PRIVACY STATEMENT

Due to legal reasons, the privacy statement is currently only available in German.

Introduction

With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer").

Stand: 14. October 2019

Responsible

Sabrina Siemons
SABRINA - Your personal language consultant
Piazza Fie' di Sopra 7
39050 Fie' allo Sciliar
Italia

Email: info@wheelchair-tours.org
Imprint: https://www.wheelchair-tours.org/impressum/

Overview of processing

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

Types of data processed

  • Inventory data (names, addresses, etc.).
  • Content data (text input, photographs, videos).
  • Contact information (email, phone numbers).
  • Meta/communication data (device information, IP addresses).
  • Usage data (web pages visited, interest in content, access times).
  • Contract data (subject matter of the contract, term, customer category).
  • Payment data (bank details, invoices, payment history).

Categories of persons concerned

  • Employees (employees, applicants, former employees).
  • Business and Contractual Partners.
  • Interested parties.
  • Communication partner.
  • Customers.
  • Users (website visitors, users of online services).

Purposes of the processing

  • Affiliate Tracking.
  • Provision of our online offer and user friendliness.
  • Visit Action Evaluation.
  • Office and organizational procedures.
  • Direct marketing (by e-mail or post).
  • Feedback (collecting feedback, e.g. via form).
  • Interest-based and behavioral marketing.
  • Contact requests and communication.
  • Conversion measurement (measurement of the effectiveness of marketing measures).
  • Profiling (creating profiles of users).
  • Remarketing.
  • Reach measurement (access statistics, recognition of returning visitors).
  • Security Measures.
  • Tracking (interest/behavioural profiling, cookies).
  • Contractual performance and service.
  • Managing and responding to requests.

Relevant legal bases

In the following, we share the legal basis of the General Data Protection Regulation (GDPR) on the basis of which we process personal data. Please note that in addition to the regulations of the GDPR, the national data protection regulations in your or our country of residence and domicile may apply.

  • Consent (Art. 6 para. 1 p. 1 lit. a DSGVO) - The data subject has given his/her consent to the processing of personal data relating to him/her for one or more specific purposes.
  • Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO) - The processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the request of the data subject.
  • Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO) - The processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Protection of vital interests (Art. 6 para. 1 p. 1 lit. d. DSGVO) - The processing is necessary in order to protect the vital interests of the data subject or of another natural person.
  • Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO) - Processing is necessary for the purposes of the legitimate interests of the controller or of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regimes in GermanyIn addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, the processing for other purposes and the transmission as well as automated decision-making in individual cases including profiling. Furthermore, it regulates data processing for employment purposes (Section 26 BDSG), in particular with regard to the establishment, performance or termination of employment relationships as well as the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

Security measures

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

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as the access, input, transfer, safeguarding of availability and its separation. We also have procedures in place to ensure the exercise of data subject rights, deletion of data and response to data compromise. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.

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

Transmission and disclosure of personal data

In the course of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organisational units or persons or that it is disclosed to them. The recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.

Data processing in third countries

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

Subject to express consent or contractually or legally required transfer, we only process or allow data to be processed in third countries with a recognised level of data protection, which includes US processors certified under the "Privacy Shield", or on the basis of special guarantees, such as contractual obligation through so-called standard protection clauses of the EU Commission or the existence of certifications.

use of cookies

Cookies" are small files that are stored on the user's device. Within the cookies, different information can be stored. The information can include, for example, the language settings on a website, the login status, a shopping cart or where a video was watched.

Cookies are also generally used when a user's interests or behaviour (e.g. viewing certain content, using functions, etc.) are stored in a user profile via individual websites. These profiles are used, for example, to display ads to users that match their potential interests. This process is also referred to as "tracking", i.e. tracking the potential interests of users. The term cookies also includes other technologies that perform the same functions as cookies (e.g., when users' details are stored using pseudonymous online identifiers, also known as "user IDs").

Insofar as we use cookies or "tracking" technologies, we will inform you about this in our data protection declaration.

Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for the processing of your data is your declared consent. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g., in the business operation of our online offer and its improvement) or if the use of cookies is necessary to fulfil our contractual obligations.

