).
-> Legal Bases: Consent (Art. 6 para. 1 s. 1 lit. a GDPR).
-> Possibility of Objection (Opt-Out): You can cancel the receipt of our newsletter at any time, i.e., revoke your consents, or object to further receipt. A link to cancel the newsletter can be found either at the end of each newsletter or you can use one of the above-mentioned contact options, preferably email.
Additional Notes on Processing Methods, Procedures, and Services:
-> Measurement of Opening and Click Rates: 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 shipping service provider, from their server when the newsletter is opened. As part of this retrieval, initially technical information, such as information about the browser and your system, as well as your IP address and time of retrieval are collected. This information is used to technically improve our newsletters based on the technical data or the target audience and their reading behaviors, based on their retrieval locations (which can be determined using the IP address) or access times. This analysis also includes determining if the newsletters are opened, when they are opened, and which links are clicked. This information is associated with the individual newsletter recipients and stored in their profiles until deletion. The analyses serve us 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. Legal Bases: Consent (Art. 6 para. 1 s. 1 lit. a GDPR).
19. Promotional Communication via Email, Mail, Fax or Telephone
We process personal data for the purposes of promotional communication, which may be done via various channels, such as email, phone, mail, or fax, in accordance with legal regulations.
Recipients have the right to revoke given consents at any time or to object to the promotional communication at any time.
After revocation or objection, we store the data required to prove the previously existing authorization for contact or sending until three years after the end of the year of the revocation or objection, based on our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. Based on the legitimate interest, to permanently consider the revocation or objection of the users, we also store the data necessary to avoid renewed contact (e.g., depending on the communication channel, the email address, phone number, name).
-> Types of Processed Data: Inventory data (e.g., names, addresses); Contact data (e.g., email, phone numbers).
-> Affected Persons: Communication partners.
-> Purposes of Processing: Direct marketing (e.g., by email or postal).
-> Legal Bases: Consent (Art. 6 para. 1 s. 1 lit. a GDPR); Legitimate interests (Art. 6 para. 1 s. 1 lit. f GDPR).
20. Contests and Competitions
We process the personal data of participants in contests and competitions only in compliance with the relevant data protection regulations, as far as the processing is contractually required for the provision, execution, and handling of the contest, the participants have consented to the processing or the processing serves our legitimate interests (e.g., in the security of the contest or the protection of our interests from misuse by possible recording of IP addresses when submitting contest entries).
If participants' contributions are published as part of the contests (e.g., within a vote or presentation of the contest contributions or the winners or reporting on the contest), we point out that the participants' names may also be published in this context. Participants can object to this at any time.
If the contest takes place within an online platform or a social network (e.g., Facebook or Instagram, hereafter referred to as "Online Platform"), the terms of use and data protection regulations of the respective platforms also apply. In these cases, we point out that we are responsible for the information provided by the participants in the context of the contest and inquiries regarding the contest should be directed to us.
The data of the participants are deleted as soon as the contest or competition is ended, and the data is no longer necessary to inform the winners or because queries regarding the contest are expected. Generally, the data of the participants are deleted at the latest 6 months after the end of the contest. Data of winners can be retained for a longer period to answer queries about the prizes or to fulfill the prize services; in this case, the retention period depends on the type of prize and is, for example, for items or services, up to three years to be able to handle warranty cases. Furthermore, the participants' data may be stored for a longer period, e.g., in the form of reporting on the contest in online and offline media.
If data were also collected for other purposes within the framework of the contest, their processing and retention period are governed by the privacy notices for this use (e.g., in the case of registration for a newsletter as part of a contest).
-> Types of Processed Data: Inventory data (e.g., names, addresses); Content data (e.g., entries in online forms); Meta-, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
-> Affected Persons: Contest and competition participants.
-> Purposes of Processing: Conducting contests and competitions.
-> Legal Bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 s. 1 lit. b GDPR).
