As of: July 1, 2023
Table of contents
Contact data protection officer
Transfer and Disclosure of Personal Data
Data processing in third countries
Commercial and business services
Provision of online offerings and web hosting
Newsletters and electronic notifications
Web analysis, monitoring and optimization
Presences in social networks (social media)
Plugins and embedded functions and content
Changes and updates to the data protection declaration
Responsible person
BONJOUR BERLIN
Owner: Ruslan Scharfmann
Kurfürstendamm 197
10719 Berlin
Germany
Email address: info@bonjour-berlin.com
Telephone: +49(0)30 33931010
Imprint: https://www.bonjour-berlin.com/pages/impressum
Contact data protection officer
BONJOUR BERLIN
Owner: Ruslan Scharfmann
Kurfürstendamm 197
10719 Berlin
Germany
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 (e.g. names, addresses).
Content data (e.g. entries in online forms).
Contact details (e.g. email, telephone numbers).
Meta/communication data (e.g. device information, IP addresses).
Usage data (e.g. websites visited, interest in content, access times).
Location data (information about the geographical position of a device or person).
Contract data (e.g. subject matter of the contract, term, customer category).
Payment data (e.g. bank details, invoices, payment history).
Categories of data subjects
Business and contractual partners.
Interested persons.
Communication partner.
Customers.
Users (e.g. website visitors, users of online services).
Purposes of processing
Assessment of creditworthiness and creditworthiness.
Provision of our online offering and user-friendliness.
Visit action evaluation.
Office and organizational procedures.
Cross-device tracking (processing of user data across devices for marketing purposes).
Direct marketing (e.g. via email or post).
Interest-based and behavioral marketing.
Contact inquiries and communication.
Conversion measurement (measuring the effectiveness of marketing measures).
Profiling (creating user profiles).
Remarketing.
Reach measurement (e.g. access statistics, recognition of returning visitors).
Safety measures.
Tracking (e.g. interest/behavioral profiling, use of cookies).
Provision of contractual services and customer service.
Managing and responding to inquiries.
Target group formation (determination of target groups relevant for marketing purposes or other output of content).
Automated decisions in individual cases
Credit report (decision based on a credit check).
Relevant legal bases
Below we provide information on the legal basis of the General Data Protection Regulation (GDPR), on the basis of which we process personal data. Please note that in addition to the regulations of the GDPR, the national data protection regulations may apply in your or our country of residence and domicile. If more specific legal bases apply in individual cases, we will inform you of these in the data protection declaration.
Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR) – The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
Fulfillment of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR) – Processing is necessary for the performance of a contract to which the data subject is a party or to carry out pre-contractual measures at the request of the data subject take place.
Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR) – 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 controller or a third party, unless the interests or fundamental rights and freedoms of the data subject are infringing on the protection of personal data Data requirements predominate.
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, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, ensuring availability and its separation. We have also set up procedures to ensure that the rights of those affected are exercised, data are deleted and responses are made to data threats. We also take the protection of personal data into account when developing or selecting hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
SSL encryption (https) : To protect your data transmitted via our online offering, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.
Transfer and Disclosure of Personal Data
As part of our processing of personal data, the data may be transmitted to or disclosed to other bodies, companies, legally independent organizational units or persons. The recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude 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 in the context of using third-party services or disclosing or transferring data to other people, bodies or companies takes place, this only takes place in accordance with the legal requirements.
Subject to express consent or contractually or legally required transfer, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligations through so-called standard protection clauses of the EU Commission, if certifications or binding internal data protection regulations exist (Articles 44 to 49 GDPR, EU Commission information page: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).
Use of cookies
Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user's computer. A cookie is primarily used to store information about a user during or after their visit to an online offering. The information stored can include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was watched. The term “cookies” also includes other technologies that fulfill the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also referred to as “user IDs”).
The following cookie types and functions 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 their browser.
Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The interests of users, which are used to measure reach or for marketing purposes, can also be stored in such a cookie.
First-party cookies: First-party cookies are set by us.
Third-party cookies (also: third-party cookies) : Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
Necessary (also: essential or absolutely necessary) cookies: Cookies can be absolutely necessary for the operation of a website (e.g. to save logins or other user input or for security reasons).
