Data Protection Policy
Introduction
With the following data protection declaration we would like to explain to you which types of your personal data (hereinafter also referred to as “data”) we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both in the context of the provision of our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).
As of December 17, 2019
Content overview
- Introduction
- Responsible person
- Overview of the processing
- Relevant legal bases
- Safety measures
- Transmission and disclosure of personal data
- Data processing in third countries
- Use of cookies
- Commercial and business services
- Payment service provider
- Blogs and publication media
- Contact
- Provision of the online offer and web hosting
- Cloud services
- Newsletter and broad communication
- Online marketing
- Affiliate Programs and Affiliate Links
- Presence in social networks
- Plugins and embedded functions as well as content
- Deletion of data
- Change and update of the data protection declaration
- Data Subject Rights
- Definitions of terms
Responsible person
Arnold, Kienreich
Krumme Straße, 70
10627, Berlin, Germany
E-mail address: arnold[at]vegansandfriends.com
Overview of the 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. text input, photographs, videos).
- 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).
- Contract data (e.g. subject of the contract, duration, customer category).
- Payment data (e.g. bank details, invoices, payment history).
Categories of data subjects
- Employees (e.g. employees, applicants, former employees).
- Business and contractual partners.
- Interested persons.
- Communication partners.
- Customers.
- Users (e.g. website visitors, users of online services).
Purposes of processing
- Affiliate tracking.
- Provision of our online offer and user-friendliness.
- Visit action evaluation.
- Office and organizational procedures.
- Direct marketing (e.g. by email or post).
- Feedback (e.g. collecting feedback via an online form).
- Interest-based and behavioral marketing.
- Contact requests and communication.
- Conversion measurement (measurement of the effectiveness of marketing measures).
- Profiling (creation of user profiles).
- Remarketing.
- Range measurement (e.g. access statistics, recognition of returning visitors).
- Safety measures.
- Tracking (e.g. interest / behavior-based profiling, use of cookies).
- Contractual activities and services.
- Management and answering of inquiries.
Relevant legal bases
In the following we share the legal basis of the General Data Protection Regulation (GDPR), on the basis of which we process the personal data. Please note that in addition to the regulations of the GDPR, the national data protection requirements in your or our country of residence and domicile may apply.
- Consent (Art. 6 Para. 1 S. 1 lit. a GDPR) – The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
- Fulfillment of contracts and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b GDPR) – The processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Legal obligation (Art. 6 Para. 1 S. 1 lit. c. GDPR) – The processing is necessary for compliance with a legal obligation to which the controller is subject.
- Protection of vital interests (Art. 6 Para. 1 S. 1 lit. d. GDPR) – Processing is necessary to protect the vital interests of the data subject or another natural person.
- Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national data protection regulations apply in Germany. This includes in particular the law on the protection against misuse of personal data during data processing (Federal Data Protection Act – BDSG). The BDSG contains in particular special regulations on the right to information, the right to erasure, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases including profiling. It also regulates data processing for the purpose of employment (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states can apply.
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 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, securing the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, transfer, securing of availability and their separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to the threat to the data. Furthermore, we consider the protection of personal data already in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and data protection-friendly default settings.
SSL encryption (https): We use SSL encryption to protect your data transmitted via our online services. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.
Transmission and disclosure of personal data
As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons or they are disclosed to them. The recipients of this data can 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 a case, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.
Data processing in third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing in the context of the use of third-party services or the disclosure or transmission of data to other persons, offices or companies takes place, this is only done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transmission, we only process or allow the data to pass through third countries with a recognized level of data protection, including the US processors certified under the “Privacy Shield”, or on the basis of special guarantees, such as contractual obligations Process so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data -protection / international-dimension-data-protection_en).
Use of cookies
Cookies are text files that contain data from websites or domains visited and are stored on the user’s computer by a browser. A cookie is primarily used to store information about a user during or after their visit to an online offer. The stored information can include, for example, the language settings on a website, the login status, a shopping cart or the point where a video was viewed. The term cookies also includes other technologies that perform the same functions as cookies (e.g. if user information is stored using pseudonymous online identifiers, also known as “user IDs”)
A distinction is made between the following cookie types and functions:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
- Permanent cookies: Permanent cookies are saved 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 ourselves.
