With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as „data“) that we process for what purposes and to what extent. This privacy policy applies to all personal data processing carried out by us, both in the context of providing our services and particularly on our websites, in mobile applications, and within external online presences, such as our social media profiles (collectively referred to as the „online offering“).
The terms used are not gender-specific.
Status: August 8, 2024
Table of Contents
- Preamble
- Controller
- Overview of Processing Activities
- Relevant Legal Bases
- Security Measures
- Transmission of Personal Data
- Data Processing in Third Countries
- Deletion of Data
- Use of Cookies
- Business Services
- Payment Procedures
- Provision of Online Offering and Web Hosting
- Registration, Login, and User Account
- Community Features
- Single Sign-On Login
- Contact and Inquiry Management
- Push Notifications
- Newsletter and Electronic Notifications
- Marketing Communication via Email, Post, Fax, or Telephone
- Web Analysis, Monitoring, and Optimization
- Presence in Social Networks (Social Media)
- Plugins and Embedded Functions and Content
- Changes and Updates to the Privacy Policy
- Rights of Data Subjects
- Definitions
Controller
Squadhouse Media GmbH & Co. KG
Ehrenbergstrasse 18
78532 Tuttlingen
datenschutz@sq.de
Authorized Representative:
Matthias Dorn
Email Address:
datenschutz@sq.de
Overview of Processing Activities
The following overview summarizes the types of data processed and the purposes of their processing, as well as references to the affected individuals.
Types of Data Processed:
- Inventory data
- Payment data
- Contact data
- Content data
- Contract data
- Usage data
- Meta, communication, and procedural data
- Event data (Facebook)
Categories of Affected Individuals:
- Customers
- Prospects
- Communication partners
- Users
- Business and contractual partners
Purposes of Processing:
- Provision of contractual services and customer support
- Contact inquiries and communication
- Security measures
- Direct marketing
- Reach measurement
- Office and organizational procedures
- Administration and response to inquiries
- Feedback
- Marketing
- Profiles with user-related information
- Registration processes
- Provision of our online offering and user-friendliness
- Information technology infrastructure
Relevant Legal Bases
Below you will find an overview of the legal bases of the GDPR on which we base the processing of personal data. Please note that, in addition to the regulations of the GDPR, national data protection regulations may apply in your or our country of residence. If specific legal bases apply in individual cases, we will inform you in this privacy policy.
- Consent (Art. 6 para. 1 sentence 1 lit. a GDPR) – The data subject has given their consent to the processing of personal data concerning them for one or more specific purposes.
- Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR) – The processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject before entering into a contract.
- Legal obligation (Art. 6 para. 1 sentence 1 lit. c GDPR) – The processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR) – The processing is necessary for the purposes of the legitimate interests pursued by the controller or 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.
In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany, in particular, the Federal Data Protection Act (BDSG). This law includes special provisions on the right of access, the right to deletion, the right to object, the processing of special categories of personal data, processing for other purposes, and transmission as well as automated decision-making, including profiling. Additionally, the BDSG regulates data processing for employment purposes (§ 26 BDSG), especially with regard to the establishment, execution, or termination of employment relationships, and the consent of employees. Furthermore, data protection laws of individual federal states may apply.
Security Measures
In accordance with legal requirements, we implement appropriate technical and organizational measures, taking into account the state of the art, the costs of implementation, the nature, scope, circumstances, and purposes of the processing, as well as the varying likelihood and severity of risks to the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk.
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 of availability, and separation of data. Additionally, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to data breaches. We also consider the protection of personal data during the development or selection of hardware, software, and procedures, according to the principles of data protection by design and by default.
TLS Encryption (https): To protect your data transmitted through our online offering, we use TLS encryption. You can recognize encrypted connections by the „https://“ prefix in the address bar of your browser.
Transmission of Personal Data
In the course of our processing of personal data, it may happen that the data is transmitted to other entities, companies, legally independent organizational units, or persons or disclosed to them. Recipients of this data may include IT service providers or providers of services and content embedded in a website. In such cases, we comply with legal requirements and conclude corresponding contracts or agreements that serve the protection of your data with the recipients of 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 if processing takes place in the context of using third-party services or the disclosure or transmission of data to other persons, entities, or companies, this is only done in accordance with legal requirements.
