Preamble

With the following privacy policy we would like to inform you which types of your personal data (hereinafter also abbreviated as ” data”) we process for which purposes and in which scope. The privacy statement applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online services”).

The terms used are not gender-specific.

Last Update: 26. February 2020

Table of contents

Controller

Jane Di Renzo
Türrschmidtstr. 35
10317 Berlin
Germany

E-mail address: contact@sulit.eu

Legal Notice: https://www.sulit.eu/about/code-of-conduct/

Overview of processing operations

The following table summarises the types of data processed, the purposes for which they are processed and the concerned data subjects.

Categories of Processed Data

  • Inventory data (e.g. names, addresses).
  • Content data (e.g. text input, photographs, videos).
  • Contact data (e.g. e-mail, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Location data (Data that indicates the location of the end device of an end user).
  • Contract data (e.g. contract object, duration, customer category).
  • Payment Data (e.g. bank details, invoices, payment history).

Special Categories of Data

  • Data revealing racial or ethnic origin.

Categories of Data Subjects

  • Business and contractual partners.
  • Prospective customers.
  • Communication partner (Recipients of e-mails, letters, etc.).
  • Customers.
  • Users (e.g. website visitors, users of online services).

Purposes of Processing

  • Provision of our online services and usability.
  • Conversion Tracking.
  • Office and organisational procedures.
  • Cross-Device Tracking (Device-independent processing of user data for marketing purposes).
  • Direct marketing (e.g. by e-mail or postal).
  • Feedback (e.g. collecting feedback via online form).
  • Interest-based and behavioral marketing.
  • contact requests and communication.
  • Conversion tracking (Measurement of the effectiveness of marketing activities).
  • Profiling (Creating user profiles).
  • Remarketing.
  • Web Analytics (e.g. access statistics, recognition of returning visitors).
  • Security measures.
  • Targeting (e.g. profiling based on interests and behaviour, use of cookies).
  • Polls and Questionnaires (e.g. surveys with input options, multiple choice questions).
  • Contractual services and support.
  • Managing and responding to inquiries.
  • Custom Audiences (Selection of relevant target groups for marketing purposes or other output of content).

Legal Bases for the Processing

In the following we inform you about 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 may apply in your country or in our country of residence or domicile. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Article 6 (1) (a) GDPR) – The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  • Performance of a contract and prior requests (Article 6 (1) (b) GDPR) – Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Compliance with a legal obligation (Article 6 (1) (c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Pprotection of vital interests (Article 6 (1) (d) GDPR) – Processing is necessary in order to protect the vital interests of the data subject or of another natural person.
  • Legitimate Interests (Article 6 (1) (f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Security Precautions

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

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, transmission, securing and separation of the data. In addition, we have established procedures to ensure that data subjects’ rights are respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and service providers, in accordance with the principle of privacy by design and privacy by default.

SSL encryption (httpss): In order to protect your data transmitted via our online services in the best possible way, 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 context of our processing of personal data, it may happen that the data is transferred to other places, companies or persons or that it is disclosed to them. Recipients of this data may include, for example, payment institutions within the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are embedded in a website. In such a case, the legal requirements will be respected and in particular corresponding contracts or agreements, which serve the protection of your data, will be concluded with the recipients of your data.

Use of Cookies

Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after his visit within an online service. The information stored can include, for example, the language settings on a website, the login status, a shopping basket or the location where a video was viewed. The term “cookies” also includes other technologies that fulfil the same functions as cookies (e.g. if user information is stored using pseudonymous online identifiers, also referred to as “user IDs”).

The following types and functions of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed his browser.
  • Permanent cookies: Permanent cookies remain stored even after closing the browser. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The interests of users who are used for range measurement or marketing purposes can also be stored in such a cookie.
  • First-Party-Cookies: First-Party-Cookies are set by ourselves.
  • Third party cookies: Third party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential) cookies: Cookies can be necessary for the operation of a website (e.g. to save logins or other user inputs or for security reasons).
  • Statistics, marketing and personalisation cookies: Cookies are also generally used to measure a website’s reach and when a user’s interests or behaviour (e.g. viewing certain content, using functions, etc.) are stored on individual websites in a user profile. Such profiles are used, for example, to display content to users that corresponds to their potential interests. This procedure is also referred to as “tracking”, i.e. tracking the potential interests of users. . If we use cookies or “tracking” technologies, we will inform you separately in our privacy policy or in the context of obtaining consent.

