Privacy Policy

Privacy Policy Introduction and Overview

We have written this privacy policy (version 02.02.2023-312400343) in order to explain to you, in accordance with the provisions of the General Data Protection Regulation (EU) 2016/679 and applicable national laws, which personal data (data for short) we as the controller – and the processors commissioned by us (e.g. providers) – process, will process in the future and what legal options you have. The terms used are to be considered gender-neutral.

In short: We provide you with comprehensive information about any of your personal data we process.

Privacy policies usually sound very technical and use legal terminology. However, this privacy policy is intended to describe the most important things to you as simply and transparently as possible.

So long as it aids transparency, technical terms are explained in a reader-friendly manner, links to further information are provided and graphics are used. We are thus informing in clear and simple language that we only process personal data in the context of our business activities if there is a legal basis for it. This is certainly not possible with brief, unclear and legal-technical statements, as is often standard on the internet when it comes to data protection. I hope you find the following explanations interesting and informative. Maybe you will also find some information that you have not been familiar with.

If you still have questions, we kindly ask you to contact the responsible body named below or in the imprint, follow the existing links and look at further information on third-party sites. You can of course also find our contact details in the imprint.

Scope

This privacy policy applies to all personal data processed by our company and to all personal data processed by companies commissioned by us (processors). With the term personal data, we refer to information within the meaning of Article 4 No. 1 GDPR, such as the name, email address and postal address of a person. The processing of personal data ensures that we can offer and invoice our services and products, be it online or offline. The scope of this privacy policy includes:

all online presences (websites, online shops) that we operate Social media presences and email communication

mobile apps for smartphones and other devices

 

In short: This privacy policy applies to all areas in which personal data is processed in a structured manner by the company via the channels mentioned. Should we enter into legal relations with you outside of these channels, we will inform you separately if necessary.

Legal bases

In the following privacy policy, we provide you with transparent information on the legal principles

 

and regulations, i.e. the legal bases of the General Data Protection Regulation, which enable us to process personal data.

Whenever EU law is concerned, we refer to REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016. You can of course access the General Data Protection Regulation of the EU online at EUR-Lex, the gateway to EU law, at

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679. We only process your data if at least one of the following conditions applies:

1. Consent (Article 6 Paragraph 1 a GDPR): You have given us your consent to process data for a specific purpose. An example would be the storage of data you entered into a contact form.
2. Contract (Article 6 Paragraph 1 b GDPR): We process your data in order to fulfill a contract or pre-contractual obligations with you. For example, if we conclude a sales contract with you, we need personal information in advance.
3. Legal obligation (Article 6 Paragraph 1 c GDPR): If we are subject to a legal obligation, we will process your data. For example, we are legally required to keep invoices for our bookkeeping. These usually contain personal data.
4. Legitimate interests (Article 6 Paragraph 1 lit. f GDPR): In the case of legitimate interests that do not restrict your basic rights, we reserve the right to process personal data. For example, we have to process certain data in order to be able to operate our website securely and economically. Therefore, the processing is a legitimate interest.

 

Other conditions such as making recordings in the interest of the public, the exercise of official authority as well as the protection of vital interests do not usually occur with us. Should such a legal basis be relevant, it will be disclosed in the appropriate place.

In addition to the EU regulation, national laws also apply:

 

In Austria this is the Austrian Data Protection Act (Datenschutzgesetz), in short DSG.

In Germany this is the Federal Data Protection Act (Bundesdatenschutzgesetz), in short

BDSG.

 

Should other regional or national laws apply, we will inform you about them in the following sections.

Contact details of the data protection controller

If you have any questions about data protection, you will find the contact details of the responsible person or controller below:

Basile GmbH Lerchenstr. 2

74226 Nordheim Deutschland

E-Mail: info@basilegmbh.com

 

Phone: +49 (0) 7133 901827-0

Company details: https://www.basilegmbh.de/impressum

 

Storage Period

It is a general criterion for us to store personal data only for as long as is absolutely necessary for the provision of our services and products. This means that we delete personal data as soon as any reason for the data processing no longer exists. In some cases, we are legally obliged to keep certain data stored even after the original purpose no longer exists, such as for accounting purposes.

If you want your data to be deleted or if you want to revoke your consent to data processing, the data will be deleted as soon as possible, provided there is no obligation to continue its storage.

We will inform you below about the specific duration of the respective data processing, provided we have further information.

Rights in accordance with the General Data Protection Regulation

In accordance with Articles 13, 14 of the GDPR, we inform you about the following rights you have to ensure fair and transparent processing of data:

According to Article 15 DSGVO, you have the right to information about whether we are processing data about you. If this is the case, you have the right to receive a copy of the data and to know the following information:

for what purpose we are processing;

the categories, i.e. the types of data that are processed;

who receives this data and if the data is transferred to third countries, how security can be guaranteed;

how long the data will be stored;

the existence of the right to rectification, erasure or restriction of processing and the right to object to processing;

that you can lodge a complaint with a supervisory authority (links to these authorities can be found below);

the origin of the data if we have not collected it from you;

Whether profiling is carried out, i.e. whether data is automatically evaluated to arrive at a personal profile of you.

You have a right to rectification of data according to Article 16 GDPR, which means that we must correct data if you find errors.

You have the right to erasure (“right to be forgotten”) according to Article 17 GDPR, which specifically means that you may request the deletion of your data.

According to Article 18 of the GDPR, you have the right to restriction of processing, which means that we may only store the data but not use it further.

According to Article 20 of the GDPR, you have the right to data portability, which means that

 

we will provide you with your data in a standard format upon request.

According to Article 21 DSGVO, you have the right to object, which entails a change in processing after enforcement.

If the processing of your data is based on Article 6(1)(e) (public interest, exercise of official authority) or Article 6(1)(f) (legitimate interest), you may object to the processing. We will then check as soon as possible whether we can legally comply with this objection.

If data is used to conduct direct advertising, you may object to this type of data processing at any time. We may then no longer use your data for direct marketing.

If data is used to conduct profiling, you may object to this type of data processing at any time. We may no longer use your data for profiling thereafter.

According to Article 22 of the GDPR, you may have the right not to be subject to a decision based solely on automated processing (for example, profiling).

You have the right to lodge a complaint under Article 77 of the GDPR. This means that you can complain to the data protection authority at any time if you believe that the data processing of personal data violates the GDPR.

In short: you have rights – do not hesitate to contact the responsible party listed above with us!

 

If you believe that the processing of your data violates data protection law or your data protection rights have been violated in any other way, you can complain to the supervisory authority. For Austria, this is the data protection authority, whose website can be found at https://www.dsb.gv.at/. In Germany, there is a data protection officer for each federal state. For more information, you can contact the Federal Commissioner for Data Protection and Freedom of Information (BfDI). The following local data protection authority is responsible for our company:

 

Baden-Württemberg Data protection authority

State Commissioner for Data Protection: Dr. Stefan Brink

Address: Königstraße 10a, 70173 Stuttgart

Phone number: 07 11/61 55 41-0

E-mail address: poststelle@lfdi.bwl.de

Website: https://www.baden-wuerttemberg.datenschutz.de/

 

Data transfer to third countries

We only transfer or process data to countries outside the EU (third countries) if you consent to this processing, if this is required by law or if it is contractually necessary. In any case, we generally only do so to the permitted extent. In most cases, your consent is the most important reason for data being processed in third countries. When personal data is being processed in third countries such as the USA, where many software manufacturers offer their services and have their servers located, your personal data may be processed and stored in unexpected ways.

We want to expressly point out, that according to the European Court of Justice, there is currently no adequate level of protection for data transfer to the USA. Data processing by US services (such

 

as Google Analytics) may result in data processing and retention without the data having undergone anonymisation processes. Furthermore, US government authorities may be able to access individual data. The collected data may also get linked to data from other services of the same provider, should you have a user account with the respective provider. We try to use server locations within the EU, whenever this is offered and possible.

We will provide you with more details about data transfer to third countries in the appropriate sections of this privacy policy, whenever applicable.

Security of data processing operations

In order to protect personal data, we have implemented both technical and organisational measures. We encrypt or pseudonymise personal data wherever this is possible. Thus, we make it as difficult as we can for third parties to extract personal information from our data.

Article 25 of the GDPR refers to “data protection by technical design and by data protection-friendly default” which means that both software (e.g. forms) and hardware (e.g. access to server rooms) appropriate safeguards and security measures shall always be placed. If applicable, we will outline the specific measures below.

TLS encryption with https

The terms TLS, encryption and https sound very technical, which they are indeed. We use HTTPS (Hypertext Transfer Protocol Secure) to securely transfer data on the Internet.

This means that the entire transmission of all data from your browser to our web server is secured

– nobody can “listen in”.

 

We have thus introduced an additional layer of security and meet privacy requirements through technology design Article 25 Section 1 GDPR). With the use of TLS (Transport Layer Security), which is an encryption protocol for safe data transfer on the internet, we can ensure the protection of confidential information.

You can recognise the use of this safeguarding tool by the little lock-symbol , which is situated in your browser’s top left corner in the left of the internet address (e.g. examplepage.uk), as well as by the display of the letters https (instead of http) as a part of our web address.

If you want to know more about encryption, we recommend you to do a Google search for “Hypertext Transfer Protocol Secure wiki” to find good links to further information.

Communications

 

If you contact us and communicate with us via phone, email or online form, your personal data may be processed.

The data will be processed for handling and processing your request and for the related business transaction. The data is stored for this period of time or for as long as is legally required.

Affected persons

The above-mentioned processes affect all those who seek contact with us via the communication channels we provide.

Telephone

When you call us, the call data is stored in a pseudonymised form on the respective terminal device, as well as by the telecommunications provider that is being used. In addition, data such as your name and telephone number may be sent via email and stored for answering your inquiries. The data will be erased as soon as the business case has ended and the legal requirements allow for its erasure.

Email

If you communicate with us via email, your data is stored on the respective terminal device (computer, laptop, smartphone, …) as well as on the email server. The data will be deleted as soon as the business case has ended and the legal requirements allow for its erasure.

Online forms

If you communicate with us using an online form, your data is stored on our web server and, if necessary, forwarded to our email address. The data will be erased as soon as the business case has ended and the legal requirements allow for its erasure.

Legal bases

Data processing is based on the following legal bases:

 

Art. 6 para. 1 lit. a GDPR (consent): You give us your consent to store your data and to continue to use it for the purposes of the business case;

Art. 6 para. 1 lit. b GDPR (contract): For the performance of a contract with you or a processor such as a telephone provider, or if we have to process the data for pre-contractual activities, such as preparing an offer;

Art. 6 para. 1 lit. f GDPR (legitimate interests): We want to conduct our customer inquiries and business communication in a professional manner. Thus, certain technical facilities such email programs, Exchange servers and mobile network operators are necessary to efficiently operate our communications.