- Third-party cookies: Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
- Necessary (also: essential or absolutely required) cookies: On the one hand, 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: In addition, cookies are usually also used in the context of range measurement and when the interests of a user or his behavior (e.g. viewing certain content, using functions, etc.) on individual websites get saved in a user profile. Such profiles are used to show users, for example, content that corresponds to their potential interests. This process is also known as “tracking”, i.e. following up the potential interests of users. Insofar as we use cookies or “tracking” technologies, we will inform you separately in our data protection declaration or in the context of obtaining consent.
Notes on legal bases: The legal basis on which we process your personal data with the help of cookies depends on whether we ask for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in a business operation of our online offer and its improvement) or, if the use of cookies is necessary, to fulfill our contractual obligations.
General information on revocation and objection (opt-out): Depending on whether 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 explain your objection using the settings of your browser, e.g. by deactivating the use of cookies (which can also restrict the functionality of our online offer). 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 http://optout.aboutads.info and http://www.youronlinechoices.com/. In addition, you can receive further objection notices in the context of the information on the service providers and cookies used.
Processing of cookie data on the basis of consent: Before we process or have data processed in the context of the use of cookies, we ask the users for consent that can be revoked at any time. Before the consent has not been given, cookies may be used that are necessary for the operation of our online offer. They are used on the basis of our interest and the interest of users in the expected functionality of our online offer.
- Processed data types: usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information, IP addresses).
- Affected persons: 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”) in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with the contractual partners (or pre-contractual), e.g. to answer 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 as well as 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 contractual partners (e.g. to telecommunications, transport and other auxiliary services and subcontractors involved , 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 scope of this data protection declaration.
We inform the contractual partners before or as part of the data collection, e.g. in online forms, by special labeling (e.g. colors) or symbols (e.g. asterisks or similar), or personally, which data are required for the aforementioned purposes.
We delete the data after the expiry of statutory warranty and comparable obligations, i.e. basically after 4 years, unless the data is stored in a customer account, e.g. as long as it must be kept for archiving reasons for legal reasons (e.g. for Tax purposes usually 10 years). We delete data disclosed to us by the contractual partner in the context of an order in accordance with the specifications of the order, generally after the end of the order.
Insofar as 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 offer (e.g. customer or user account, in short “customer account”). If the registration of a customer account is required, contractual partners will be informed of this as well as the information required for registration. The customer accounts are not public and cannot be indexed by search engines. As part of the registration as well as subsequent logins and uses of the customer account, we save the IP addresses of the customers along with the access times in order to be able to prove the 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, subject to their retention being required for legal reasons. It is the customer’s responsibility to secure their data if the customer account is terminated.
Shop and e-commerce: We process our customers’ data in order to enable them to select, purchase or order the selected products, goods and related services, as well as their payment and delivery or execution.
The information required is marked as such in the context of the order or comparable purchase process and includes the information required for delivery or provision and billing as well as contact information in order to be able to hold any consultation.
Publication activity: We process the data from our contact partners, interview partners and other persons who are the subject of our journalistic, editorial, journalistic and related activities. In this context, we refer to the application of protective regulations for freedom of expression and freedom of the press in accordance with Art. 85 GDPR in conjunction with the respective national laws. The processing serves to fulfill our order activities and otherwise takes place in particular on the basis of the general interest in information and media offers.
- Processed data types: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact details (e.g. e-mail, telephone numbers), contract data (e.g. subject 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: contractual services, contact inquiries and communication, office and organizational procedures, administration and answering inquiries, security measures.
- Legal basis: Contract fulfillment 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 S. 1 lit. f. GDPR).
Payment service provider
In the context of contractual and other legal relationships, due to legal obligations or otherwise based on our legitimate interests, we offer the persons concerned 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 provider includes inventory data such as name and address, bank data such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, sum 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 will be transmitted by the payment service provider to credit reporting agencies. The purpose of this transmission is to check your identity and creditworthiness. We refer to the terms and conditions and the data protection information of the payment service providers.