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

General information on Withdrawal of consent and objection (Opt-Out): Respective of whether processing is based on consent or legal permission, you have the option at any time to object to the processing of your data using cookie technologies or to revoke consent (collectively referred to as “opt-out”). You can initially explain your objection using the settings of your browser, e.g. by deactivating the use of cookies (which may also restrict the functionality of our online services). An objection to the use of cookies for online marketing purposes can be raised for a large number of services, especially in the case of tracking, via the websites https://www.aboutads.info/choices/ and https://www.youronlinechoices.com. In addition, you can receive further information on objections in the context of the information on the used service providers and cookies.

Processing Cookie Data on the Basis of Consent: Before we process or have processed data within the context of the usage of cookies, we ask the users for their consent, which can be revoked at any time. Before the consent has not been given, we may use cookies that are necessary for the operation of our online services. Their use is based on our interest and the user’s interest in the expected functionality of our online services.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Commercial Services

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

We process this data in order to fulfil our contractual obligations, safeguard our rights and for the purposes of the administrative tasks associated with this data and the business-related organisation. We will only pass on the data of the contractual partners within the scope of the applicable law to third parties insofar as this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or with the consent of the contractual partners (e.g. 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, as part of this privacy policy.

Which data are necessary for the aforementioned purposes, we inform the contracting partners before or in the context of the data collection, e.g. in on-line forms by special marking (e.g. colors), and/or symbols (e.g. asterisks or the like), or personally.

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

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

Economic Analyses and Market Research: For economic reasons and in order to be able to recognise market trends, wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., whereby the persons concerned may include contractual partners, interested parties, customers, visitors and users of our online service.

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

Online Shop and E-Commerce: We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and related services, as well as their payment and delivery, or performance of other services.

The required details are identified as such in the course of the ordering or comparable purchasing process and include the details required for delivery, or other way of making the product aviable and invoicing as well as contact information in order to be able to hold any consultation.

Agency Services: We process the data of our customers within the scope of our contractual services, which may include e.g. conceptual and strategic consulting, campaign planning, software and design development / consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis / consulting services and training services.

Education and Training Services: We process the data of the participants of our education and training programmes (uniformly referred to as ” students”) in order to provide them with our educational and training services. The data processed, the type, scope and purpose of the processing and the necessity of its processing are determined by the underlying contractual and educational relationship. The processing also includes the performance evaluation and evaluation of our services and the teachers and instructors.

As part of our activities, we may also process special categories of data, in particular information on the health of persons undergoing training or further training and data revealing ethnic origin, political opinions, religious or philosophical convictions. To this end, we obtain, if necessary, the express consent of the students to be trained and further educated and process the special categories of data otherwise only if it is necessary for the provision of training services, for purposes of health care, social protection or protection of vital interests of the students to be trained and further educated.

Insofar as it is necessary for the fulfilment of our contract, for the protection of vital interests or by law, or with the consent of the trainees, we disclose or transfer the data of the students to third parties or agents, e.g. public authorities or in the field of IT, office or comparable services, in compliance with the requirements of professional law.

Coaching: We process the data of our clients and interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to provide them with our services. The data processed, the type, scope and purpose of their processing and the necessity of their processing are determined by the underlying contractual and client relationship.

Within the scope of our services, we may also process special categories of data, here in particular information on the health of clients, possibly with reference to their sexual life or sexual orientation and data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs. To this end, we obtain the express consent of clients where necessary and process the special categories of data otherwise for the purposes of health care, if the data is public or wit an other legal persmission.

Insofar as it is necessary for the fulfilment of our contractual obligations, the protection of vital interests or by law, or with theclients’s consent, we disclose or transfer the clients’s data to third parties or agents, such as public authorities, accounting offices and in the field of IT, office or comparable services, in compliance with professional regulations.