Statistics, marketing and personalization cookies : Cookies are also generally used as part of reach measurement and when the interests of a user or their behavior (e.g. viewing certain content, using functions, etc.) on individual websites are reflected in a user profile get saved. Such profiles are used, for example, to show users content that corresponds to their potential interests. This process is also referred to as “tracking”, ie tracking the potential interests of users. . If we use cookies or “tracking” technologies, we will inform you separately in our data protection declaration or when obtaining consent.
Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this is the case and you agree to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g. in operating our online offering and improving it) or if the use of cookies is necessary to fulfill our contractual obligations.
Storage period: Unless we provide you with explicit information about the storage period of permanent cookies (e.g. as part of a so-called cookie opt-in), please assume that the storage period can be up to two years.
General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke your consent or to object to the processing of your data using cookie technologies ( collectively referred to as “opt-out”). You can first declare your objection using your browser settings, for example by deactivating the use of cookies (which may also limit the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared using a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ become. You can also receive further objection information as part of the information about the service providers and cookies used.
Processing of cookie data based on consent : Before we process or have data processed as part of the use of cookies, we ask users for their consent, which can be revoked at any time. Before consent has been given, cookies may be used that are absolutely necessary for the operation of our online offering.
Cookie settings/objection option:
Types of data processed: usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Data subjects: Users (e.g. website visitors, users of online services).
Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Commercial and business services
We process data from 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 as well as associated measures and as part of communication with the contractual partners (or pre-contractual), e.g. to respond to inquiries answer.
We process this data to fulfill our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information and the business organization. We only pass on the data of the contractual partners to third parties within the framework of applicable law to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations or with the consent of the data subjects (e.g. to the telecommunications, transport and other auxiliary services involved). Subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.
We inform the contractual partners which data is required for the aforementioned purposes before or as part of the data collection, e.g. in online forms, through special marking (e.g. colors) or symbols (e.g. asterisks, etc.), or in person.
We delete the data after the expiry of statutory warranty and comparable obligations, ie, in principle after 4 years, unless the data is stored in a customer account, for example as long as it must be retained for legal archiving reasons (e.g. for Tax purposes usually 10 years). We delete data that was 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.
To the extent that 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 offering (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 the information required for registration. Customer accounts are not public and cannot be indexed by search engines. As part of the registration and subsequent logins and use of the customer account, we store the customers' IP addresses along with the access times in order to be able to prove registration and prevent any misuse of the customer account.
If customers have canceled their customer account, the data relating to the customer account will be deleted, unless their retention is required for legal reasons. It is the customer's responsibility to secure their data if the customer account is terminated.
Economic analyzes and market research : For business reasons and in order to be able to identify market trends, wishes of contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc., with the group of affected persons including contractual partners, interested parties, customers, Visitors and users of our online offering 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). If available, we can take into account the profiles of registered users including their information, for example about the services they have used. The analyzes serve us alone and are not disclosed externally unless they are anonymous analyzes with summarized, i.e. anonymized, values. We also take the privacy of users into account and process the data for analysis purposes as pseudonymously as possible and, if possible, anonymously (e.g. as summarized data).
Shop and e-commerce : We process our customers' data to enable them to select, purchase or order the selected products, goods and related services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution to our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such as part of the ordering or comparable purchase process and includes the information required for delivery, provision and billing as well as contact information in order to be able to make any consultations.
Types of data processed: 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. subject matter 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: interested parties, business and contractual partners, customers.
Purposes of processing: provision of contractual services and customer service, contact inquiries and communication, office and organizational procedures, management and response to inquiries, security measures, visit action evaluation, interest-based and behavioral marketing, profiling (creation of user profiles).
Legal basis: Fulfillment of the contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legal obligation (Art. 6 Para. 1 S. 1 lit. c. GDPR), legitimate interests (Art. 6 Para. 1 p. 1 lit. f. GDPR).
Payment service provider
As part of contractual and other legal relationships, due to legal obligations or otherwise based on our legitimate interests, we offer the data subjects efficient and secure payment options and use other payment service providers in addition to banks and credit institutions (collectively “payment service providers”).
The data processed by the payment service providers 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, but only information with confirmation or negative information about the payment. Under certain circumstances, the data may be transmitted by the payment service provider to credit reporting agencies. The purpose of this transmission is to check identity and creditworthiness. For this purpose, we refer to the general terms and conditions and data protection information of the payment service providers.