The terms and conditions and data protection notices of the respective payment service providers, which can be called up within the respective websites or transaction applications, apply to payment transactions. We refer to this also for the purpose of further information and assertion of revocation, information and other rights of data subjects.
- Processed data types: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of the contract, duration, 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: contractual performance and service.
- Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Par. 1 S. 1 lit. f. GDPR).
Used services and service providers:
- Klarna / instant bank transfer: payment services; Service provider: Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden; Website: https://www.klarna.com/en; Data protection declaration: https://www.klarna.com/international/privacy-policy.
- PayPal: payment services and solutions (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Website: https://www.paypal.com/en; Data protection declaration: https://www.paypal.com/uk/webapps/mpp/ua/privacy-full.
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). The data of the readers are only processed for the purposes of the publication medium to the extent that it is necessary for its presentation and communication between authors and readers or for reasons of security. We also refer to the information on the processing of visitors to our publication medium in the context of this data protection notice.
Comments and contributions: If users leave comments or other contributions, their IP addresses can be saved on the basis of our legitimate interests. This is done for our safety if someone leaves illegal content in comments and posts (insults, prohibited political propaganda, etc.). In this case we can be prosecuted for the comment or contribution ourselves and are therefore interested in the identity of the author.
We also reserve the right to process user information for the purpose of spam detection on the basis of our legitimate interests.
On the same legal basis, we reserve the right to save the IP addresses of users for the duration of surveys and to use cookies in order to avoid multiple votes.
The personal information communicated in the context of the comments and contributions, any contact and website information as well as the content will be stored permanently by us until the user objects.
Gravatar profile pictures: We use the Gravatar service within our online offer and in particular in the blog.
Gravatar is a service to which users can log in and store profile pictures and their email addresses. If users leave posts or comments on other online presences (especially in blogs) with the respective e-mail address, their profile pictures can be displayed next to the posts or comments. For this purpose, the email address provided by the users is transmitted in encrypted form to Gravatar in order to check whether a profile has been saved for them. This is the sole purpose of transmitting the email address. It will not be used for other purposes, but will be deleted afterwards.
Gravatar is used on the basis of our legitimate interests, since with the help of Gravatar we offer authors of posts and comments the opportunity to personalize their posts with a profile picture.
By displaying the images, Gravatar learns the IP address of the user, as this is necessary for communication between a browser and an online service.
If users do not want a user picture linked to their Gravatar email address to appear in the comments, they should use an email address that is not stored with Gravatar to comment. We also point out that it is also possible to use an anonymous e-mail address or no e-mail address at all if the 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.
- Processed data types: inventory data (e.g. 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).
- Affected persons: users (e.g. website visitors, users of online services).
- Purposes of processing: Contractual activities and services, feedback (e.g. collecting feedback via an online form), security measures, administration and answering of inquiries, provision of our online offer and user-friendliness.
- Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. S. 1 lit. a. GDPR), protection of vital interests (Art. 6 para. 1 S. 1 lit. d. GDPR).
Used services and service providers:
- Profile pictures of Gravatar: Profile pictures; Service provider: Automattic Inc., 60 29th Street # 343, San Francisco, CA 94110, USA; Website: https://automattic.com; Privacy policy: https://automattic.com/privacy.
- UpdraftPlus: Backup software and backup storage; Service provider: Simba Hosting Ltd., 11, Barringer Way, St. Neots, Cambs., PE19 1LW, GB; Website: https://updraftplus.com/.
Contact
When you contact us (e.g. via the contact form, email, phone or via social media), the details of the inquiring person are processed, insofar as this is necessary to answer the contact inquiries and any requested measures.
The answering of contact inquiries in the context 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 legitimate interests in answering the inquiries.
- Processed data types: inventory data (e.g. 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).
- Affected persons: communication partner.
- Purposes of processing: contact requests and communication.
- Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Par. 1 S. 1 lit. f. GDPR).
Provision of the online offer and web hosting
In order to be able to provide our online offer safely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we can use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.