Revocation and objection (opt-out): Regardless of whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent given or to object to the processing of your data by cookie technologies (collectively referred to as "opt-out").

You can initially declare your objection by means of your browser settings, e.g. by deactivating the use of cookies (whereby this may also restrict the functionality of our online offer).

An objection to the use of cookies for online marketing purposes can be made for a large number of services, especially in the case of tracking, via the US-American site http://www.aboutads.info/choices/ or the EU side http://www.youronlinechoices.com/ or generally on http://optout.aboutads.info can be explained.

You will also receive further information on the possibility to object in the context of the information on the respective processing in this data protection declaration.

Processing of cookie data on the basis of consentBefore we process or have data processed within the scope of the use of cookies, we ask the users for a consent that can be revoked at any time. Before the consent has not been expressed, cookies are used at most, which are necessary for the operation of our online offer. Their use is based on our interest and the interest of users in the expected functionality of our online offer.

  • Types of data processed: Usage data (web pages visited, interest in content, access times), meta/communication data (device information, IP addresses).
  • Persons Concerned: Users (website visitors, users of online services).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f DSGVO).

Commercial and business services

We process data of our contractual and business partners, e.g. customers and of interested parties (collectively referred to as "contractual partners") in the context of contractual and comparable legal relationships as well as related measures and communication with the contractual partners (or pre-contractual), e.g. to answer inquiries.

We process this data to fulfil our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as for business organisation. In this context, we only disclose the data of the contractual partners to third parties within the scope of the applicable law to the extent that this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or with the consent of the contractual partners (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about further processing, e.g. for marketing purposes, within the scope of this data protection declaration.

We inform the contractual partners of the data required for the above-mentioned purposes before or in the course of data collection, e.g. in online forms by means of special marking (e.g. colours), or symbols (e.g. asterisks or similar), or in person.

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

Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms shall apply in the relationship between the users and the providers.

Customer accountContractual partners can create an account within our online offer (e.g., customer or user account, "customer account" for short). If the registration of a customer account is required, contractual partners will be informed of this as well as of the information required for the registration. The customer accounts are not public and cannot be indexed by search engines. Within the scope of registration and subsequent logins and uses of the customer account, we store the IP addresses of the customers together with the access times in order to prove the registration and to be able to prevent any misuse of the customer account.

If customers have terminated their customer account, their data with regard to the customer account will be deleted, subject to their retention being required for legal reasons. It is the responsibility of the customer to back up their data upon termination of the customer account.

Publication activityWe process the data of our contact partners, interview partners and other persons who are the subject of our journalistic, editorial and journalistic and related activities. In this regard, we refer to the validity of protective provisions of freedom of opinion and freedom of the press pursuant to Art. 85 DSGVO in conjunction with the respective national laws. The processing serves us the fulfillment of commissioned activities and takes place otherwise in particular on the basis of the interest of the general public in information and media offers.

  • Types of data processed: Inventory data (names, addresses, etc.), payment data (bank details, invoices, payment history), contact data (e-mail, telephone numbers), contract data (subject matter of contract, term, customer category), usage data (websites visited, interest in content, access times), meta/communication data (device information, IP addresses).
  • Persons Concerned: Interested parties, business and contractual partners, customers.
  • Purposes of processing: Contractual performance and service, contact requests and communication, office and organizational procedures, managing and responding to requests, security measures.
  • Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Payment service provider

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

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

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

  • Types of data processed: Inventory data (names, addresses, etc.), payment data (bank details, invoices, payment history), contractual data (subject matter of contract, term, customer category), usage data (websites visited, interest in content, access times), meta/communication data (device information, IP addresses).
  • Persons Concerned: Customers, prospects.
  • Purposes of processing: Contact requests and communication, affiliate tracking.
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Supplementary notes:

Digistore24

Registration and login

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

Users may be informed of information relevant to their user account, such as technical changes, by e-mail. If users have terminated their user account, their data relating to the user account will be deleted, subject to a legal obligation to retain data. It is the responsibility of the users to save their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract.