The terms and conditions and data protection information of the respective payment service providers apply to payment transactions, which can be accessed on the respective websites or transaction applications. We also refer to these for further information and to assert cancellation, information and other rights of those affected.
Types of data processed: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter 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 parties.
Purposes of processing: provision of contractual services and customer service.
Legal basis: Fulfillment of the 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).
Services and service providers used:
PayPal: payment services and solutions (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à rl et Cie, SCA, 22-24 Boulevard Royal, L-2449 Luxembourg; Website: https://www.paypal.com/de ; Data protection declaration: https://www.paypal.com/de/webapps/mpp/ua/privacy-full .
Credit check
If we make advance payments or take comparable economic risks (e.g. when ordering on account), we reserve the right to provide identity and credit information to assess the credit risk based on mathematical-statistical procedures from specialized service companies (credit agencies) in order to protect our legitimate interests ).
We process the information received from the credit reporting agencies about the statistical probability of a payment default as part of an appropriate, discretionary decision on the establishment, implementation and termination of the contractual relationship. We reserve the right to refuse payment on account or any other advance payment in the event of a negative result of the credit check.
The decision as to whether we make advance payments is made in accordance with Art. 22 GDPR solely on the basis of an automated decision in individual cases, which our software makes based on the information from the credit reporting agency.
If we obtain express consent from contractual partners, the legal basis for the credit report and the transmission of the customer's data to the credit agencies is consent. If consent is not obtained, the credit information is provided on the basis of our legitimate interests in the reliability of our payment claims.
Types of data processed: 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. subject matter of the contract, term, customer category).
Affected persons: customers, interested parties.
Purposes of processing: Assessment of creditworthiness and creditworthiness.
Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Automated decisions in individual cases: credit information (decision based on a credit check).
Services and service providers used:
Association of Creditreform eV associations: credit reporting agency; Service provider: Association of Associations Creditreform eV, Hellersbergstraße 12, D-41460 Neuss, Germany; Website: https://www.creditreform.de/ ; Data protection declaration: https://www.creditreform.de/datenschutz .
Provision of online offerings and web hosting
In order to be able to provide our online offering securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offering can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security and technical maintenance services.
The data processed 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 to be able to deliver the content of online offerings to browsers, and all entries made within our online offering or on websites.
Email sending and hosting : The web hosting services we use also include sending, receiving and storing emails. For these purposes, the addresses of the recipients and senders as well as other information regarding the sending of emails (e.g. the providers involved) as well as the contents of the respective emails are processed. The aforementioned data may also be processed for SPAM detection purposes. We ask you to note that emails on the Internet are generally not sent encrypted. As a rule, emails are encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore assume no responsibility for the transmission path of emails between the sender and receipt on our server.
Collection of access data and log files : We ourselves (or our web hosting provider) collect data about every access to the server (so-called server log files). The server log files include the address and name of the websites and files accessed, date and time of access, amount 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 address. Addresses and the requesting provider belong.
The server log files can be used on the one hand for security purposes, for example to avoid overloading the servers (particularly in the case of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the utilization of the servers and their stability.
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).
Data subjects: Users (e.g. website visitors, users of online services).
Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
contact
When you contact us (e.g. via contact form, email, telephone or via social media), the information provided by the person making the request will be processed to the extent that this is necessary to answer the contact request and any requested measures.
Answering contact inquiries within the framework of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to answer (pre-)contractual inquiries and otherwise on the basis of the legitimate interests in answering the inquiries.
Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. email, 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 data information, IP addresses).
Affected persons: communication partners, interested parties.
Purposes of processing: contact requests and communication, management and response to inquiries.
Legal basis: Fulfillment of the 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).
Services and service providers used:
Newsletters and electronic notifications
We only send newsletters, emails and other electronic notifications (hereinafter “newsletter”) with the consent of the recipient or legal permission. If the contents are specifically described when registering for the newsletter, they are decisive for the user's consent. Our newsletters also contain information about our services and us.
In order to register for our newsletters, it is generally sufficient to provide your email address. However, we may ask you to provide a name so that you can be addressed personally in the newsletter, or other information if this is necessary for the purposes of the newsletter.
