General Privacy Policy
The protection of your data is very important to us. We only process data on a legally compliant basis and consider it our duty to protect your data from any misuse. We use your data only for purposes to which you have authorized us.
Table of Contents
1. Objective and responsible body
2. Basic information on data processing
3. Processing of personal data
4. Collection of access data
5. Cookies & reach measurement
6. Google Analytics
7. Google Re-/Marketing Services
8. Facebook social plugins
9. Facebook remarketing
10. Newsletter
11. Integration of services and content of third parties
12. User rights and deletion
13. Changes to the privacy policy
1. Objective and responsible body
This Privacy Policy clarifies the nature, scope and purpose of the processing (including collection, processing, use and consent) of personal information contained in our online offering and the related websites, features and content (collectively referred to as “online offer” or “Website”). The privacy policy applies regardless of the domains, systems, platforms, and devices (such as desktop or mobile) on which the online offering is being run.
Provider of the online offer and responsible for the data protection law is [company_name], owner: [company_owner], [adress_street], [adress_zip_location] (hereinafter referred to as “provider”, “we” or “us”). For the contact possibilities we refer to our imprint.
The term “user” includes all customers and visitors of our online offer. The terms used, such as “Users” are to be understood gender-neutral.
2. Basic information on data processing
We only process users’ personal data in compliance with the relevant data protection regulations in accordance with the requirements of data minimization and purpose limitation (see Processing Principles: EU GDPR Article 5). This means that the data of the users are processed only in the presence of a legal permit or obligation, for the fulfillment of contractual obligations (which are necessary, for example, for the provision of the services offered) or in the presence of your consent.
We take organizational, contractual and technical security measures in accordance with the state of the art to ensure that the provisions of the data protection laws are complied with and in order to protect the data processed by us against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons.
Insofar as data transmission to third parties is necessary for the fulfillment of legal requirements, the fulfillment of the services to be provided within the framework of contractual obligations or on the basis of your explicit consent, we always ensure that this is done safely and in accordance with data protection regulations and in accordance with EU GDPR Article 5.
(Webshop, if applicable): A transfer of data to third parties does not take place, with the exception of the transmission of credit card data to the involved bank institutes / payment service providers for the purpose of debiting the purchase price, to the transport company / shipping company commissioned by us for the delivery of the goods as well as to our tax consultant Fulfillment of our tax obligations.
3. Processing of personal data
The personal data are, in addition to the use expressly mentioned in this privacy policy, processed for the following purposes on the basis of statutory requirements, to fulfill the contract or your express consent:
– The provision, execution, maintenance, optimization and security of our services, services and user services;
– Ensuring effective customer service and technical support.
Insofar as data transmission to third parties is necessary for the fulfillment of legal requirements, the fulfillment of the services to be provided within the framework of contractual obligations or on the basis of your express consent, we always ensure that this is done safely and in accordance with data protection regulations in accordance with EU GDPR Article 5.
(Webshop, if applicable): A transfer of data to third parties does not take place, with the exception of the transmission of credit card data to the involved bank institutes / payment service providers for the purpose of debiting the purchase price, to the transport company / shipping company commissioned by us for the delivery of the goods as well as to our tax consultant Fulfillment of our tax obligations.
When contacting us (via contact form or e-mail), the details of the user are stored for the purpose of processing the request as well as in the event that follow-up questions arise.
Personal data will be deleted if they have fulfilled their purpose and deletion does not conflict with any retention requirements.
4. Collection of access data
We collect data about every access to the server where this service is located (so-called server log files). The access data includes name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
We use the log data without linking it to the specific person of a user or other profiling according to the statutory provisions only for statistical evaluations for the purpose of operation, security and optimization of our online offer. However, we reserve the right to retrospectively check the log data if, on the basis of concrete evidence, the legitimate suspicion of unlawful use exists.
5. Cookies & reach measurement
Cookies are information transmitted from our web server or third-party web servers to users’ web browsers and are stored there for later retrieval. The use of cookies in the context of pseudonymous range measurement is described in this privacy policy.