 

Data Processing Agreement (DPA)

In this section, we would like to explain what a Data Processing Agreement is and why it is needed. As the term “Data Processing Agreement” is quite lengthy, we will often only use the acronym DPA here in this text. Like most companies, we do not work alone, but also use the services of other companies or individuals. By involving different companies or service providers, we may pass on personal data for processing. These partners then act as processors with whom we conclude a contract, the so-called Data Processing Agreement (DPA). Most importantly for you to know is that any processing of your personal data takes place exclusively according to our instructions and must be regulated by the DPA.

 

Who are the processors?

As a company and website owner, we are responsible for any of your data that is processed by us. In addition to the controller, there may also be so-called processors involved. This includes any company or person who processes your personal data. More precisely and according to the GDPR’s definition, this means: Any natural or legal person, authority, institution or other entity that processes your personal data is considered a processor. Processors can therefore be service providers such as hosting or cloud providers, payment or newsletter providers or large companies such as Google or Microsoft.

To make the terminology easier to comprehend, here is an overview of the GDPR’s three roles:

 

Data subject (you as a customer or interested party) → Controller (we as a company and contracting entity) → Processors (service providers such as web hosts or cloud providers)

Contents of a Data Processing Agreement

As mentioned above, we have concluded a DPA with our partners who act as processors. First and foremost, it states that the processor processes the data exclusively in accordance with the GDPR. The contract must be concluded in writing, although an electronic contract completion is also considered a “written contract”. Any processing of personal data only takes place after this contract is concluded. The contract must contain the following:

indication to us as the controller obligations and rights of the controller categories of data subjects

type of personal data

type and purpose of data processing subject and duration of data processing location of data processing

Furthermore, the contract contains all obligations of the processor. The most important obligations are:

 

ensuring data security measures

 

taking possible technical and organisational measures to protect the rights of the data subject maintaining a data processing record

cooperation with the data protection authority upon request performing a risk analysis for any received personal data

subprocessors may only be appointed with the written consent of the controller

 

You can see an example of what a DPA looks like at https://gdpr.eu/data-processing-agreement/. This link shows a sample contract.

Cookies

 

What are cookies?

Our website uses HTTP-cookies to store user-specific data.

In the following we explain what cookies are and why they are used, so that you can better understand the following privacy policy.

Whenever you surf the Internet, you are using a browser. Common browsers are for example, Chrome, Safari, Firefox, Internet Explorer and Microsoft Edge. Most websites store small text-files in your browser. These files are called cookies.

It is important to note that cookies are very useful little helpers. Almost every website uses cookies. More precisely, these are HTTP cookies, as there are also other cookies for other uses. HTTP cookies are small files that our website stores on your computer. These cookie files are automatically placed into the cookie-folder, which is the “brain” of your browser. A cookie consists of a name and a value. Moreover, to define a cookie, one or multiple attributes must be specified.

Cookies store certain user data about you, such as language or personal page settings. When you re-open our website to visit again, your browser submits these “user-related” information back to our site. Thanks to cookies, our website knows who you are and offers you the settings you are familiar to. In some browsers, each cookie has its own file, while in others, such as Firefox, all cookies are stored in one single file.

The following graphic shows a possible interaction between a web browser such as Chrome and the web server. The web browser requests a website and receives a cookie back from the server. The browser then uses this again as soon as another page is requested.

 

 

There are both first-party cookies and third-party cookies. First-party cookies are created directly by our site, while third-party cookies are created by partner-websites (e.g. Google Analytics). Each cookie must be evaluated individually, as each cookie stores different data. The expiry time of a cookie also varies from a few minutes to a few years. Cookies are not software programs and do not contain viruses, trojans or other malware. Cookies also cannot access your PC’s information.

This is an example of how cookie-files can look:

 

Name: _ga

Value: GA1.2.1326744211.152312400343-9

Purpose: Differentiation between website visitors

Expiry date: after 2 years

A browser should support these minimum sizes: At least 4096 bytes per cookie

At least 50 cookies per domain At least 3000 cookies in total

Which types of cookies are there?

The exact cookies that we use, depend on the used services, which will be outlined in the following sections of this privacy policy. Firstly, we will briefly focus on the different types of HTTP-cookies.

There are 4 different types of cookies:

 

Essential cookies

These cookies are necessary to ensure the basic functions of a website. They are needed when a user for example puts a product into their shopping cart, then continues surfing on different websites and comes back later in order to proceed to the checkout. These cookies ensure the shopping cart does not get deleted, even if the user closes their browser window.

 

Purposive cookies

These cookies collect information about user behaviour and whether the user receives any error messages. Furthermore, these cookies record the website’s loading time as well as its behaviour in different browsers.

Target-orientated cookies

These cookies ensure better user-friendliness. Thus, information such as previously entered locations, fonts sizes or data in forms stay stored.

Advertising cookies

These cookies are also known as targeting cookies. They serve the purpose of delivering customised advertisements to the user. This can be very practical, but also rather annoying.

Upon your first visit to a website you are usually asked which of these cookie-types you want to accept. Furthermore, this decision will of course also be stored in a cookie.

If you want to learn more about cookies and do not mind technical documentation, we recommend https://tools.ietf.org/html/rfc6265, the Request for Comments of the Internet Engineering Task Force (IETF) called “HTTP State Management Mechanism”.

Purpose of processing via cookies

The purpose ultimately depends on the respective cookie. You can find out more details below or from the software manufacturer that sets the cookie.

Which data are processed?

Cookies are little helpers for a wide variety of tasks. Unfortunately, it is not possible to tell which data is generally stored in cookies, but in the privacy policy below we will inform you on what data is processed or stored.

Storage period of cookies

The storage period depends on the respective cookie and is further specified below. Some cookies are erased after less than an hour, while others can remain on a computer for several years.

You can also influence the storage duration yourself. You can manually erase all cookies at any time in your browser (also see “Right of objection” below). Furthermore, the latest instance cookies based on consent will be erased is after you withdraw your consent. The legality of storage will remain unaffected until then.

Right of objection – how can I erase cookies?

You can decide for yourself how and whether you want to use cookies. Regardless of which service or website the cookies originate from, you always have the option of erasing, deactivating or only partially accepting cookies. You can for example block third-party cookies but allow all other cookies.

 

If you want to find out which cookies have been stored in your browser, or if you want to change or erase cookie settings, you can find this option in your browser settings:

Chrome: Clear, enable and manage cookies in Chrome Safari: Manage cookies and website data in Safari Firefox: Clear cookies and site data in Firefox

Internet Explorer: Delete and manage cookies Microsoft Edge: Delete cookies in Microsoft Edge

If you generally do not want cookies, you can set up your browser in a way to notify you whenever a cookie is about to be set. This gives you the opportunity to manually decide to either permit or deny the placement of every single cookie. This procedure varies depending on the browser.

Therefore, it might be best for you to search for the instructions in Google. If you are using Chrome, you could for example put the search term “delete cookies Chrome” or “deactivate cookies Chrome” into Google.

Legal basis

The so-called “cookie directive” has existed since 2009. It states that the storage of cookies requires your consent (Article 6 Paragraph 1 lit. a GDPR). Within countries of the EU, however, the reactions to these guidelines still vary greatly. In Austria, however, this directive was implemented in Section 96 (3) of the Telecommunications Act (TKG). In Germany, the cookie guidelines have not been implemented as national law. Instead, this guideline was largely implemented in Section 15 (3) of the Telemedia Act (TMG).

For absolutely necessary cookies, even if no consent has been given, there are legitimate interests (Article 6 (1) (f) GDPR), which in most cases are of an economic nature. We want to offer our visitors a pleasant user experience on our website. For this, certain cookies often are absolutely necessary.

This is exclusively done with your consent, unless absolutely necessary cookies are used. The legal basis for this is Article 6 (1) (a) of the GDPR.

In the following sections you will find more detail on the use of cookies, provided the used software does use cookies.

Customer Data

 

What is customer data?

In order to be able to offer our services and contractual services, we also process data from our customers and business partners. This data always includes personal data. Customer data is all information that is processed on the basis of contractual or pre-contractual agreements so that the offered services can be provided. Customer data is therefore all the information we collect and process about our customers.

 

Why do we process customer data?

There are many reasons why we collect and process customer data. The main reason is that we simply need specific data to provide our services. Sometimes for example your email address may be enough. But if you purchase a product or service, we may e. g. also need data such as your name, address, bank details or other contract data. This data will subsequently be used for marketing and sales optimisation so that we can improve our overall service for our customers and clients. Another important reason for data processing is our customer service, which is very important to us. We want you to have the opportunity to contact us at any time with questions about our offers. Thus, we may need certain data such as your email address at the very least.

 

What data is processed?

Exactly which data is stored can only be shown by putting them in categories. All in all, it always depends on which of our services you receive. In some cases, you may only give us your email address so that we can e. g. contact you or answer your questions. In other instances, you may purchase one of our products or services. Then we may need significantly more information, such as your contact details, payment details and contract details.

Here is a list of potential data we may receive and process: Name

Contact address

Email address Phone number Your birthday

Payment data (invoices, bank details, payment history, etc.) Contract data (duration, contents)

Usage data (websites visited, access data, etc.) Metadata (IP address, device information)

How long is the data stored?

We erase corresponding customer data as soon as we no longer need it to fulfill our contractual obligations and purposes, and as soon as the data is also no longer necessary for possible warranty and liability obligations. This can for example be the case when a business contract ends.

Thereafter, the limitation period is usually 3 years, although longer periods may be possible in individual cases. Of course, we also comply with the statutory retention requirements. Your

 

customer data will certainly not be passed on to third parties unless you have given your explicit consent.

Legal Basis

The legal basis for the processing of your data is Article 6 Paragraph 1 Letter a GDPR (consent), Article 6 Paragraph 1 Letter b GDPR (contract or pre-contractual measures), Article 6 Paragraph 1 Letter f GDPR (legitimate interests) and in special cases (e. g. medical services) Art. 9 (2) lit. GDPR (processing of special categories).

In the case of protecting vital interests, data processing is carried out in accordance with Article 9 Paragraph 2 Letter c. GDPR. For the purposes of health care, occupational medicine, medical diagnostics, care or treatment in the health or social sectors or for the administration of systems and services in health or social sectors, the processing of personal data takes place in accordance with Art. 9 Para. 2 lit. h. GDPR. If you voluntarily provide data of these special categories, the processing takes place on the basis of Article 9 Paragraph 2 lit. a GDPR.