Subject to express consent or legally required transmission, we only process or allow data to be processed in third countries with a recognized level of data protection, contractual obligations through so-called EU Commission standard protection clauses, certification, or binding internal data protection rules (Art. 44 to 49 GDPR, EU Commission information page: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).
Deletion of Data
The data processed by us will be deleted in accordance with legal requirements as soon as their permitted consents are revoked, or other permissions cease to apply (e.g., if the purpose for processing this data ceases or they are no longer required for the purpose). If the data is not deleted because it is required for other and legally permissible purposes, its processing will be limited to these purposes. This means the data will be locked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons, or whose storage is necessary for asserting, exercising, or defending legal claims or protecting the rights of another natural or legal person.
Our privacy notices may also contain further information on the retention and deletion of data, which takes precedence for the respective processing operations.
Use of Cookies
Cookies are small text files or other markers that store information on end devices and retrieve information from them. For example, cookies can be used to save the login status in a user account, the contents of a shopping cart in an e-shop, or the viewed content or functions used in an online offer. Cookies can also be used for various purposes, such as to ensure the functionality, security, and convenience of online offers, as well as to create analyses of visitor flows.
Notice on Consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, except where such consent is not legally required. Consent is particularly not necessary if the storage and retrieval of the information (including cookies) are strictly necessary to provide users with a telemedia service that they have expressly requested (i.e., our online offering). The revocable consent is clearly communicated to users and includes information on the specific use of cookies.
Legal Bases for Data Processing: The legal basis on which we process personal data using cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is the declared consent. Otherwise, the data processed with the help of cookies is based on our legitimate interests (e.g., in a business-efficient operation of our online offering and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations, it is based on these obligations. We explain for which purposes the cookies are processed in this privacy policy or in the context of obtaining consent and processing procedures.
Storage Duration: Regarding the storage duration, the following types of cookies are distinguished:
- Temporary cookies (also known as session or session cookies): Temporary cookies are deleted at the latest after a user leaves an online offer and closes their 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 data collected with the help of cookies can be used to measure reach. Unless users are explicitly informed about the type and storage duration of cookies (e.g., during consent), users should assume that cookies are permanent and that their storage duration can be up to two years.
General Information on Revocation and Objection (Opt-Out): Users can revoke the consents they have given at any time and also object to the processing in accordance with legal requirements under Art. 21 GDPR. Users can also express their objection via the settings of their browser, e.g., by deactivating the use of cookies (which may restrict the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be made via the websites https://optout.aboutads.info and https://www.youronlinechoices.com.
Further Information on Processing Procedures, Processes, and Services:
- Processing of Cookie Data Based on Consent: We use a cookie consent management procedure in which users‘ consent to the use of cookies, or the processing mentioned in the cookie consent management procedure, is obtained and managed by the users. In this process, the consent declaration is stored to avoid having to repeat the query and to be able to prove the consent in accordance with legal obligations. Storage can take place on the server and/or in a cookie (so-called opt-in cookie or by comparable technologies) to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following notes apply: The storage of the consent can take up to two years. In this context, a pseudonymous user identifier is formed and stored together with the time of consent, information on the scope of the consent (e.g., which categories of cookies and/or service providers), as well as the browser, system, and end device used.
- Complianz: Cookie consent management; Service provider: Hosted locally on our server, no data transfer to third parties; Website: https://complianz.io/; Privacy policy: https://complianz.io/legal/; More information: A unique user ID, language, types of consent, and the time of consent are stored server-side and in a cookie on the user’s device.
Business Services
We process data from our contractual and business partners, such as customers and interested parties (collectively referred to as „contractual partners“) in the context of contractual and comparable legal relationships and related measures, as well as in the context of communication with contractual partners (or pre-contractually), e.g., to respond to inquiries.