The data processed as part of the provision of the hosting offer can include all information relating to the users of our online offer that is generated in the context of use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or from websites.
E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as other information regarding the sending of e-mails (e.g. the providers involved) and the content of the respective e-mails are processed. The aforementioned data can also be processed for the purpose of recognizing SPAM. Please note that emails on the internet are generally not sent in encrypted form. As a rule, e-mails are encrypted on the transport route, but (if no so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the receipt on our server.
Collection of access data and log files: We (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files can include the address and name of the websites and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP Addresses and the requesting provider.
The server log files can be used on the one hand for security purposes, e.g. to avoid overloading the server (especially in the case of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the load on the servers and their stability.
- Processed data types: content data (e.g. text input, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information, IP addresses).
- Affected persons: users (e.g. website visitors, users of online services).
- Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Cloud services
We use software services (so-called “cloud services”, also known as “software as a service”) that are accessible via the Internet and run on the servers of their providers for the following purposes: document storage and management, calendar management, sending e-mails, spreadsheets and presentations, exchange of documents, content and information with specific recipients or publication of websites, forms or other content and information as well as chats and participation in audio and video conferences.
In this context, personal data can be processed and stored on the provider’s servers, insofar as these are part of communication processes with us or otherwise processed by us, as set out in this data protection declaration. This data can include, in particular, master data and contact details of the users, data on transactions, contracts, other processes and their content. The cloud service providers also process usage data and metadata, which they use for security purposes and for service optimization.
If we use cloud services to provide forms or other documents and content for other users or publicly accessible websites, the providers can place cookies on the users’ devices for the purposes of web analysis or to remember user settings (e.g. in the case of media control).
Notes on legal bases: If we ask for consent to the use of cloud services, the legal basis for processing is consent. Furthermore, their use can be part of our (pre) contractual services, provided that the use of cloud services has been agreed in this context. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient and secure administration and collaboration processes).
- Processed data types: inventory data (e.g. 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).
- Affected persons: customers, employees (e.g. employees, applicants, former employees), interested parties, communication partners.
- Purposes of processing: office and organizational procedures.
- Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Used services and service providers:
Google Cloud Services: Cloud Storage 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://cloud.google.com/; Data protection declaration: https://www.google.com/policies/privacy, security information: https://cloud.google.com/security/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000000001L5AAI&status=Aktive; Standard contractual clauses (ensuring the level of data protection when processing in third countries): https://cloud.google.com/terms/data-processing-terms; Additional information on data protection: https://cloud.google.com/terms/data-processing-terms.
Newsletter and broad communication
We send newsletters, e-mails and other electronic notifications (hereinafter “newsletter”) only with the consent of the recipient or legal permission. If the content of the newsletter is specifically described when registering for the newsletter, they are decisive for the consent of the user. In addition, our newsletters 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 can ask you to provide a name for the purpose of addressing you personally in the newsletter, or to provide further information if this is necessary for the purposes of the newsletter.
Double opt-in procedure: The registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registering you will receive an email in which you will be asked to confirm your registration. This confirmation is necessary so that nobody can register with someone else’s email address. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation times as well as the IP address. Changes to your data stored by the shipping service provider are also logged.
Deletion and restriction of processing: We can save the unsubscribed email 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 previous existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a blacklist for this purpose alone.
The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving that it has proceeded properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure mailing system.
Notes on legal bases: The newsletter is sent on the basis of the recipient’s consent 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. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded based on our legitimate interests to prove that it was carried out in accordance with the law.
Contents: Information about us, our services, promotions and offers.
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 its server Information such as information about the browser and your system, as well as your IP address and the time of access, are collected.
This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes the determination of whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our endeavor nor, if used, that of the shipping service provider to observe 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 take place, subject to the expressed consent of the user, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves both our business interests and the expectations of the users.
A separate revocation of the success measurement is unfortunately not possible, in this case the entire newsletter subscription must be canceled or objected.
- Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, 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 partner.
- Purposes of processing: direct marketing (e.g. by 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).
- Objection option (opt-out): You can cancel the 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 given above, preferably e-mail.