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

  • Types of data processed: Inventory data (names, addresses, etc.), contact data (email, phone numbers), content data (text entries, photographs, videos), meta/communication data (device information, IP addresses).
  • Persons Concerned: Users (website visitors, users of online services).
  • Purposes of processing: Contractual performance and service, security measures, administration and response to inquiries.
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data is processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.

Comments and contributionsWhen users leave comments or other contributions, their IP addresses may be stored on the basis of our legitimate interests. This is done for our security in case someone leaves unlawful content in comments and posts (insults, forbidden political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.

Furthermore, we reserve the right, on the basis of our legitimate interests, to process the user's details for the purpose of spam detection.

On the same legal basis, we reserve the right, in the case of surveys, to store the IP addresses of users for their duration and to use cookies in order to avoid multiple votes.

The personal information provided in the context of comments and contributions, any contact and website information as well as the content-related information will be permanently stored by us until the user objects.

Akismet anti-spam checkWe use the service "Akismet" on the basis of our legitimate interests. With the help of Akismet, comments from real people are distinguished from spam comments. For this purpose, all comment details are sent to a server in the USA, where they are analysed and stored for four days for comparison purposes. If a comment has been classified as spam, the data is stored beyond this time. This information includes the name entered, the email address, the IP address, the comment content, the referrer, information on the browser used as well as the computer system and the time of the entry.

Users are welcome to use pseudonyms, or to refrain from entering their name or email address. You can prevent the transmission of data completely by not using our commenting system. That would be a shame, but unfortunately we don't see any alternatives that work just as effectively.

  • Types of data processed: Inventory data (names, addresses, etc.), contact data (e-mail, telephone numbers), content data (text entries, photographs, videos), usage data (web pages visited, interest in content, access times), meta/communication data (device information, IP addresses).
  • Persons Concerned: Users (website visitors, users of online services).
  • Purposes of processing: Contractual performance and service, feedback (collection of feedback, e.g. via form), security measures, administration and response to inquiries.
  • Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO), Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Protection of vital interests (Art. 6 para. 1 p. 1 lit. d. DSGVO).

Services used and service providers:

Contact

When contacting us (e.g. via contact form, email, telephone or via social media), the information of the inquiring persons is processed insofar as this is necessary to answer the contact inquiries and any requested measures.

The answering of contact requests in the context of contractual or pre-contractual relations is carried out for the fulfilment of our contractual obligations or the answering of (pre)contractual requests and, moreover, on the basis of the legitimate interests in answering the requests.

  • Types of data processed: Inventory data (names, addresses, etc.), contact data (e-mail, telephone numbers), content data (text entries, photographs, videos).
  • Persons Concerned: Communication partner.
  • Purposes of processing: Contact requests and communication.
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Surveys and interviews

The surveys and questionnaires we conduct (hereinafter "surveys") are evaluated anonymously. Personal data is only processed insofar as this is necessary for the provision and technical implementation of the survey (e.g. processing of the IP address in order to display the survey in the user's browser or to enable a resumption of the survey with the aid of a temporary cookie (session cookie)) or users have consented to this.

Notes on legal bases: Where we ask participants to consent to the processing of their data, this is the legal basis for the processing, otherwise the processing of participants' data is based on our legitimate interests in conducting an objective survey.

  • Types of data processed: Contact data (e-mail, telephone numbers), content data (text entries, photographs, videos), usage data (web pages visited, interest in content, access times), meta/communication data (device information, IP addresses).
  • Persons Concerned: Communication partner.
  • Purposes of processing: Contact enquiries and communication, direct marketing (by e-mail or post).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f DSGVO).

Services used and service providers:

  • SurveyMonkey: SurveyMonkey Survey Services; Service Provider: SurveyMonkey Europe UC, 2nd Florr, 2 Shelbourne Buildings, Shelbourne Road, Dublin, Ireland.Website: https://www.surveymonkey.de/; Privacy Policy: https://www.surveymonkey.de/mp/legal/privacy-basics/

Provision of the online offer and web hosting

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

The data processed within the scope of the provision of the hosting offer may include all information relating to the users of our online offer, which accrue within the scope of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers and all entries made within our online offer or from websites.