We process this data to fulfill our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations, and remedies for warranty and other performance failures. In addition, we process the data to protect our rights and for administrative tasks related to these obligations and business organization. We also process the data based on our legitimate interests in the proper and economic operation of our business and in security measures to protect our contractual partners and our business from misuse, endangerment of their data, secrets, information, and rights (e.g., through the involvement of 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 applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the above-mentioned purposes or to fulfill legal obligations. Further forms of processing, such as for marketing purposes, are disclosed to contractual partners in this privacy policy.
Which data is required for the above-mentioned purposes is communicated to contractual partners before or during data collection, e.g., in online forms, by special marking (e.g., colors) or symbols (e.g., asterisks or similar), or personally.
We delete the data after the expiry of legal warranty and comparable obligations, i.e., generally after four years, unless the data is stored in a customer account, for example, if it is required for legal archiving reasons. The legal retention period for tax-relevant documents, as well as commercial books, inventories, opening balances, annual financial statements, work instructions required for understanding these documents, and other organizational documents and booking receipts, is ten years, and for received commercial and business letters and copies of sent commercial and business letters, six years. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statement, or the management report, the commercial or business letter was received or sent, or the booking receipt was created.
If we use third-party providers or platforms to provide our services, the terms and privacy policies of the respective third-party providers or platforms apply to the relationship between users and the providers.
ayment Procedures
In the context of contractual and other legal relationships, as well as due to legal obligations or on the basis of our legitimate interests, we offer data subjects efficient and secure payment methods and use other service providers in addition to banks and credit institutions for this purpose (collectively referred to as „payment service providers“).
The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs, and checksums, as well as the contract, sum, and recipient-related information. These details are necessary to carry out the transactions. The entered data will only be processed by the payment service providers and stored with them. This means that we do not receive any account or credit card-related information, but only information about whether the payment was confirmed or rejected. Under certain circumstances, the payment service providers may transmit the data to credit agencies. This transmission is intended to verify identity and creditworthiness. In this regard, we refer to the general terms and conditions and privacy notices of the payment service providers.
For the payment transactions, the terms and privacy notices of the respective payment service providers apply, which can be accessed on the respective websites or transaction applications. We also refer to these for further information and the assertion of rights of revocation, information, and other data subject rights.
Processed Data Types:
- Inventory data (e.g., names, addresses)
- Payment data (e.g., bank details, invoices, payment history)
- Contact data (e.g., email, telephone numbers)
- Contract data (e.g., contract subject, duration, customer category)
- Usage data (e.g., visited websites, interest in content, access times)
- Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status)
Affected Persons:
- Customers
- Interested parties
Purposes of Processing:
- Provision of contractual services and customer service
Legal Bases:
- Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR)
Further Information on Processing Procedures, Methods, and Services:
- Apple Pay: Payment services (technical integration of online payment methods); Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR); Website: https://www.apple.com/apple-pay/; Privacy policy: https://www.apple.com/legal/privacy/.
- Google Pay: Payment services (technical integration of online payment methods); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR); Website: https://pay.google.com/intl/en/about/; Privacy policy: https://policies.google.com/privacy.
Provision of the Online Offering and Web Hosting
We process the data of our users to provide them with our online services. For this purpose, we process the IP address of the user, which is necessary to deliver the contents and functions of our online services to the browser or end device.
Processed Data Types:
- Usage data (e.g., visited websites, interest in content, access times)
- Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status)
- Content data (e.g., entries in online forms)
Affected Persons:
- Users (e.g., website visitors, users of online services)
Purposes of Processing:
- Provision of our online offering and user-friendliness
- Information technology infrastructure (operation and provision of information systems and technical devices like computers, servers, etc.)
- Security measures
Legal Bases:
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR)
Further Information on Processing Procedures, Methods, and Services:
- Provision of Online Offering on Rented Storage Space: To provide our online offering, we use storage space, computing capacity, and software that we rent from a corresponding server provider (also known as a „web host“); Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
- Collection of Access Data and Log Files: Access to our online offering is logged in the form of so-called „server log files.“ These server log files may include the address and name of the retrieved websites and files, the date and time of retrieval, the amount of data transferred, a report on the successful retrieval, the browser type and version, the operating system of the user, the referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g., to prevent server overloads (especially in the case of abusive attacks, such as DDoS attacks), as well as to ensure the stability of the servers; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR); Deletion of Data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is required for evidence purposes is exempt from deletion until the respective incident has been fully clarified.