 

Web hosting

 

What is web hosting?

Every time you visit a website nowadays, certain information – including personal data – is automatically created and stored, including on this website. This data should be processed as sparingly as possible, and only with good reason. By website, we mean the entirety of all websites on your domain, i.e. everything from the homepage to the very last subpage (like this one here). By domain we mean example.uk or examplepage.com.

When you want to view a website on a screen, you use a program called a web browser. You probably know the names of some web browsers: Google Chrome, Microsoft Edge, Mozilla Firefox, and Apple Safari.

The web browser has to connect to another computer which stores the website’s code: the web server. Operating a web server is complicated and time-consuming, which is why this is usually done by professional providers. They offer web hosting and thus ensure the reliable and flawless storage of website data.

Whenever the browser on your computer establishes a connection (desktop, laptop, smartphone) and whenever data is being transferred to and from the web server, personal data may be

 

processed. After all, your computer stores data, and the web server also has to retain the data for a period of time in order to ensure it can operate properly.

Illustration:

 

 

 

Why do we process personal data?

The purposes of data processing are:

 

1. Professional hosting of the website and operational security
2. To maintain the operational as well as IT security
3. Anonymous evaluation of access patterns to improve our offer, and if necessary, for prosecution or the pursuit of claims.li>

 

Which data are processed?

Even while you are visiting our website, our web server, that is the computer on which this website is saved, usually automatically saves data such as

the full address (URL) of the accessed website (e. g. https://www.examplepage.uk/examplesubpage.html?tid=312400343) browser and browser version (e.g. Chrome 87)

the operating system used (e.g. Windows 10)

the address (URL) of the previously visited page (referrer URL) (e. g. https://www.examplepage.uk/icamefromhere.html/)

the host name and the IP address of the device from the website is being accessed from (e.g. COMPUTERNAME and 194.23.43.121)

date and time

in so-called web server log files

How long is the data stored?

Generally, the data mentioned above are stored for two weeks and are then automatically deleted. We do not pass these data on to others, but we cannot rule out the possibility that this data may be viewed by the authorities in the event of illegal conduct.

In short: Your visit is logged by our provider (company that runs our website on special computers (servers)), but we do not pass on your data without your consent!

 

Legal basis

The lawfulness of processing personal data in the context of web hosting is justified in Art. 6 para. 1 lit. f GDPR (safeguarding of legitimate interests), as the use of professional hosting with a provider is necessary to present the company in a safe and user-friendly manner on the internet, as well as to have the ability to track any attacks and claims, if necessary.

1&1 IONOS Webhosting Privacy Policy

We use IONOS by 1&1 to host our website. In Germany, 1&1 IONOS SE is located at Elgendorfer Str. 57, 56410 Montabaur, in Austria you can find 1&1 IONOS SE at Gumpendorfer Straße 142/PF 266, 1060 Vienna. IONOS offers the following web hosting services: Domain, Website & Shop, Hosting & WordPress, Marketing, Email & Office, IONOS Cloud and Server.

If you would like to learn more about IONOS website privacy, please visit the privacy policy at ionos.com.

Data Processing Agreement (DPA) IONOS

In accordance with Article 28 of the General Data Protection Regulation (GDPR), we have entered into a Data Processing Agreement (DPA) with IONOS. What exactly a DPA is and especially what must be included in a DPA, you can read in our general section “Data Processing Agreement (DPA)”.

This contract is required by law because IONOS processes personal data on our behalf. It clarifies that IONOS may only process data they receive from us according to our instructions and must comply with the GDPR. You can find the link to the Data Processing Agreement (DPA) under https://www.ionos.co.uk/help/data-protection/overview-of-the-general-data-protection-regulation-g dpr/contract-for-data-processing/.

 

Web Analytics

 

What is Web Analytics?

We use software on our website, which is known as web analytics, in order to evaluate website visitor behaviour. Thus, data is collected, which the analytic tool provider (also called tracking tool) stores, manages and processes. Analyses of user behaviour on our website are created with this data, which we as the website operator receive. Most tools also offer various testing options. These

 

enable us, to for example test which offers or content our visitors prefer. For this, we may show you two different offers for a limited period of time. After the test (a so-called A/B test) we know which product or content our website visitors find more interesting. For such testing as well as for various other analyses, user profiles are created and the respective data is stored in cookies.

Why do we run Web Analytics?

We have a clear goal in mind when it comes to our website: we want to offer our industry’s best website on the market. Therefore, we want to give you both, the best and most interesting offer as well as comfort when you visit our website. With web analysis tools, we can observe the behaviour of our website visitors, and then improve our website accordingly for you and for us. For example, we can see the average age of our visitors, where they come from, the times our website gets visited the most, and which content or products are particularly popular. All this information helps us to optimise our website and adapt it to your needs, interests and wishes.

 

Which data are processed?

The exact data that is stored depends on the analysis tools that are being used. But generally, data such as the content you view on our website are stored, as well as e. g. which buttons or links you click, when you open a page, which browser you use, which device (PC, tablet, smartphone, etc.) you visit the website with, or which computer system you use. If you have agreed that location data may also be collected, this data may also be processed by the provider of the web analysis tool.

Moreover, your IP address is also stored. According to the General Data Protection Regulation (GDPR), IP addresses are personal data. However, your IP address is usually stored in a pseudonymised form (i.e. in an unrecognisable and abbreviated form). No directly linkable data such as your name, age, address or email address are stored for testing purposes, web analyses and web optimisations. If this data is collected, it is retained in a pseudonymised form. Therefore, it cannot be used to identify you as a person.

The following example shows Google Analytics’ functionality as an example for client-based web tracking with JavaScript code.

 

 

The storage period of the respective data always depends on the provider. Some cookies only retain data for a few minutes or until you leave the website, while other cookies can store data for several years.

Duration of data processing

If we have any further information on the duration of data processing, you will find it below. We generally only process personal data for as long as is absolutely necessary to provide products and services. The storage period may be extended if it is required by law, such as for accounting purposes for example for accounting.

Right to object

You also have the option and the right to revoke your consent to the use of cookies or third-party providers at any time. This works either via our cookie management tool or via other opt-out functions. For example, you can also prevent data processing by cookies by managing, deactivating or erasing cookies in your browser.

Legal basis

The use of Web Analytics requires your consent, which we obtained with our cookie popup. According to Art. 6 para. 1 lit. a of the GDPR (consent), this consent represents the legal basis for the processing of personal data, such as by collection through Web Analytics tools.

In addition to consent, we have a legitimate interest in analysing the behaviour of website visitors, which enables us to technically and economically improve our offer. With Web Analytics, we can recognise website errors, identify attacks and improve profitability. The legal basis for this is Art. 6 para. 1 lit. f of the GDPR (legitimate interests). Nevertheless, we only use these tools if you have given your consent.

 

Since Web Analytics tools use cookies, we recommend you to read our privacy policy on cookies. If you want to find out which of your data are stored and processed, you should read the privacy policies of the respective tools.

If available, information on special Web Analytics tools can be found in the following sections.

 

Google Remarketing Privacy Policy

We use Google Remarketing, an advertising analysis tool, for our website. The provider of this service is the American company Google Inc. The entity responsible for all Google services in Europe is the company Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland).

Google also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.

Google uses standard contractual clauses approved by the EU Commission as the basis for data processing by recipients based in third countries (i. e. outside the European Union, Iceland, Liechtenstein, Norway, and thus especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). Standard Contractual Clauses (SCC) are legal templates provided by the EU Commission. Their purpose is to ensure that your data complies with European data privacy standards, even if your data is transferred to and stored in third countries (such as the USA). With these clauses, Google commits to comply with the EU‘s level of data protection when processing relevant data, even if it is stored, processed and managed in the USA. These clauses are based on an implementing order by the EU Commission. You can find the order and the standard contractual clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.

Google holds a contract on commissioned processing in accordance with Art. 28 DSGVO, which acts as the data protection law basis for our customer relationship with Google. This refers to the EU standard contractual clauses in terms of content. Here you can find the order processing conditions: https://business.safety.google/intl/en/adsprocessorterms/

You can find out more about the data that is processed through the use of Google Remarketing in their Privacy Policy at https://policies.google.com/privacy?hl=en.

Google Tag Manager Privacy Policy

 

What is Google Tag Manager?

We use Google Tag Manager by the company Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA) for our website.

This Tag Manager is one of Google’s many helpful marketing products. With it, we can centrally integrate and manage code sections of various tracking tools, that we use on our website.

In this privacy statement we will explain in more detail, what Google Tag Manager does, why we use it and to what extent your data is processed.

Google Tag Manager is an organising tool with which we can integrate and manage website tags centrally and via a user interface. Tags are little code sections which e.g. track your activities on our website. For this, segments of JavaScript code are integrated to our site’s source text. The tags often come from Google’s intern products, such as Google Ads or Google Analytics, but tags from other companies can also be integrated and managed via the manager. Since the tags have different tasks, they can collect browser data, feed marketing tools with data, embed buttons, set cookies and track users across several websites.

 

Why do we use Google Tag Manager for our website?

Everybody knows: Being organised is important! Of course, this also applies to maintenance of our website. In order to organise and design our website as well as possible for you and anyone who is interested in our products and services, we rely on various tracking tools, such as Google Analytics. The collected data shows us what interests you most, which of our services we should improve, and which other persons we should also display our services to. Furthermore, for this tracking to work, we must implement relevant JavaScript Codes to our website. While we could theoretically integrate every code section of every tracking tool separately into our source text, this would take too much time and we would lose overview. This is the reason why we use Google Tag Manager. We can easily integrate the necessary scripts and manage them from one place. Additionally, Google Tag Manager’s user interface is easy to operate, and requires no programming skills. Therefore, we can easily keep order in our jungle of tags.

 

What data is stored by Google Tag Manager?

Tag Manager itself is a domain that neither uses cookies nor stores data. It merely functions as an “administrator“ of implemented tags. Data is collected by the individual tags of the different web analysis tools. Therefore, in Google Tag Manager the data is sent to the individual tracking tools and does not get saved.

However, with the integrated tags of different web analysis tools such as Google Analytics, this is quite different. Depending on the analysis tool used, various data on your internet behaviour is collected, stored and processed with the help of cookies. Please read our texts on data protection for more information on the articular analysis and tracking tools we use on our website.