Consulting: We process the data of our clients, clients as well as interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to provide them with our consulting services. The data processed, the type, scope and purpose of the processing and the necessity of its processing are determined by the underlying contractual and client relationship.

Insofar as it is necessary for the fulfilment of our contract, for the protection of vital interests or by law, or with the consent of the client, we disclose or transfer the client’s data to third parties or agents, such as authorities, courts, subcontractors or in the field of IT, office or comparable services, taking into account the professional requirements.

We process the data of our visitors, patrons and interested parties (uniformly referred to as “visitors”) in order to provide the ordered meals and drinks as well as to provide other services and surrenders and to invoice our services.

As part of our assignment it may be necessary for us to process special categories of data within the meaning of Article 9 (1) GDPR, in particular information on the health of a person. The processing takes place in order to protect the health interests of the visitors (e.g. in the case of information on allergies) and otherwise only with the consent of the visitors.

Insofar as it is necessary for the fulfilment of the contract or by law, or if it is consented to by the customer, or if it is based on our legitimate interests, we disclose or transfer the customer’s data, e.g. to the service providers, authorities, accounting offices involved in the fulfilment of our services as well as in the area of IT, office or comparable services.

Artistic and Literary Services: We process the data of our clients in order to enable them to select, acquire or commission the selected services or works and related tasks, as well as their payment and delivery, or execution or provision.

The required details are identified as such within the framework of the conclusion of the order, order or comparable contract and include the details required for delivery and invoicing as well as contact information in order to be able to hold any consultations.

Publishing Activities: We process the data of our contact partners, interviewed persons and other persons who are the subject of our editorial, journalistic and related activities. Here we refer to the validity of protection regulations of freedom of opinion and freedom of the press according to Article 85 GDPR in connection with the respective national laws. The processing serves us the fulfilment of order activities and is otherwise based in particular on the interest of the general public in information and media products.

Events: We process the data of the participants of the events, events and similar activities offered or organized by us (hereinafter uniformly referred to as “participants” and “events”) in order to enable them to participate in the events and to make use of the services or actions associated with their participation.

Insofar as we process health-related data, religious, political or other special categories of data in this context, this is done within the framework of disclosure (e.g. for thematically oriented events or serves health care, security or is done with the consent of the data subjects).

The necessary information is identified as such in the context of the conclusion of the agreement, booking or comparable contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any enquiries. Insofar as we gain access to information of end customers, employees or other persons, we process this in accordance with the legal and contractual requirements.

  • Processed data types: Inventory data (e.g. names, addresses), Payment Data (e.g. bank details, invoices, payment history), Contact data (e.g. e-mail, telephone numbers), Contract data (e.g. contract object, duration, customer category), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
  • Special categories of data: Health Data (Article 9 (1) GDPR), Data related to sexual preferences, sex life, and/or sexual orientation (Article 9 (1) GDPR), Rreligious or philosophical beliefs (Article 9 (1) GDPR), Data revealing racial or ethnic origin.
  • Data subjects: Prospective customers, Business and contractual partners, Customers.
  • Purposes of Processing: Contractual services and support, contact requests and communication, Office and organisational procedures, Managing and responding to inquiries, Conversion Tracking, Interest-based and behavioral marketing, Profiling (Creating user profiles), Security measures.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Payment Service Provider

In addition to banks and credit institutions, we use other payment service providers on the basis of our interests in efficient and secure payment procedures, whose platforms users and we can use to perform payment transactions.

  • Processed data types: Inventory data (e.g. names, addresses), Payment Data (e.g. bank details, invoices, payment history), Contract data (e.g. contract object, duration, customer category), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses), Contact data (e.g. e-mail, telephone numbers).
  • Data subjects: Customers, Prospective customers.
  • Purposes of Processing: Contractual services and support.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Services and service providers being used:

Blogs and publication media

We use blogos or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data will only be processed for the purposes of the publication medium 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 privacy policy.