- Email Dispatch and Hosting: The web hosting services we use also include the sending, receiving, and storage of emails. For these purposes, the addresses of the recipients and senders, as well as other information related to email dispatch (e.g., the involved providers) and the content of the respective emails, are processed. The aforementioned data may also be processed for SPAM detection purposes. We ask that you note that emails on the internet are generally not sent in encrypted form. Emails are usually encrypted during transmission, but (unless an end-to-end encryption method is used) not on the servers from which they are sent and received. Therefore, we cannot take responsibility for the transmission path of the emails between the sender and our server; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
- Content Delivery Network: We use a „Content Delivery Network“ (CDN). A CDN is a service that helps deliver the content of an online offering, especially large media files, such as graphics or scripts, via regionally distributed and internet-connected servers faster and more securely; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
Single Sign-On Login
Single Sign-On (SSO) refers to procedures that allow users to log in with a user account at one provider of Single Sign-On procedures (e.g., a social network) to also access our online offering. A prerequisite for Single Sign-On authentication is that users are registered with the respective Single Sign-On provider and enter the necessary access data in the appropriate online form or are already logged in to the Single Sign-On provider and confirm the Single Sign-On login via a button.
Authentication takes place directly with the respective Single Sign-On provider. In the context of such authentication, we receive a user ID with information that the user is logged in under this user ID at the respective Single Sign-On provider and an ID that cannot be used for any other purpose (so-called „user handle“). Whether additional data is transmitted to us depends solely on the Single Sign-On procedure used, on the data releases selected during authentication, and also on the privacy settings of the user account at the Single Sign-On provider. Depending on the Single Sign-On provider and the choices made by the user, various data may be shared, typically including the email address and username.
The password entered as part of the Single Sign-On procedure with the respective Single Sign-On provider is neither visible nor stored by us.
Users should be aware that the information stored with us may be automatically matched with their user account at the Single Sign-On provider, but this is not always possible or actually done. If, for example, users‘ email addresses change, they must update this manually in their user account with us.
The Single Sign-On login can be used in the context of, or before, contract fulfillment, where users are required to provide the login credentials, or otherwise, with consent or in line with our legitimate interests in offering an efficient and secure login process.
Should users decide they no longer wish to use the connection of their user account at the Single Sign-On provider for Single Sign-On login, they must remove this connection within their user account at the Single Sign-On provider. If users wish to delete their data from us, they must terminate their registration with us.
Processed Data Types:
- Inventory data (e.g., names, addresses)
- Contact data (e.g., email, telephone numbers)
- Usage data (e.g., visited websites, interest in content, access times)
- Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status)
- Event data (Facebook) („Event data“ refers to data that may be transmitted to Facebook via Facebook Pixel (via apps or other methods) and relates to individuals or their actions, such as interactions with content, functions, app installations, product purchases, etc.; event data is used to create target groups for content and ads (custom audiences); event data does not include the actual content (such as written comments), nor login information or contact information (such as names, email addresses, and phone numbers); event data is deleted by Facebook after a maximum of two years, while the target audiences created from the event data are deleted when our Facebook account is deleted).
Affected Persons:
- Users (e.g., website visitors, users of online services)
Purposes of Processing:
- Provision of contractual services and customer support
- Security measures
- Registration process
Legal Bases:
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR)
Further Information on Processing Procedures, Methods, and Services:
Contact and Inquiry Management
When contacting us (e.g., by post, contact form, email, telephone, or via social media) and within the context of existing user and business relationships, the information of the inquiring individuals is processed to the extent necessary to respond to contact inquiries and any requested measures.