Email sending and hostingThe web hosting services we use also include the sending, receiving and storing of e-mails. For these purposes, the addresses of the recipients and senders, as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of identifying SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted during transport, but not on the servers from which they are sent and received (unless a so-called end-to-end encryption procedure is used). We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.

  • Types of data processed: Content data (text input, photographs, videos), usage data (web pages visited, interest in content, access times), meta/communication data (device information, IP addresses).
  • Persons Concerned: Users (website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Cloud services

We use software services accessible via the Internet and running on the servers of their providers (so-called "cloud services", also referred to as "software as a service") for the following purposes: document storage and management, calendar management, sending e-mails, spreadsheets and presentations, exchanging documents, content and information with specific recipients or publishing web pages, forms or other content and information, as well as chats and participation in audio and video conferences.

In this context, personal data may be processed and stored on the servers of the providers, insofar as these are part of communication processes with us or are otherwise processed by us as set out in the context of this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents. The cloud service providers also process usage data and metadata used by them for security purposes and service optimization.

Insofar as we use cloud services to provide documents and content to other users or publicly accessible websites, forms or the like, the providers may store cookies on users' devices for the purposes of web analytics or to remember users' settings (e.g. in the case of media control).

Notes on legal bases: Insofar as we ask for consent to use the cloud services, the legal basis for processing data for online marketing purposes is consent. Furthermore, their use may be a component of our (pre)contractual services, provided that the use of the cloud services has been agreed within this framework. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient and secure management and collaboration processes.).

  • Types of data processed: Inventory data (names, addresses, etc.), contact data (e-mail, telephone numbers), content data (text entries, photographs, videos), usage data (web pages visited, interest in content, access times), meta/communication data (device information, IP addresses).
  • Persons Concerned: Customers, employees (employees, applicants, former employees), interested parties, communication partners.
  • Purposes of processing: Office and organizational procedures.

Newsletter and broad communication

We send newsletters, e-mails and other electronic notifications (hereinafter "newsletter") only with the consent of the recipients or a legal permission. Insofar as the contents of the newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. Otherwise, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient if you provide your e-mail address. However, we may ask you to provide a name in order to address you personally in the newsletter or to provide further details if these are required for the purposes of the newsletter.

Double opt-in procedure: The registration for our newsletter is always carried out in a so-called double opt-in process. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other email addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address. Changes to your data stored with the shipping service provider are also logged.

cancellation and restriction of processing: We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove consent previously given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a blacklist for this purpose alone.

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Notes on legal bases: Newsletters are sent on the basis of the recipients' consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and insofar as this is permitted by law, e.g. in the case of existing customer advertising. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests in order to prove that it has been carried out in accordance with the law.

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

  • Types of data processed: Inventory data (names, addresses, etc.), contact data (e-mail, telephone numbers), meta/communication data (device information, IP addresses), usage data (websites visited, interest in content, access times).
  • Persons Concerned: Communication partner.
  • Purposes of processing: Direct marketing (by e-mail or post).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f DSGVO).
  • Possibility of objection (Opt-Out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the above contact options, preferably e-mail, for this purpose.

Services used and service providers:

Web analysis and optimization

The web analysis (also referred to as "reach measurement"), serves to evaluate the visitor flows of our online offer and may include their behavior, interests or demographic information, such as age or gender as pseudonymous values. With the help of the range analysis, we can recognize, for example, at what time our online offer or its functions or contents are most frequently used or invite re-use, as well as which areas require optimization.

In addition to web analysis, we may also use testing procedures, e.g. to test and optimize different versions of our online offer or its components.

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

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

Notes on legal bases: If we ask users for their consent (e.g. in the context of a so-called "cookie banner consent"), the legal basis for processing data for online marketing purposes is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer. In this regard, we refer to the note on the use of cookies in this privacy policy.