Double opt-in process: Registration for our newsletter generally takes place using a so-called double opt-in process. This means that after registering you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can log in with someone else's email address. Registrations for the newsletter are logged in order to be able to provide evidence of the registration process in accordance with legal requirements. This includes storing the registration and confirmation times 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 email addresses for up to three years based on our legitimate interests before we delete them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of 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 event of obligations to permanently observe contradictions, we reserve the right to store the email address in a blocking list (so-called “blacklist”) for this purpose alone.
The registration process is recorded on the basis of our legitimate interests for the purpose of providing evidence of its proper execution. If we commission a service provider to send emails, this is based on our legitimate interests in an efficient and secure shipping system.
Notes on legal bases: 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 to existing customers. If we commission a service provider to send emails, this is done on the basis of our legitimate interests. The registration process is recorded based on our legitimate interests to demonstrate that it was carried out in accordance with the law.
Content: Information about us, our services, promotions and offers.
Analysis and measurement of success : The newsletters contain a so-called “web beacon”, ie a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from their server. As part of this retrieval, technical information is initially collected, such as information about the browser and your system, as well as your IP address and the time of retrieval.
This information is used to technically improve our newsletter 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 access times. This analysis also includes determining whether 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 intention nor, if used, that of the shipping service provider to monitor individual users. Rather, the evaluations serve us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
The evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purposes of using a user-friendly and secure newsletter system that serves both our business interests and meets the expectations of the users.
Unfortunately, it is not possible to revoke the success measurement separately; in this case, the entire newsletter subscription must be canceled or objected to.
Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. email, telephone 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. via email 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).
Option to object (opt-out): You can cancel your receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email.
Services and service providers used:
CleverReach: email marketing platform; Service provider: CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede, Germany; Website: https://www.cleverreach.com/de ; Data protection declaration: https://www.cleverreach.com/de/datenschutz/ .
Mailchimp: email marketing platform; Service provider: “Mailchimp” – Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Website: https://mailchimp.com ; Privacy Policy: https://mailchimp.com/legal/privacy/ .
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Web analysis, monitoring and optimization
Web analysis (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and can 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, identify at what time our online offering or its functions or content are used most frequently or invite reuse. We can also understand which areas require optimization.
In addition to web analysis, we can also use testing procedures, for example to test and optimize different versions of our online offering or its components.
For these purposes, so-called user profiles can be created and stored in a file (so-called “cookie”) or similar procedures can be used for the same purpose. This information may include, for example, content viewed, websites visited and elements used there and technical information such as the browser used, the computer system used and information about times of use. If users have consented to the collection of their location data, this can also be processed, depending on the provider.
The users’ IP addresses are also stored. However, we use an IP masking process (ie pseudonymization by shortening the IP address) to protect users. In general, as part of web analysis, A/B testing and optimization, no clear user data (such as email addresses or names) is stored, but rather 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 procedures.
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 will be processed based on 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).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Range measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behavioral profiling, use of cookies), visit action evaluation, profiling (creation of 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).
Services and service providers used:
etracker: web analysis/range measurement; Service provider: etracker GmbH, Erste Brunnenstraße 1 20459 Hamburg, Germany; Website: https://www.etracker.com ; Data protection declaration: https://www.etracker.com/datenschutz/ ; Option to object (opt-out): https://www.etracker.de/privacy?et= [PLEASE-INSERT-YOUR-Account-ID].
Matomo (without cookies): Matomo is a privacy-friendly web analysis software that is used without cookies and in which returning users are identified using a so-called “digital fingerprint”, which is stored anonymously and changed every 24 hours; With the “digital fingerprint” user movements within our online offering are recorded using pseudonymized IP addresses in combination with user browser settings in such a way that conclusions about the identity of individual users are not possible; Service provider: web analysis/range measurement in self-hosting; Website: https://matomo.org/ .
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 procedures are used, through which the user information relevant to the display of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information about times of use. If users have consented to the collection of their location data, this can also be processed.