Processed Data Types:
- Contact data (e.g., email, telephone numbers)
- Content data (e.g., entries in online forms)
- Usage data (e.g., visited websites, interest in content, access times)
- Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status)
Affected Persons:
Purposes of Processing:
- Contact inquiries and communication
- Administration and response to inquiries
- Feedback (e.g., collecting feedback via online form)
- Provision of our online offering and user-friendliness
Legal Bases:
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR)
- Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR)
Further Information on Processing Procedures, Methods, and Services:
- Contact Form: When users contact us via our contact form, email, or other communication channels, we process the data provided to us for handling the communicated request; Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
Push Notifications
With the consent of the users, we can send push notifications to users. Push notifications are messages displayed on the screens, devices, or browsers of the users, even when our online service is not being actively used.
To subscribe to the push notifications, users must confirm the query from their browser or device to receive push notifications. This consent process is documented and stored. The storage is necessary to recognize whether users have agreed to receive the push notifications and to be able to prove the consent. For these purposes, a pseudonymous identifier of the browser (so-called „push token“) or the device ID of a device is stored.
Push notifications may be necessary to fulfill contractual obligations (e.g., to inform users about important technical or organizational matters related to the use of our online offering). Otherwise, push notifications will only be sent based on user consent.
Processed Data Types:
- Usage data (e.g., visited websites, interest in content)
- Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers)
Affected Persons:
Purposes of Processing:
- Provision of our online offering and user-friendliness
Legal Bases:
- Consent (Art. 6 para. 1 sentence 1 lit. a GDPR)
- Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR)
Newsletter and Electronic Notifications
We send newsletters, emails, and other electronic notifications (hereinafter „newsletters“) only with the consent of the recipients or legal permission. If the content of the newsletter is specifically described during registration, it is decisive for the user’s consent. In addition, our newsletters contain information about our services and us.
To subscribe to our newsletters, it is generally sufficient to provide your email address. However, we may ask you to provide a name for personal addressing in the newsletter or other information, provided this is necessary for the purposes of the newsletter.
Double-Opt-In Process: The registration for our newsletter is done in a so-called double-opt-in procedure. This means that after registration, you will receive an email in which you will be asked to confirm your registration. This confirmation is necessary to ensure that no one can register with another’s email address. The registrations for the newsletter are logged to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation times as well as the IP address. Likewise, the changes to your data stored with the email service provider are logged.
Deletion and Limitation of Processing: We may store the email addresses of unsubscribed users for up to three years based on our legitimate interests before deleting them to prove a formerly given consent. The processing of this data is limited to the purpose of possible defense against claims. An individual deletion request is possible at any time if the former existence of consent is confirmed. In the case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a blocklist (so-called „blocklist“).
The logging of the registration process is based on our legitimate interests for the purpose of proving its proper execution. If we commission a service provider to send emails, this is done based on our legitimate interests in a secure and efficient delivery system.
Content:
- Information about us, our services, promotions, and offers
Processed Data Types:
- Inventory data (e.g., names, addresses)
- Contact data (e.g., email, telephone numbers)
- Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status)
- Usage data (e.g., visited websites, interest in content, access times)
Affected Persons:
Purposes of Processing:
- Direct marketing (e.g., via email or post)
Legal Bases:
- Consent (Art. 6 para. 1 sentence 1 lit. a GDPR)
Opt-Out Option: You can unsubscribe from our newsletter at any time, i.e., revoke your consents or object to further receipt. You will find a link to unsubscribe at the end of each newsletter or you can otherwise use one of the contact options provided above, preferably email.