The usage of this online offer is also possible with the exclusion of cookies. If users do not want cookies stored on their computer, they are asked to disable the option in their browser’s system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
There is a possibility to manage many companies’ online advertising cookies via the US website http://www.aboutads.info/choices or the EU page http://www.youronlinechoices.com/uk/your-ad-choices/.
6. Google Analytics
We use Google Analytics, a web analytics service provided by Google Ireland Ltd. (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by the users are usually transmitted to a Google server in the USA and stored there.
Google will use this information on our behalf to evaluate the use of our online offering by users, to compile reports on the activities within this online offering and to provide us with other services related to the use of this online offer and internet usage. In this case, pseudonymous usage profiles of the users can be created from the processed data.
We only use Google Analytics with activated IP anonymization. This means that the IP address of users will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases the full IP address will be sent to a Google server in the US and shortened there.
The IP address submitted by the user’s browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; users may also prevent data collection by Google of data which is generated by the cookie and related to their use of the online offer as well as the processing of such data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
For more information about Google’s use of data, settings and opt-out options, please visit Google’s websites: https://www.google.com/intl/en/policies/privacy/partners (“Google’s use of your data when you use websites or our partners’ apps “), http://www.google.com/policies/technologies/ads (” Use of data for promotional purposes “), http://www.google.com/settings/ads (” Managing information provided by Google used to show you ads “) and http://www.google.com/ads/preferences (” Determine which ads Google shows you “).
7. Google Re-/Marketing Services
We use the Google Ireland Ltd. Marketing and Remarketing Services (“Google Marketing Services”), Gordon House, 4 Barrow St,Dublin, D04 E5W5, Ireland, (“Google”).
Google Marketing Services allows us to better target advertisements for and on our website so that we only present ads to users that potentially match their interests. E.g.: It is called remarketing if users are also shown ads for products they are interested in on other websites.
For these purposes, when Google and our other websites that are running Google Marketing Services are activated, Google runs a code and so-called (re) marketing tags (invisible graphics or code, etc., also named web beacon) are added and incorporated into the website. With their help, the user is provided with an individual cookie, viz. a small file is saved (instead of cookies, comparable technologies can also be used).
The cookies can be set by different domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. In this file it is noted which web pages users visited, what content they are interested in and what offers they have clicked, as well as technical information about the browser and operating system, referring web pages, visit time and other information about the use of the online offer.
The IP address of the users is also recorded, whereby in the context of Google Analytics the IP address is shortened within member states of the European Union or other contracting states of the Agreement on the European Economic Area. Only in exceptional cases data is transmitted to a Google server in the US and shortened there. The IP address will not be merged with data of the user within other offers from Google. The information mentioned above may also be associated with information from other sources. So that ads according to the interests of the users can be displayed when they visit other websites.
The data of the users are pseudonymised processed in the context of the Google marketing services. That means Google stores and processes e.g. not the name or e-mail address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. From the perspective of Google, the ads are not managed and displayed to a specifically identifiable person, but to the cookie owner, regardless of who that cookie owner is. This does not apply if users have explicitly allowed Google to process their data without this pseudonymization. The information collected about users by “DoubleClick” is transmitted to Google and stored on Google’s servers in the United States.
Among the Google marketing services we use is amongst others the online advertising program “Google AdWords”. In the case of Google AdWords, each advertiser receives a different “conversion cookie”. Cookies cannot be tracked through AdWords advertisers’ websites. The information collected through the cookie is used to generate conversion statistics for AdWords advertisers who have opted for conversion tracking. Advertisers will see the total number of users who clicked on their ad and were redirected to a conversion tracking tag page. However, they do not receive information that personally identifies users.
We embed third-party ads based on Google’s DoubleClick marketing service. DoubleClick uses cookies, which allow Google and its affiliate websites to serve ads based on users’ visits to this site or other sites on the Internet.
We also engage third-party ads based on the Google AdSense marketing service. AdSense uses cookies, which allow Google and its affiliate websites to serve ads based on users’ visits to this site or other sites on the Internet.
Another Google marketing service we use is the Google Tag Manager, which allows additional Google analytics and marketing services to be integrated into our website (e.g. AdWords, DoubleClick, or Google Analytics).