  • Persons Concerned: Users (website visitors, users of online services).
  • Purposes of processing: Reach measurement (access statistics, recognition of returning visitors), tracking (interest/behaviour-related profiling, cookies), visit action evaluation, profiling (creating profiles of users).
  • Security Measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f DSGVO).

Online Marketing

We process personal data for online marketing purposes, including but not limited to the display of promotional and other content (collectively, "Content") based on users' potential interests and measuring its effectiveness.

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

The IP addresses of the users are also stored. However, we use existing IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that we, as well as the providers of the online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles.

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

Exceptionally, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing procedures we use and the network links the profiles of the users in the aforementioned data. We ask you to note that users can make additional agreements with the providers, e.g. by giving their consent as part of the registration process.

In principle, we only receive access to summarised information about the success of our advertisements. However, within the framework of so-called conversion measurement, we can check which of our online marketing methods have led to a so-called conversion, i.e. e.g. to a conclusion of a contract with us. The conversion measurement is used solely to analyse the success of our marketing measures.

Notes on legal bases: If we ask users for their consent (e.g. in the context of a so-called "cookie banner consent"), the legal basis for processing data for online marketing purposes is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer. We refer to the note on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (web pages visited, interest in content, access times), meta/communication data (device information, IP addresses).
  • Persons Concerned: Users (website visitors, users of online services), interested parties.
  • Purposes of processing: Tracking (interest/behavioural profiling, cookies), remarketing, visit action evaluation, interest-based and behavioural marketing, profiling (creating profiles of users), conversion measurement (measuring the effectiveness of marketing measures), reach measurement (access statistics, recognition of returning visitors).
  • Security Measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f DSGVO).
  • Possibility of objection (Opt-Out): We refer to the data protection notices of the respective providers and the objection options given for the providers (so-called "opt-out"). If no explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for the respective areas: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. (c) USA: https://www.aboutads.info/choices. d) Cross-territorial: http://optout.aboutads.info.

Services used and service providers:

Presence in social networks

We maintain online presences within social networks in order to communicate with users active there or to offer information about us there.

We would like to point out that user data may be processed outside the European Union. This may result in risks for the users, because, for example, the enforcement of the rights of the users could be made more difficult. With regard to US providers that are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we point out that they thereby undertake to comply with the data protection standards of the EU.

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

For a detailed description of the respective processing and the possibilities of objection (opt-out), we refer to the respective data protection declarations and information of the operators of the respective networks.

Also in the case of information requests and the assertion of data subject rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, you can contact us.

  • Types of data processed: Inventory data (names, addresses, etc.), contact data (e-mail, telephone numbers), content data (text entries, photographs, videos), usage data (web pages visited, interest in content, access times), meta/communication data (device information, IP addresses).
  • Persons Concerned: Users (website visitors, users of online services).
  • Purposes of processing: Contact requests and communication, tracking (interest/behavioural profiling, cookies), remarketing, reach measurement (access statistics, recognition of returning visitors).
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

Plugins and embedded functions and content

We integrate functional and content elements within our online offer that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These can be, for example, graphics, videos or social media buttons and posts (hereinafter uniformly referred to as "content").

The integration always requires that the third-party providers of this content process the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is therefore required for the presentation of this content or function. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be combined with such information from other sources.

Notes on legal bases: If we ask users for their consent (e.g. in the context of a so-called "cookie banner consent"), the legal basis for processing data for online marketing purposes is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer. We refer to the note on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (web pages visited, interest in content, access times), meta/communication data (device information, IP addresses).
  • Persons Concerned: Users (website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness, contractual performance and service.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

Planning, organization and auxiliary tools

We use services, platforms and software from other providers (hereinafter referred to as "third-party providers") for the purposes of organizing, managing, planning and providing our services. When selecting third-party providers and their services, we observe the legal requirements.

In this context, personal data may be processed and stored on the servers of the third-party providers. This may include various data that we process in accordance with this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents.

If users are referred to the third-party providers or their software or platforms in the course of communication, business or other relationships with us, the third-party providers may process usage data and metadata, which may be processed by them for security purposes, service optimization or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data for online marketing purposes is consent. Furthermore, their use may be a component of our (pre)contractual services, provided that the use of the third-party providers has been agreed within this framework. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services.).