Further Information on Processing Procedures, Methods, and Services:
- Measurement of Opening and Click Rates: The newsletters contain a so-called „web beacon,“ i.e., a pixel-sized file that is retrieved from our server, or, if we use an email service provider, from their server when the newsletter is opened. As part 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 to improve the technical performance of our services based on the technical data or the target groups and their reading behavior based on their access locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether newsletters are opened, when they are opened, and which links are clicked. This information is assigned to individual newsletter recipients and stored in their profiles until they are deleted. The evaluations are used to recognize the reading habits of our users and adapt our content to them or send different content according to the interests of our users. The measurement of the opening rates and click rates, as well as the storage of the measurement results in user profilesMeasurement of the opening rates and click rates, as well as the storage of the measurement results in user profiles, are based on user consent. A separate objection to the measurement of performance is unfortunately not possible; in this case, the entire newsletter subscription must be canceled. In this case, the stored profile information will be deleted.Processed Data Types:
- Inventory data (e.g., names, addresses)
- Contact data (e.g., email, telephone numbers)
- Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status)
- Usage data (e.g., accessed content, interactions with content)
Legal Bases:
- Consent (Art. 6 para. 1 sentence 1 lit. a GDPR)
Marketing Communication via Email, Post, Fax, or Telephone
We process personal data for marketing communication purposes, which may be carried out via various channels, such as email, telephone, post, or fax, in accordance with legal requirements.
Recipients have the right to revoke any consent they have given at any time or to object to marketing communication at any time.
After revocation or objection, we store the data necessary to prove the prior authorization to contact or send communications for up to three years based on our legitimate interests. The processing of this data is limited to the purpose of defending against potential claims. In the case of obligations to permanently respect objections, we reserve the right to store the necessary data (e.g., depending on the communication channel, the email address, telephone number, or name) in a blocklist for this purpose.
Processed Data Types:
- Inventory data (e.g., names, addresses)
- Contact data (e.g., email, telephone numbers)
Affected Persons:
Purposes of Processing:
- Direct marketing (e.g., via email or post)
Legal Bases:
- Consent (Art. 6 para. 1 sentence 1 lit. a GDPR)
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR)
Web Analysis, Monitoring, and Optimization
Web analysis (also referred to as „reach measurement“) serves to evaluate visitor traffic on our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize when our online offering or its functions or content are most frequently used, or invite repeat use. Similarly, we can identify which areas need optimization.
In addition to web analysis, we may also use test procedures, for example, to test and optimize different versions of our online offering or its components.
Unless otherwise indicated below, for these purposes, profiles may be created that summarize the data about a user’s session, and information may be stored in a browser or a device and retrieved from it. The collected information may include, in particular, the visited websites and their elements, as well as technical information such as the browser used, the computer system, and the time spent on the website. If users have consented to the collection of their location data, this may also be processed.
The IP addresses of users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, the data stored in the context of web analysis, A/B testing, and optimization is not clear data of users (such as email addresses or names) but pseudonymous data. This means that we, as well as the providers of the used software, do not know the actual identity of the users, only the information stored in their profiles for the respective procedures.
Processed Data Types:
- Usage data (e.g., visited websites, interest in content, access times)
- Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status)
Affected Persons:
- Users (e.g., website visitors, users of online services)
Purposes of Processing:
- Reach 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 Bases:
- Consent (Art. 6 para. 1 sentence 1 lit. a GDPR)
Further Information on Processing Procedures, Methods, and Services:
- Google Tag Manager: Google Tag Manager is a solution that allows us to manage website tags through a user interface and integrate other services into our online offering (referred to in more detail elsewhere in this privacy policy). The Tag Manager itself (which implements the tags) does not create user profiles or store cookies. Only the IP address of the user is transmitted to Google, which is necessary to run the Google Tag Manager; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms; Standard contractual clauses (guaranteeing data protection levels for processing in third countries): https://business.safety.google/adsprocessorterms.
- Matomo: Matomo is software used for web analysis and reach measurement. In the course of using Matomo, cookies are generated and stored on the users‘ end device. The data collected during the use of Matomo is only processed by us and not shared with third parties. Cookies are stored for a maximum duration of 13 months; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR); Deletion of Data: Cookies have a storage duration of a maximum of 13 months.
Presence in Social Networks (Social Media)
We maintain online presences within social networks and process data of users in this context to communicate with users active there or to offer information about us.
We point out that user data may be processed outside the European Union. This may result in risks for the users, for example, because the enforcement of user rights could be more difficult.
Furthermore, user data is generally processed within social networks for market research and advertising purposes. For example, user profiles can be created based on user behavior and interests. The usage profiles can in turn be used, for example, to display advertisements inside and outside the networks that presumably correspond to the users‘ interests. For these purposes, cookies are usually stored on users‘ devices in which the user behavior and interests are stored. Additionally, data can be stored in the usage profiles, regardless of the devices used by the users (especially if the users are members of the respective platforms and are logged in).