21. Surveys and Questionnaires
We conduct surveys and questionnaires to collect information for the communicated purpose of the survey or questionnaire. The surveys and questionnaires (hereinafter "surveys") we conduct are evaluated anonymously. Personal data is processed only to the extent necessary for the provision and technical implementation of the surveys (e.g., processing the IP address to display the survey in the user's browser or using a cookie to enable the resumption of the survey).
-> Types of Processed Data: Contact data (e.g., email, phone numbers); Content data (e.g., entries in online forms); Usage data (e.g., visited websites, interest in content, access times); Meta-, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
-> Affected Persons: Communication partners; Participants.
-> Purposes of Processing: Feedback (e.g., collecting feedback via online form).
-> Legal Bases: Legitimate interests (Art. 6 para. 1 s. 1 lit. f GDPR).
22. Web Analysis, Monitoring, and Optimization
Web analysis (also referred to as "reach measurement") serves the evaluation of the visitor streams of our online offer and can include behavior, interests, or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online offer or its functions or contents are most frequently used or invite for reuse. We can also understand which areas need optimization.
In addition to web analysis, we can also use testing procedures to test and optimize different versions of our online offer or its components.
Unless otherwise stated below, profiles, i.e., data aggregated from a usage process, can be created and stored in a browser or on a user's device for these purposes. The collected data particularly includes visited web pages, used elements on these pages, technical information such as the browser used, the computer system, as well as information about usage times. If users have consented to the collection of their location data, these can also be processed.
User IP addresses are also stored. However, we use an IP masking process (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no clear data of users (such as email addresses or names) are stored in the context of web analytics, A/B testing, and optimization, but pseudonyms. This means that we, as well as the providers of the used software, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.
-> Types of Processed Data: Usage data (e.g., visited web pages, interest in content, access times); Meta-, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
-> Affected Persons: Users (e.g., website visitors, users of online services).
-> Purposes of Processing: Reach measurement (e.g., access statistics, recognition of returning visitors); Profiles with user-related information (creating user profiles); Tracking (e.g., interest/behavior-related profiling, use of cookies); Provision of our online offer and user-friendliness.
-> Security Measures: IP masking (pseudonymization of the IP address).
-> Legal Bases: Consent (Art. 6 para. 1 s. 1 lit. a GDPR).
Additional Notes on Processing Methods, Procedures, and Services:
-> Google Analytics: Web analysis, reach measurement, and measurement of user flows; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Bases: Consent (Art. 6 para. 1 s. 1 lit. a GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms; Standard Contractual Clauses (Ensuring level of data protection in third countries): https://business.safety.google/adsprocessorterms; Opt-Out Possibility: Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated; Additional Information: https://privacy.google.com/businesses/adsservices (Types of processing and processed data).
23. Online Marketing
We process personal data for online marketing purposes, which may include marketing advertising spaces or displaying promotional and other content (collectively referred to as "content") based on the potential interests of users and measuring their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar procedures are used, by which the user-related information relevant to the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, communication partners, and technical information such as the browser used, the computer system used as well as information on usage times and used functions. If users have consented to the collection of their location data, these can also be processed.
The IP addresses of the users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no clear data of users (such as email addresses or names) are stored in the context of online marketing procedures, but pseudonyms. This means that we, as well as the providers of the online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is usually stored in the cookies or by using similar procedures. These cookies can later be read out and analyzed for the purpose of content presentation, as well as supplemented with further data and stored on the server of the online marketing procedure provider.
Exceptionally, clear data can be assigned to the profiles. This is the case when the users are, for example, members of a social network whose online marketing procedures we use and the network connects the profiles of the users with the aforementioned information. We ask users to note that they may make additional agreements with the providers, e.g., by consent during registration.
We generally only have access to summarized information about the success of our advertisements. However, we can check within the framework of so-called conversion measurements whether our online marketing procedures have led to a so-called conversion, e.g., to a contract conclusion with us. The conversion measurement is used solely to analyze the success of our marketing measures.
Unless otherwise specified, we ask you to assume that used cookies are stored for a period of two years.
