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Data protection

Introduction

With the following data protection declaration, we would like to inform you about which types of your personal data (hereinafter also referred to as "data") we process for which purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both within the framework 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").

The terms used are not gender specific.

As of January 14, 2022

Table of Contents

 

  • Introduction

  • Responsible

  • Overview of processing

  • Relevant legal bases

  • Safety measures

  • Transmission of personal data

  • Data processing in third countries

  • Deletion of data

  • Use of cookies

  • Business Achievements

  • Use of online platforms for offer and sales purposes

  • payment procedure

  • Provision of the online offer and web hosting

  • Registration, login and user account

  • Contact and request management

  • Communication via Messenger

  • Cloud services

  • Newsletters and electronic notifications

  • Web analysis, monitoring and optimization

  • Online marketing

  • Presence in social networks (social media)

  • Change and update of the privacy policy

  • Rights of data subjects

  • Definitions of terms

 

Responsible

kroot GmbH
Hochfeldstrasse9
86159 Augsburg

Email address: 

info@kroot.de

Overview of processing

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

Types of data processed

  • Inventory data.

  • Payment details.

  • Contact details.

  • Content data.

  • Contract data.

  • Usage data.

  • Meta/Communication Data.

  • Applicant data.

  • Contact information (Facebook).

  • Event Data (Facebook).

 

Categories of data subjects

  • Customers.

  • Employees.

  • Interested persons.

  • Communication partner.

  • User.

  • Applicant.

  • Business and contractual partners.

 

Purposes of processing

  • Provision of contractual services and customer service.

  • Contact Requests and Communication.

  • Safety measures.

  • Direct marketing.

  • Range measurement.

  • Office and organizational procedures.

  • Remarketing.

  • Conversion measurement.

  • Target group building.

  • Management and response to inquiries.

  • Feedback.

  • Marketing.

  • Profiles with user-related information.

  • Target group building.

  • Provision of our online offer and user-friendliness.

 

Relevant legal bases

Below you will find an overview of the legal bases of the GDPR, on the basis of which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If more specific legal bases are relevant in individual cases, we will inform you of them in the data protection declaration.

 

  • Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR) - The person concerned has given their consent to the processing of their personal data for a specific purpose or several specific purposes.

  • Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. DSGVO) - The processing is necessary for the fulfillment of a contract to which the data subject is a party, or for the implementation of pre-contractual measures, which are required at the request of the data subject take place.

  • Legal obligation (Art. 6 Para. 1 S. 1 lit. c. GDPR) - The processing is necessary to fulfill a legal obligation to which the person responsible is subject.

  • Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR) - Processing is necessary to safeguard the legitimate interests of the person responsible or a third party, unless the interests or fundamental rights and freedoms of the data subject, which protect personal Data require prevail.

In addition to the data protection regulations of the General Data Protection Regulation, national data protection regulations apply in Germany. This includes in particular the law on the 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, processing for other purposes and transmission as well as automated decision-making in individual cases including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (§ 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

 

Safety measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons to ensure a level of protection appropriate to the risk.

The measures include, in particular, securing the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, disclosure, securing availability and their separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to data threats. Furthermore, we already take the protection of personal data into account during the development or 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): In order 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 line of your browser.

Transmission of personal data

As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons or that it is disclosed to them. The recipients of this data can include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such a case, we observe the legal requirements and, in particular, conclude appropriate 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 within the framework of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies takes place, this is only done in accordance with the legal requirements. 

Subject to express consent or contractually or legally required transmission, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, if there are certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as your consent to processing is revoked or other permissions are no longer applicable (e.g. if the purpose of processing this data no longer applies or it is not required for the purpose).

If the data is not deleted because it is required for other, legally permissible purposes, its processing will be limited to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.

As part of our data protection information, we can provide users with further information on the deletion and storage of data that applies specifically to the respective processing.

Use of cookies

Cookies are small text files or other memory notes that store information on end devices and read information from the end devices. For example, to save the login status in a user account, the content of a shopping cart in an e-shop, the content accessed or the functions used in an online offer. Cookies can also be used for various purposes, e.g. for the purpose of functionality, security and comfort of online offers as well as the creation of analyzes of visitor flows. 