The users’ IP addresses are also stored. However, we use available IP masking procedures (ie pseudonymization by shortening the IP address) to protect users. In general, as part of the online marketing process, no clear user data (such as e-mail addresses or names) is stored, but rather pseudonyms. This means that we as well as the providers of online marketing processes do not know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is usually stored in cookies or using similar methods. These cookies can later generally be read on other websites that use the same online marketing process, analyzed for the purposes of displaying content, and supplemented with further data and stored on the server of the online marketing process provider.
In exceptional cases, 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 processes we use and the network connects the users' profiles with the aforementioned information. We ask you to note that users can make additional agreements with the providers, for example by giving consent during registration.
We generally only receive access to aggregated information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, ie, for example, to the conclusion of a contract with us. Conversion measurement is used solely to analyze the success of our marketing measures.
Unless otherwise stated, we ask you to 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 will be processed based on 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.
Facebook pixel : With the help of the Facebook pixel, Facebook is able to determine the visitors to our online offering as a target group for the display of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to only show the Facebook ads placed by us to those users on Facebook and within the services of partners cooperating with Facebook (so-called “Audience Network” https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offering or who have certain characteristics (e.g. interest in certain topics or products, which are evident from the websites visited), which 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 interest of the users and do not appear annoying. With the help of the Facebook pixel, we can also track the effectiveness of Facebook advertisements for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook advertisement (so-called “conversion measurement”).
Types of data processed: usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information about the geographical position of a device or a person).
Affected persons: users (e.g. website visitors, users of online services), interested parties.
Purposes of processing: Tracking (e.g. interest/behavioral profiling, use of cookies), remarketing, visit action evaluation, interest-based and behavioral marketing, profiling (creation of user profiles), conversion measurement (measuring the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of recurring visitors), target group formation (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes).
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).
Option to object (opt-out): We refer to the data protection information of the respective providers and the objection options specified for the providers (so-called “opt-out”). If no explicit opt-out option has been provided, you have the option of turning off cookies in your browser settings. However, this may restrict the functions of our online offering. 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-territorial: https://optout.aboutads.info .
Services and service providers used:
Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offering. The Tag Manager itself (which implements the tags) does not process any personal data of users. With regard to the processing of users' personal data, reference is made to the following information on Google services. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com ; Privacy policy: https://policies.google.com/privacy .
Google Analytics: online marketing and web analysis; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/ ; Privacy policy: https://policies.google.com/privacy ; Option to object (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de , settings for the display of advertising: https://adssettings.google.com/authenticated .
Google Ads and conversion measurement: We use the online marketing process “Google Ads” to place advertisements in 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 have on the advertisements. We also measure the conversion of the ads. However, we only know the anonymous total number of users who clicked on our ad and were redirected to a page with a so-called “conversion tracking tag”. However, we ourselves do not receive any information that can 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; Website: https://marketingplatform.google.com ; Privacy policy: https://policies.google.com/privacy .
Google Ad Manager: We use the “Google Marketing Platform” (and services such as “Google Ad Manager”) to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.). The Google Marketing Platform is characterized by displaying ads in real time based on users' presumed interests. This allows us to display advertisements for and within our online offering in a more targeted manner in order to only present users with advertisements that potentially match their interests. For example, if a user is shown ads for products that they were interested in on other online offerings, this is referred to as “remarketing”. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com ; Privacy policy: https://policies.google.com/privacy .
Facebook Pixel: Service provider: https://www.facebook.com , Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA ; Website: https://www.facebook.com ; Data protection declaration: https://www.facebook.com/about/privacy ; Option to object (opt-out): https://www.facebook.com/settings?tab=ads .
Presences in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with active users there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This can result in risks for users because, for example, it could make it more difficult to enforce users' rights.
Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on usage behavior and the resulting interests of users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behavior and interests of the users are stored. Furthermore, data can also be stored in the usage profiles regardless of the devices used by the users (particularly 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 options for objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of the rights of those affected, we would also like to point out that these can most effectively be asserted with the providers. Only the providers have access to user data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. email, 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 data information, IP addresses).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: contact requests and communication, tracking (e.g. interest/behavioral profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Services and service providers used:
Instagram: social network; Service provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com ; Data protection declaration: https://instagram.com/about/legal/privacy .