Comment subscriptions: When users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests. This is done for our safety, if someone leaves illegal contents (insults, forbidden political propaganda, etc.) in comments and contributions. In this case, we ourselves can be prosecuted for the comment or contribution and are therefore interested in the author’s identity.

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

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

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

WordPress emojis and smilies: Within our WordPress blog, graphic emojis (or smilies), i.e. small graphic files that express feelings, that are obtained from external servers, are used for the efficient integration of content elements. Here the providers of the servers collect the IP addresses of the users. This is necessary so that the emoji files can be transmitted to the browsers of the users.

Akismet Anti-Spam Checking: We use the “Akismet” service on the basis of our legitimate interests. With the help of Akismet, comments from real people are distinguished from spam comments. All comments are sent to a server in the USA, where they are analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data will be stored beyond that time. This information includes the name entered, the e-mail address, the IP address, the comment content, the referrer, information about the browser used, 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 completely prevent the transmission of data by not using our comment system. That is a pity, but unfortunately we do not see any alternatives that work just as effectively.

  • Processed data types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Content data (e.g. text input, photographs, videos), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses), Contract data (e.g. contract object, duration, customer category).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of Processing: Contractual services and support, Feedback (e.g. collecting feedback via online form), Security measures, Managing and responding to inquiries.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR), Consent (Article 6 (1) (a) GDPR), Pprotection of vital interests (Article 6 (1) (d) GDPR).

Services and service providers being used:

Contacting us

When contacting us (e.g. by contact form, e-mail, telephone or via social media), the data of the inquiring persons are processed insofar as this is necessary to answer the contact enquiries and any requested activities.

The response to contact enquiries within the framework of contractual or pre-contractual relationships is made in order to fulfil our contractual obligations or to respond to (pre)contractual enquiries and otherwise on the basis of the legitimate interests in responding to the enquiries.

  • Processed data types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Content data (e.g. text input, photographs, videos).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
  • Purposes of Processing: contact requests and communication.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Communication via Messenger

We use Messenger services for communication purposes and therefore ask you to observe the following information regarding the functionality of the Messenger, encryption, use of the metadata of the communication and your objection options.

You can also contact us by alternative means, e.g. telephone or e-mail. Please use the contact options provided to you or use the contact options provided within our online services.

In the case of encryption of content (i.e. the content of your message and attachments), we point out that the communication content (i.e. the content of the message and attachments) is encrypted end-to-end. This means that the content of the messages is not visible, not even by the messenger providers themselves. You should always use a current version of the messenger with activated encryption, so that the encryption of the message contents is guaranteed.

However, we would like to point out to our communication partners that although messenger service providers do not see the content, they can find out that and when communication partners communicate with us and process technical information on the communication partner’s device used and, depending on the settings of their device, also location information (so-called metadata).

Information on Legal basis: If we ask communication partners for permission before communicating with them via Messenger, the legal basis of our processing of their data is their consent. Otherwise, if we do not request consent and you contact us, for example, voluntarily, we use Messenger in our dealings with our contractual partners and as part of the contract initiation process as a contractual measure and in the case of other interested parties and communication partners on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners for communication via messengers. We would also like to point out that we do not transmit the contact data provided to us to the messenger service providers for the first time without your consent.

Withdrawal, objection and deletion: You can withdraw your consent or object to communication with us via Messenger at any time.In the case of communication via messenger, we delete the messages in accordance with our general data retention policy (i.e. as described above after the end of contractual relationships, archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information provided by the communication partners, if no reference to a previous conversation is to be expected and there are no legal obligations to store the messages to prevent their deletion.

Reservation of reference to other means of communication: Finally, we would like to point out that we reserve the right, for reasons of your safety, not to answer inquiries about Messenger. This is the case if, for example, internal contractual matters require special secrecy or if an answer via the messenger does not meet the formal requirements. In such cases we refer you to more appropriate communication channels.

Skype: The end-to-end encryption of Skype requires its activation (unless it is enabled by default).