Used services and service providers:
- 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; Data protection declaration: https://mailchimp.com/legal/privacy/; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active.
Online marketing
We process personal data for online marketing purposes, which can 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 processes are used, by means of which the user information relevant to the presentation of the aforementioned content is saved. This information can include 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 on usage times. If users have consented to their location data being collected, this can also be processed.
The IP addresses of the users are also saved. However, we use available IP masking procedures (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) are stored in the online marketing process, but pseudonyms. This means that we and 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 the cookies or by means of similar processes. These cookies can later generally also be read out on other websites that use the same online marketing process, analyzed for the purpose of displaying content and supplemented with additional data and stored on the server of the online marketing process provider.
As an exception, clear data can be assigned to the profiles. This is the case if the users are e.g. members of a social network whose online marketing method we use and the network connects the profiles of the users in the aforementioned information. We ask you to note that users can make additional agreements with the providers, e.g. through consent during registration.
In principle, we only have access to summarized information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e., for example, to a contract with us. The conversion measurement is used solely to analyze the success of our marketing measures.
Unless otherwise stated, we ask you to assume that the 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 on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would like to draw your attention to the information on the use of cookies in this data protection declaration.
- Processed data types: usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information, IP addresses).
- Affected persons: users (e.g. website visitors, users of online services), interested parties.
- Purposes of processing: Tracking (e.g. interest / behavior-related profiling, use of cookies), remarketing, visitor action evaluation, interest-based and behavior-related marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), range measurement (e.g. access statistics, recognition of recurring Visitors).
- 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).
- Objection option (opt-out): We refer to the data protection notices of the respective providers and the options for objection given to the providers (so-called “opt-out”). If no explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. However, this can restrict the functions of our online offer. 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-regional: http://optout.aboutads.info.
Used services and service providers:
- 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/; Data protection declaration: https://policies.google.com/privacy; Privacy Shield (ensuring data protection level when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active Opposition option (opt-out): Opt-out plug-in: http://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.
Affiliate Programs and Affiliate Links
In our online offer, we include so-called affiliate links or other references (which may include discount codes, for example) to the offers and services of third-party providers (collectively referred to as “affiliate links”). If users follow the affiliate links or then take advantage of the offers, we can receive a commission or other benefits from these third-party providers (collectively referred to as “commission”).
In order to be able to track whether the users have taken advantage of the offers of an affiliate link used by us, it is necessary for the respective third party provider to find out that the users have followed an affiliate link used within our online offer. The assignment of the affiliate links to the respective business deals or to other promotions (e.g. purchases) is used solely for the purpose of commission accounting and is canceled as soon as it is no longer required for the purpose.
For the purposes of the aforementioned assignment of affiliate links, the affiliate links can be supplemented with certain values that are part of the link or that can be stored in some other way, e.g. in a cookie. The values may include the starting website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer and an online identifier of the user.
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. Furthermore, their use can be part of our (pre) contractual services, provided that the use of third-party providers has been agreed in this context. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would like to draw your attention to the information on the use of cookies in this data protection declaration.
- Processed data types: contract data (e.g. subject of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information, IP addresses).
- Affected persons: users (e.g. website visitors, users of online services).
- Processing purposes: affiliate tracking.
- Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S. . 1 lit. f. GDPR).
Presence in social networks
We maintain an online presence within social networks in order to communicate with the users who are active there or to offer information about us there.
We would like to point out that user data can be processed outside of the European Union. This can result in risks for the user because, for example, the enforcement of user rights could be made more difficult. With regard to US providers who are certified under the Privacy Shield or who offer comparable guarantees of a secure level of data protection, we would like to point out that they undertake to comply with EU data protection standards.
In addition, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on user behavior and the resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements inside 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 the interests of the users are stored. Furthermore, data can be stored in the usage profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
For a detailed description of the respective forms of processing and the possibilities of 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 rights of data subjects, we point out that these can be most effectively asserted with the providers. Only the providers have access to the data of the users and can take appropriate measures and provide information. If you still need help, you can contact us.
- Processed data types: inventory data (e.g. 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).
- Affected persons: users (e.g. website visitors, users of online services).