Facebook: social network; Service provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com ; Data protection declaration: https://www.facebook.com/about/privacy ; Option to object (opt-out): Settings for advertisements: https://www.facebook.com/settings?tab=ads ; Additional information on data protection: Agreement on joint processing of personal data on Facebook pages: https://www.facebook.com/legal/terms/page_controller_addendum , data protection information for Facebook pages: https://www.facebook.com/legal/ terms/information_about_page_insights_data .
LinkedIn: social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: https://www.linkedin.com ; Privacy policy: https://www.linkedin.com/legal/privacy-policy ; Option to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out .
Twitter: social network; Service provider: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Data protection declaration: https://twitter.com/de/privacy , (settings) https://twitter.com/personalization .
YouTube: social network; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Privacy policy: https://policies.google.com/privacy ; Option to object (opt-out): https://adssettings.google.com/authenticated .
Xing: social network; Service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Website: https://www.xing.de ; Data protection declaration: https://privacy.xing.com/de/datenschutzerklaerung .
Plugins and embedded functions and content
We include functional and content elements in our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). This can be, for example, graphics, videos or social media buttons as well as posts (hereinafter referred to as “content”).
The integration always requires that the third party providers of this content process the users' IP address, as without the IP address they would not be able to send the content to their browser. The IP address is therefore required to display this content or functions. We strive to only use content whose respective providers only use the IP address to deliver the content. Third parties may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offering, as well as being linked to such information from other sources.
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 will be processed based on 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), location data (information about the geographical position of a device or a person), content data (e.g. entries in online forms ), inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers).
Data subjects: users (e.g. website visitors, users of online services), communication partners.
Purposes of processing: Provision of our online offering and user-friendliness, provision of contractual services and customer service, contact requests and communication, tracking (e.g. interest/behavioral profiling, use of cookies), interest-based and behavioral marketing, profiling (creation of user profiles), security measures, administration and Responding to inquiries.
Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR), consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 p. 1 lit. b. GDPR).
Services and service providers used:
Facebook plugins and content: Facebook social plugins and content – This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online offering within Facebook. The list and appearance of the Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/ ; Service provider: https://www.facebook.com , Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com ; Data protection declaration: https://www.facebook.com/about/privacy ; Option to object (opt-out): Settings for advertisements: https://www.facebook.com/settings?tab=ads .
Google Fonts: We integrate the fonts (“Google Fonts”) from the provider Google, whereby the user’s data is used solely for the purpose of displaying the fonts in the user’s browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform presentation and taking into account possible licensing restrictions for their integration. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://fonts.google.com/ ; Privacy policy: https://policies.google.com/privacy .
Google Maps: We integrate the maps from the “Google Maps” service provided by Google. The data processed may include, in particular, IP addresses and location data of users, which, however, are not collected without their consent (usually carried out as part of the settings of their mobile devices); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://cloud.google.com/maps-platform ; Privacy policy: https://policies.google.com/privacy ; Option to object (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de , settings for the display of advertising: https://adssettings.google.com/authenticated .
ReCaptcha: We include the “ReCaptcha” function to detect bots, for example when making entries in online forms. User behavioral information (e.g. mouse movements or queries) is evaluated in order to distinguish humans from bots. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://www.google.com/recaptcha/ ; Privacy policy: https://policies.google.com/privacy ; Option to object (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de , settings for the display of advertising: https://adssettings.google.com/authenticated .
Twitter plugins and content: Twitter plugins and buttons - This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online offering within Twitter. Service provider: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Website: https://twitter.com/de ; Data protection declaration: https://twitter.com/de/privacy .
YouTube videos: video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://www.youtube.com ; Privacy policy: https://policies.google.com/privacy ; Option to object (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de , settings for the display of advertising: https://adssettings.google.com/authenticated .
Deletion of data
The data processed by us will be deleted in accordance with the legal requirements as soon as the consent for processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or it is not necessary for the purpose).
Unless the data is deleted because it is required for other legally permissible purposes, its processing will be limited to these purposes. This means that the data is 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.
Further information on the deletion of personal data can also be provided in the individual data protection information in this data protection declaration.
Changes and updates to the data protection declaration
We ask you to regularly inform yourself about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes to 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 for companies and organizations in this data protection declaration, please note that the addresses may change over time and ask you to check the information before contacting us.