  • Processed data types: Contact data (e.g. e-mail, telephone numbers), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses), Content data (e.g. text input, photographs, videos).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
  • Purposes of Processing: contact requests and communication, Direct marketing (e.g. by e-mail or postal).
  • Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Services and service providers being used:

Online Conferences, Meetings and Webinars

We use third-party platforms and applications (hereinafter referred to as “third party providers”) for the purposes of conducting video and audio conferences, webinars and other types of video and audio meetings. When selecting third-party providers and their services, we observe the legal requirements.

In this context, data of the communication participants will be processed and stored on the servers of third parties, as far as these are part of communication processes with us. This data may include, but is not limited to, registration and contact details, visual and voice contributions, chat entries and shared screen content.

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

Information on legal basis: If we ask the users for their consent to the use of third party providers, the legal basis of the processing is consent. Furthermore, the processing can be a component of our (pre)contractual services, provided that the use of the third party was agreed within this context. Otherwise, user data will be processed on the basis of our legitimate interest in efficient and secure communication with our communication partners. In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Processed data types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Content data (e.g. text input, photographs, videos), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.), Users (e.g. website visitors, users of online services).
  • Purposes of Processing: Contractual services and support, contact requests and communication, Office and organisational procedures.
  • Legal Basis: Consent (Article 6 (1) (a) GDPR), Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Services and service providers being used:

Surveys and Questionnaires

The surveys and questionnaires (“surveys”) carried out by us are evaluated anonymously. Personal data is only processed insofar as this is necessary for the provision and technical execution of the survey (e.g. processing the IP address 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 participants have consented.

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

  • Processed data types: Contact data (e.g. e-mail, telephone numbers), Content data (e.g. text input, photographs, videos), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.), Users (e.g. website visitors, users of online services).
  • Purposes of Processing: contact requests and communication, Direct marketing (e.g. by e-mail or postal), Targeting (e.g. profiling based on interests and behaviour, use of cookies), Feedback (e.g. collecting feedback via online form), Profiling (Creating user profiles).
  • Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Services and service providers being used:

Provision of online services and web hosting

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

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

Collection of Access Data and Log Files: We, ourselves or our web hosting provider, collect data on the basis of each access to the server (so-called server log files). Server log files may include the address and name of the web pages and files accessed, the date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a general rule, IP addresses and the requesting provider.

The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the stability and optimal load balancing of the servers .

  • Processed data types: Content data (e.g. text input, photographs, videos), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Newsletter and Broadcast Communication

We send newsletters, e-mails and other electronic communications (hereinafter referred to as “newsletters”) only with the consent of the recipient or a legal permission. Insofar as the contents of the newsletter are specifically described within the framework of registration, they are decisive for the consent of the user. Otherwise, our newsletters contain information about our services and us.

In order to subscribe to our newsletters, it is generally sufficient to enter your e-mail address. We may, however, ask you to provide a name for the purpose of contacting you personally in the newsletter or to provide further information if this is required for the purposes of the newsletter.

Double opt-in procedure: The registration to our newsletter takes place in general in a so-called Double-Opt-In procedure. This means that you will receive an e-mail after registration asking you to confirm your registration. This confirmation is necessary so that no one can register with external e-mail 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 storing the login and confirmation times as well as the IP address. Likewise the changes of your data stored with the dispatch service provider are logged.

Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to provide evidence of prior consent. The processing of these data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of a consent is confirmed at the same time. In the case of an obligation to permanently observe an objection, we reserve the right to store the e-mail address solely for this purpose in a blacklist.

Information on legal bases: The sending of the newsletter is based on the consent of the recipients or, if consent is not required, on the basis of our legitimate interests in direct marketing. Insofar as we engage a service provider for sending e-mails, this is done on the basis of our legitimate interests. The registration procedure is recorded on the basis of our legitimate interests for the purpose of demonstrating that it has been conducted in accordance with the law.

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

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

This information is used for the technical improvement of our newsletter on the basis of technical data or target groups and their reading behaviour on the basis of their retrieval points (which can be determined with the help of the IP address) or access times. This analysis also includes determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. It is, however, neither our endeavour nor, if used, that of the shipping service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The evaluation of the newsletter and the measurement of success is carried out, subject to the express consent of the user, on the basis of our legitimate interests for the purposes of using a user-friendly and secure newsletter system which serves both our business interests and the expectations of the user.

