This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as „data“) within our online offer and the websites, functions and contents connected with it as well as external online presences, such as our social media profile (hereinafter referred to collectively as „online offer“). With regard to the terms used, such as „processing“ or „responsible party“, we refer to the definitions in Art. 4 of the Basic Data Protection Regulation (DSGVO).
Sabine Schrader / Lost in Translation
Owner: Sabine Schrader
Legal notice: https://www.lostintranslation.de/legal/
the types of data processed:
- Stock data (for example, names, addresses).
- Contact data (e.g., e-mail, telephone numbers).
- Content data (e.g., text entries, photographs, videos).
- Usage data (e.g., websites visited, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).
Categories of data subjects
Visitors and users of the online offer (in the following we will refer to the persons concerned collectively as „users“).
Purpose of processing
- Provision of the online offer, its functions, and contents.
- Answering of contact requests and communication with users.
- security measures.
- Reach measuring/marketing
„personal data“ shall mean any information relating to an identified or identifiable natural person (hereinafter referred to as „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. a cookie) or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
„Processing“ means any operation or set of operations that are performed upon personal data, whether or not by automatic means. The term is broad and covers virtually all processing of data.
„pseudonymization“ shall mean the processing of personal data in such a way that the personal data cannot be related to a specific data subject without the use of supplementary information, provided that this supplementary information is kept separate and is subject to technical and organizational measures ensuring that the personal data is not related to an identified or identifiable natural person
„profiling“ shall mean any automated processing of personal data consisting in using such personal data to evaluate certain personal aspects relating to a natural person, in particular in order to analyze or predict aspects relating to the performance of work, economic situation, health, personal preferences, interests, reliability, conduct, location or change of location of that natural person
Controller“ shall mean the natural or legal person, public authority, agency or other bodies which alone or jointly with others determines the purposes and means of the processing of personal data.
„processor“ shall mean any natural or legal person, public authority, agency or other bodies which processes personal data on behalf of the controller
Relevant legal basis
In accordance with Art. 13 DSGVO, we inform you of the legal basis of our data processing. If the legal basis is not stated in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 Para. 1 lit. a and Art. 7 DSGVO, the legal basis for processing for the purpose of fulfilling our services and implementing contractual measures and answering inquiries is Art. 6 Para. 1 lit. b DSGVO, the legal basis for processing for the purpose of fulfilling our legal obligations is Art. 6 Para. 1 lit. c DSGVO and the legal basis for processing for the purpose of safeguarding our legitimate interests is Art. 6 Para. 1 lit. f DSGVO. In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6 paragraph 1 lit. d DSGVO serves as a legal basis.
In accordance with Art. 32 DSGVO and taking into account the state of the art, the implementation costs and the nature, scope, circumstances, and purposes of the processing as well as the varying probability of occurrence and severity of the risk to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.
Such measures shall include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical access to data, as well as access, input, disclosure, safeguarding of availability and segregation of data relating to them. Furthermore, we have established procedures to ensure that data subjects‘ rights are exercised, data is deleted, and we respond to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software, and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly default settings (Art. 25 DSGVO).
Cooperation with contract processors and third parties
If in the course of our processing, we disclose data to other persons and companies (processors or third parties), transfer it to them or otherwise grant them access to the data, this will only be done on the basis of a legal authorization (e.g. if the data must be transferred to third parties, such as payment service providers, in accordance with Art. 6 Para. 1 letter b DSGVO for the fulfillment of the contract), if you have given your consent if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosters, etc.).
If we commission third parties to process data on the basis of a so-called „contract processing agreement“, this is done on the basis of Art. 28 DSGVO.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using the services of third parties or disclosure or transfer of data to third parties, this will only take place if it is done to fulfill our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we will only process or transfer data to a third country if the special requirements of Art. 44 ff. DSGVO. In other words, processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to that of the EU (e.g. for the USA through the „Privacy Shield“) or compliance with officially recognized special contractual obligations (so-called „standard contractual clauses“).