Notes on consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, except where not required by law. In particular, consent is not necessary if the storage and reading of the information, including cookies, is absolutely necessary in order to provide the users with a telemedia service (i.e. our online offer) that they have expressly requested. The revocable consent is clearly communicated to the users and contains the information on the respective cookie use.

Notes on the legal basis for data protection: The legal basis under data protection law on which we process the personal data of users with the help of cookies depends on whether we ask users for their consent. If the users consent, the legal basis for the processing of your data is the declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offer and improving its usability) or, if this is done in the context of fulfilling our contractual obligations, if the use of cookies is necessary to enable our to fulfill contractual obligations. We will explain the purposes for which we process cookies in the course of this data protection declaration or as part of our consent and processing processes.

Storage period: With regard to the storage period, the following types of cookies are distinguished:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his end device (e.g. browser or mobile application).

  • Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the user data collected with the help of cookies can be used to measure reach. Unless we provide users with explicit information on the type and storage period of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and the storage period can be up to two years.

 

General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also object to the processing in accordance with the legal requirements in Art. 21 DSGVO (further information on the objection is provided in this data protection declaration). Users can also declare their objection using the settings in their browser.

Further information on processing processes, procedures and services:

  • Processing of cookie data on the basis of consent: We use a cookie consent management procedure, in the context of which the user consents to the use of cookies or the processing mentioned in the context of the cookie consent management procedure and providers can be obtained and managed and revoked by the users. The declaration of consent is stored here so that the query does not have to be repeated and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies) in order to be able to assign the consent to a user or his device. Subject to individual information about the providers of cookie management services, the following information applies: The duration of the storage of the consent can be up to two years. A pseudonymous user identifier is created and stored with the time of the consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) and the browser, system and end device used.

 

Business Achievements

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

We process this data to fulfill our contractual obligations. This includes in particular the obligations to provide the agreed services, any updating obligations and remedy in the case of warranty and other service disruptions. In addition, we process the data to protect our rights and for the purpose of the administrative tasks associated with these obligations and the corporate organization. In addition, we process the data on the basis of our legitimate interests in proper and economical business management and security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. to involve telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of the applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.

We inform the contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special markings (e.g. colours) or symbols (e.g. asterisks or similar), or personally.

We delete the data after statutory warranty and comparable obligations have expired, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. for as long as it has to be kept for legal archiving reasons (e.g. for tax purposes usually 10 years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications of the order, generally 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 apply in the relationship between the users and the providers. 

Customer account

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

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

Economic analysis and market research

For business reasons and in order to be able to identify market trends, the wishes of contractual partners and users, we analyze the data we have on business transactions, contracts, inquiries, etc., whereby the group of persons concerned includes contractual partners, interested parties, customers, visitors and users of our online offer can fall.

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

Contact form for job applicants

Instead of linking to their job portal, our customers can use our contact form for inquiries from job seekers. Job applicants can leave their personal data. This data is stored on our servers. The data includes email address, name (first and last name) and telephone number of the job seeker and is made available to the customer who placed the relevant job advertisement.

Recruitment services

As part of our services, which include in particular the search for potential job candidates, contacting them and their placement, we process the data of the job candidates and the personal data of the potential employers or their employees.

We process the information and contact details provided by the job candidate for the purpose of establishing, implementing and, if necessary, terminating a contract for the placement of a job. In addition, we can ask interested parties questions about the success of our brokerage service at a later point in time, in accordance with legal requirements.

We process the data of the job candidates as well as the employers to fulfill our contractual obligations in order to be able to process the requests made to us for the placement of jobs to the satisfaction of the parties involved.

We can log the mediation processes in order to be able to prove the existence of the contractual relationship and the consent of the interested parties in accordance with the statutory accountability obligations (Art. 5 Para. 2 DSGVO). This information will be retained for a period of three to four years in the event that we need to provide evidence of the original request (e.g. to be able to prove authorization to contact the job candidate).

  • Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); Contact information (e.g. email, phone numbers); Contract data (e.g. subject of the contract, term, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses); Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, curriculum vitae, certificates and other information about a specific position or voluntarily provided by applicants about their person or qualifications) .

  • Affected persons: customers; Interested persons; business and contractual partners; applicant.