A separate objection to the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled or objected to.

  • Processed data types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Meta/communication data (e.g. device information, IP addresses), Usage data (e.g. websites visited, interest in content, access times).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
  • Purposes of Processing: Direct marketing (e.g. by e-mail or postal).
  • Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • 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 contact options listed above, preferably e-mail.

Services and service providers being used:

Web Analysis and Optimization

Web analysis is used to evaluate the visitor traffic on our website and may include the behaviour, interests or demographic information of users, such as age or gender, as pseudonymous values. With the help of web analysis we can e.g. recognize, at which time our online services or their functions or contents are most frequently used or requested for repeatedly, as well as which areas require optimization.

In addition to web analysis, we can also use test procedures, e.g. to test and optimize different versions of our online services or their components.

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

The IP addresses of the users are also stored. However, we use any existing IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect the user. In general, within the framework of web analysis, A/B testing and optimisation, no user data (such as e-mail addresses or names) is 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 processes.

Information on legal basis: If we ask the users for their consent to the use of third party providers, the legal basis of the processing is consent. Furthermore, the processing can be a component of our (pre)contractual services, provided that the use of the third party was agreed within this context. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of Processing: Web Analytics (e.g. access statistics, recognition of returning visitors), Targeting (e.g. profiling based on interests and behaviour, use of cookies), Conversion Tracking, Profiling (Creating user profiles), Interest-based and behavioral marketing.
  • Security measures: IP Masking (Pseudonymization of the IP address).
  • Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Services and service providers being used:

Onlinemarketing

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

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

The IP addresses of the users are also stored. However, we use provided IP masking procedures (i.e. pseudonymisation by shortening the IP address) to ensure the protection of the user’s by using a pseudonym. In general, within the framework of the online marketing process, no clear user data (such as e-mail addresses or names) is secured, but pseudonyms. This means that we, as well as the providers of online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in the cookies or similar memorizing procedures. These cookies can later, generally also on other websites that use the same online marketing technology, be read and analyzed for purposes of content display, as well as supplemented with other data and stored on the server of the online marketing technology 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 technology we use and the network links the profiles of the users in the aforementioned data. Please note that users may enter into additional agreements with the social network providers or other service providers, e.g. by consenting as part of a registration process.

As a matter of principle, we only gain access to summarised information about the performance of our advertisements. However, within the framework of so-called conversion measurement, we can check which of our online marketing processes have led to a so-called conversion, i.e. to the conclusion of a contract with us. The conversion measurement is used alone for the performance analysis of our marketing activities.

Unless otherwise stated, we kindly ask you to consider that cookies used will be stored for a period of two years.

Information on legal basis: 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 this consent. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online services. In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

Facebook Pixel: With the help of the Facebook pixel, Facebook is on the one hand able to determine the visitors of our online services as a target group for the presentation of ads (so-called “Facebook ads”). Accordingly, we use Facebook pixels to display Facebook ads placed by us only to Facebook users and within the services of partners cooperating with Facebook (so-called “audience network” https://www.facebook.com/audiencenetwork/ ) who have shown an interest in our online services or who have certain characteristics (e.g. interests in certain topics or products that are determined on the basis of the websites visited) that we transmit to Facebook (so-called “custom audiences”). With the help of Facebook pixels, we also want to ensure that our Facebook ads correspond to the potential interest of users and do not appear annoying. The Facebook pixel also enables us to track the effectiveness of Facebook ads for statistical and market research purposes by showing whether users were referred to our website after clicking on a Facebook ad (known as “conversion tracking”).