For a detailed description of the respective forms of processing and the options to object (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.
Also, in the case of information requests and the assertion of user rights, we point out that these are most effectively asserted with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, you can contact us.
Processed Data Types:
- Contact data (e.g., email, telephone numbers)
- Content data (e.g., entries in online forms)
- Usage data (e.g., visited websites, interest in content, access times)
- Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status)
Affected Persons:
- Users (e.g., website visitors, users of online services)
Purposes of Processing:
- Contact inquiries and communication
- Feedback (e.g., collecting feedback via online forms)
- Marketing
Legal Bases:
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR)
Further Information on Social Media Processing Procedures, Methods, and Services:
- Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR); Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
- Facebook Pages: Profiles within the social network Facebook – We are jointly responsible with Meta Platforms Ireland Limited for collecting (but not for further processing) data of visitors to our Facebook page (so-called „Fanpage“). This data includes information about the types of content users view or interact with, or the actions they take (as detailed under „Things you and others do and provide“ in Facebook’s data policy: https://www.facebook.com/policy), as well as information about the devices used by visitors (e.g., IP addresses, operating system, browser type, language settings, cookie data). As explained in Facebook’s data policy under „How do we use this information?“, Facebook also collects and uses information to provide analytics services, known as „Page Insights,“ to page operators, enabling them to gain insights into how people interact with their pages and the content associated with them. We have entered into a special agreement with Facebook („Page Insights Information,“ https://www.facebook.com/legal/terms/page_controller_addendum), which specifies in particular what security measures Facebook must observe and in which Facebook has agreed to fulfill data subject rights (i.e., users can, for example, request information or deletion directly from Facebook). The rights of users (in particular, to access, deletion, objection, and complaints to the relevant supervisory authority) are not restricted by these agreements with Facebook. Further details can be found in the „Page Insights Information“ (https://www.facebook.com/legal/terms/information_about_page_insights_data); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Standard contractual clauses (guaranteeing data protection level for processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Further information: Joint responsibility agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data. Joint responsibility is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which also covers the transfer of the data to the parent company Meta Platforms, Inc. in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Data processing agreement: https://legal.linkedin.com/dpa; Standard contractual clauses (guaranteeing data protection level for processing in third countries): https://legal.linkedin.com/dpa; Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Pinterest: Social network; Service provider: Pinterest Europe Limited, 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR); Website: https://www.pinterest.com; Privacy policy: https://policy.pinterest.com/en/privacy-policy; Further information: Pinterest Data Sharing Annex (ANNEX A): https://business.pinterest.com/en/pinterest-advertising-services-agreement.
Plugins and Embedded Functions and Content
We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as „third-party providers“). These may be, for example, graphics, videos, or city maps (hereinafter uniformly referred to as „content“).
The integration always requires that the third-party providers of this content process the IP address of the users, as they would not be able to send the content to their browser without the IP address. The IP address is therefore necessary for the display of this content or function. We strive to use only content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as „web beacons“) for statistical or marketing purposes. Pixel tags can be used to evaluate visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, visit times, and other information regarding the use of our online offering, as well as being combined with such information from other sources.