  • Purposes of processing: provision of contractual services and customer service; Safety measures; contact requests and communication; office and organizational procedures; managing and responding to inquiries; Conversion measurement (measurement of the effectiveness of marketing measures); Profiles with user-related information (creating user profiles).

  • Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR); Legal obligation (Art. 6 Para. 1 S. 1 lit. c. GDPR).

 

Use of online platforms for offer and sales purposes

We offer our services on online platforms operated by other service providers. In this context, the data protection notices of the respective platforms apply in addition to our data protection notices. This applies in particular with regard to the execution of the payment process and the methods used on the platforms for measuring reach and for interest-based marketing.

  • Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); Contact information (e.g. email, phone numbers); Contract data (e.g. subject of the contract, term, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses); Contact information (Facebook) ("Contact information" is data that (clearly) identifies data subjects, such as names, e-mail addresses and telephone numbers, sent to Facebook, e.g. via Facebook pixel or upload for matching purposes can be transmitted for the purpose of forming custom audiences; after the comparison for the purpose of forming target groups, the contact information will be deleted); Event data (Facebook) ("Event data" is data that can be transmitted by us to Facebook, e.g. via Facebook pixels (via apps or other means) and relates to people or their actions; Data includes, for example, information about visits to websites, interactions with content, functions, installation of apps, purchases of products, etc. The event data is processed in order to form target groups for content and advertising information (custom audiences); event data do not contain the actual content (such as comments written), no login information and no contact information (i.e. no names, e-mail addresses and telephone numbers).Event data will be deleted by Facebook after a maximum of two years formed target groups with the deletion of our Facebook account).

  • Data Subjects: Customers.

  • Purposes of processing: Provision of contractual services and customer service.

  • Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

 

Further information on processing processes, procedures and services:

  • Facebook jobs: job search and application-related services within the Facebook platform; Service Provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; site:https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Standard contractual clauses (ensuring the level of data protection when processing in third countries):https://www.facebook.com/legal/EU_data_transfer_addendum; Order processing contract:https://www.facebook.com/legal/terms/dataprocessing.

  • Facebook advertisements: placement of advertisements within the Facebook platform and evaluation of the ad results; Service Provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Standard contractual clauses (guarantee of data protection when processing in third countries): The "Facebook-EU data transmission supplement" (https://www.facebook.com/legal/EU_data_transfer_addendum) in the case of order processing by Facebook as the basis for processing event data from EU citizens in the USA and inclusion in the "Facebook Platform Terms of Use" (https://developers.facebook.com/terms) with regard to the independent processing of event data by Facebook in the context of ad placement; Possibility of objection (opt-out): We refer primarily to the data protection and advertising settings in the profile of the user on the Facebook platform as well as within the framework of Facebook's consent procedure and Facebook's contact options for the exercise of information and other data subject rights in Facebook's data protection declaration; Further information: The "Data Processing Conditions" (https://www.facebook.com/legal/terms/dataprocessing/update) with regard to event data that Facebook processes on behalf of companies to provide reports and analysis;  Furthermore, the "addendum for those responsible" applies as an agreement on joint responsibility (Art. 26 Para. 1 S. 3 GDPR), which applies in the case of the self-responsible processing of event data by Facebook for targeting purposes and improving and securing the Facebook Products.

  • TikTok: social network / video platform; Service Provider: musical.ly Inc., 10351 Santa Monica Blvd #310, Los Angeles, CA 90025 USA; Website: https://www.tiktok.com; Privacy Policy: https://www.tiktok.com/de/privacy-policy.

 

Payment procedure

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

The data processed by the payment service provider includes inventory data such as name and address, bank details such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered will only be processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, only information with confirmation or negative information about the payment. Under certain circumstances, the payment service provider may transmit the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. For this we refer to the terms and conditions and the data protection information of the payment service provider.

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

  • Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); Contract data (e.g. subject of the contract, term, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).

  • Affected persons: customers; Interested persons.

  • Purposes of processing: Provision of contractual services and customer service.

  • Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

 

Further information on processing processes, procedures and services:

 

Provision of the online offer and web hosting

In order to be able 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 as part of the provision of the hosting offer may include all information relating to the users of our online offer that arises in the context of use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or on websites.

  • Types of data processed: content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).