- Purposes of processing: Contact requests and communication, tracking (e.g. interest / behavior-related profiling, use of cookies), remarketing, range measurement (e.g. access statistics, recognition of returning visitors).
- Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Used services and service providers:
- Instagram: social network; Service provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Data protection declaration: http://instagram.com/about/legal/privacy.
- Facebook: social network; Service provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, 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; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Opposition option (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.
- Pinterest: social network; Service provider: Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA ,; Website: https://www.pinterest.com; Data protection declaration: https://about.pinterest.com/de/privacy-policy; Opposition option (opt-out): https://about.pinterest.com/de/privacy-policy.
Plugins and embedded functions and content
We incorporate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These can be graphics, videos or social media buttons as well as posts (hereinafter uniformly referred to as “content”).
The integration always presupposes that the third-party providers of this content process the IP address of the user, since without the IP address they would not be able to send the content to their browser. The IP address is therefore required for the display of this content or functions. We strive to only use content whose respective providers only use the IP address to deliver the content. Third-party providers can 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 contain, among other things, technical information on the browser and operating system, the websites to be referred to, the time of visit and other information on the use of our online offer, 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 on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would like to draw your attention to the information on the use of cookies in this data protection declaration.
Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offering that we access from servers of other providers (e.g. function libraries that we use for the purpose of displaying or user-friendliness of our online offering). The respective providers collect the IP address of the user and can process it for the purposes of transmitting the software to the user’s browser and for security purposes as well as to evaluate and optimize their offer.
- Processed data types: usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information, IP addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos) , Inventory data (e.g. names, addresses).
- Affected persons: users (e.g. website visitors, users of online services), communication partners.
- Purposes of processing: Provision of our online offer and user-friendliness, contractual services and services, contact inquiries and communication, direct marketing (e.g. by email or post), tracking (e.g. interest / behavior-based profiling, use of cookies), interest-based and behavior-related marketing, profiling (Creation of user profiles), security measures, administration and answering inquiries.
- Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR), consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), fulfillment of contracts and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR).
Used services and service providers:
- Facebook Social Plugins: Facebook Social Plugins – This can include, for example, content such as images, videos or texts and buttons with which users can share content from this online offer within Facebook. The list and the appearance of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/; Service provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, 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; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Opposition option (opt-out): Settings for advertisements: https://www.facebook.com/settings?tab=ads.
- Google Maps: We integrate the maps from the “Google Maps” service provided by Google. The processed data may include, in particular, the users’ IP addresses and location data, which, however, are not collected without their consent (usually in the context 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://maps.google.de; Data protection declaration: https://policies.google.com/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TRkEAAW&status=Active; Opposition option (opt-out): Opt-out plug-in: http://tools.google.com/dlpage/gaoptout?hl=de, settings for displaying advertisements: https://adssettings.google.com/authenticated.
- Instagram plugins and buttons: Instagram plugins and buttons – this may include, for example, content such as images, videos or text and buttons with which users can share content from this online offer within Instagram. Service provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Data protection declaration: http://instagram.com/about/legal/privacy.
- Pinterest plugins and buttons: Pinterest 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 offer within Pinterest. Service provider: Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA; Website: https://www.pinterest.com; Data protection declaration: https://about.pinterest.com/de/privacy-policy.
- Twitter plugins and buttons: Twitter plugins and buttons – this may include, for example, content such as images, videos or text and buttons with which users can share content from this online offer 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; 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; Data protection declaration: https://policies.google.com/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; Opposition option (opt-out): Opt-out plug-in: http://tools.google.com/dlpage/gaoptout?hl=de, settings for displaying advertisements: 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 permitted for processing is revoked or other permissions are no longer applicable (e.g. if the purpose of processing this data is no longer applicable or is not required for the purpose).
If the data is not 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 law 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 found in the individual data protection information of this data protection declaration.
Change and update of the data protection declaration
We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as the changes to the data processing carried out by us 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 of 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.