We allowed Google via the account settings for the Tag Manager to receive anonymised data from us. However, this exclusively refers to the use of our Tag Manager and not to your data, which are saved via code sections. We allow Google and others, to receive selected data in anonymous form.

 

Therefore, we agree to the anonymised transfer of our website data. However, even after extensive research we could not find out what summarised and anonymous data it is exactly that gets transmitted. What we do know is that Google deleted any info that could identify our website.

Google combines the data with hundreds of other anonymous website data and creates user trends as part of benchmarking measures. Benchmarking is a process of comparing a company’s results with the ones of competitors. As a result, processes can be optimised based on the collected information.

How long and where is the data stored?

When Google stores data, this is done on Google’s own servers. These servers are located all over the world, with most of them being in America. At https://www.google.com/about/datacenters/inside/locations/?hl=en you can read in detail where Google’s servers are.

In our individual data protection texts on the different tools you can find out how long the respective tracking tools store your data.

How can I delete my data or prevent data retention?

Google Tag Manager itself does not set any cookies but manages different tracking websites’ tags. In our data protection texts on the different tracking tools you can find detailed information on how you can delete or manage your data.

Please note that when using this tool, your data may also be stored and processed outside the EU. Most third countries (including the USA) are not considered secure under current European data protection law. Data must not be transferred, stored and processed to insecure third countries, unless there are suitable guarantees (such as EU standard contractual clauses) between us and the non-European service provider.

 

Legal basis

The use of the Google Tag Manager requires your consent, which we obtained via our cookie popup. According to Art. 6 para. 1 lit. a GDPR (consent), this consent is the legal basis for personal data processing, such as when it is collected by web analytics tools.

In addition to consent, we have a legitimate interest in analysing the behaviour of website visitors and thus technically and economically improving our offer. With the help of Google Tag Managers we can also improve profitability. The legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests). We only use Google Tag Manager if you have given us your consent.

Google also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.

Google uses standard contractual clauses approved by the EU Commission as basis for data

 

processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Google to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847

The Google Ads Data Processing Terms, which reference the standard contractual clauses, can be found at https://business.safety.google/intl/en/adsprocessorterms/

If you want to learn more about Google Tag Manager, we recommend their FAQs at https://support.google.com/tagmanager/?hl=en#topic=3441530.

 

Matomo privacy policy

On our website we use Matomo, a web analysis tool. The provider of this service is the company InnoCraft Ltd, 7 Waterloo Quay PO625, 6140 Wellington, New Zealand. You can find out more on the data that are being processed when using Matomo, in their Privacy Policy at https://matomo.org/privacy-policy/. Questions regarding data protection can be sent by e-mail to privacy@matomo.org.

Email-Marketing

 

What is Email-Marketing?

We use email marketing to keep you up to date. If you have agreed to receive our emails or newsletters, your data will be processed and stored. Email marketing is a part of online marketing. In this type of marketing, news or general information about a company, product or service are emailed to a specific group of people who are interested in it.

If you want to participate in our email marketing (usually via newsletter), you usually just have to register with your email address. To do this, you have to fill in and submit an online form. However, we may also ask you for your title and name, so we can address you personally in our emails.

The registration for newsletters generally works with the help of the so-called “double opt-in procedure”. After you have registered for our newsletter on our website, you will receive an email, via which you can confirm the newsletter registration. This ensures that you own the email address

 

you signed up with, and prevents anyone to register with a third-party email address. We or a notification tool we use, will log every single registration. This is necessary so we can ensure and prove, that registration processes are done legally and correctly. In general, the time of registration and registration confirmation are stored, as well as your IP address. Moreover, any change you make to your data that we have on file is also logged.

Why do we use Email-Marketing?

Of course, we want to stay in contact with you and keep you in the loop of the most important news about our company. For this, we use email marketing – often just referred to as “newsletters”

– as an essential part of our online marketing. If you agree to this or if it is permitted by law, we will send you newsletters, system emails or other notifications via email. Whenever the term “newsletter” is used in the following text, it mainly refers to emails that are sent regularly. We of course don’t want to bother you with our newsletter in any way. Thus, we genuinely strive to offer only relevant and interesting content. In our emails you can e.g. find out more about our company and our services or products. Since we are continuously improving our offer, our newsletter will always give you the latest news, or special, lucrative promotions. Should we commission a service provider for our email marketing, who offers a professional mailing tool, we do this in order to offer you fast and secure newsletters. The purpose of our email marketing is to inform you about new offers and also to get closer to our business goals.

 

Which data are processed?

If you subscribe to our newsletter via our website, you then have to confirm your membership in our email list via an email that we will send to you. In addition to your IP and email address, your name, address and telephone number may also be stored. However, this will only be done if you agree to this data retention. Any data marked as such are necessary so you can participate in the offered service. Giving this information is voluntary, but failure to provide it will prevent you from using this service. Moreover, information about your device or the type of content you prefer on our website may also be stored. In the section “Automatic data storage” you can find out more about how your data is stored when you visit a website. We record your informed consent, so we can always prove that it complies with our laws.

 

Duration of data processing

If you unsubscribe from our e-mail/newsletter distribution list, we may store your address for up to three years on the basis of our legitimate interests, so we can keep proof your consent at the time. We are only allowed to process this data if we have to defend ourselves against any claims.

However, if you confirm that you have given us your consent to subscribe to the newsletter, you can submit an individual request for erasure at any time. Furthermore, if you permanently object to your consent, we reserve the right to store your email address in a blacklist. But as long as you have voluntarily subscribed to our newsletter, we will of course keep your email address on file.

 

Withdrawal – how can I cancel my subscription?

You have the option to cancel your newsletter subscription at any time. All you have to do is revoke your consent to the newsletter subscription. This usually only takes a few seconds or a few clicks.

Most of the time you will find a link at the end of every email, via which you will be able to cancel the subscription. Should you not be able to find the link in the newsletter, you can contact us by email and we will immediately cancel your newsletter subscription for you.

Legal basis

Our newsletter is sent on the basis of your consent (Article 6 (1) (a) GDPR). This means that we are only allowed to send you a newsletter if you have actively registered for it beforehand. Moreover, we may also send you advertising messages on the basis of Section 7 (3) UWG (Unfair Competition Act), provided you have become our customer and have not objected to the use of your email address for direct mail.

If available – you can find information on special email marketing services and how they process personal data, in the following sections.

MailPoet Privacy Policy

We use MailPoet on our website, which is a service for our email marketing. The service provider is the Irish company Aut O’Mattic A8C Ireland Ltd, Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Irland. You can find out more about the data that is processed through the use of MailPoet in the privacy policy at https://automattic.com/privacy/.

Social Media

 

What is Social Media?

In addition to our website, we are also active on various social media platforms. For us to be able to target interested users via social networks, user data may be processed. Additionally, elements of social media platforms may be embedded directly in our website. This is e.g. the case if you click a so-called social button on our website and are forwarded directly to our social media presence. So- called social media are websites and apps on which registered members can produce and exchange content with other members, be it openly or in certain groups and networks.

 

Why do we use Social Media?

For years, social media platforms have been the place where people communicate and get into contact online. With our social media presence, we can familiarise interested people better with our products and services. The social media elements integrated on our website help you switch to our social media content quickly and hassle free.

The data that is retained and processed when you use a social media channel is primarily used to conduct web analyses. The aim of these analyses is to be able to develop more precise and personal marketing and advertising strategies. The evaluated data on your behaviour on any social media platform can help to draw appropriate conclusions about your interests. Moreover, so-called user profiles can be created. Thus, the platforms may also to present you with customised advertisements. For this, cookies are usually placed in your browser, which store data on your user behaviour.

We generally assume that we will continue to be responsible under Data Protection Law, even when using the services of a social media platform. However, the European Court of Justice has ruled that, within the meaning of Art. 26 GDPR, in certain cases the operator of the social media platform can be jointly responsible with us. Should this be the case, we will point it out separately and work on the basis of a related agreement. You will then find the essence of the agreement for the concerned platform below.

Please note that when you use social media platforms or our built-in elements, your data may also be processed outside the European Union, as many social media channels, such as Facebook or Twitter, are American companies. As a result, you may no longer be able to easily claim or enforce your rights regarding your personal data.

Which data are processed?

Exactly which data are stored and processed depends on the respective provider of the social media platform. But usually it is data such as telephone numbers, email addresses, data you enter in contact forms, user data such as which buttons you click, what you like or who you follow, when you visited which pages, as well as information about your device and IP address. Most of this data is stored in cookies. Should you have a profile on the social media channel you are visiting and are logged in, data may be linked to your profile.

All data that are collected via social media platforms are also stored on the providers’ servers. This means that only the providers have access to the data and can provide you with appropriate information or make changes for you.

If you want to know exactly which data is stored and processed by social media providers and how you can object to the data processing, we recommend you to carefully read the privacy policy of the respective company. We also recommend you to contact the provider directly if you have any questions about data storage and data processing or if you want to assert any corresponding rights.

 

Duration of data processing

Provided we have any further information on this, we will inform you about the duration of the data processing below. The social media platform Facebook example stores data until they are no longer needed for the company’s own purposes. However, customer data that is synchronised with your own user data is erased within two days. Generally, we only process personal data for as long as is absolutely necessary for the provision of our services and products. This storage period can also be exceeded however, if it is required by law, such as e.g. in the case of accounting.

 

Right to object

You also retain the right and the option to revoke your consent to the use of cookies or third-party providers such as embedded social media elements at any time. This can be done either via our cookie management tool or via other opt-out functions. You can e.g. also prevent data collection via cookies by managing, deactivating or erasing cookies in your browser.

Since cookies may be used with social media tools, we also recommend you to read our privacy policy on cookies. If you want to find out which of your data is stored and processed, we advise you to read the privacy policies of the respective tools.

Legal basis

If you have consented to the processing and storage of your data by integrated social media elements, this consent serves as the legal basis for data processing (Art. 6 para. 1 lit. a GDPR). Generally, provided you have given your consent, your data will also be stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f GDPR) in maintaining fast and good communication with you and other customers and business partners. Nevertheless, we only use the tools if you have consented. Most social media platforms also set cookies on your browser to store data. We therefore recommend you to read our privacy policy on cookies carefully and to take a look at the privacy policy or cookie policy of the respective service provider.

in the following section you can find information on special social media platforms – provided this information is available.

Facebook Privacy Policy

 

What are Facebook tools?

We use selected Facebook tools on our website. Facebook is a social media network of the company Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland. With the aid of this tool we can provide the best possible offers to you and anyone interested in our products and services.