  • Affected persons: users (e.g. website visitors, users of online services).

  • Purposes of processing: Provision of our online offer and user-friendliness.

  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

 

Further information on processing processes, procedures and services:

  • Collection of access data and log files: We ourselves (or our web hosting provider) collect data for every access to the server (so-called server log files). The address and name of the retrieved websites and files, date and time of retrieval, amounts of data transferred, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP Addresses and the requesting provider belong. The server log files can be used for security purposes, e.g. to avoid overloading the server (especially in the case of abusive attacks, so-called DDoS attacks) and on the other hand to reduce the load on the server and ensure their stability; Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or made anonymous. Data whose further storage is required for evidence purposes are excluded from deletion until the respective incident has been finally clarified.

 

Registration, login and user account

Users can create a user account. As part of the registration, the users are informed of the required mandatory information and processed for the purpose of providing the user account on the basis of contractual fulfillment of obligations. The processed data includes in particular the login information (user name, password and an e-mail address).

When using our registration and login functions and when using the user account, we store the IP address and the time of the respective user action. The storage takes place on the basis of our legitimate interests as well as those of the users in protection against misuse and other unauthorized use. In principle, this data will not be passed on to third parties, unless it is necessary to pursue our claims or there is a legal obligation to do so.

Users can be informed by email about processes that are relevant to their user account, such as technical changes.

  • Types of data processed: Inventory data (e.g. names, addresses); Contact information (e.g. email, phone numbers); Content data (e.g. entries in online forms); Meta/communication data (e.g. device information, IP addresses).

  • Affected persons: users (e.g. website visitors, users of online services).

  • Purposes of processing: provision of contractual services and customer service; Safety measures; Management and response to inquiries.

  • Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

 

Further information on processing operations, procedures and services:

  • Deletion of data after termination: If users have terminated their user account, their data with regard to the user account will be deleted, subject to a legal permission, obligation or consent of the user.

  • No storage obligation for data: It is the user's responsibility to back up 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 contract period.

 

Contact and request management

When contacting us (e.g. via contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the details of the requesting person are processed to the extent necessary to answer the contact request and any requested measures.

The answering of contact inquiries as well as the administration of contact and inquiry data within the framework of contractual or pre-contractual relationships takes place to fulfill our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of the legitimate interests in answering the inquiries and maintenance of User or Business Relationships.

  • Types of data processed: Inventory data (e.g. names, addresses); Contact information (e.g. email, phone numbers); Content data (e.g. entries in online forms).

  • Affected persons: communication partners.

  • Purposes of processing: contact requests and communication.

  • Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

 

Communication via Messenger

We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messenger, on encryption, on the use of the metadata of the communication and on your options to object.

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

In the case of end-to-end encryption of content (ie the content of your message and attachments), please note that the communication content (ie the content of the message and attached images) is encrypted from end-to-end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messenger with activated encryption to ensure that the message content is encrypted.

However, we also point out to our communication partners that the providers of the messengers cannot see the content, but can find out that and when communication partners communicate with us as well as technical information on the device used by the communication partner and, depending on the settings of their device, also location information ( so-called metadata) are processed.

Notes on the legal basis:  If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for your consent and you contact us, for example, we use Messenger in relation to our contractual partners and in the context of contract initiation as a contractual measure and in the case of other interested parties and communication partners on the basis of our legitimate interests in fast and efficient communication and fulfillment of the needs of our communication partners in communication via messenger. We would also like to point out that we will not transmit the contact data you have given us to Messenger for the first time without your consent.

Revocation, objection and deletion: You can revoke your consent at any time and 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 deletion guidelines (ie, as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information from the communication partner, if no reference to a previous conversation is to be expected and the deletion does not conflict with any statutory retention requirements.

Reservation of the reference to other communication channels: Finally, we would like to point out that for reasons of your security we reserve the right not to answer inquiries via Messenger. This is the case, for example, when internal contract details require particular secrecy or an answer via messenger does not meet the formal requirements. In such cases, we will refer you to more appropriate communication channels.

  • Types of data processed: contact details (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. entries in online forms).

  • Affected persons: communication partners.

  • Purposes of processing: contact requests and communication; Direct marketing (e.g. by e-mail or post).