Rights of data subjects
You have the right to request confirmation as to whether or not data in question is being processed and to obtain information about this data and to receive further information and a copy of the data in accordance with Art. 15 DSGVO.
You have accordingly. Art. 16 DPA, you have the right to request the completion of data concerning you or the correction of incorrect data concerning you.
Under Art. 17 DSGVO, you have the right to demand that data concerning you be deleted immediately, or alternatively, under Art. 18 DSGVO, to demand that the processing of the data be restricted.
You have the right to request that the data concerning you which you have made available to us be received in accordance with Art. 20 DSGVO and to demand that it be passed on to other responsible parties.
You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 DSGVO.
Right of withdrawal
You have the right to revoke consents granted in accordance with Art. 7 Para. 3 DSGVO with effect for the future
Right of objection
You can object to the future processing of data concerning you at any time in accordance with Art. 21 DSGVO. In particular, you may object to processing for the purposes of direct advertising.
Cookies and right of objection for direct advertising
Cookies“ are small files that are stored on the user’s computer. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or „session cookies“ or „transient cookies“, are cookies that are deleted after a user leaves an online offer and closes his browser.
In such a cookie, for example, the contents of a shopping cart in an online shop or a login status can be stored. Cookies are described as „permanent“ or „persistent“ if they remain stored even after the browser is closed. For example, the login status can be saved if the user visits it after several days. Likewise, the interests of the users can be stored in such a cookie, which are used for range measurement or marketing purposes. Third-party cookies“ are cookies that are offered by providers other than the person responsible for operating the online service (otherwise, if they are only the cookies of this person, they are called „first-party cookies“).
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional limitations of this online offer.
Deletion of data
The data processed by us will be deleted or restricted in their processing in accordance with articles 17 and 18 DSGVO. Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory storage obligations. If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
According to the legal requirements in Germany, the storage takes place in particular for 10 years according to §§ 147 para. 1 AO, 257 para. 1 nos. 1 and 4, para. 4 HGB (books, records, management reports, accounting vouchers, commercial books, documents relevant for taxation, etc.) and 6 years according to § 257 para. 1 nos. 2 and 3, para. 4 HGB (commercial letters).
In accordance with legal requirements in Austria, the retention is in particular for 7 J in accordance with § 132 para. 1 BAO (accounting documents, vouchers/invoices, accounts, vouchers, commercial documents, statement of income and expenditure, etc.), for 22 years in connection with real estate and for 10 years for documents in connection with electronically provided services, telecommunications, radio and television services which are provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.
Additionally, we process
- Contract data (e.g., subject matter of the contract, duration, customer category).
- Payment data (e.g., bank details, payment history)
from our customers, interested parties and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising, and market research.
We process the data of our customers within the scope of our contractual services, which include conceptual and strategic consulting, campaign planning, software, and design development/consulting or maintenance, implementation of campaigns and processes/handling, server administration, data analysis/consulting services and training services.
We process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter of the contract, duration), payment data (e.g., bank details, payment history), usage and metadata (e.g., in the context of the evaluation and performance measurement of marketing measures). As a matter of principle, we do not process special categories of personal data, unless they are part of a commissioned processing. Those affected include our customers, interested parties and their customers, users, website visitors or employees, as well as third parties. The purpose of processing is to provide contractual services, billing, and customer service.
The legal bases of the processing are derived from Art. 6 para. 1 lit. b DSGVO (contractual services), Art. 6 para. 1 lit. f DSGVO (analysis, statistics, optimisation, security measures). We process data which are necessary for the justification and fulfilment of the contractual services and point out the necessity of their disclosure. Disclosure to external parties is only made if it is necessary within the scope of an order. When processing the data provided to us within the scope of an order, we act in accordance with the instructions of the client and the legal requirements of order processing in accordance with Art. 28 DSGVO and do not process the data for any other purposes than those specified in the order.