If your data is collected and forwarded via our embedded Facebook elements or via our Facebook page (fanpage), both we and Facebook Ireland Ltd. are responsible for this. However, should any further processing occur, then Facebook is solely responsible for this data. Our joint commitments were also set out in a publicly available agreement at https://www.facebook. com / legal / controller_addendum . It e.g. states that we must clearly inform you about the use of Facebook tools on our website. We are also responsible for ensuring that the tools are securely integrated into our website and are in accordance with the applicable privacy laws. Facebook, on the other hand, is e.g. responsible for the data security of Facebook’s products. If you have any questions about Facebook’s data collection and processing, you can contact the company directly. Should you direct the question to us, we are obliged to forward it to Facebook.

In the following we will give you an overview on the different Facebook tools, as well as on what data is sent to Facebook and how you can erase this data.

Along with many other products, Facebook also offers so called “Facebook Business Tools”. This is Facebook’s official name for its tools, but it is not very common. Therefore, we decided to merely call them “Facebook tools”. They include the following:

Facebook-Pixel

Social Plugins (e.g. the “Like” or “Share“ button) Facebook Login

Account Kit

APIs (application programming interface) SDKs (Softwart developmept kits) Plattform-integrations

Plugins Codes Specifications

Documentations Technologies and Services

With these tools Facebook can extend its services and is able to receive information on user activities outside of Facebook.

Why do we use Facebook tools on our website?

We only want to show our services and products to people who are genuinely interested in them. With the help of advertisements (Facebook Ads) we can reach exactly these people. However, to be able to show suitable adverts to users, Facebook requires additional information on people’s needs and wishes. Therefore, information on the user behaviour (and contact details) on our website, are

 

provided to Facebook. Consequently, Facebook can collect better user data and is able to display suitable adverts for our products or services. Thanks to the tools it is possible to create targeted, customised ad campaigns of Facebook.

Facebook calls data about your behaviour on our website “event data” and uses them for analytics services. That way, Facebook can create “campaign reports” about our ad campaigns’ effectiveness on our behalf. Moreover, by analyses we can get a better insight in how you use our services, our website or our products. Therefore, some of these tools help us optimise your user experience on our website. With the social plugins for instance, you can share our site’s contents directly on Facebook.

 

What data is stored by Facebook tools?

With the use of Facebook tools, personal data (customer data) may be sent to Facebook. Depending on the tools used, customer data such as name, address, telephone number and IP address may be transmitted.

Facebook uses this information to match the data with the data it has on you (if you are a Facebook member). However, before the customer data is transferred to Facebook, a so called “Hashing” takes place. This means, that a data record of any size is transformed into a string of characters, which also has the purpose of encrypting data.

Moreover, not only contact data, but also “event data“ is transferred. These data are the information we receive about you on our website. To give an example, it allows us to see what subpages you visit or what products you buy from us. Facebook does not disclose the obtained information to third parties (such as advertisers), unless the company has an explicit permission or is legally obliged to do so. Also, “event data“ can be linked to contact information, which helps Facebook to offer improved, customised adverts. Finally, after the previously mentioned matching process, Facebook deletes the contact data.

To deliver optimised advertisements, Facebook only uses event data, if they have been combined with other data (that have been collected by Facebook in other ways). Facebook also uses event data for the purposes of security, protection, development and research. Many of these data are transmitted to Facebook via cookies. Cookies are little text files, that are used for storing data or information in browsers. Depending on the tools used, and on whether you are a Facebook member, a different number of cookies are placed in your browser. In the descriptions of the individual Facebook tools we will go into more detail on Facebook cookies. You can also find general information about the use of Facebook cookies at https://www.facebook.com/policies/cookies.

 

How long and where are the data stored?

Facebook fundamentally stores data, until they are no longer of use for their own services and products. Facebook has servers for storing their data all around the world. However, customer data is cleared within 48 hours after they have been matched with their own user data.

 

How can I erase my data or prevent data retention?

In accordance with the General Data Protection Regulation (GDPR) you have the right of information, rectification, transfer and deletion of your data.

The collected data is only fully deleted, when you delete your entire Facebook account. Deleting your Facebook account works as follows:

• Click on settings in the top right side in

 

• Then, click “Your Facebook information“ in the left

 

• Now click on “Deactivation and deletion”.

 

• Choose “Permanently delete account“ and then click on “Continue to account deletion“.

 

• Enter your password, click on “continue“ and then on “Delete account“.

 

The retention of data Facebook receives via our site is done via cookies (e.g. with social plugins), among others. You can deactivate, clear or manage both all and individual cookies in your browser. How this can be done differs depending on the browser you use. The following instructions show, how to manage cookies in your browser:

Chrome: Clear, enable and manage cookies in Chrome Safari: Manage cookies and website data in Safari Firefox: Clear cookies and site data in Firefox

Internet Explorer: Delete and manage cookies Microsoft Edge: Delete cookies in Microsoft Edge

If you generally do not want to allow any cookies at all, you can set up your browser to notify you whenever a cookie is about to be set. This gives you the opportunity to decide upon the permission or deletion of every single cookie.

Legal basis

If you have consented to your data being processed and stored by integrated Facebook tools, this consent is the legal basis for data processing (Art. 6 para. 1 lit. a GDPR). Generally, your data is also stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f GDPR) to maintain fast and good communication with you or other customers and business partners.

Nevertheless, we only use these tools if you have given your consent. Most social media platforms also set cookies on your browser to store data. We therefore recommend you to read our privacy policy about cookies carefully and to take a look at the privacy policy or Facebook’s cookie policy.

Facebook also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for

 

data transfers to the USA. This can be associated with various risks to the legality and security of data processing.

Facebook uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Facebook to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847

We hope we could give you an understanding of the most important information about the use of Facebook tools and data processing. If you want to find out more on how Facebook use your data, we recommend reading the data policies at https://www.facebook.com/about/privacy/update.

Facebook Login Privacy Policy

We integrated the convenient Facebook Login to our website. With it, you can easily log into our site with your Facebook account, without having to create a new user account. If you decide to register via the Facebook Login, you will be redirected to the social media network Facebook. There, you can log in with your Facebook user data. By using this method to log in, data on you and your user behaviour is stored and transmitted to Facebook.

To save the data, Facebook uses various cookies. In the following we will show you the most significant cookies that are placed in your browser or that already exist when you log into our site via the Facebook Login:

Name: fr

Value: 0jieyh4c2GnlufEJ9..Bde09j…1.0.Bde09j

Purpose: This cookie is used to make the social plugin function optimally on our website.

Expiry date: after 3 months

 

Name: datr

Value: 4Jh7XUA2312400343SEmPsSfzCOO4JFFl

Purpose: Facebook sets the “datr” cookie, when a web browser accesses facebook.com. The cookie helps to identify login activities and protect users.

Expiry date: after 2 years

 

Name: _js_datr

Value: deleted

Purpose: Facebook sets this session cookie for tracking purposes, even if you do not have a Facebook account or are logged out.

Expiry date: after the end of the session

 

Note: The cookies we stated are only a small range of the cookies which are available to Facebook. Other cookies include for example _ fbp, sb or wd. It is not possible to disclose an exhaustive list,

 

since Facebook have a multitude of cookies at their disposal which they use in variation.

 

On the one hand, Facebook Login enables a fast and easy registration process. On the other hand, it gives us the opportunity to share data with Facebook. In turn, we can customise our offer and advertising campaigns better to your needs and interests. The data we receive from Facebook by this means, is public data such as

your Facebook name your profile picture

your stored email address friends lists

button clicks (e.g. “Like“ button) date of birth

language

place of residence

 

In return, we provide Facebook with information about your activities on our website. These include information on the terminal device you used, which of our subpages you visit, or what products you have bought from us.

By using Facebook Login, you agree to the data processing. You can terminate this agreement anytime. If you want to learn more about Facebook’s data processing, we recommend you to read Facebook’s Data Policy at https://www.facebook.com/policy.php.

If you are registered with Facebook, you can change your advertisement settings anytime at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.

Twitter Privacy Policy

 

What is Twitter?

We have incorporated Twitter functions on our website. These are, for example, embedded tweets, timelines, buttons or hashtags. Twitter is a short message service and social media platform from the firm Twitter Inc., One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland.

To our knowledge, in the European Economic Area and Switzerland, a mere integration of the Twitter function does not transfer any personal data or data about your web activities to Twitter. Only when you interact with the Twitter functions, such as by clicking a button, data could be sent

 

to Twitter and get saved as well as processed there. We have no influence on this processing of data and do not bare any responsibility for it. Within this privacy statement, we want to give you an overview of what data Twitter stores, what Twitter does with this data and how you can largely protect yourself from data transmission.

For some, Twitter is a news service, for others, a social media platform, and for others still it is a microblogging service. All these terms are justified and mean pretty much the same.

Both individuals as well as companies use Twitter for communicating with interested people via short messages. Twitter only allows 280 characters per message. These messages are called “tweets”. In contrast to Facebook, for example, the service does not focus on the expansion of a network of “friends”, but strives to be regarded as an open, worldwide news platform. On Twitter you can also have an anonymous account and tweets can be deleted by both, either the company or the users themselves.

 

Why do we use Twitter on our website?

Like many other websites and companies, we try to use different channels for offering our services and communicating with our customers. Twitter is a truly useful “small” news service, which is why it has grown dear to us. We regularly tweet or retweet exciting, funny or interesting content. We understand that you do not have the time to follow every channel after channel, as you surely have enough other things to do. That is why we also have integrated Twitter functions to our website.

That way, you can experience our Twitter activities “on site” or come to our Twitter page via a direct link. With the integration, we want to strengthen the service and user-friendliness on our website.

What data is stored by Twitter?

You will find integrated Twitter functions on some of our subpages. If you interact with Twitter content, such as by clicking a button, Twitter may collect and save data. This can happen even if you don’t have a Twitter account yourself. Twitter calls this data “log data”. It includes demographic data, browser cookie IDs, your smartphone’s ID, hashed email addresses, and information on which pages you have visited on Twitter and what actions you have taken there. Of course, Twitter stores more data if you have a Twitter account and are logged in. This retention is usually done via cookies. Cookies are small text files that are usually set in your browser and transmit various information to Twitter.

We will now show you which cookies are placed if you are not logged in to Twitter but visit a website with built-in Twitter functions. Please consider this list as an example. We do not claim for this list to be extensive, since the array of cookies always changes and depends on your individual actions with Twitter content.

The following cookies have been used in our test:

 

Name: personalization_id

Value: “v1_cSJIsogU51SeE312400343”

Purpose: This cookie stores information on how you use the website and what ad may have led you to Twitter.