Rights of data subjects
As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:
Right to object: 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 carried out on the basis of Article 6 (1) (e) or (f) of the GDPR; This also applies to profiling based on these provisions. If your personal data is processed for the purpose of 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 connected to such direct advertising.
Right to revoke consent: You have the right to revoke 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 receive 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 that the data concerning you be completed or that incorrect data concerning you be corrected.
Right to deletion and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be deleted immediately or, alternatively, to request a restriction on the processing of the data in accordance with the legal requirements.
Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with legal requirements or to request that it be transmitted to another person responsible.
Complaint to a supervisory authority: In accordance with the legal requirements, you also have the right to lodge a complaint with a supervisory authority, in particular in the member state of your usual place of residence, your place of work or the place of the alleged violation, if you are of the opinion that the processing of your data concerns you personal data violates the GDPR.
Definitions of terms
This section provides an overview of the terms used in this data protection declaration. Many of the terms are taken from the law and are defined primarily in Article 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended primarily to provide understanding. The terms are sorted alphabetically.
Visit action evaluation: “Visit action evaluation” (“conversion tracking”) refers to a process with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users' devices within the websites on which the marketing measures take place and then accessed again on the target website. For example, we can understand whether the advertisements we placed on other websites were successful).
Credit information: Automated decisions are based on automatic data processing without human intervention (e.g. in the case of an automatic rejection of a purchase on account, an online credit application or an online application process without any human intervention. According to Art. 22 GDPR, such automated decisions are only permitted if if those affected give their consent, if they are necessary for the fulfillment of a contract or if national laws allow these decisions.
Cross-device tracking: Cross-device tracking is a form of tracking in which user behavior and interest information is recorded across devices in so-called profiles by assigning users an online identifier. This allows user information to be analyzed for marketing purposes, regardless of the browser or device used (e.g. mobile phones or desktop computers). For most providers, the online identifier is not linked to clear data such as names, postal addresses or email addresses.
IP masking: “IP masking” is a method in which the last octet, i.e. the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing procedures, especially in online marketing
Interest-based and behavioral marketing: Interest- and/or behavioral marketing occurs when users' potential interests in advertisements and other content are predetermined as accurately as possible. This is done based on information about their previous behavior (e.g. visiting and staying on certain websites, purchasing behavior or interaction with other users), which is stored in a so-called profile. Cookies are usually used for these purposes.
Conversion measurement: Conversion measurement is a procedure that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users' devices within the websites on which the marketing measures take place and then accessed again on the target website. For example, we can understand whether the advertisements 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”); A natural person is considered identifiable if he or she 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 one or more special features, which are an expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
Profiling: “Profiling” refers to any type of automated processing of personal data, which consists in using that personal data to identify certain personal aspects relating to a natural person (depending on the type of profiling, this may include information relating to the Age, gender, location data and movement data, interaction with websites and their content, shopping behavior, social interactions with other people) to analyze, evaluate or predict them (e.g. interests in certain content or products, click behavior on a website or the whereabouts). Cookies and web beacons are often used for profiling purposes.
Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, identify at what time visitors visit their website and what content they are interested in. This allows you, for example, to better adapt the content of the website to the needs of your visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyzes of the use of an online offering.
Remarketing: “Remarketing” or “retargeting” is used when, for example, for advertising purposes, 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, for example in advertisements.
Location data: Location data is created when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, a WLAN or similar technical mediators and location determination functions. Location data is used to indicate at which geographically determinable position on earth the respective device is located. Location data can e.g. B. can be used to display map functions or other information dependent on a location.
Tracking: “Tracking” is when the behavior of users can be tracked across multiple online offerings. As a rule, behavioral and interest information is stored in cookies or on the servers of the tracking technology providers with regard to the online offers used (so-called profiling). This information can then be used, for example, to show users advertisements that are likely to match their interests.
Controller: The “controller” 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” means any operation or series of operations carried out on personal data, whether or not by automated means. The term is wide-ranging and includes practically every handling of data, be it collecting, evaluating, storing, transmitting or deleting.
Target group formation: Target group formation (or “custom audiences”) is when target groups are determined for advertising purposes, e.g. displaying advertisements. For example, based on a user's interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which he viewed the products. “Lookalike audiences” (or similar target groups) are when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are usually used for the purpose of forming custom audiences and lookalike audiences.