For the sake of simplicity, in this text I use “we” as a personal pronoun, even if it refers to me as an individual.
- contact information (e.g. e-mail)
- content data (e.g. text input)
- usage data (e.g. websites visited, interest in content, access times)
- meta / communication data (e.g. device information, IP addresses).
Visitors and users of our online offerings (hereinafter generally referred to as “users”).
Purpose of processing
- provision of our online offers, its functions and contents
- answering contact requests and communicating with users
- safety measures
- audience measurement / marketing
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter the “data subject”); a natural person is considered as identifiable, if the person can be identified directly or indirectly, in particular by assigning the person to an identifier such as a name, an identification number, locational data, an online identifier (e.g. cookie) or one or more special features that express the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.
“Processing” is any process performed with or without the aid of automated procedures or any such process associated with personal data. The term goes far and includes virtually every handling of data.
“Pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without additional information being provided, in case such additional information is kept separate and is subject to technical and organizational measures to ensure that the personal data can not be assigned to an identified or identifiable natural person.
“Profiling” is any kind of automated processing of personal data which involves the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular analyzing or predicting aspects relating to job performance, economic situation, health, personal preferences, interests, reliability, behavior, whereabouts or relocation of that natural person.
“Responsible person” is any natural or legal person, public authority, body or body that decides, alone or in concert with others, on the purposes and means of processing personal data.
“Processor” means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the responsible person.
Relevant legal bases
In accordance with article 13 GDPR, we inform you about the legal basis of our data processing. For users within the scope of the General Data Protection Regulation (GDPR), i. the EU and the EEC, unless the legal basis in the data protection declaration is not mentioned, following applies:
The legal basis for obtaining consent is article 6 para. 1 a) and article 7 GDPR;
The legal basis for processing data for the fulfillment of our services and the performance of contractual measures as well as the answer to inquiries is article 6 para. 1 b) GDPR;
The legal basis for processing to fulfill our legal obligations is article 6 para. 1 c) GDPR;
In the event that vital interests of the data subject or another natural person require the processing of personal data, article 6 para. 1 d) GDPR serves as legal basis.
The legal basis for processing data required to perform a task in public interest or in execution of an official authority, which has been delegated to the controller is article 6 para. 1 e) GDPR.
The legal basis for processing data in order to safeguard our legitimate interests is article 6 para. 1 f) GDPR.
The processing of data for purposes other than those to which they have been granted for, is determined according to the specifications of article 6 para. 4 GDPR.
The processing of special categories of data (according to article 9 para. 1 GDPR) is determined by the specifications in article 9 para. 2 GDPR.
We will take appropriate technical and organizational measures in accordance with legal requirements, taking into account current state of the art technologies, implementation costs and the nature, scope, circumstances and purposes of the processing as well as the likelihood and sererity of the risk to rights and freedom of natural persons to ensure a level of protection appropriate to the risk.
Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their (digital) access, input, disclosure, availability and separation.
Collaboration with external processors, controllers and third parties
If, in the course of our data processing, we disclose data to other persons and companies (external processors, joint controllers or third parties), transmit data to them or otherwise grant them access to this data, this will only be done on the basis of a legal permission (e.g. if data transmission to third parties, such as payment service providers, is required to fulfill the contract), users have consented to it, a legal obligation forces us to do so or on the basis of our legitimate interests (e.g. the use of agents, web hosts, etc.).
If we disclose data to other companies in our corporate group, transmit them or otherwise grant access to them, this is done in particular for administrative purposes as our legitimate interest and, moreover, on a basis that complies with legal requirements.
Data transmissions 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 Swiss Confederation) or in the context of the use of third party services or disclosure/transfer of data to other persons or companies, this will only happen if it is 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 process or leave the data in a third country only in the presence of legal requirements. That means the processing is e.g. based on specific guarantees, such as the officially recognized level of data protection in the EU (for example, the US Privacy Shield) or compliance with officially recognized specific contractual obligations.
Rights of data subjects/affected persons
You have the right to ask for confirmation as to whether the data in question is being processed and for information about this data as well as for further information and copying of the data in accordance with legal requirements.
You have the right, in accordance with the legal requirements, to demand the completion of data concerning you or the correction of incorrect data concerning you.
In accordance with the statutory provisions, you have the right to demand a immediate deletion of the relevant data, or alternatively to demand a restriction of the processing of the data in accordance with the statutory provisions.
You have the right to request data relating to you that has been provided to us, be obtained in accordance with legal requirements and to request their transmission to other persons responsible.
You also have the right, in accordance with the legal requirements, to submit a complaint to the responsible supervisory authority.
Right to cancel given consent
You have the right to withdraw granted consent with effect for the future.
Right of objection
You may refuse to the future processing of your data in accordance with legal requirements at any time. The objection may in particular be made against processing for direct marketing purposes.
Cookies and right of objection for direct marketing
The data processed by us will be deleted or restricted in accordance with legal requirements. Unless explicitly stated in this privacy statement, the data stored by us will be deleted as soon as they are no longer necessary for their intended purpose and the deletion does not conflict with any statutory storage requirements.
Unless the data is not deleted because it is required for other and legitimate purposes, its processing will be restricted. That means, the data will be locked and will not be processed for other purposes. This applies, for example, for data that must be kept for commercial or tax reasons.
When contacting us (for example, by using a contact form, e-mail, telephone or via social media) the information of the user to process the contact request and its processing are processed in accordance with article 6 para. 1 b) GDPR (in the context of contractual / pre-contractual relationships), article 6 para. 1 f) (other requests) GDPR. User information can be stored in a Customer Relationship Management System (“CRM System”) or similar request organization systems.
We delete requests, if they are no longer required. We check the requirement every two years; Furthermore, the legal archiving obligations apply.
Hosting and e-mailing
The hosting services we use are designed to provide the following services: infrastructure and platform services, computing capacity, storage and database services, e-mailing, security, and technical maintenance services we use to operate this online service.
With this 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 to this online service on the basis of our legitimate interests in an efficient and secure provision of this online service in accordance to article 6 para. 1 f) GDPR, article 28 GDPR (conclusion of contract processing contract).
Collection of access data and log files
We, or our hosting provider, collects on the basis of our legitimate interests in accordance to article 6 para. 1 f) GDPR Data on every access to the server on which this service is located (so-called server log files). This access data includes the name of the accessed web page, file, date and time of access, amount of data transferred, notification on successful access, browser agent and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Logfile information is stored for security reasons (for example, to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Data whose further retention is required for evidential purposes shall be exempted from the cancellation until final clarification of the incident.