Data Subject Rights
As the data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 18 and 21 GDPR:
- Right of objection: You have the right to object at any time to the processing of your personal data based on Art. 6 Paragraph 1 lit. e or f GDPR for reasons that arise from your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you are processed in order to operate direct mail, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such advertising; this also applies to profiling insofar as it is connected to such direct advertising.
- Right to withdraw consent: You have the right to withdraw 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 request information about this data as well as further information and a copy of the data in accordance with the legal requirements.
- Right to correction: In accordance with the legal requirements, you have the right to request the completion of the data relating to you or the correction of incorrect data relating to you.
- Right to deletion and restriction of processing: In accordance with the legal requirements, you have the right to request that the data relating to you be deleted immediately or, alternatively, to request that the processing of the data be restricted in accordance with the legal requirements.
- Right to data portability: You have the right to receive data relating to you that you have provided to us in accordance with the legal requirements in a structured, common and machine-readable format or to request that it be transmitted to another person responsible.
- Complaint to the 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 habitual residence, your place of work or the place of the alleged infringement, if you are of the opinion that the processing of the personal data concerning you 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 primarily defined in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended primarily for understanding. The terms are sorted alphabetically.
- Affiliate tracking: As part of affiliate tracking, links that the linked websites use to refer users to websites with product or other offers are logged. The operators of the linked websites can receive a commission if users follow these so-called affiliate links and then take advantage of the offers (e.g. buy goods or use services). For this, it is necessary that the provider can track whether users who are interested in certain offers then take advantage of the affiliate links. It is therefore necessary for affiliate links to function properly that they are supplemented by certain values that become part of the link or are otherwise stored, e.g. in a cookie. The values include in particular the originating website (referrer), the time, an online identifier for the operator of the website on which the affiliate link was located, an online identifier for the respective offer, an online identifier for the user and tracking-specific values, such as advertising material ID, partner ID and categorizations.
- Conversion measurement: The conversion measurement is a procedure 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 are carried out and then retrieved again on the target website. For example, we can see whether the advertisements we placed on other websites were successful.
- Conversion Tracking: “Conversion Tracking” describes a procedure 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 are carried out and then retrieved again on the target website. For example, we can see whether the advertisements we placed on other websites were successful.
- IP masking: “IP masking” is a method in which the last octet, ie the last two digits 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 pseudonymising processing methods, especially in online marketing.
- Interest-based and behavior-based marketing: One speaks of interest-based and / or behavior-based marketing when potential interests of users in advertisements and other content are predetermined as precisely as possible. This is done on the basis of information on their previous behavior (e.g. visiting certain websites and lingering on them, buying behavior or interaction with other users), which are stored in a so-called profile. Cookies are usually used for these purposes.
- Personal data: “Personal data” is all information relating to an identified or identifiable natural person (hereinafter “data subject”); A natural person is regarded as identifiable who can be identified directly or indirectly, in particular by means of assignment 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 express the physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person.
- Processing: “Processing” is any process carried out with or without the help of automated processes or any such series of processes in connection with personal data. The term is broad and includes practically every handling of data, be it the collection, evaluation, storage, transmission or deletion.
- Profiling: “Profiling” refers to any type of automated processing of personal data that consists of using this personal data to identify certain personal aspects that relate to a natural person (depending on the type of profiling, this includes 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. the interests in certain content or products, the click behavior on a website or 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 offer and can include the behavior or interests of visitors in certain information, such as the content of websites. With the help of the reach analysis, website owners can, for example, see at what time visitors visit their website and what content they are interested in. This enables you, for example, to better adapt the website content to the needs of your visitors. For the purpose of range analysis, pseudonymous cookies and web beacons are often used in order to recognize returning visitors and thus to receive more precise analyzes of the use of an online offer.
- Remarketing: One speaks of “remarketing” or “retargeting” when, for example, it is noted for advertising purposes which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
- Responsible: “Responsible” 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.
- Tracking: One speaks of “tracking” when the behavior of users can be traced across several online offers. As a rule, behavioral and interest information with regard to the online offers used is stored in cookies or on servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to show users advertisements that are likely to correspond to their interests.
Created with free “Datenschutz-Generator.de” by Dr. Thomas Schwenke