Privacy Policy

This data protection declaration explains to you the type, scope, and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the associated websites, functions, and contents as well as external online presences, e.g. our social media profile (hereinafter jointly referred to as “online offer”). With regard to the terms used, such as “processing” or “person responsible”, we refer to the definitions in Art. 4 of the Basic Data Protection Ordinance (DSGVO).

Responsible Party
Christian Heidorn
c/o phabric GmbH
Knorrestr. 5
20099 Hamburg
GERMANY

E-Mail: [email protected]
Data Privacy Officer: [email protected]

Types of processed data:

  • Inventory data (e.g. names, addresses).
  • Contact details (e.g., e-mail, telephone numbers).
  • Content data (e.g., text input, photographs, videos).
  • Usage data (e.g., visited websites, 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 (hereinafter referred to as “users”). Purpose of the data processing

  • Provision of the online offer, its functions, and contents.
  • Answer contact requests and communicate with users.
  • Security measures.
  • Range measurement/marketing

Specific terms used

“Personal data” means 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 assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more special features that express the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.

“processing” means any operation or series of operations carried out with or without the aid of automated procedures in connection with personal data. The term goes a long way and covers practically every handling of data.

“pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that this additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

“Profiling” means any automated processing of personal data consisting in the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular, to analyze or predict aspects relating to the work performance, economic situation, health, personal preferences, interests, reliability, behavior, location or relocation of that natural person.

Responsible” means the natural or legal person, authority, institution, or other body that alone or together with others decides on the purposes and means of processing personal data.

“processor” means a natural or legal person, authority, institution, or other body processing personal data on behalf of the controller.

In accordance with Art. 13 DSGVO, we inform you of the legal basis of our data processing. If the legal basis is not mentioned 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 the performance of our services and performance of contractual measures as well as for answering inquiries is Art. 6 para. 1 lit. b DSGVO, the legal basis for processing to fulfill our legal obligations is Art. 6 para. 1 lit. c DSGVO and the legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f DSGVO. In the event that the vital interests of the data subject or another natural person require the processing of personal data, Article 6(1)(d) DSGVO serves as the legal basis.

Safety precautions

We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, implementation costs, and the nature, scope, circumstances, and purposes of processing as well as the different probability of occurrence and severity of the risk to the rights and freedoms of natural persons, in accordance with Art. 32 DSGVO.

Such measures shall in particular include ensuring the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as the access, input, transmission, security of availability, and its separation. Furthermore, we have established procedures to ensure the exercise of rights of data subjects, deletion of data, and reaction to the endangerment of data. Furthermore, we already consider the protection of personal data during the development or selection of hardware, software, and procedures, in accordance with the principle of data protection through technology design and data protection-friendly pre-settings (Art. 25 DSGVO).

Cooperation with contract processors and third parties

If we disclose data to other persons and companies (contract processors or third parties) within the scope of our processing, transmit it to them, or otherwise grant them access to the data, this shall only take place on the basis of a legal permission (e.g. if transmission of the data to third parties, such as payment service providers, in accordance with Art. 6 Para. 1 lit. b DSGVO for contract fulfillment is necessary), if you have consented, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we commission third parties with the processing of data on the basis of a so-called “order processing contract”, 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 occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this only takes place if it occurs for the fulfillment of 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 if the special requirements of Art. 44 ff. Process DSGVO. This means, for example, the processing is carried out on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to the EU (e.g. for the USA by 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 the data concerned are being processed and to request information about these data as well as further information and a copy of the data in accordance with Art. 15 DSGVO.

They have correspondingly. In accordance with Article 16 of the DSBER, you have the right to request the completion of data concerning you or the correction of inaccurate data concerning you.

In accordance with Art. 17 DSGVO, you have the right to demand that relevant data be deleted immediately or, alternatively, to demand a restriction on the processing of the data in accordance with Art. 18 DSGVO.

You have the right to request that the data concerning you that you have provided to us be received in accordance with Art. 20 DSGVO and to request its transmission to other persons responsible.

In accordance with Art. 77 DSGVO, they also have the right to file a complaint with the competent supervisory authority.

Right of revocation

You have the right to revoke consents granted pursuant to Art. 7 para. 3 DSGVO with future effect

Right of objection

You can object to the future processing of the data concerning you in accordance with Art. 21 DSGVO at any time. An objection may be lodged in particular against processing for direct marketing purposes.