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses), Location data (Data that indicates the location of the end device of an end user).
  • Data subjects: Users (e.g. website visitors, users of online services), Prospective customers.
  • Purposes of Processing: Targeting (e.g. profiling based on interests and behaviour, use of cookies), Remarketing, Conversion Tracking, Interest-based and behavioral marketing, Profiling (Creating user profiles), Conversion tracking (Measurement of the effectiveness of marketing activities), Web Analytics (e.g. access statistics, recognition of returning visitors), Custom Audiences (Selection of relevant target groups for marketing purposes or other output of content), Cross-Device Tracking (Device-independent processing of user data for marketing purposes).
  • Security measures: IP Masking (Pseudonymization of the IP address).
  • Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Opt-Out: We refer to the privacy policies of the respective service providers and the possibilities for objection (so-called \”opt-out\”). If no explicit opt-out option has been specified, it is possible to deactivate cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered collectively for each area:a) Europe: https://www.youronlinechoices.eu.
    b) Canada: https://www.youradchoices.ca/choices.
    c) USA: https://www.aboutads.info/choices.
    d) Cross-regional: https://optout.aboutads.info.

Services and service providers being used:

Profiles in Social Networks

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

We would like to point out that user data may be processed outside the European Union. This may entail risks for users, e.g. by making it more difficult to enforce users’ rights. With regard to US providers certified under the Privacy Shield or offering comparable guarantees of a secure level of data protection, we would like to point out that they thereby commit themselves to comply with EU data protection standards.

In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the associated interests of users. The user profiles can then be used, for example, to place advertisements within and outside the networks which are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer, in which the user’s usage behaviour and interests are stored. Furthermore, data can be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective networs or will become members later on).

For a detailed description of the respective processing operations and the opt-out options, please refer to the respective data protection declarations and information provided by the providers of the respective networks.

Also in the case of requests for information and the exercise of rights of data subjects, we point out that these can be most effectively pursued 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, please do not hesitate to contact us.

  • Processed data types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Content data (e.g. text input, photographs, videos), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of Processing: contact requests and communication, Targeting (e.g. profiling based on interests and behaviour, use of cookies), Remarketing, Web Analytics (e.g. access statistics, recognition of returning visitors).
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Services and service providers being used:

Plugins and embedded functions and content

Within our online services, we integrate functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may, for example, be graphics, videos or social media buttons as well as contributions (hereinafter uniformly referred to as “Content”).

The integration always presupposes that the third-party providers of this content process the IP address of the user, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents or functions. We strive to use only those contents, whose respective offerers use the IP address only for the distribution of the contents. Third parties may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring websites, visit times and other information about the use of our website, as well as may be linked to such information from other sources.

Information on legal basis: If we ask users for their consent (e.g. in the context of a so-called “cookie banner consent”), the legal basis for processing is this consent. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online services. We refer you to the note on the use of cookies in this privacy policy.

Integration of third-party software, scripts or frameworks: We incorporate into our online services software which we retrieve from servers of other providers (e.g. function libraries which we use for the purpose of displaying or user-friendliness of our online services). The respective providers collect the user’s IP address and can process it for the purposes of transferring the software to the user’s browser as well as for security purposes and for the evaluation and optimisation of their services.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses), Contact data (e.g. e-mail, telephone numbers), Content data (e.g. text input, photographs, videos), Inventory data (e.g. names, addresses).
  • Data subjects: Users (e.g. website visitors, users of online services), Communication partner (Recipients of e-mails, letters, etc.).
  • Purposes of Processing: Provision of our online services and usability, Contractual services and support, contact requests and communication, Direct marketing (e.g. by e-mail or postal), Targeting (e.g. profiling based on interests and behaviour, use of cookies), Interest-based and behavioral marketing, Profiling (Creating user profiles), Security measures, Managing and responding to inquiries.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR), Consent (Article 6 (1) (a) GDPR), Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Services and service providers being used:

Planning, Organization and Utilities

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

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

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

Information on legal basis: If we ask the users for their consent to the use of third party providers, the legal basis of the processing is consent. Furthermore, the processing can be a component of our (pre)contractual services, provided that the use of the third party was agreed within this context. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Processed data types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Content data (e.g. text input, photographs, videos), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.), Users (e.g. website visitors, users of online services).
  • Purposes of Processing: Web Analytics (e.g. access statistics, recognition of returning visitors), Targeting (e.g. profiling based on interests and behaviour, use of cookies), Profiling (Creating user profiles), Office and organisational procedures, contact requests and communication, Managing and responding to inquiries, Feedback (e.g. collecting feedback via online form), Polls and Questionnaires (e.g. surveys with input options, multiple choice questions), Custom Audiences (Selection of relevant target groups for marketing purposes or other output of content).
  • Legal Basis: Consent (Article 6 (1) (a) GDPR), Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Services and service providers being used:

Changes and Updates to the Privacy Policy

We kindly ask you to inform yourself regularly about the contents of our data protection declaration. We will adjust the privacy policy as changes in our data processing practices make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, we ask you to note that addresses may change over time and to verify the information before contacting us.

Terminology and Definitions

This section provides an overview of the terms used in this privacy policy. Many of the terms are drawn from the law and defined mainly in Article 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended above all for the purpose of comprehension. The terms are sorted alphabetically.

  • Controller: “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Conversion Tracking: “Conversion Tracking” refers to a procedure by which the effectiveness of marketing measures can be determined. As a rule, a cookie is stored on the devices of the users within the websites on which the marketing measures are carried out and then called up again on the target website (e.g. this enables us to track whether the ads we placed on other websites were successful).
  • Conversion tracking: Conversion tracking is a method used to evaluate the effectiveness of marketing measures. 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 called up again on the target website (e.g. we can thus trace whether the advertisements placed by us on other websites were successful).
  • Cross-Device Tracking: Cross-Device Tracking is a form of tracking in which behavior and interest information of the user is recorded across all devices in so-called profiles by assigning an online identifier to the user. This means that user information can usually be analysed for marketing purposes, regardless of the browser or device used (e.g. mobile phone or desktop computer). With most Cross-Device Tracking providers, the online identifier is not linked to plain data such as names, postal addresses or e-mail addresses.
  • Custom Audiences: Target group formation (or “custom audiences”) is the term used when target groups are determined for advertising purposes, e.g. display of advertisements. For example, a user’s interest in certain products or topics on the Internet may be used to infer that that user is interested in advertisements for similar products or the online store in which they viewed the products. Lookalike Audiences” (or similar target groups) is the term used to describe content that is viewed as suitable by users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies are generally used for the purposes of creating custom audiences and lookalike audiences. Target groups can be created by processing visitors of an online service or can be uploaded to the provider of an online marketing technology by means of uploading (which is usually done pseudonymised).
  • IP Masking: IP masking is a method by which the last octet, i.e. the last two numbers of an IP address, are deleted so that the IP address alone can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymising processing methods, particularly in online marketing.
  • Interest-based and behavioral marketing: Interest-related and/or behaviour-related marketing is the term used when potential user interest in advertisements and other content is predicted if possible. This is done on the basis of information on the previous behaviour of users (e.g. visiting and staying on certain websites, purchasing behaviour or interaction with other users), which is stored in a so-called profile. For these purposes cookies are usually used.
  • Personal Data: “personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Processing: The term “processing” covers a wide range and practically every handling of data, be it collection, evaluation, storage, transmission or erasure.
  • Profiling: “Profiling” means any automated processing of personal data consisting in 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 includes information regarding age, gender, location and movement data, interaction with websites and their contents, shopping behaviour, social interactions with other people) (e.g. interests in certain contents or products, click behaviour on a website or the location). Cookies and web beacons are often used for profiling purposes.
  • Remarketing: Remarketing” or “retargeting” is the term used, for example, to indicate for advertising purposes which products a user is interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Targeting: Tracking” is the term used when the behaviour of users can be traced across several websites. As a rule, behavior and interest information with regard to the websites used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users presumably corresponding to their interests.
  • Web Analytics: Web Analytics serves the evaluation of visitor traffic of online services and can determine their behavior or interests in certain information, such as content of websites. With the help of web analytics, website owners, for example, can recognize at what time visitors visit their website and what content they are interested in. This allows them, for example, to optimize the content of the website to better meet the needs of their visitors. For purposes of web analytics, pseudonymous cookies and web beacons are frequently used in order to recognise returning visitors and thus obtain more precise analyses of the use of an online service.

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