For more information about Google’s data usage for marketing, see their overview page: https://www.google.com/policies/technologies/ads, Google’s Privacy Policy is available at https://www.google.com/policies/privacy.
If you wish to opt-out of Google Marketing Services, you may take advantage of Google’s settings and opt-out options: http://www.google.com/ads/preferences.
8. Facebook social plugins
Our online offering uses social plugins (“plugins”) from the social network facebook.com operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland (“Facebook”). The plugins are recognizable by one of the Facebook logos (white “f” on blue tile, the terms “Like” or a “thumbs up” sign) or are marked with the addition “Facebook Social Plugin”. The list and appearance of Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
When a user invokes a feature of this online offering that includes such a plugin, their device establishes a direct connection to the Facebook servers. The content of the plugin is transmitted by Facebook directly to the device of the user and incorporated into the online offer. In the process, user profiles can be created from the processed data. We therefore have no influence on the amount of data that Facebook collects with the help of this plugin and therefore informs the users according to our knowledge.
By integrating plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to his Facebook account. If users interact with the plugins, for example, press the Like button or leave a comment, the information is transmitted from your device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will find out and save their IP address. According to Facebook, only an anonymous IP address is stored in Germany.
The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the related rights and setting options for protecting the privacy of users, can be found in Facebook’s privacy policy: https://www.facebook.com/about/privacy/.
If a user is a Facebook member and does not want Facebook to collect data about him via this online offer and link it to his member data stored on Facebook, he must log out of Facebook and delete his cookies before using our online offer. Other settings and possible revocations regarding the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US-American site http://www.aboutads.info/choices/ or the EU page http://www.youronlinechoices.com/. The settings are platform independent, which means that they are adopted for all devices, such as desktop computers or mobile devices.
9. Facebook remarketing
Within our on-line offer so-called “Facebook pixels” of the social network Facebook, which are operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland (“Facebook”).
With the help of the Facebook pixel, Facebook is able to designate the visitors of our offer as a target group for the presentation of advertisements, so-called “Facebook Ads”. Accordingly, we use Facebook pixel to display Facebook ads only to those Facebook users who have also shown an interest in our website. In other words, with the help of the Facebook pixel, we want to make sure that our Facebook ads are in line with the potential interest of users and are not annoying. With the help of the Facebook pixel, we can also understand the effectiveness of the Facebook ads for statistical and market research purposes by seeing if users were redirected to our site after clicking on a Facebook ad.
Facebook pixel is directly integrated by Facebook when calling our website and can save a so-called cookie (a small file) on your device.
If you log in to Facebook or visit Facebook in a logged-in state, the visit of our offer is noted in your profile. The data collected about you are anonymous to us, so they do not give us any indications about the identity of the users. However, the data is stored and processed by Facebook, so that a connection to the respective user profile is possible. The processing of the data by Facebook is part of Facebook’s data usage policy. Accordingly, you will learn more about how the remarketing pixel works and more generally about how Facebook ads are displayed in Facebook’s Data Usage Policy: https://www.facebook.com/policy.php.
You may object to the data collection and use of your data by Facebook Pixel to display Facebook Ads. To do this, you can visit the page set up by Facebook and follow the instructions for the usage-based advertising settings: https://www.facebook.com/settings?tab=ads or the contradiction on the US-American site http://www.aboutads.info/choices/ or the EU page http://www.youronlinechoices.com/. The settings are platform independent, that means they are adopted for all devices, such as desktop computers or mobile devices.
10. Newsletter
With the following information, we will explain the contents of our newsletter, the registration, sending and statistical evaluation procedures as well as your right of objection. By subscribing to our newsletter, you agree to the receipt and the procedures described.
Content of the newsletter: We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter “newsletter”) only with the consent of the recipient or a legal permission. Insofar as the contents of a newsletter are concretely described, they are authoritative for the consent of the users. In general our newsletters contain the following information: our products, offers, promotions and our company.
Double opt-in and logging: Registration for our newsletter is done in a so-called double-opt-in procedure. After registration, you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with an invalid or not owned e-mail addresses. The registration for the newsletter will be logged in order to prove the registration process according to the legal requirements. This includes the storage of the login and the confirmation time, as well as the IP address. Likewise, changes to your data stored by the newsletter service provider will be logged.