 

Expiry date: after 2 years

 

Name: lang

Value: en

Purpose: This cookie stores your default or preferred language.

Expiry date: after end of session

 

Name: guest_id

Value: 312400343v1%3A157132626

Purpose: This cookie is set to identify you as a guest.

Expiry date: after 2 years

 

Name: fm

Value: 0

Purpose: Unfortunately, we could not find out the purpose of this cookie.

Expiry date: after end of session

 

Name: external_referer

Value: 3124003432beTA0sf5lkMrlGt

Purpose: This cookie collects anonymous data, such as how often you visit Twitter and how long you visit Twitter.

Expiry date: after 6 days

 

Name: eu_cn

Value: 1

Purpose: This cookie stores user activity and is used for Twitter’s various advertising purposes.

Expiry date: after one year

 

Name: ct0

Value: c1179f07163a365d2ed7aad84c99d966

Purpose: Unfortunately we could not find any information on this cookie.

Expiry date: after 6 hours

 

Name: _twitter_sess

Value: 53D%253D–dd0248312400343-

Purpose: With this cookie you can use functions within Twitter’s website.

Expiry date: after end of session

 

Note: Twitter also works with third parties. Therefore, we have recognized the three Google Analytics cookies _ga, _gat, _gid in our test.

On the one hand, Twitter uses the collected data for gaining better understand on user behaviour, and thus to improve their own services and advertising offers. On the other hand, the data are also used for internal security measures.

 

How long and where are the data stored?

When Twitter collects data from other websites, after a maximum of 30 days, they will be deleted, summarised or otherwise concealed. Twitter’s servers are in various server centres in the United States. Accordingly, it can be assumed that the gathered data will be collected and stored in America. In our research we could not clearly determine whether Twitter also owns servers in Europe. Generally, Twitter may keep collected data stored until either the data are no longer useful to the company, until you delete the data or until a potential legal deletion period has been reached.

 

How can I erase my data or prevent data retention?

In their Privacy Policy, Twitter repeatedly emphasise that they do not save data from external website visits, provided you or your browser are in the European Economic Area or Switzerland. However, if you interact directly with Twitter, the company will of course store your data.

If you have a Twitter account, you can manage your data by clicking on “More” under the “Profile” button. Then click on “Settings and privacy”. Here you can manage data processing individually.

If you do not have a Twitter account, you can go to twitter.com and click “Settings”. At “Personalisation and data” you can manage data that is collected on you.

As mentioned above, most data are stored via cookies, which you can manage, deactivate or delete in your browser. Please note that when changing cookie settings in your browser, the edits will only affect that very browser. This means that if you use another browser in the future, you will have to manage your cookie settings there again. In the following you will find instructions for managing cookies in the most popular browsers.

Chrome: Clear, enable and manage cookies in Chrome Safari: Manage cookies and website data in Safari Firefox: Clear cookies and site data in Firefox

Internet Explorer: Delete and manage cookies Microsoft Edge: Delete cookies in Microsoft Edge

You can also set your browser to notify you about each individual cookie. This lets you decide individually whether you want to allow or deny a cookie.

Twitter also uses the data for personalised advertising in-and outside of Twitter. You can switch off personalised advertising in the settings under “Personalization and data”. If you use Twitter on a browser, you can deactivate personalised advertising at http://optout.aboutads.info/?c=2&lang=EN.

Legal basis

If you have consented processing and storage of your data by integrated social media elements,

 

this consent is the legal basis for data processing (Art. 6 para. 1 lit. a GDPR) . Generally, your data is also stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f GDPR) to maintain fast and good communication with you or other customers and business partners. We only use integrated social media elements if you have given your consent. Most social media platforms also place cookies in your browser to store data. We therefore recommend you to read our privacy policy about cookies carefully and to also take a look at the privacy policy or the cookie policy of the respective service provider.

Twitter processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.

Twitter uses standard contractual clauses, which are approved by the EU Commission, as the basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfers there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige ShareThis to comply with the EU’s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847

We hope we could give you a basic overview of Twitter’s data processing. We do not receive any data from Twitter and are not responsible for what Twitter does with your data. If you have any further questions on this topic, we recommend you to read Twitter’s privacy statement at https://twitter.com/en/privacy.

Online Marketing

 

What is Online Marketing?

Online Marketing refers to all measures that are carried out online to achieve marketing goals, such as increasing brand awareness or doing business transactions. Furthermore, our Online Marketing measures aim to draw people’s attention to our website. In order to be able to show our offer to many interested people, we do Online Marketing. It mostly is about online advertising, content marketing or search engine optimisation. For this, personal data is also stored and processed, to enable us to use Online Marketing efficiently and targeted. On the one hand, the data help us to only show our content to people who are interested in it. On the other hand, it helps us to measure

 

the advertising success of our Online Marketing measures.

 

Why do we use Online Marketing tools?

We want to show our website to everyone who is interested in our offer. We are aware that this is not possible without conscious measures being taken. That is why we do Online Marketing. There are various tools that make working on our Online Marketing measures easier for us. These also provide suggestions for improvement via data. Thus, we can target our campaigns more precisely to our target group. The ultimate purpose of these Online Marketing tools is to optimise our offer.

Which data are processed?

For our Online Marketing to work and to measure its success, user profiles are created and data are

e.g. stored in cookies (small text files). With the help of this data, we can not only advertise in the traditional way, but also present our content directly on our website in the way you prefer. There are various third-party tools that offer these functions and thus collect and store your data accordingly. The aforementioned cookies e.g. store the pages you visit on our website, how long you view these pages, which links or buttons you click or which website you came from. What is more, technical information may also be stored. This may include e.g. your IP address, the browser and device you use to visit our website or the time you accessed our website as well as the time you left. If you have agreed for us to determine your location, we can also store and process it.

Your IP address is stored in pseudonymised form (i.e. shortened). What is more, distinct data that directly identify you as a person, such as your name, address or email address, are only stored in pseudonymised for advertising and Online Marketing purposes. With this data we cannot identify you as a person and only retain the pseudonymised information that is stored in your user profile.

Under certain circumstances, cookies may also be utilised, analysed and used for advertising purposes on other websites that use the same advertising tools. Thus, your data may then also be stored on the servers of the respective provider of the advertising tool.

In rare exceptions, unique data (name, email address, etc.) may also be stored in the user profiles. This can happen, if you are for example a member of a social media channel that we use for our Online Marketing measures and if the network connects previously received data with the user profile.

We only ever receive summarised information from the advertising tools we use that do store data on their servers. We never receive data that can be used to identify you as an individual. What is more, the data only shows how well-placed advertising measures have worked. For example, we can see what measures have caused you or other users to visit our website and purchase a service or product. Based on these analyses we can improve our advertising offer in the future and adapt it more precisely to the needs and wishes of people who are interested.

 

Duration of data processing

Below we will inform you on the duration of data processing, provided we have this information. In general, we only process personal data for as long as is absolutely necessary to provide our

 

services and products. Data stored in cookies are retained for different lengths of time. Some cookies are deleted after you leave a website, while others may be stored in your browser for a number of years. However, in the respective privacy policies of the respective provider, you will usually find detailed information on the individual cookies this provider uses.

Right of withdrawal

You also retain the right and the option to revoke your consent to the use of cookies or third-party providers at any time. This can be done either via our cookie management tool or via other opt-out functions. You can for example also prevent data collection by cookies if you manage, deactivate or erase cookies in your browser. The legality of the processing remains unaffected to the point of revocation.

Since Online Marketing tools usually use cookies, we also recommend you to read our privacy policy on cookies. If you want to find out which of your data is stored and processed, you should read the privacy policies of the respective tools.

Legal basis

If you have consented to the use of third-party providers, then this consent is the legal basis for the corresponding data processing. According to Art. 6 para. 1 lit. a GDPR (consent) , this consent is the legal basis for personal data processing, as may be done when data is collected by online marketing tools.

Moreover, we have a legitimate interest in measuring our online marketing activities in anonymised form, in order to use this data for optimising our offer and our Marketing. The corresponding legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests) . Nevertheless, we only use these tools if you have given your consent.

Information on special online marketing tools can be found in the following sections, provided this information is available.

Google Ads (Google AdWords) Conversion Tracking Privacy Policy

 

What is Google Ads conversion tracking?

We use Google Ads (previously Google AdWords) as an online marketing measure, to advertise our products and services. Thus, we want to draw more people’s attention on the internet to the high quality of our offers. As part of our advertising measures with Google Ads, we use the conversion tracking of Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”) on our website. With the aid of this free tracking tool we can tailor our advertising offer better to your interests and needs. In the following article we will explain, why we use conversion tracking, what data gets saved and how you can prevent this data retention.

Google Ads (previously Google AdWords) is the internal online advertising sxstem of the company Google LLC. We are convinced of our offer‘s quality and would like as many people as possible to discover our website. For this, Google Ads offers the best platform within the online environment. Of course, we also want to get an overview of the cost-benefit factor of our advertising campaigns. Thence, we use Google Ads’ conversion tracking tool.

But what is a conversion actually? A conversion occurs, when you turn from an interested visitor into an acting website visitor. This happens every time you click on our ad and then make another action, such as paying a visit to our website. With Google’s conversion tracking tool, we can understand what happens after a user clicks our Google ad. It shows us for instance if products get bought, services are used or whether users have subscribed to our newsletter.

Why do we use Google Ads conversion tracking on our website?

We use Google Ads to show our offer also across other websites. Our aim is for our advertising campaigns to reach only those people, who are interested in our offers. With the conversion tracking tool, we see what keywords, ads, ad groups and campaigns lead to the desired customer actions. We see how many customers interact with our ads on a device, to then convert. With this data we can calculate our cost-benefit-factor, measure the success of individual ad campaigns and therefore optimise our online marketing measures. With the help of the obtained data we can give our website a more interesting design and customise our advertising offer better to your needs.

 

What data is stored with Google Ads conversion tracking?

For a better analysis of certain user actions, we have integrated a conversion tracking tag, or code snippet to our website. Therefore, if you click one of our Google ads, a Google domain stores the cookie “conversion” on your computer (usually in the browser) or on your mobile device. Cookies are little text files that save information on your computer.

Here are data of the most significant cookies for Google’s conversion tracking:

 

Name: Conversion

Value: EhMI_aySuoyv4gIVled3Ch0llweVGAEgt-mr6aXd7dYlSAGQ312400343-3

Purpose: This cookie saves every conversion you make on our website after you came to us via a Google ad.