-> Types of Processed Data: Usage data (e.g., visited websites, interest in content, access times); Meta-, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
-> Affected Persons: Users (e.g., website visitors, users of online services).
-> Purposes of Processing: Reach measurement (e.g., access statistics, recognition of returning visitors); Tracking (e.g., interest/behavior-related profiling, use of cookies); Marketing; Profiles with user-related information (creating user profiles); Conversion measurement (measuring the effectiveness of marketing measures).
-> Security Measures: IP masking (pseudonymization of the IP address).
-> Legal Bases: Consent (Art. 6 para. 1 s. 1 lit. a GDPR); Legitimate interests (Art. 6 para. 1 s. 1 lit. f GDPR).
-> Objection Option (Opt-Out): We refer to the privacy policies of the respective providers and the possibilities of objection stated by the providers (so-called "Opt-Out"). If no explicit opt-out option has been specified, it is possible that you can disable cookies in the settings of your browser. However, this may limit the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered collectively for respective areas: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-regional: https://optout.aboutads.info.
Additional Notes on Processing Methods, Procedures, and Services:
-> Google Ads and Conversion Measurement: Online marketing procedures for the purpose of placing content and advertisements within the advertising network of the service provider (e.g., in search results, in videos, on websites, etc.), so that they are displayed to users who have a presumed interest in the ads. We also measure the conversion of the ads, i.e., whether users have taken them as an opportunity to interact with the ads and use the advertised offers (so-called Conversion). However, we only receive anonymous information and no personal information about individual users; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Bases: Consent (Art. 6 para. 1 s. 1 lit. a GDPR), Legitimate interests (Art. 6 para. 1 s. 1 lit. f GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Additional Information: Types of processing and processed data: https://privacy.google.com/businesses/adsservices; Data Processing Conditions between Controllers and Standard Contractual Clauses for Third Country Transfers of Data: https://business.safety.google/adscontrollerterms.
24. Affiliate Programs and Affiliate Links
In our online offer, we integrate so-called affiliate links or other references (which may include search masks, widgets, or discount codes) to the offers and services of third-party providers (collectively referred to as "Affiliate Links"). When users follow the affiliate links or subsequently take advantage of the offers, we may receive a commission or other benefits (collectively referred to as "Commission") from these third-party providers.
To be able to track whether users have taken advantage of the offers of an affiliate link used by us, it is necessary that the respective third-party providers learn that users have followed an affiliate link within our online offer. The assignment of the affiliate links to the respective business transactions or other actions (e.g., purchases) serves solely the purpose of commission settlement and is canceled as soon as it is no longer necessary for this purpose.
For the purposes of the aforementioned assignment of the affiliate links, the affiliate links may be supplemented with certain values that are a part of the link or otherwise, e.g., in a cookie, can be stored. The values may include, in particular, the initial website (referrer), the time, an online identifier of the operators of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer, and an online identifier of the user.
Notes on Legal Bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and recipient-friendly services). In this context, we would also like to refer to the information on the use of cookies in this privacy policy.
-> Types of Processed Data: Contract data (e.g., subject matter of the contract, term, customer category); Usage data (e.g., visited websites, interest in content, access times); Meta-, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
-> Affected Persons: Users (e.g., website visitors, users of online services).
-> Processing purposes: Affiliate tracking.
-> Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
25. Offering an affiliate program
We offer an affiliate program, i.e., commissions or other benefits (collectively referred to as "commission") for users (referred to as "affiliates") who refer to our offers and services. The referral is made through a link or other methods (e.g., discount codes) assigned to the respective affiliate, allowing us to recognize that the use of our services was based on the referral (collectively referred to as "affiliate links").
To track whether users have perceived our services based on the affiliate links used by affiliates, it is necessary for us to know that users have followed an affiliate link. The allocation of affiliate links to the respective transactions or other use of our services serves solely for the purpose of commission settlement and is canceled once it is no longer necessary for the purpose.