We delete the data after the expiry of statutory warranty and comparable obligations. The necessity of storing the data is reviewed every three years; in the case of statutory archiving obligations, the deletion is carried out after the expiry of these obligations (6 years, in accordance with § 257 para. 1 HGB, 10 years, in accordance with § 147 para. 1 AO). In the case of data that has been disclosed to us by the client within the scope of an order, we delete the data in accordance with the specifications of the order, in principle after the end of the order.
Therapeutic services and coaching
We process the data of our clients and interested parties and other clients or contractual partners (uniformly referred to as „clients“) in accordance with Art. 6 Para. 1 lit. b) DSGVO in order to provide them with our contractual or pre-contractual services. The data processed in this context, the nature, scope and purpose of such processing and the necessity of processing it, shall be determined by the underlying contractual relationship. The processed data basically includes the inventory and master data of the clients (e.g. name, address, etc.), as well as contact data (e.g. e-mail address, telephone number, etc.), contractual data (e.g. services used, fees, names of contact persons, etc.) and payment data (e.g. bank details, payment history, etc.).
Within the scope of our services, we may also process special categories of data in accordance with Art. 9 Para. 1 DSGVO, in particular data concerning the health of clients, if necessary with reference to their sexual life or sexual orientation, ethnic origin or religious or ideological convictions. For this purpose, we obtain, if necessary, according to art. 6 para. 1 lit. a., art. 7, art. 9 para. 2 lit. a. DSGVO and otherwise process the special categories of data for purposes of health care on the basis of Art. 9 Paragraph 2 lit. h. DSGVO, Art. 22 Para. 1 No. 1 b. BDSG.
Insofar as it is necessary for the performance of the contract or legally required, we disclose or transfer the clients‘ data within the scope of communication with other specialists, third parties involved in the performance of the contract as necessary or typically, such as billing offices or comparable service providers, insofar as this is necessary for the provision of our services in accordance with Art. 6 Para. 1 lit b. DSGVO, legally according to Art. 6 Paragraph 1 lit. c. DSGVO, our interests or those of our clients in efficient and cost-effective health care as a legitimate interest in accordance with Art. 6 para. 1 lit f. DSGVO or is necessary according to Art. 6 para. 1 lit. d. DSGVO to protect vital interests of clients or another natural person or within the framework of consent according to Art. 6 para. 1 lit. a., Art. 7 DSGVO.
The data is deleted when the data is no longer necessary for the fulfillment of contractual or statutory duties of care as well as the handling of possible warranty and comparable obligations, whereby the necessity of keeping the data is reviewed every three years; in all other respects, the statutory retention obligations apply.
We process the data of our contractual partners and interested parties as well as other principals, customers, clients, clients or contractual partners (uniformly referred to as „contractual partners“) in accordance with Art. 6 Par. 1 lit. b. DSGVO in order to provide them with our contractual or pre-contractual services. The data processed in this context, the nature, scope, and purpose of such processing and the necessity of processing it, shall be determined by the underlying contractual relationship.
The processed data includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g., e-mail addresses and telephone numbers) as well as contract data (e.g., services used, contract contents, contractual communication, names of contact persons) and payment data (e.g., bank details, payment history).
As a matter of principle, we do not process special categories of personal data, unless they are part of a commissioned or contractual processing.
We process data which are necessary for the justification and fulfillment of the contractual services and point out the necessity of their specification if this is not evident for the contractual partners. Disclosure to external persons or companies will only be made if it is necessary within the scope of a contract. When processing the data provided to us within the scope of an order, we act in accordance with the instructions of the client and the legal requirements.
When using our online services, we may store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the interests of the users in protection against misuse and other unauthorized use. As a matter of principle, this data is not passed on to third parties, unless it is necessary to pursue our claims in accordance with Art. 6 Para. 1 lit. f. DSGVO or there is a legal obligation to do so in accordance with Art. 6 Paragraph 1 lit. c. DSGVO.