Expiry date: after 3 months

 

Name: _gac

Value: 1.1558695989.EAIaIQobChMIiOmEgYO04gIVj5AYCh2CBAPrEAAYASAAEgIYQfD_BwE

Purpose: This is a classic Google Analytics Cookie that records various actions on our website.

Expiry date: after 3 months

 

Note: The cookie _gac only appears in connection with Google Analytics. The above list does not claim to be exhaustive, as Google repeatedly change the cookies they use for analytical evaluation.

As soon as you complete an action on our website, Google identifies the cookie and saves your action as a so-called conversion. For as long as you surf our website, provided the cookie has not expired, both Google and us can determine that you found your way to us via a Google ad. Then, the cookie is read and sent back to Google Ads, together with the conversion data. Moreover, other cookies may also be used for measuring conversions. Google Ads‘ conversion tracking can be fine- tuned and improved with the aid of Google Analytics. Furthermore, ads which Google displays in various places across the web, might be placed under our domain with the name “ gads” or “_gac”. Since September 2017, analytics.js retains various campaign information with the _gac cookie. This cookie stores data, as soon as you open one of our sites that has been set up for Google Ads’ auto- tagging. In contrast to cookies that are placed for Google domains, Google can only read these conversion cookies when you are on our website. We do neither collect nor receive any personal data. We do obtain a report with statistical evaluations by Google. With the help thereof, we can not only see the total number of users who clicked our ad, but also what advertising measures were well received.

 

How long and where is the data stored?

At this point we want to reiterate, that we have no influence on how Google use the collected data. According to Google, the data are encrypted and stored on a secure server. In most cases, conversion cookies expire after 30 days, and do not transmit any personalised data. The cookies named “conversion“ and “_gac“ (which is used with Google Analytics) have an expiry date of 3 months.

How can I erase my data or prevent data retention?

You have the possibility to opt out of Google Ads’ conversion tracking. The conversion tracking can be blocked by deactivating the conversion tracking cookie via your browser. If you do this, you will not be considered for the statistic of the tracking tool. You can change the cookie settings in your browser anytime. Doing so, works a little different in every browser. Hence, in the following you will find an instruction on how to manage cookies in your browser:

Chrome: Clear, enable and manage cookies in Chrome Safari: Manage cookies and website data in Safari Firefox: Clear cookies and site data in Firefox

Internet Explorer: Delete and manage cookies

 

Microsoft Edge: Delete cookies in Microsoft Edge

 

If you generally do not want to allow any cookies at all, you can set up your browser to notify you whenever a potential cookie is about to be set. This lets you decide upon permitting or denying the cookie’s placement. By downloading and installing the browser plugin at https://support.google.com/ads/answer/7395996 you can also deactivate all “advertising cookies”. Please consider that by deactivating these cookies, you cannot prevent all advertisements, only personalised ads.

 

Legal basis

If you have consented to the use of Google Ads Conversion Tracking, your consent is the legal basis for the corresponding data processing. According to Art. 6 para. 1 lit. a GDPR (consent), this consent is the legal basis for personal data processing, as may be done when collected by Google Ads Conversion Tracking.

We also have legitimate interest in using Google Ads Conversion Tracking to optimise our online service and marketing measures. The corresponding legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests). Nevertheless, we only use Google Ads Conversion Tracking if you have consented to it.

Google also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.

Google uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Google to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847

The Google Ads Data Processing Terms, which reference the standard contractual clauses, can be found at https://business.safety.google/intl/en/adsprocessorterms/

If you would like to find out more about data protection at Google, we recommend Google’s privacy policy at: https://policies.google.com/privacy?hl=en-GB.

Security & Anti-spam

 

 

 

 

 

 

 

 

 

 

 

 

What is Security & Anti-spam software?

So-called security & Anti-spam software can protect you and us from various spam or phishing emails and other potential cyber-attacks. Spam includes advertising emails from mass mailings that you did not sign up for yourself. Such emails are also called data garbage and can also cause costs. Other spam such as phishing emails, on the other hand, are messages that aim to gain trust via fake messages or websites in order to obtain personal information. Anti-spam software usually protects against unwanted spam messages or malicious emails that could inject viruses into our system. We also use general firewall and security systems that protect our devices from unwanted network attacks.

 

Why do we use Security & Anti-spam software?

We put great importance on our website’s security. After all, this is not just about our safety, but also about your safety. Unfortunately, cyber threats are now part of everyday life in the world of IT and the internet. Hackers e. g. often try to steal personal data from IT systems with the help of cyber attacks. And therefore a good defence system is absolutely necessary. A security system monitors all incoming and outgoing connections to our network or computer. In order to achieve even greater security against cyber attacks, we also use other external security services on our devices in addition to standardised security systems. Unauthorised data transmissions are thus better prevented and this is how we protect ourselves from cybercrime.

 

Which data are processed by Security & Anti-spam software?

The data that is collected and stored of course depends on the respective service. However, we always try to only use programs that collect data very sparingly or only store data that is necessary for the fulfilment of the offered service. In general, the service may store data such as name, address, IP address, email address and technical data such as browser type or browser version. Any performance and log data may also be collected in order to identify possible incoming threats in good time. This data will be processed as part of the provided services and in compliance with applicable laws. This also includes the GDPR for US providers (via the Standard Contractual Clauses). In some cases, security services also work with third parties who may store and/or process data under instructions and in accordance with privacy policies and other security measures. Data is usually stored using cookies.

 

Duration of data processing

We will inform you below about the duration of data processing, provided we have further information on this. For example, security programs store data until you or we revoke data storage. In general, personal data is only stored for as long as is absolutely necessary for the provision of the services. Unfortunately, in many cases, we do not have precise information from the providers about their data storage periods.

 

Right to object

You also have the right and the option to revoke your consent to the use of cookies or third-party security software at any time. This can be done either via our cookie management tool or via other opt-out functions. For example, you can also prevent data collection through cookies by managing, deactivating or erasing the cookies in your browser.

Since cookies may also be used with security services, we recommend you read our privacy policy on cookies. To find out exactly which of your data is stored and processed, you should read the privacy policies of the respective tools.

Legal Basis

We use security services mainly on the basis of our legitimate interests (Art. 6 Para. 1 lit. f GDPR) in a good security system and protection against various cyber attacks.

Certain data processing requires your consent – in particular, the use of cookies and security functions. If you have agreed to the processing and storage of your data by integrated security services, your consent is the legal basis for data processing (Article 6 (1) (a) GDPR). Most of the services we use set cookies on your browser to store data. We, therefore, recommend you read our privacy policy on cookies carefully and consult the privacy policy or cookie policy of the relevant service provider.

Information on special tools – if available – can be found in the following sections.

 

Google reCAPTCHA Privacy Policy

 

What is reCAPTCHA?

Our primary goal is to provide you an experience on our website that is as secure and protected as possible. To do this, we use Google reCAPTCHA from Google Inc. (1600 Amphitheater Parkway Mountain View, CA 94043, USA). With reCAPTCHA we can determine whether you are a real person from flesh and bones, and not a robot or a spam software. By spam we mean any electronically undesirable information we receive involuntarily. Classic CAPTCHAS usually needed you to solve text or picture puzzles to check. But thanks to Google’s reCAPTCHA you usually do have to do such puzzles. Most of the times it is enough to simply tick a box and confirm you are not a bot. With the new Invisible reCAPTCHA version you don’t even have to tick a box. In this privacy policy you will find out how exactly this works, and what data is used for it.

reCAPTCHA is a free captcha service from Google that protects websites from spam software and misuse by non-human visitors. This service is used the most when you fill out forms on the Internet. A captcha service is a type of automatic Turing-test that is designed to ensure specific actions on the Internet are done by human beings and not bots. During the classic Turing-test (named after computer scientist Alan Turing), a person differentiates between bot and human. With Captchas, a computer or software program does the same. Classic captchas function with small tasks that are easy to solve for humans but provide considerable difficulties to machines. With reCAPTCHA, you no longer must actively solve puzzles. The tool uses modern risk techniques to distinguish people from bots. The only thing you must do there, is to tick the text field “I am not a robot”. However, with Invisible reCAPTCHA even that is no longer necessary. reCAPTCHA, integrates a JavaScript element into the source text, after which the tool then runs in the background and analyses your user behaviour. The software calculates a so-called captcha score from your user actions. Google uses this score to calculate the likelihood of you being a human, before entering the captcha. reCAPTCHA and Captchas in general are used every time bots could manipulate or misuse certain actions (such as registrations, surveys, etc.).

 

Why do we use reCAPTCHA on our website?

We only want to welcome people from flesh and bones on our side and want bots or spam software of all kinds to stay away. Therefore, we are doing everything we can to stay protected and to offer you the highest possible user friendliness. For this reason, we use Google reCAPTCHA from Google. Thus, we can be pretty sure that we will remain a “bot-free” website. Using reCAPTCHA, data is transmitted to Google to determine whether you genuinely are human. reCAPTCHA thus ensures our website’s and subsequently your security. Without reCAPTCHA it could e.g. happen that a bot would register as many email addresses as possible when registering, in order to subsequently “spam” forums or blogs with unwanted advertising content. With reCAPTCHA we can avoid such bot attacks.

 

What data is stored by reCAPTCHA?

reCAPTCHA collects personal user data to determine whether the actions on our website are made by people. Thus, IP addresses and other data Google needs for its reCAPTCHA service, may be sent to Google. Within member states of the European Economic Area, IP addresses are almost always compressed before the data makes its way to a server in the USA. Moreover, your IP address will

 

not be combined with any other of Google’s data, unless you are logged into your Google account while using reCAPTCHA. Firstly, the reCAPTCHA algorithm checks whether Google cookies from other Google services (YouTube, Gmail, etc.) have already been placed in your browser. Then reCAPTCHA sets an additional cookie in your browser and takes a snapshot of your browser window.

The following list of collected browser and user data is not exhaustive. Rather, it provides examples of data, which to our knowledge, is processed by Google.

Referrer URL (the address of the page the visitor has come from) IP-address (z.B. 256.123.123.1)

Information on the operating system (the software that enables the operation of your computers. Popular operating systems are Windows, Mac OS X or Linux)

Cookies (small text files that save data in your browser)

Mouse and keyboard behaviour (every action you take with your mouse or keyboard is stored)

Date and language settings (the language and date you have set on your PC is saved)

All Javascript objects (JavaScript is a programming language that allows websites to adapt to the user. JavaScript objects can collect all kinds of data under one name)

Screen resolution (shows how many pixels the image display consists of)

 

Google may use and analyse this data even before you click on the “I am not a robot” checkmark. In the Invisible reCAPTCHA version, there is no need to even tick at all, as the entire recognition process runs in the background. Moreover, Google have not given details on what information and how much data they retain.