Cookies and right of objection in direct advertising

We use cookies to personalise content, ads and to analyse our traffic. We also share information about your use of our site with our advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services.

Cookies” are small files that are stored on the user’s computer. Different data 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 or her 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 content of a shopping basket in an online shop or a login status can be stored. Cookies are referred to as “permanent” or “persistent” and remain stored even after the browser is closed. For example, the login status can be saved when users visit it after several days. Likewise, the interests of users used for range measurement or marketing purposes may be stored in such a cookie. Third-party cookies” are cookies that are offered by providers other than the person responsible for operating the online offer (otherwise, if they are only its cookies, they are referred to as “first-party cookies”).

We may use temporary and permanent cookies and clarify this within the framework of our data protection declaration.

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 restrictions of this online offer.

A general objection to the use of cookies used for online marketing purposes can be declared for many of the services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that in this case not all functions of this online offer can be used.

Deletion of data

The data processed by us will be deleted or their processing restricted in accordance with Articles 17 and 18 DSGVO. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory storage obligations. If the data are not deleted because they are necessary for other and legally permissible purposes, their processing is 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 reasons.

According to legal requirements in Germany, the storage is carried out in particular for 10 years in accordance with §§ 147 para. 1 AO, 257 para. 1 no. 1 and 4, para. 4 HGB (books, records, management reports, accounting documents, trading books, documents relevant for taxation, etc.) and 6 years in accordance with § 257 para. 1 no. 2 and 3, para. 4 HGB (commercial letters).

In accordance with legal requirements in Austria, storage is carried out in particular for 7 years in accordance with § 132 (1) BAO (accounting documents, receipts/invoices, accounts, receipts, business papers, statement of income and expenses, 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.

Business processing

Additionally, we process

  • Contract data (for example, contract object, term, customer category).
  • Payment data (e.g., bank details, payment history)

from our customers, prospects, and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising, and market research.

Order processing in the online shop and customer account

We process the data of our customers in the context of the order processes in our online shop to enable them to select and order the selected products and services, as well as their payment and delivery, or execution.

The processed data includes inventory data, communication data, contract data, and payment data and the persons affected by the processing include our customers, interested parties, and other business partners. The processing takes place for the purpose of providing contractual services in the context of operating an online shop, billing, delivery, and customer services. We use session cookies for storing the contents of the shopping cart and permanent cookies for storing the login status.

Processing is carried out on the basis of Art. 6 Para. 1 lit. b (execution of order processes) and c (legally required archiving) DSGVO. The information marked as necessary is required to establish and fulfill the contract. We disclose the data to third parties only within the framework of delivery, payment, or within the framework of legal permits and obligations to legal advisors and authorities. The data will only be processed in third countries if this is necessary for the fulfillment of the contract (e.g. at the customer’s request upon delivery or payment).

Users can optionally create a user account, in particular by viewing their orders. During the registration process, the required information will be communicated to the users. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, subject to its storage is necessary for commercial or tax reasons according to Art. 6 Para. 1 lit. c DSGVO. Data in the customer account remain up to its deletion with subsequent archiving in the case of a legal obligation. It is up to the users to save their data before the end of the contract if they have given notice of termination.

When registering, re-registering, and using our online services, we store the IP address and the time of the respective user action. The data is stored on the basis of our legitimate interests as well as the user’s protection against misuse and other unauthorized use. A passing on of this data to third parties does not take place in principle unless it is necessary for the pursuit of our claims or there is a legal obligation according to Art. 6 Abs. 1 lit. c DSGVO.

The deletion takes place after the expiry of statutory warranty and comparable obligations, and the necessity of data storage is reviewed every three years; in the case of statutory archiving obligations, the deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) storage obligation).

Agency services

As part of our contractual services, we process our customers’ data, which includes 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., the subject matter of the contract, term), payment data (e.g., bank details, payment history), usage and metadata (e.g. as part of the evaluation and performance measurement of marketing measures). We do not process special categories of personal data unless these are part of commissioned processing. This includes our customers, prospects, their customers, users, website visitors, or employees, as well as third parties. The purpose of the processing is to provide contractual services, billing, and customer service. The legal basis for processing results from Art. 6 para. 1 lit. b DSGVO (contractual services), Art. 6 para. 1 lit. f DSGVO (analysis, statistics, optimization, safety measures). We process data that are necessary to justify and fulfill the contractual services and point out the necessity of their disclosure. Disclosure to external parties only takes place if it is necessary within the framework 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 for order processing pursuant to Art. 28 DSGVO and process the data for no other purposes than those stipulated in the order.