  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

 

Further information on processing processes, procedures and services:

 

Cloud services

We use software services that are accessible via the Internet and run on the servers of their providers (so-called "cloud services", also referred to as "software as a service") for the following purposes: Processed data types: Inventory data (e.g. names, addresses); Contact information (e.g. email, phone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).

  • Affected persons: customers; employees (e.g. employees, applicants, former employees); Interested persons; communication partner.

  • Purposes of processing: office and organizational procedures.

  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

 

Further information on processing processes, procedures and services:

 

Newsletters and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter "newsletters") only with the consent of the recipient or legal permission. If the content of the newsletter is specifically described when registering for it, it is decisive for the consent of the user. Our newsletter also contains information about our services and us.

In order to register for our newsletters, it is generally sufficient if you enter your e-mail address. However, we may ask you to provide a name so that we can address you personally in the newsletter, or other information if this is necessary for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registration you will receive an e-mail in which you will be asked to confirm your registration. This confirmation is necessary so that nobody can register with someone else's e-mail address. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider are also logged.

Deletion and restriction of processing:   We can store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time. In the case of obligations to permanently observe contradictions, we reserve the right to store the e-mail address in a blacklist (so-called "blocklist") solely for this purpose.

The registration process is logged on the basis of our legitimate interests for the purpose of proving that it was carried out properly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure shipping system.

Notes on the legal basis: The newsletter is sent on the basis of the consent of the recipient or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of advertising for existing customers. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in efficient and secure delivery. The registration process is recorded on the basis of our legitimate interests to demonstrate that it has been carried out in accordance with the law.

 

Content:

 

Information about us, our services, promotions and offers.

  • Types of data processed: Inventory data (e.g. names, addresses); Contact information (e.g. email, phone numbers); Meta/communication data (e.g. device information, IP addresses); Usage data (e.g. websites visited, interest in content, access times).

  • Affected persons: communication partners.

  • Purposes of processing: direct marketing (e.g. by e-mail or post).

  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

  • Possibility of objection (opt-out): You can cancel the receipt of our newsletter at any time, ie 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 use one of the contact options given above, preferably e-mail.

 

Further information on processing processes, procedures and services:

  • Measurement of opening and click rates for newsletters and system and transactional e-mails: The e-mails we send contain a so-called "web beacon", ie a pixel-sized file that is sent by our server when the e-mail is opened , or, if we use a shipping service provider, from whose server is retrieved. In the context of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, is collected.This information is used for the technical improvement of our e-mail dispatch based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the access times.This analysis also includes determining whether the e-mails have been opened when they are opened and which links are clicked.This information is assigned to the individual e-mail recipients and in their profile stored until they are deleted. The evaluations help us to recognize the reading habits of our users and to adapt our content and processes to the needs of our users. The measurement of the opening rates and click rates as well as the storage of the measurement results in the user profiles and their further processing are based on the consent of the users, or if we do not obtain consent, in order to fulfill our contractual obligations to provide an efficient and secure user experience to our existing customers.

  • Mailchimp: email sending and email marketing platform; Service Provider: Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Website: https://mailchimp.com; Data protection:https://mailchimp.com/legal/; Standard contractual clauses (guaranteeing the level of data protection when processing in third countries): part of the order processing contract; Order processing contract:https://mailchimp.com/legal/; More information: Special security measures: https://mailchimp.com/help/Mailchimp-european-data-transfers/.

​Web analysis, monitoring and optimization

The web analysis (also referred to as "reach measurement") serves to evaluate the flow of visitors to our online offer and can include behavior, interests or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of the range analysis, we can, for example, identify at what time our online offer or its functions or content are used most frequently or invite people to use them again. We can also understand which areas need optimization. 

In addition to web analysis, we can also use test procedures, for example to test and optimize different versions of our online offering or its components.

Unless otherwise stated below, profiles, ie data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and read from it. The information collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used and information on usage times. If users have given their consent to us or the providers of the services we use to collect their location data, location data can also be processed.

The IP addresses of the users are also saved. However, we use an IP masking process (ie pseudonymization by shortening the IP address) to protect users. In general, no clear user data (e.g. e-mail addresses or names) are stored in the context of web analysis, A/B testing and optimization, but pseudonyms. This means that we and 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 process.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed on the basis of our legitimate interests (ie interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.