For the purposes of the aforementioned allocation of affiliate links, the affiliate links can be supplemented with certain values, which are part of the link or can be stored elsewhere, e.g., in a cookie. The values may include, in particular, the referring website (referrer), the timestamp, an online identifier of the operator of the website on which the affiliate link was located, and an online identifier.
-> Processed data types: Contract data (e.g., subject matter, duration, customer category); Usage data (e.g., visited websites, interest in content).
-> Affected Persons: Users (e.g., website visitors); Business and contractual partners.
-> Processing purposes: Provision of contractual services and customer service; Affiliate tracking.
-> Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Performance of the contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
26. Customer reviews and rating processes
We participate in review and rating processes to evaluate, optimize, and promote our services. If users rate us or provide feedback through the participating review platforms or processes, the general terms and conditions and privacy policies of the providers also apply. In most cases, rating requires registration with the respective providers.
To ensure that the reviewing individuals have actually used our services, we transmit, with the customer's consent, the necessary data regarding the customer and the service used to the respective review platform (including name, email address, and order number or item number). This data is solely used to verify the authenticity of the user.
-> Processed data types: Contract data (e.g., subject matter, duration, customer category); Usage data (e.g., visited websites, interest in content, access times); Meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers, consent status).
-> Affected Persons: Customers; Users (e.g., website visitors, users of online services).
-> Processing purposes: Feedback (e.g., collecting feedback via online form); Marketing.
-> Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Additional notes on processing procedures, methods, and services:
-> Rating widget: We integrate so-called "rating widgets" into our online offering. A widget is a functional and content element integrated into our online offering that displays variable information. It can be represented, for example, in the form of a seal or similar element, partly also called a "badge". The corresponding content of the widget is displayed within our online offering, but it is retrieved from the servers of the respective widget provider at that moment. This is the only way to always show the current content, especially the current rating. For this purpose, a data connection must be established from the website called up within our online offering to the server of the widget provider, and the widget provider receives certain technical data (access data, including IP address) necessary for delivering the content of the widget to the user's browser. Furthermore, the widget provider receives information that users have visited our online offering. This information can be stored in a cookie and used by the widget provider to recognize which online offerings participating in the rating process have been visited by the user. The information can be stored in a user profile and used for advertising or market research purposes; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
27. Presences in social networks (Social Media)
We maintain online presences within social networks and process user data for communication with active users or to provide information about us.
We note that user data may be processed outside the European Union. This may pose risks for users because, for example, the enforcement of user rights could be made more difficult.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behavior and resulting interests. The user profiles can, in turn, be used to display advertisements within and outside the networks that presumably correspond to the users' interests. For these purposes, cookies are usually stored on users' computers, storing user behavior and interests. In addition, data can be stored in the user profiles regardless of the devices used by users (especially if users are members of the respective platforms and logged in to them).
For a detailed presentation of the respective processing methods and the possibility of objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.
Even in the case of information requests and the exercise of data subject rights, we point out that these can be most effectively asserted with the providers. Only the providers have access to the data of the users and can take appropriate measures and provide information directly. If you still need assistance, you can contact us.
-> Processed data types: Contact data (e.g., email, phone numbers); Content data (e.g., inputs in online forms); Usage data (e.g., visited websites, interest in content, access times); Meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers, consent status).
-> Affected Persons: Users (e.g., website visitors, users of online services).
-> Processing purposes: Contact inquiries and communication; Feedback (e.g., collecting feedback via online form); Marketing.
-> Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Additional notes on processing procedures, methods, and services:
-> Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
-> Facebook pages: Profiles within the social network Facebook - We, together with Meta Platforms Ireland Limited, are 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 the 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", for page operators to gain insights into how people interact with their pages and associated content. We have entered into a special agreement with Facebook ("Information on page insights", https://www.facebook.com/legal/terms/page_controller_addendum), which regulates, among other things, the security measures Facebook must observe and in which Facebook has agreed to fulfill the data subject rights (i.e., users can address inquiries or deletion requests directly to Facebook). The rights of users (in particular, the right to information, deletion, objection, and complaint to the responsible supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information on page insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Standard contractual clauses (ensuring the level of data protection when processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Further information: Agreement on joint responsibility: https://www.facebook.com/legal/terms/information_about_page_insights_data. Joint responsibility is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, especially concerning the transmission of data to the parent company Meta Platforms, Inc. in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
-> LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1) lit. f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Data processing agreement: https://legal.linkedin.com/dpa; Standard contractual clauses (ensuring data protection level for processing in third countries): https://legal.linkedin.com/dpa; Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
-> Pinterest: Social network; Service provider: Pinterest Europe Limited, 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1) lit. f) GDPR); Website: https://www.pinterest.com; Privacy policy: https://policy.pinterest.com/de/privacy-policy; Additional information: Pinterest Data Sharing Addendum (ATTACHMENT A): https://business.pinterest.com/de/pinterest-advertising-services-agreement.
-> TikTok: Social network / video platform; Service provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland; Legal basis: Legitimate interests (Art. 6(1) lit. f) GDPR); Website: https://www.tiktok.com; Privacy policy: https://www.tiktok.com/de/privacy-policy.
-> YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6(1) lit. f) GDPR); Privacy policy: https://policies.google.com/privacy; Opt-out option: https://adssettings.google.com/authenticated.
28. Plugins and embedded features, as well as 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"). This may involve, for example, graphics, videos, or maps (hereinafter collectively referred to as "content").
Integration always requires that the third-party providers of this content process users' IP addresses because they could not send the content to their browsers without the IP address. The IP address is therefore required for the presentation of this content or functions. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may include technical information about the browser and operating system, referring web pages, visit time, and other information about the use of our online offering, as well as be linked to such information from other sources.
Processed data types: Usage data (e.g., visited web pages, interest in content, access times); Meta, communication, and process data (e.g., IP addresses, time information, identification numbers, consent status); Inventory data (e.g., names, addresses); Contact data (e.g., email, phone numbers); Content data (e.g., entries in online forms); Location data (information about the geographical location of a device or person); Event data (Facebook) ("Event data" is data that can be transmitted to Facebook via Facebook pixels (via apps or other means) and relates to individuals or their actions; this data includes information about visits to websites, interactions with content, functions, app installations, product purchases, etc.; Event data is processed for the purpose of creating target groups for content and advertising information (Custom Audiences); Event data does not include the actual content (such as written comments), login information, or contact information (i.e., no names, email addresses, and phone numbers). Event data is deleted by Facebook after a maximum of two years, and the target groups created from it are deleted when our Facebook account is deleted).
-> Affected Persons: Users (e.g., website visitors, users of online services).
-> Purposes of processing: Provision of our online offering and user-friendliness; Marketing; Profiles with user-related information (creating user profiles).
-> Legal basis: Legitimate interests (Art. 6(1) lit. f) GDPR); Consent (Art. 6(1) lit. a) GDPR).
Further information on processing processes, procedures, and services:
-> Facebook plugins and content: Facebook Social Plugins and Content - This may include content such as images, videos, or texts and buttons with which users can share content from this online offering within Facebook. The list and appearance of Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/ - We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt as part of a transmission (but not for further processing) of "event data" collected by Facebook through Facebook Social Plugins (and embedding functions for content) executed on our online offering, for the following purposes: a) Display of content and advertising information that corresponds to the presumed interests of users; b) Delivery of commercial and transaction-related 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 ("Supplement for Responsible Parties," https://www.facebook.com/legal/controller_addendum), which in particular regulates the security measures that 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 direct inquiries or deletion requests directly to Facebook). Note: If Facebook provides us with metrics, analyses, and reports (which are aggregated, i.e., do not contain information about individual users and are anonymous to us), this processing is not carried out as part of the joint responsibility but based on a data processing agreement ("data processing conditions", https://www.facebook.com/legal/terms/dataprocessing), "data security conditions" (https://www.facebook.com/legal/terms/data_security_terms), and, with regard to processing in the USA, on the basis of standard contractual clauses ("Facebook EU Data Transfer Appendix, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular, the right to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Consent (Art. 6(1) lit. a) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy.