Processed Data Types:
- Usage data (e.g., visited websites, interest in content, access times)
- Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status)
Affected Persons:
- Users (e.g., website visitors, users of online services)
Purposes of Processing:
- Provision of our online offering and user-friendliness
Legal Bases:
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR)
Further Information on Processing Procedures, Methods, and Services:
- Integration of Third-Party Software, Scripts, or Frameworks (e.g., jQuery): We integrate software into our online offering that we retrieve from the servers of other providers (e.g., functional libraries that we use for the display or user-friendliness of our online offering). In doing so, the respective providers collect the IP address of the users and can process it for security purposes, as well as for the analysis and optimization of their services; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
- Google Fonts (Retrieved from Google Server): We integrate fonts (and symbols) for a technically secure, maintenance-free, and efficient use of fonts and symbols with regard to timeliness and loading times, their uniform display, and the consideration of possible license restrictions. The provider of the fonts receives the user’s IP address to enable the fonts to be delivered to the user’s browser. In addition, technical data (e.g., language settings, screen resolution, operating system, and hardware used) is transmitted to provide the fonts depending on the devices used and the technical environment. This data may be processed on a Google server in the USA – When visiting our online offering, the user’s browser sends HTTP requests to the Google Fonts Web API (i.e., a software interface for retrieving the fonts). The Google Fonts Web API provides users with Google Fonts‘ Cascading Style Sheets (CSS) and then the fonts specified in the CSS. These HTTP requests include (1) the IP address used by the user to access the internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the User-Agent, which describes the browser and operating system versions of the website visitors, as well as the referrer URL (i.e., the website where the Google font should be displayed). IP addresses are not logged or stored on Google servers and are not analyzed. The Google Fonts Web API logs details of HTTP requests (requested URL, User-Agent, and referrer URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families that the user wants to load. This data is logged to determine how often a particular font family is requested. In the Google Fonts Web API, the User-Agent must customize the font that is generated for the specific browser type. The User-Agent is logged primarily for debugging purposes and is used to generate aggregated usage statistics that measure the popularity of font families. These aggregated usage statistics are published on the „Analytics“ page of Google Fonts. Finally, the referrer URL is logged so that the data can be used for maintenance in production and an aggregated report on top integrations based on the number of font requests can be generated. According to Google, none of the information collected by Google Fonts is used to create profiles of end users or to display targeted ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR); Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy; Further information: https://developers.google.com/fonts/faq/privacy?hl=en.
Changes and Updates to the Privacy Policy
We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as changes in our data processing make this necessary. We will inform you as soon as changes require your cooperation (e.g., consent) or other individual notifications.
If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the details before contacting them.
Rights of the Data Subjects
As a data subject, you have the right to various rights under the General Data Protection Regulation (GDPR), which arise in particular from Articles 15 to 21 GDPR:
- Right to Object: You have the right to object, at any time, to the processing of your personal data, which is based on Art. 6 para. 1 lit. e or f GDPR, for reasons arising from your particular situation. This also applies to profiling based on these provisions. If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, including profiling, insofar as it is related to such direct marketing.
- Right of Withdrawal for Consents: You have the right to withdraw your consent at any time.
- Right of Access: You have the right to request confirmation as to whether data concerning you is being processed and to information about this data, as well as further information and a copy of the data in accordance with legal requirements.
- Right to Rectification: You have the right to request the completion of data concerning you or the correction of inaccurate data concerning you, in accordance with legal requirements.
- Right to Erasure and Restriction of Processing: In accordance with legal requirements, you have the right to request that data concerning you be deleted immediately, or alternatively, to request a restriction of the processing of the data in accordance with legal requirements.
- Right to Data Portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used, and machine-readable format, in accordance with legal requirements, or to request its transfer to another controller.
- Right to Complain to Supervisory Authority: You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or the place of the alleged infringement if you consider that the processing of personal data relating to you infringes the provisions of the GDPR.
Definitions of Terms
In this section, you will find an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined mainly in Art. 4 GDPR. The legal definitions are binding. However, the following explanations are intended primarily to aid understanding. The terms are arranged alphabetically.
- 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 reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie), or to one or more factors specific to 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 simply „profiles,“ includes any form of automated processing of personal data that consists of using this personal data to analyze, evaluate, or predict certain personal aspects related to a natural person (depending on the type of profile formation, this may include different information concerning demographics, behavior, and interests, such as interactions with websites and their content). Cookies and web beacons are often used for profiling purposes.
- Reach Measurement: Reach measurement (also referred to as web analytics) serves to evaluate the visitor flows of an online offer and can include the behavior or interests of visitors in certain information, such as website content. Website owners can use the reach analysis to understand when visitors access their website and for which content they are interested. For reach measurement purposes, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
- 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.
- Processing: „Processing“ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.