  • Types of data processed: usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).

  • Affected persons: users (e.g. website visitors, users of online services).

  • Purposes of processing: range measurement (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (creating user profiles).

  • Security measures: IP masking (pseudonymization of the IP address).

  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

 

Further information on processing processes, procedures and services:

 

Online marketing

We process personal data for online marketing purposes, which may include in particular the marketing of advertising space or the presentation 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 processes are used, by means of which the information about the user relevant to the presentation of the aforementioned content is stored. This information can include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times and functions used. If users have consented to the collection of their location data, this can also be processed.

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

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

As an exception, 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 process we use and the network connects the user's profile with the aforementioned information. We kindly ask you to note that users can make additional agreements with the providers, e.g. by giving their consent during registration.

In principle, we only receive access to summarized information about the success of our advertisements. However, we can use so-called conversion measurements to check which of our online marketing processes have led to a so-called conversion, ie, to a contract with us, for example. The conversion measurement is only used to analyze the success of our marketing measures.

Unless otherwise stated, please assume that cookies used will be stored for a period of two years.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed on the basis of our legitimate interests (ie interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.

  • Types of data processed: Event data (Facebook) ("Event data" is data that can be transmitted from us to Facebook via Facebook pixels (via apps or other means) and relates to people or their actions The data includes, for example, information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc. The event data is processed in order to form target groups for content and advertising information (custom audiences). ; Event data does not contain the actual content (such as comments written), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data will be deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).

  • Affected persons: users (e.g. website visitors, users of online services).

  • Purposes of processing: remarketing; Conversion measurement (measurement of the effectiveness of marketing measures); target group formation; Target group formation (determination of target groups relevant for marketing purposes or other output of content); Marketing; Profiles with user-related information (creating user profiles).

  • Security measures: IP masking (pseudonymization of the IP address).

  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

  • Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the possibilities of objection specified for the providers (so-called "opt-out"). If no explicit opt-out option has been specified, you can turn off cookies in your browser settings. However, this can limit the functions of our online offer. We therefore also recommend the following 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-territory: https://optout.aboutads.info.

 

Further information on processing processes, procedures and services:

  • Facebook pixel and target group formation (custom audiences): With the help of the Facebook pixel (or comparable functions, for the transmission of event data or contact information via interfaces in apps), it is possible for Facebook to determine the visitors to our online offer as a target group for the display of advertisements (so-called "Facebook Ads"). Accordingly, we use the Facebook pixel so that the Facebook ads we have placed are only available to users on Facebook and within the services of the partners cooperating with Facebook (so-called "Audience Network" https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products that are evident from the websites visited) that we transmit to Facebook ( so-called "custom audiences"). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interests of users and are not annoying. With the help of the Facebook pixel, we can also use the Facebook pixel to measure the effectiveness of the Facebook ads for understand statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called "conversion measurement"); Service Provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Standard contractual clauses (guarantee of data protection when processing in third countries): The "Facebook-EU data transmission supplement" (https://www.facebook.com/legal/EU_data_transfer_addendum) in the case of order processing by Facebook as the basis for processing event data from EU citizens in the USA and inclusion in the "Facebook Platform Terms of Use" (https://developers.facebook.com/terms) with regard to the independent processing of event data by Facebook in the context of ad placement; Further information: The "Data Processing Conditions" (https://www.facebook.com/legal/terms/dataprocessing/update) with regard to event data that Facebook processes on behalf of companies to provide reports and analysis;  Furthermore, the "addendum for those responsible" applies as an agreement on joint responsibility (Art. 26 Para. 1 S. 3 GDPR), which applies in the case of the self-responsible processing of event data by Facebook for targeting purposes and improving and securing the Facebook Products.

  • Google Ads and conversion measurement: We use the online marketing process "Google Ads" to place ads on the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads (so-called "conversion"). We also measure the conversion of the ads. However, we only find out the anonymous total number of users who clicked on our ad and were forwarded to a page with a so-called "conversion tracking tag". However, we do not receive any information that could be used to identify users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; site:https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; More information: Types of processing and processed data: https://privacy.google.com/businesses/adsservices; Data Processing Terms for Google Advertising Products: Information on Serviceshttps://business.safety.google/adscontrollerterms.