-> Google Maps: We integrate the maps of the "Google Maps" service provided by Google. The processed data may include, in particular, IP addresses and location data of users; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1) lit. f) GDPR); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy.
-> Instagram plugins and content: Instagram plugins and content - This may include content such as images, videos, or texts and buttons with which users can share content from this online offering within Instagram. - We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt as part of a transmission (but not for further processing) of "event data" collected by Facebook through Instagram functions (e.g., embedding functions for content) executed on our online offering, for the following purposes: a) Display of content and advertising information that corresponds to the presumed interests of users; b) Delivery of commercial and transaction-related 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 ("Supplement for Responsible Parties," https://www.facebook.com/legal/controller_addendum), which in particular regulates the security measures that 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 direct inquiries or deletion requests directly to Facebook). Note: If Facebook provides us with metrics, analyses, and reports (which are aggregated, i.e., do not contain information about individual users and are anonymous to us), this processing is not carried out as part of the joint responsibility but based on a data processing agreement ("data processing conditions", https://www.facebook.com/legal/terms/dataprocessing), "data security conditions" (https://www.facebook.com/legal/terms/data_security_terms), and, with regard to processing in the USA, on the basis of standard contractual clauses ("Facebook EU Data Transfer Appendix, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular, the right to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1) lit. f) GDPR); Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
-> LinkedIn plugins and content: LinkedIn plugins and content - This may include content such as images, videos, or texts and buttons with which users can share content from this online offering within LinkedIn; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1) lit. f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Data processing agreement: https://legal.linkedin.com/dpa; Standard contractual clauses (ensuring data protection level for processing in third countries): https://legal.linkedin.com/dpa; Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
-> Pinterest plugins and content: Pinterest plugins and content - This may include content such as images, videos, or texts and buttons with which users can share content from this online offering within Pinterest; Service provider: Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA; Legal basis: Legitimate interests (Art. 6(1) lit. f) GDPR); Website: https://www.pinterest.com; Privacy policy: https://policy.pinterest.com/de/privacy-policy.
-> YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6(1) lit. f) GDPR); 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 displaying advertising: https://adssettings.google.com/authenticated.
-> YouTube videos: Video content; YouTube videos are embedded via a special domain (recognizable by the "youtube-nocookie" component) in the so-called "Enhanced Privacy Mode," which means that no cookies are collected for user activity to personalize video playback. Nevertheless, information about user interaction with the video (e.g., remembering the last playback position) may be stored; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6(1) lit. f) GDPR); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy.
29. Management, Organization, and Tools
We use services, platforms, and software from other providers (hereinafter referred to as "third-party providers") for the purpose of organization, management, planning, and the provision of our services. When selecting third-party providers and their services, we comply with legal requirements.
In this context, personal data may be processed and stored on the servers of third-party providers. This may include various data that we process in accordance with this privacy policy. Such data may include, in particular, master data and contact details of users, data on transactions, contracts, other processes, and their contents.
If users are referred to third-party providers or their software or platforms in the course of communication, business, or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimization, or marketing purposes. Therefore, we kindly ask you to review the privacy policies of the respective third-party providers.
-> Processed data types: Content data (e.g., entries in online forms); Usage data (e.g., visited web pages, interest in content, access times); Meta, communication, and process data (e.g., IP addresses, time information, identification numbers, consent status).
-> Data subjects: Communication partners; Users (e.g., website visitors, users of online services).
-> Purposes of processing: Provision of contractual services and customer support; Office and organizational procedures.
30. Amendment and Update of the Privacy Policy
We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation action (e.g., consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time, and we ask you to verify the information before contacting them.
31. Rights of Data Subjects
As data subjects 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) GDPR, including profiling based on those 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, which includes profiling to the extent that it is related to such direct marketing.