Newsletter service provider: The newsletter is sent by means of “[newsletter_service]” (hereinafter referred to as “newsletter service provider”). The privacy policy of the newsletter service provider can be found here: [newsletter_service_privacy_policy].
The e-mail addresses of our Newsletter recipients, as well as their other data described in the context of these notes, are stored on the servers of the newsletter service provider. The newsletter service provider uses this information to send and evaluate the newsletter on our behalf.
Furthermore, the newsletter service provider may, according to their information, use this data to optimize or improve its own services, e.g. for the technical optimization of the sending and the presentation of the newsletter or for economic purposes, to determine from which countries the recipients come. However, the newsletter service provider does not use the data of our newsletter recipients to contact them for their purposes or to pass these contacts on to third parties.
Credentials: To subscribe to the newsletter, it is sufficient to provide your e-mail address.
Statistical Survey and Analysis – The newsletters contain a so-called “web-beacon”, a pixel-sized file that is retrieved from the server of the newsletter service provider when the newsletter is opened. This request will initially collect technical information, such as information about the browser and your system, as well as your IP address and time of retrieval. This information is used to improve the technical performance of services based on their specifications or audience and their reading habits, based on their locations (which can be determined using the IP address) or access times.
Statistical surveys also include determining if the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our endeavor nor that of the newsletter 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 accordingly or to send different content according to the interests of our users.
Termination / Revocation – You may terminate the receipt of our newsletter at any time, that means revoking your consent. At the same time, your consent for receiving any emails from the newsletter service provider and the statistical analyzes expire. A separate revocation of receiving emails from the newsletter service provider or the statistical evaluation is unfortunately not possible. A link to cancel the newsletter can be found at the end of each newsletter.
11. Integration of services and content of third parties
It may occur that contents or services of third-party providers, such as maps or fonts from other websites, are included in our online offer. The inclusion of content from third-party providers always requires that third-party providers perceive the IP address of the users, since they could not send the content to the users’ browser without the IP address.
The IP address is therefore required for the presentation of this content. Furthermore, providers of third-party content can set their own cookies and process users’ data for their own purposes. In the process, user profiles can be created from the processed data. We do our best to use this content in a data-saving and data-avoiding manner as far as possible and select reliable third-party providers with regard to data security.
The following presentation provides an overview of third-party providers as well as their contents and links to their privacy statements, with further details on the processing of data and partly revocation possibilities (so-called opt-out):
– External fonts from Google, Inc., https://www.google.com/fonts (“Google Fonts”). The integration of Google fonts is done by a server call on Google (usually in the US). Privacy Policy: https://www.google.com/policies/privacy/, opt-out: https://www.google.com/settings/ads/.
– Maps of the “Google Maps” service provided by the third-party Google Ireland Ltd., Gordon House, 4 Barrow St,Dublin, D04 E5W5, Ireland. Privacy Policy: https://www.google.com/policies/privacy/, opt-out: https://www.google.com/settings/ads/.
– Third-party Google Ireland Ltd.’s YouTube Platforms, Gordon House, 4 Barrow St,Dublin, D04 E5W5, Ireland. Privacy Policy: https://www.google.com/policies/privacy/, opt-out: https://www.google.com/settings/ads/.
12. User rights and deletion
Users have the right, upon request, to receive information free of charge about the personal data that we have stored about them.
In addition, users have the right to correct inaccurate data, revoke consent, block the processing and delete their personal information if justifiable and to file a complaint with the responsible regulatory authority in the event of unlawful processing.
The data stored with us are deleted as soon as they are no longer necessary for their purpose and the deletion does not conflict with any statutory storage requirements.
13. Changes to the privacy policy
We reserve the right to change the privacy policy in order to adapt it to changed legal situations, or to changes in the service and data processing. However, this only applies to declarations of data processing. If users’ consent is required or elements of the privacy policy contain provisions of the contractual relationship with the users, the changes will only be made with the consent of the users.
Users are requested to inform themselves regularly about the content of the privacy policy.
Status: 17.03.2019