The data will be deleted when the data is no longer required for the fulfillment of contractual or statutory duties of care or for dealing with any warranty or comparable obligations, whereby the necessity of retaining the data will be reviewed every three years; otherwise the statutory retention obligations apply.
External payment service providers
In the context of the performance of contracts, we use the payment service providers on the basis of Art. 6 para. 1 lit. b. DSGVO. Otherwise, we use external payment service providers on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. DSGVO to offer our users effective and secure payment options.
The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient-related data. These details are required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored by them. 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 payment service providers may transmit the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard 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 the payment transactions, which can be accessed within the respective websites or transaction applications. We also refer to them for further information and the assertion of rights of revocation, information and other rights of affected persons.
Administration, financial accounting, office organization, contact management
We process data within the framework of administrative tasks as well as the organization of our operations, financial accounting, and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process within the scope of providing our contractual services. The basis for processing is Art. 6 Par. 1 lit. c. DSGVO, Art. 6 para. 1 lit. f. DSGVO. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose of and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e. tasks which serve to maintain our business activities, perform our tasks and provide our services. The deletion of data in relation to contractual services and contractual communication corresponds to the information mentioned in these processing activities.
In doing so, we disclose or transfer data to the financial administration, consultants, such as tax consultants or auditors, as well as other fee agencies and payment service providers.
Furthermore, we store information on suppliers, event organisers and other business partners on the basis of our business interests, e.g. for the purpose of contacting them at a later date.
We store this data, which is mostly company-related, permanently.
Economic analyses and market research
In order to run our business economically, to identify market trends, wishes of the contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc. In doing so, we process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. DSGVO, whereby the persons concerned include contractual partners, interested parties, customers, visitors and users of our online offer.
The analyses are carried out for the purpose of business management evaluations, marketing, and market research. In doing so, we can take into account the profiles of registered users with information, e.g. on the services they have used. The analyses serve us to increase user-friendliness, to optimize our offer and business efficiency. The analyses serve solely to us and are not disclosed externally unless they are anonymous analyses with summarized values.
If these analyses or profiles are personal, they will be deleted or made anonymous upon termination by the user, otherwise after two years from the conclusion of the contract. In all other respects, the macroeconomic analyses and general tendency determinations are prepared anonymously wherever possible.
Data protection information in the application procedure
We process the applicant data only for the purpose and within the scope of the application procedure in accordance with the legal requirements. Candidate data is processed for the purpose of fulfilling our (pre-)contractual obligations within the framework of the application procedure within the meaning of Art. 6 para. 1 lit. b. DSGVO Art. 6 para. 1 lit. f. DSGVO if the data processing becomes necessary for us, e.g. within the framework of legal procedures (in Germany, § 26 BDSG also applies).
The application procedure requires that applicants provide us with their application data. If we offer an online form, the necessary applicant data are marked as such, otherwise they result from the job descriptions and basically include personal details, postal and contact addresses and the documents belonging to the application, such as cover letter, CV and certificates. In addition, applicants can voluntarily provide us with additional information.
By submitting their application to us, applicants agree to the processing of their data for the purposes of the application procedure in accordance with the type and scope described in this data protection declaration.
Insofar as special categories of personal data within the meaning of Art. 9 Para. 1 DSGVO are voluntarily communicated as part of the application procedure, their processing is additionally carried out in accordance with Art. 9 Para. 2 lit. b DSGVO (e.g. health data, such as severely disabled status or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 Para. 1 DSGVO are requested from applicants within the framework of the application procedure, their processing is additionally carried out in accordance with Art. 9 Para. 2 letter a DSGVO (e.g. health data if these are necessary for the exercise of the profession).
If made available, applicants can submit their applications to us by means of an online form on our website. The data will be transmitted to us in an encrypted form according to the state of the art.