We delete the data after the expiry of the statutory warranty and comparable obligations. The necessity of storing the data is checked every three years; in the case of statutory archiving obligations, the data is deleted after their expiry (6 years, in accordance with § 257 Paragraph 1 HGB, 10 years, in accordance with § 147 Paragraph 1 AO). In the case of data disclosed to us within the scope of an order by the customer, we delete the data in accordance with the specifications of the order, generally after the end of the order.

External payment services providers

We use external payment service providers through whose platforms users and we can make payment transactions (e.g., each with a link to the data protection declaration, Paypal (https://www.paypal.com/de/webapps/mpp/ua/privacy-full), Klarna (https://www.klarna.com/de/datenschutz/), Skrill (https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/), Giropay (https://www.giropay.de/rechtliches/datenschutz-agb/), Visa (https://www.visa.de/datenschutz), Mastercard (https://www.mastercard.de/de-de/datenschutz.html), American Express (https://www.americanexpress.com/de/content/privacy-policy-statement.html)

As part of the fulfillment of contracts, we suspend the payment service providers on the basis of Art. 6 para. 1 lit. b. DSGVO. Furthermore, we employ external payment service providers on the basis of our legitimate interests in accordance with Art. 6 para. 1 lit. b. DSGVO provides our users with 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 numbers or credit card numbers, passwords, TANs and checksums as well as contract, totals, and recipient information. This information is required to execute 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. The data may be transferred by the payment service providers to credit agencies. The purpose of this transmission is to verify identity and creditworthiness. For this, we refer to the terms and conditions and data protection information of the payment service providers.

For payment transactions, the terms and conditions and the data protection information of the respective payment service providers, which can be accessed within the respective websites or transaction applications, apply. We refer to these also for the purpose of further information and assertion of rights of revocation, information, and other interested parties.

Administration, financial accounting, office organization, contact management

We process data within the framework of administrative tasks as well as the organization of our company, financial accounting, and compliance with legal obligations, e.g. archiving. We process the same data that we process in the course of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c. DSGVO, Art. 6 para. 1 lit. f. DSGVO. Customers, prospects, business partners, and website visitors are affected by the processing. The purpose and our interest in the processing lie in the administration, financial accounting, office organization, and archiving of data, thus tasks which serve the maintenance of our business activities, perception of our tasks, and provision of our services. The deletion of the data with regard to contractual services and contractual communication corresponds to the information provided in these processing activities.

We disclose or transmit data to the tax authorities, consultants, such as tax consultants or auditors, as well as other fee offices and payment service providers.

Furthermore, we store information on suppliers, event organizers, and other business partners on the basis of our business interests, e.g. for the purpose of making contact at a later date. We store this data, which is mainly company-related, permanently.

Business analyses and market research

In order to operate our business economically, and to be able to recognize market tendencies and wishes of the contracting parties and users, we analyze the data available to us for business processes, contracts, inquiries, etc. We process inventory data, communication data, contract data, payment data, usage data, and 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 economic evaluations, marketing, and market research. 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, the optimization of our offer, and economic efficiency. The analyses serve us alone and are not disclosed externally unless they are anonymous analyses with aggregated values.

If these analyses or profiles are personal, they will be deleted or made anonymous upon termination of the user, otherwise after two years from the conclusion of the contract. For the rest, macroeconomic analyses and general trend determinations are prepared anonymously wherever possible.

Participation in affiliate partner programs

Within our online offer, we use tracking measures customary in the industry on the basis of our legitimate interests (i.e. interest in the analysis, optimization, and economic operation of our online offer) in accordance with Art. 6 para. 1 letter f DSGVO, insofar as these are necessary for the operation of the affiliate system. Below we explain the technical background to the users.

The services offered by our contractual partners can also be advertised and linked on other websites (so-called affiliate links or after-buy systems, e.g. links or services of third parties are offered after the conclusion of a contract). The operators of the respective websites receive a commission if users follow the affiliate links and then take advantage of the offers.