  • Outbrain: display of personalized advertisements; Service Provider: Outbrain Inc, 39 West 13th Street, 3rd floor, New York, NY 10011, USA; Website: https://www.outbrain.com; Privacy Policy: https://www.outbrain.com/legal/privacy; Standard contractual clauses (ensuring the level of data protection when processing in third countries): use in contracts with Outbrain service providers; Deletion of data: The stored personal data will be deleted or made anonymous after 13 months.

 

Presence in social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.

We would like to point out that user data can be processed outside of the European Union. This can result in risks for the user, because it could make it more difficult to enforce the users' rights, for example.

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

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

Also in the case of requests for information and the assertion of data subject rights, we would like to 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 take appropriate measures and provide information directly. If you still need help, you can contact us.

  • Types of data processed: contact details (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).

  • Affected persons: users (e.g. website visitors, users of online services).

  • Purposes of processing: contact requests and communication; Feedback (e.g. collecting feedback via online form); Marketing.

  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

 

Further information on processing processes, procedures and services:

 

Change and update of the privacy policy

We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as the changes in the data processing we carry out 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 data protection declaration, please note that the addresses can change over time and ask you to check the information before contacting us.

 

Rights of data subjects

As a data subject, you have various rights under the GDPR, which result in particular from Art. 15 to 21 GDPR:

  • Right of objection: You have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data, which is based on Article 6 Paragraph 1 lit. e or f GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed in order to operate direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct advertising.

  • Right of withdrawal for consent: You have the right to withdraw your consent at any time.

  • Right to information: You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with legal requirements.

  • Right to rectification: In accordance with legal requirements, you have the right to request the completion of the data concerning you or the correction of incorrect data concerning you.

  • Right to deletion and restriction of processing: You have the right, in accordance with the legal requirements, to request that data concerning you be deleted immediately, or alternatively to request a restriction of the processing of the data in accordance with the legal requirements.

  • Right to data portability: You have the right to receive the data that you have provided to us in accordance with the legal requirements in a structured, common and machine-readable format or to request that it be transmitted to another person responsible.

  • Complaint to supervisory authority: In accordance with the legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State in which you usually reside, the supervisory authority your place of work or the place of the alleged infringement to lodge a complaint if you consider that the processing of your personal data infringes the GDPR.

 

Definitions of terms

This section provides you with an overview of the terms used in this data protection declaration. Many of the terms are taken from the law and defined above all in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended primarily for understanding. The terms are sorted alphabetically.

 

  • Conversion measurement: The conversion measurement (also known as "visit action evaluation") is a method with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the user's device within the website on which the marketing measures take place and then called up again on the target website. For example, we can use this to understand whether the ads we placed on other websites were successful. 

  • Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special features, expressing the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. 

  • Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any type of automated processing of personal data, which consists of using this personal data to determine certain personal aspects relating to a natural person (depending on the type of profiling, different information regarding demographics, behavior and interests, such as interaction with websites and their content, etc.) can be analyzed, evaluated or predicted (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are commonly used for profiling purposes. 

  • Range measurement: The range measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offer and can include the behavior or interests of visitors in certain information, such as website content. With the help of the range analysis, website owners can, for example, see at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for range analysis purposes in order to recognize returning visitors and thus obtain more precise analyzes of the use of an online offer. 

  • Remarketing: We speak of "remarketing" or "retargeting" when, for advertising purposes, for example, it is noted 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.  

  • Responsible: The "responsible person" is the natural or legal person, authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data. 

  • Processing: "Processing" is any process or series of processes carried out with or without the aid of automated processes in connection with personal data. The term goes far and covers practically every handling of data, be it collection, evaluation, storage, transmission or deletion. 

  • Target group formation: One speaks of target group formation (or "custom audiences") when target groups are determined for advertising purposes, e.g. display of advertisements. For example, based on the interest of a user in certain products or topics on the Internet, it can be concluded that this user is for advertisements for similar products or the online shop in which he viewed the products. One speaks of "lookalike audiences" (or similar target groups) when the content assessed as suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. For the purpose of creating custom audiences and lookalike audiences, cookies and web beacons are usually used. 

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