  • Types of data processed: Inventory data (names, addresses, etc.), contact data (e-mail, telephone numbers), content data (text entries, photographs, videos), usage data (web pages visited, interest in content, access times), meta/communication data (device information, IP addresses).
  • Persons Concerned: Communication partners, users (website visitors, users of online services).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose).

If the data are not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.

Further information on the deletion of personal data can also be found in the individual data protection notices of this data protection declaration.

Changes and updates to the privacy policy

We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

Rights of data subjects

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to revoke any consent you have given at any time.
  • Right to Information: You have the right to obtain confirmation as to whether or not personal data in question is being processed and to obtain information on such data and a copy thereof in accordance with the law.
  • Right of rectification: In accordance with the law, you have the right to request that data concerning you be completed or that inaccurate data concerning you be corrected.
  • Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that the data concerned be deleted immediately or, alternatively, to demand restriction of the processing of the data in accordance with the statutory provisions.
  • Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements, or to demand that it be transferred to another responsible party.
  • Complaint to supervisory authority: You also have the right, in accordance with the law, to lodge a complaint with the competent supervisory authority.

Definitions

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

  • Affiliate Tracking: Affiliate tracking logs links that the linking websites use to direct users to websites with product or other offers. The operators of the respective linking websites can receive a commission if users follow these so-called affiliate links and subsequently take advantage of the offers (e.g. buy goods or use services). For this purpose, it is necessary for the providers to be able to track whether users who are interested in certain offers subsequently take advantage of them at the instigation of the affiliate links. It is therefore necessary for the functionality of affiliate links that they are supplemented by certain values that become part of the link or are stored elsewhere, e.g. in a cookie. The values include in particular the source website (referrer), time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as tracking-specific values such as, for example, advertising material ID, partner ID and categorizations.
  • Visit Action Evaluation: "Conversion tracking" is a method of determining the effectiveness of marketing efforts. For this purpose, a cookie is usually stored on the devices of the users within the websites on which the marketing measures take place and then retrieved again on the target website (e.g. we can thus track whether the ads we have placed on other websites were successful).
  • IP Masking: IP masking" is the term used to describe a method in which the last octet, i.e. the last two numbers of an IP address, are deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing methods, especially in online marketing.
  • Interest-based and behavioral marketing: Interest-based and/or behaviour-based marketing is when the potential interest of users in advertisements and other content is determined as precisely as possible. This is done on the basis of information about their previous behaviour (e.g. visiting and staying on certain websites, buying behaviour or interaction with other users), which is stored in a so-called profile. Cookies are generally used for these purposes.
  • Conversion measurement: Conversion measurement is a method that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users' devices within the websites on which the marketing measures take place and then retrieved again on the target website (e.g. we can thus track whether the ads we have placed on other websites were successful).
  • Profiling: Profiling" is any form of automated processing of personal data consisting of the use of such personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information relating to age, gender, location data and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Range Measurement : Reach measurement (also referred to as web analytics) is used to evaluate the flow of visitors to an online offering and can include visitors' behavior or interests in certain information, such as website content. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This allows them, for example, to better optimize the content of the website to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Remarketing: We speak of "remarketing" or "retargeting" when, for example, it is noted for advertising purposes which products a user was interested in on a website, in order to remind the user of these products on other websites, e.g. in advertisements.
  • Tracking: Tracking" is when the behaviour of users can be traced across several online services. As a rule, behavioural and interest information relating to the online services used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that presumably correspond to their interests.
  • Processing: "Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually any handling of data, be it collection, analysis, storage, transmission or deletion.

Created with Datenschutz-Generator.de by Dr. jur. Thomas Schwenke

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As you may have noticed, we are currently in the process of translating our website and adding more languages. Since this is technically somewhat complex, not all pages are currently available in all languages or only in one language. Translation by an AI (artificial intelligence) is available. 

Due to the installation of the translation technology in the website, some formatting has unfortunately broken. We try to restore these as soon as possible. 

Thank you for your understanding!