Applicants can also send us their applications by e-mail. Please note, however, that e-mails are generally not encrypted and that applicants must ensure that they have encrypted themselves. We can therefore not assume any responsibility for the transmission path of the application between the sender and the receipt on our server and therefore recommend rather use an online form or the postal dispatch. This is because instead of applying via the online form and e-mail, applicants still have the option of sending us their application by post.
In the event of a successful application, the data provided by the applicants can be processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicants‘ data is deleted. Applicants‘ data is also deleted if an application is withdrawn, which applicants are entitled to do at any time.
Subject to a justified revocation by the applicants, the data will be deleted after the expiry of a period of six months so that we can answer any follow-up questions regarding the application and meet our obligations to provide evidence under the Equal Treatment Act. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements.
DISQUS commentary function
On the basis of our legitimate interests in efficient, secure and user-friendly comment management in accordance with Art. 6 Para. 1 lit. f. DSGVO, we use the commentary service DISQUS, offered by DISQUS, Inc. 301 Howard St, Floor 3 San Francisco, California- 94105, USA. DISQUS is certified under the Privacy-Shield Agreement and thus offers a guarantee to comply with European data protection law: https://www.privacyshield.gov/participant?id=a2zt0000000TRkEAAW&status=Active.
To use the DISQUS comment function, users can log in using their own DISQUS user account or an existing social media account (e.g. OpenID, Facebook, Twitter or Google). DISQS obtains the user’s login data from the platforms. It is also possible to use the DISQUS comment function as a guest without creating or using user accounts at DISQUS or one of the specified social media providers.
We merely embed DISQUS and its functions on our website, whereby we can influence the comments of the users. However, the users enter into a direct contractual relationship with DISQUS, within the framework of which DISQS processes the comments of the users and is a contact person for any deletion of the users‘ data. In this regard we refer to the data protection declaration of DISQUS: https://help.disqus.com/terms-and-policies/disqus-privacy-policy and also point out to the users that they can assume that DISQUS will save not only the content of the comments but also their IP address and the time of the comment as well as cookies on the users‘ computers and can use them to display advertising. However, users may object to the processing of their data for the purpose of displaying advertisements: https://disqus.com/data-sharing-settings.
Comments and contributions
If users leave comments or other contributions, their IP addresses may be changed on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO for 7 days. This is done for our security if someone leaves illegal content in comments and contributions (insults, prohibited political propaganda, etc.). In this case we can be prosecuted ourselves for the comment or contribution and are therefore interested in the identity of the author.
Furthermore, we reserve the right, on the basis of our legitimate interests in accordance with Art. 6 para. 1 lit. f. DSGVO, we reserve the right to process the information provided by users for the purpose of spam detection.
The data provided in the context of the comments and contributions will be stored permanently by us until the users object.
Retrieval of profile pictures at Gravatar
We use within our online offer and especially in our blog the service Gravatar of Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA.
Gravatar is a service where users can register and store profile pictures and their e-mail addresses. If users leave contributions or comments on other websites (especially blogs) using their e-mail address, their profile pictures can be displayed alongside the contributions or comments. For this purpose, the e-mail address provided by the user is transmitted in encrypted form to Gravatar for the purpose of checking whether a profile is stored for it. This is the sole purpose of transmitting the e-mail address and it will not be used for other purposes but will be deleted afterward.
The use of Gravatar is based on our legitimate interests in the sense of Art. 6 para. 1 lit. f) DSGVO, because with the help of Gravatar we offer the possibility to personalise the contributions and comments of the authors with a profile picture.
If users do not want a user picture linked to their email address to appear in their comments, they should use an email address that is not registered with Gravatar. We would also like to point out that it is also possible to use an anonymous e-mail address or no e-mail address at all, if users do not want their own e-mail address to be sent to Gravatar. Users can completely prevent the transmission of data by not using our comment system.
Recall of emojis and smilies
The use of the emojis is based on our legitimate interests, i.e. interest in an attractive design of our online offer according to Art. 6 para. 1 lit. f. DSGVO.