The following cookies are used by reCAPTCHA: With the following list we are referring to Google’s reCAPTCHA demo version at https://www.google.com/recaptcha/api2/demo.

For tracking purposes, all these cookies require a unique identifier. Here is a list of cookies that Google reCAPTCHA has set in the demo version:

Name: IDE

Value: WqTUmlnmv_qXyi_DGNPLESKnRNrpgXoy1K-pAZtAkMbHI-312400343-8

Purpose: This cookie is set by DoubleClick (which is owned by Google) to register and report a user’s interactions with advertisements. With it, ad effectiveness can be measured, and appropriate optimisation measures can be taken. IDE is stored in browsers under the domain doubleclick.net.

Expiry date: after one year

 

Name: 1P_JAR

Value: 2019-5-14-12

Purpose: This cookie collects website usage statistics and measures conversions. A conversion e.g. takes place, when a user becomes a buyer. The cookie is also used to display relevant adverts to users. Furthermore, the cookie can prevent a user from seeing the same ad more than once.

Expiry date: after one month

 

Name: ANID

 

Value: U7j1v3dZa3124003430xgZFmiqWppRWKOr

Purpose: We could not find out much about this cookie. In Google’s privacy statement, the cookie is mentioned in connection with “advertising cookies” such as “DSID”, “FLC”, “AID” and “TAID”. ANID is stored under the domain google.com.

Expiry date: after 9 months

 

Name: CONSENT

Value: YES+AT.de+20150628-20-0

Purpose: This cookie stores the status of a user’s consent to the use of various Google services. CONSENT also serves to prevent fraudulent logins and to protect user data from unauthorised attacks.

Expiry date: after 19 years

 

Name: NID

Value: 0WmuWqy312400343zILzqV_nmt3sDXwPeM5Q

Purpose: Google uses NID to customise advertisements to your Google searches. With the help of cookies, Google “remembers” your most frequently entered search queries or your previous ad interactions. Thus, you always receive advertisements tailored to you. The cookie contains a unique ID to collect users’ personal settings for advertising purposes.

Expiry date: after 6 months

 

Name: DV

Value: gEAABBCjJMXcI0dSAAAANbqc312400343-4

Purpose: This cookie is set when you tick the “I am not a robot” checkmark. Google Analytics uses the cookie personalised advertising. DV collects anonymous information and is also used to distinct between users.

Expiry date: after 10 minutes

 

Note: We do not claim for this list to be extensive, as Google often change the choice of their cookies.

How long and where are the data stored?

Due to the integration of reCAPTCHA, your data will be transferred to the Google server. Google have not disclosed where exactly this data is stored, despite repeated inquiries. But even without confirmation from Google, it can be assumed that data such as mouse interaction, length of stay on a website or language settings are stored on the European or American Google servers. The IP address that your browser transmits to Google does generally not get merged with other Google data from the company’s other services.

However, the data will be merged if you are logged in to your Google account while using the reCAPTCHA plug-in. Google’s diverging privacy policy applies for this.

How can I erase my data or prevent data retention?

If you want to prevent any data about you and your behaviour to be transmitted to Google, you must fully log out of Google and delete all Google cookies before visiting our website or use the

 

reCAPTCHA software. Generally, the data is automatically sent to Google as soon as you visit our website. To delete this data, you must contact Google Support at https://support.google.com/?hl=en-GB&tid=312400343.

If you use our website, you agree that Google LLC and its representatives automatically collect, edit and use data.

Please note that when using this tool, your data can also be stored and processed outside the EU. Most third countries (including the USA) are not considered secure under current European data protection law. Data to insecure third countries must not simply be transferred to, stored and processed there unless there are suitable guarantees (such as EU’s Standard Contractual Clauses) between us and the non-European service provider.

Legal basis

If you have consented to the use of Google reCAPTCHA, your consent is the legal basis for the corresponding data processing. According to Art. 6 Paragraph 1 lit. a GDPR (consent) your consent is the legal basis for the processing of personal data, as can occur when processed by Google reCAPTCHA.

We also have a legitimate interest in using Google reCAPTCHA to optimise our online service and make it more secure. The corresponding legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests). Nevertheless, we only use Google reCAPTCHA if you have given your consent to it.

Google also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.

Google uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Google to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.

The Google Ads Data Processing Terms, which reference the standard contractual clauses, can be found at https://business.safety.google/intl/en/adsprocessorterms/.

You can find out a little more about reCAPTCHA on Google’s web developer page at https://developers.google.com/recaptcha/. Google goes into the technical development of the reCAPTCHA in more detail here, but you will look in vain for detailed information about data storage and data protection issues. A good overview of the basic use of data by Google can be found in the in-house data protection declaration at https://policies.google.com/privacy?hl=en-GB.

 

Wordfence Privacy Policy

We use Wordfence, a WordPress security plug-in, for our website. The service provider is the American company Defiant, Inc., 1700 Westlake Ave N Ste 200, Seattle, WA 98109, USA.

Wordfence also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.

Wordfence uses standard contractual clauses approved by the EU Commission as the basis for data processing by recipients based in third countries (i. e. outside the European Union, Iceland, Liechtenstein, Norway, and thus especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). Standard Contractual Clauses (SCC) are legal templates provided by the EU Commission. Their purpose is to ensure that your data complies with European data privacy standards, even if your data is transferred to and stored in third countries (such as the USA). With these clauses, Wordfence commits to comply with the EU‘s level of data protection when processing relevant data, even if it is stored, processed and managed in the USA. These clauses are based on an implementing order by the EU Commission. You can find the order and the standard contractual clauses here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=en

The General Data Protection Regulation, which corresponds to the standard contractual clauses, can be found at https://www.wordfence.com/help/general-data-protection-regulation/.

You can learn more about the data processed using Wordfence in the Privacy Policy at https://www.wordfence.com/privacy-policy/.

Web Design Introduction

 

What is web design?

We use various tools on our website for the purpose of our web design. Contrary to common belief, web design is not just about making our website look nice, but rather also about functionality and performance. But of course, a good-looking website is also a major goal of professional web design. Web design is a part of media design and deals with the visual as well as the structural and functional design of a website. Our aim with our web design is to improve your experience on our

 

site. In web design jargon, this is called User Experience (UX) and usability. User Experience entails all impressions and experiences that website visitors come across on a website. What is more, usability is part of the User Experience, as it determines how user-friendly a website is. This includes the clear structuring of content, subpages or products, along with how quickly and easily the website enables you to find what you are looking for. In order to offer you the best possible experience on our website, we also use so-called third-party web design tools. Therefore, all tools and services that help improve our website’s design are classified under the category “web design”. This may, for example, include fonts, various plugins or other integrated web design functions.

 

Why do we use web design tools?

The way you absorb information on a website depends very much on its structure, functionality and visual perception. Therefore, good and professional web design has become increasingly important for us. We are constantly working on improving our site as a way of further extending our services for you as a website visitor. Furthermore, a beautiful and functioning website also has economic advantages for us. Needless to say, you will only visit it and take advantage of our offers if you feel completely at ease.

 

What data is stored by web design tools?

When you visit our website, any web design elements integrated into our pages may process your data. The exact data that is processed depends on the tools used. Below you can see exactly which tools we use for our website. For more information about data processing, we recommend you also read the respective privacy policy of the respective tools. There you can usually find out which data is processed, whether cookies are used and how long the data is stored. Moreover, fonts such as Google Fonts, for example, also automatically transmit information such as your language settings, IP address, browser version, browser screen resolution and browser name to Google’s servers.

 

Duration of data processing

Data processing times are very individual and depend on the web design elements used. For example, when cookies are used, the retention period can be as little as a minute, but it may also be a few years. Please make yourself familiar with this topic. You may for example read our general section on cookies as well as the Privacy Policies of the tools used. There you can likely find out exactly which cookies are used and what information is stored there. For example, Google Font files are stored for one year, in order to improve the loading speed of a website. In principle, data is only kept for as long as is necessary to provide the service. But legal requirements may require data to be stored for longer.

 

Right to object

You also retain the right and the option to revoke your consent to the use of cookies or third-party providers at any time. You can do this either via our cookie management tool or via other opt-out functions. You can also prevent cookies from collecting your data by managing, deactivating or deleting the cookies in your browser. However, among web design elements (typically fonts) there

 

is also data that cannot be erased easily. This is the case whenever data is automatically collected as soon as a page is accessed and then directly transmitted to a third party (e.g. Google). In these cases, please contact the support of the respective provider. In the case of Google, you can reach support at https://support.google.com/?hl=de.

Legal Basis

If you have consented to the use of web design tools, this consent serves as the legal basis for the relevant data processing. According to Article 6 (1) (a) GDPR (consent), your consent represents the legal basis for the processing of personal data, as it may occur when it is collected by web design tools. We also have a legitimate interest in web design to improve on our website. After all, only then can we provide you with a beautiful and professional web offer. The corresponding legal basis for this is Article 6 (1) (f) GDPR (legitimate interests). However, we strongly want to emphasise once more that we only use web design tools if you have given your consent.

You can find information on different web design tools – if available – in the following sections.

 

Google Fonts Local Privacy Policy

On our website we use Google Fonts, by the company Google Inc. The responsible entity for the European area is Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland). We have integrated Google fonts locally, i.e. on our web server and not on Google’s servers. This means that no connection to Google’s servers and therefore no data transfer or retention take place.

What are Google Fonts?

Google Fonts was previously called Google Web Fonts. It is an interactive list with over 800 fonts which Google offer for free use. With the use of Google Fonts, it is possible to utilise fonts without uploading them to your own server. In order to prevent any transfer of information to Google’s servers, we downloaded the fonts to our own server. This way we can comply with data privacy and do not transmit any data to Google Fonts.

Closing Remarks

Congratulations! If you are reading these lines, you have most likely familiarised yourself with our entire Privacy Policy – or at least scrolled down here. As you can see from the scope of our Privacy Policy, we do not take the protection of your personal data lightly.

We find it important to inform you about the processing of your personal data to the best of our abilities. In doing so, we not only want to tell you which data is processed but also explain to you why we use various software programs. In general, Privacy Policies have very technical and legal jargon. However, since most of you are not web developers or solicitors, we wanted to take a different approach and explain the facts in simple and clear language. Of course, this is not always possible due to the subject matter. Therefore, you can also find a more detailed explanation of the most important terms at the end of the Privacy Policy.

If you have any questions about data protection on our website, please do not hesitate to contact us or the responsible body. We wish you all the best and hope to soon welcome you to our website