-> Right to Withdraw Consent: You have the right to withdraw your consent at any time.
-> Right to Information: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data and other information as provided by law.
-> Right to Rectification: You have the right to have inaccurate personal data concerning you corrected without undue delay in accordance with the statutory requirements.
-> Right to Erasure and Restriction of Processing: You have the right to demand that personal data concerning you be deleted immediately, or alternatively, to demand that the processing of your data be restricted in accordance with the statutory requirements.
-> Right to Data Portability: You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format or to request its transmission to another controller in accordance with the statutory requirements.
-> Right to Lodge a Complaint with a Supervisory Authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR
The competent supervisory authority for us is:
Berlin Commissioner for Data Protection and Freedom of Information
Meike Kamp
Alt-Moabit 59-61
10555 Berlin
Email:
mailbox@datenschutz-berlin.de
Phone:
030/138 89-0
Website:
https://www.datenschutz-berlin.de
32. Definitions
In this section, you will find an overview of the terminology used in this privacy policy. To the extent that the terminology is legally defined, the legal definitions shall apply. The following explanations are primarily intended to aid understanding.
-> Affiliate Tracking: Affiliate tracking involves logging links that refer users from linking websites to websites with product or other offers. The operators of the linking websites may receive a commission if users follow these so-called affiliate links and subsequently avail themselves of the offers (e.g., purchase goods or use services). For this purpose, it is necessary for the providers to be able to track whether users who are interested in certain offers subsequently act on the recommendation of the affiliate links. Therefore, the functionality of affiliate links requires them to be supplemented with certain values that become part of the link or are stored elsewhere, e.g., in a cookie. These values include, in particular, the referring website (referrer), the timestamp, an online identifier of the operators of the website containing the affiliate link, an online identifier of the respective offer, an online identifier of the user, as well as tracking-specific values such as advertising material ID, partner ID, and categorizations.
-> Conversion Tracking: Conversion tracking (also referred to as "visit action evaluation") is a method for determining the effectiveness of marketing measures. Typically, a cookie is stored on users' devices within the websites where the marketing measures take place, and it is then retrieved again on the target website. For example, this allows us to track whether the advertisements we place on other websites have been successful.
-> Personal Data: "Personal data" refers to any information relating to an identified or identifiable natural person (hereinafter referred to as the "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 characteristics that express the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
-> User Profiles: The processing of "user profiles" or simply "profiles" encompasses any form of automated processing of personal data, which involves using these personal data to analyze, evaluate, or predict certain personal aspects related to a natural person (depending on the type of profiling, this may include different information regarding demographics, behavior, and interests, such as interaction with websites and their content, etc.). For profiling purposes, cookies and web beacons are often used.
-> Reach Measurement: Reach measurement (also referred to as web analytics) serves to evaluate the visitor flows of an online offering and may include the behavior or interests of visitors in specific information, such as website content. With the help of reach analysis, website owners can, for example, determine when visitors access their website and which content they are interested in. This enables them to better tailor 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 obtain more accurate usage analyses of an online offering.
-> Location Data: Location data is generated when a mobile device (or another device with the technical capabilities of location determination) connects to a cell, a Wi-Fi, or similar technical means and functions of location determination. Location data is used to indicate the geographically determinable position on Earth where the respective device is located. Location data can, for example, be used to display map functions or other location-dependent information.
-> Tracking: "Tracking" refers to the ability to trace the behavior of users across multiple online offerings. In most cases, behavioral and interest information regarding the online offerings used is stored in cookies or on the servers of the providers of tracking technologies (referred to as profiling). This information can subsequently be used, for example, to display advertisements to users that are likely to match their interests.
-> Controller: The "controller" is the natural or legal person, authority, agency, or other body that alone or jointly with others determines the purposes and means of processing personal data.
-> Processing: "Processing" is any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and encompasses practically any handling of data, including collecting, evaluating, storing, transmitting, or deleting it.