When contacting us (e.g. via contact form, e-mail, telephone or social media), the user’s details are processed for the purpose of handling the contact request and its processing in accordance with Art. 6 Para. 1 lit. b) DSGVO. The user’s details may be stored in a customer relationship management system („CRM system“) or comparable enquiry organisation.
We delete the enquiries if they are no longer required. We review the necessity every two years; furthermore, the statutory archiving obligations apply.
With the following notes, we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.
Content of the newsletter: We send newsletters, e-mails and other electronic notifications containing advertising information (hereinafter „newsletter“) only with the consent of the recipients or legal permission. Insofar as the contents of the newsletter are specifically described in the context of a registration for the newsletter, they are decisive for the consent of the users. Furthermore, our newsletters contain information about our services and us.
Double-Opt-In and logging: The registration for our newsletter is done in a so-called Double-Opt-In procedure. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with foreign e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider are also logged.
Registration data: To subscribe to the newsletter, it is sufficient to enter your e-mail address. Optionally, we ask you to enter a name for personal contact in the newsletter.
The dispatch of the newsletter and the associated measurement of success are based on the consent of the recipients in accordance with Art. 6 Para. 1 lit. a, Art. 7 DSGVO in conjunction with § 7 Para. 2 No. 3 UWG or, if consent is not required, on our legitimate interests in direct marketing in accordance with Art. 6 Para. 1 lt. f. DSGVO in conjunction with § Art. 7 para. 3 UWG.
The registration procedure is recorded on the basis of our legitimate interests in accordance with Art. 6 Para. 1 lit. f DSGVO. We are interested in the use of a user-friendly and secure newsletter system that serves our business interests as well as the expectations of the users and also allows us to prove consent.
Cancellation/revocation – You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time.
Newsletter – Mailchimp
The newsletters are sent via the mailing service provider „MailChimp“, a newsletter mailing platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view the data protection regulations of the mailing service provider here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC d/b/a MailChimp is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with the European level of data protection (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active). The mail-order service provider is used on the basis of our legitimate interests according to art. 6 para. 1 lit. f DSGVO and an order processing contract according to art. 28 para. 3 sentence 1 DSGVO.
The mail-order service provider may use the recipient’s data in pseudonymous form, i.e. without allocation to a user, to optimize or improve its own services, e.g. for the technical optimization of the dispatch and presentation of the newsletters or for statistical purposes. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.
Newsletter – a measurement of success
The newsletters contain a so-called „web-beacon“, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a mailing service provider, from their server. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and time of retrieval are initially collected.
This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined by means of the IP address) or the access times. Statistical surveys also include 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 dispatch service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
Unfortunately, it is not possible to cancel the performance measurement separately, in which case the entire newsletter subscription must be canceled.
Hosting and e-mail dispatch
The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services, and technical maintenance services which we use for the purpose of operating this online offer.
For this purpose, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer in accordance with Art. 6 para. 1 lit. f DSGVO in conjunction with Art. 28 DSGVO (conclusion of contract processing agreement).
Collection of access data and log files
We, or our hosting provider, on the basis of our legitimate interests as defined in Art. 6 para. 1 lit. f. DSGVO data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited site), IP address and the requesting provider.
For security reasons (e.g. to clarify misuse or fraud), log file information is stored for a maximum of 7 days and then deleted. Data whose further storage is required for evidential purposes is excluded from deletion until final clarification of the respective incident.
Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf in order to evaluate the use of our website by users, to compile reports on the activities within this website and to provide us with further services associated with the use of this website and the Internet. The processed data can be used to create pseudonymous user profiles of the users.
We only use Google Analytics with activated IP anonymization. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transferred to a Google server in the USA and shortened there.
The IP address transmitted by the user’s browser is not merged with other Google data. Users can prevent the storage of cookies by adjusting their browser software accordingly; users can also prevent the collection of data generated by the cookie and related to their use of the online offer to Google and the processing of this data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
The personal data of users will be deleted or anonymized after 14 months.
Target group formation with Google Analytics
We use Google Analytics in order to display the advertisements placed within Google’s advertising services and those of its partners only to those users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products determined by the websites visited) which we transmit to Google (so-called „remarketing“ or „Google Analytics Audiences“). With the help of remarketing audiences, we also want to ensure that our ads match the potential interest of users.
Google AdWords and conversion measurement
On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, („Google“).
Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
We use the Google „AdWords“ online marketing process to place ads on the Google advertising network (e.g., in search results, in videos, on web pages, etc.) to be displayed to users who have a presumed interest in the ads. This allows us to better target ads for and within our online services to show users only ads that potentially match their interests. For example, if a user is shown ads for products that he or she has shown an interest in on other websites, this is called „remarketing“. For these purposes, when you visit our and other websites where the Google advertising network is active, Google executes code directly from Google and (re)marketing tags (invisible graphics or code, also known as „web beacons“) are embedded in the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies).
This file records which websites the user has visited, what content he is interested in and which offers the user has clicked on, as well as technical information about the browser and operating system, referring websites, visiting time and other information about the use of the online offer.
We also receive an individual „conversion cookie“. The information obtained with the help of the cookie is used by Google to compile conversion statistics for us. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page with a conversion tracking tag. We do not receive any information that personally identifies users.
User data is processed pseudonymously within the Google advertising network. This means that Google does not store and process, for example, the name or e-mail address of the user, but processes the relevant data cookie-related within pseudonymous user profiles. This means that from Google’s point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who that cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymization. The information collected about users is transmitted to Google and stored on Google’s servers in the USA.
Online presence in social media
We maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services.
We point out that user data may be processed outside the European Union. This can result in risks for the users because the enforcement of the users‘ rights could be made more difficult. With regard to US providers who are certified under the Privacy-Shield, we would like to point out that they thereby undertake to comply with the data protection standards of the EU.
Furthermore, user data is generally processed for market research and advertising purposes. For example, user profiles can be created from the user behavior and the resulting interests of the users. The user profiles can, in turn, be used, for example, to place advertisements inside and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users‘ computers, in which the usage behaviour and interests of the users are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
The processing of users‘ personal data is based on our legitimate interests in effective user information and communication with users in accordance with Art. 6 Para. 1 lit. f. DSGVO. If the users are asked by the respective providers of the platforms to give their consent to the aforementioned data processing, the legal basis of the processing is Art. 6 para. 1 lit. a., Art. 7 DSGVO.
For a detailed presentation of the respective processing and the possibilities of objection (opt-out), we refer to the following linked information of the providers.
Also in the case of requests for information and the assertion of user rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. Should you nevertheless need help, please contact us.
- Google/ YouTube (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – Datenschutzerklärung: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated, Datenschutzschild: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – Datenschutzerklärung/ Opt-Out: http://instagram.com/about/legal/privacy/.
- Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) – Datenschutzerklärung: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization, Datenschutzschild: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.
- Pinterest (Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA) – Datenschutzerklärung/ Opt-Out: https://about.pinterest.com/de/privacy-policy.
- LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Irland) – Datenschutzerklärung https://www.linkedin.com/legal/privacy-policy , Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active.
- Xing (XING AG, Dammtorstraße 29-32, 20354 Hamburg, Deutschland) – Datenschutzerklärung/ Opt-Out: https://privacy.xing.com/de/datenschutzerklaerung.
- Wakalet (Wakelet Limited, 76 Quay Street, Manchester, M3 4PR, Vereinigtes Königreich) – Datenschutzerklärung/ Opt-Out: https://wakelet.com/privacy.html.
- Soundcloud (SoundCloud Limited, Rheinsberger Str. 76/77, 10115 Berlin, Deutschland) – Datenschutzklärung/ Opt-Out: https://soundcloud.com/pages/privacy.