In summary, it is necessary for the online offer that we can track whether users who are interested in affiliate links and/or the offers available from us subsequently perceive the offers at the request of the affiliate links or our online platform. For this purpose, the affiliate links and our offers are supplemented by specific values that can be set as part of the link or otherwise, e.g. in a cookie. The values include in particular the initial website (referrer), time, an online identification of the operator of the website on which the affiliate link was located, an online identification of the respective offer, an online identification of the user, as well as tracking specific values such as advertising media ID, partner ID, and categorizations.

The online identifiers used by us are pseudonymous values. This means that the online identifiers themselves do not contain any personal data such as names or e-mail addresses. You only help us to determine whether the same user who clicked on an affiliate link or was interested in an offer via our online offer has accepted the offer, i.e. has concluded a contract with the provider, for example. However, the online identification is personal insofar as the partner company and also we, the online identification together with other user data are available. Only in this way can the partner company inform us whether the user has accepted the offer and we can, for example, pay out the bonus.

Registration function

Users can create a user account. Within the scope of registration, the required mandatory data are communicated to the users and processed on the basis of Art. 6 para. 1 letter b DSGVO for the purpose of providing the user account. The processed data includes in particular the login information (name, password, and e-mail address). The data entered during registration will be used for the purpose of using the user account and its purpose.

Users may be notified by e-mail of information relevant to their user account, such as technical changes. If users have canceled their user account, their data will be deleted with regard to the user account, subject to a statutory retention obligation. It is up to the users to save their data before the end of the contract if they have given notice of termination. We are entitled to irretrievably delete all user data stored during the term of the contract.

As part of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The data is stored on the basis of our legitimate interests as well as the user’s protection against misuse and other unauthorized use. A passing on of this data to third parties does not take place in principle unless it is necessary to pursue our claims or there is a legal obligation in accordance with Art. 6 para. 1 lit. c DSGVO. The IP addresses are anonymized or deleted after 7 days at the latest.

Retrieval of profile pictures from Gravatar

We use the service Gravatar of Automattic Inc. 60 29th Street #343, San Francisco, CA 94110, USA, within our online offer and especially in our blog.

Gravatar is a service where users can log in and store profile pictures and their e-mail addresses. If users leave contributions or comments with the respective e-mail address on other online presences (above all in blogs), their profile pictures can be displayed next to the contributions or comments. For this purpose, the e-mail address provided by the users is transmitted to Gravatar in encrypted form for the purpose of checking whether a profile has been saved for it. This is the sole purpose of the transmission of the e-mail address and it will not be used for other purposes but will be deleted thereafter.

The use of Gravatar is based on our legitimate interests within the meaning of Art. 6 Para. 1 letter f) DSGVO, as we offer the possibility of personalizing their contributions with a profile picture with the help of Gravatar.

By displaying the images, Gravatar obtains the IP address of the users, as this is necessary for communication between a browser and an online service. For more information on Gravatar’s collection and use of the data, please refer to Automattic’s privacy policy: https://automattic.com/privacy/.

If users do not want an image associated with their email address to appear in Gravatar’s comments, you should use a non-Gravatar email address for commenting. We would also like to point out that it is also possible to use an anonymous or no e-mail address if users do not wish their own e-mail address to be sent to Gravatar. Users can completely prevent the transfer of data by not using our comment system.

Retrieval of emojis and smilies

Within our WordPress blog, graphical emojis (or smilies), i.e. small graphical files that express feelings, are used that are obtained from external servers. The providers of the servers collect the IP addresses of the users. This is necessary so that the emoji files can be transmitted to the users’ browsers. The Emojie service is offered by Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA. Automattic’s privacy policy: https://automattic.com/privacy/. The server domains used are s.w.org and twemoji.maxcdn.com, whereby to our knowledge these are so-called content-delivery networks, i.e. servers that serve only a fast and secure transmission of the files, and the personal data of the users are deleted after the transmission.

Emojis are used on the basis of our legitimate interests, i.e. interest in an attractive design of our online offer in accordance with Art. 6 para. 1 lit. f. DSGVO.

Contact

When contacting us (e.g. via a contact form, e-mail, telephone, or social media), the user’s details are processed for processing the contact inquiry and its processing in accordance with Art. 6 para. 1 lit. b) DSGVO. User information can be stored in a customer relationship management system (“CRM system”) or comparable request organization.

We delete the requests if they are no longer necessary. We review this requirement every two years; the statutory archiving obligations also apply.

Newsletter

With the following information, 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 the receipt and the described procedures.

Content of the newsletter: We send newsletters, e-mails, and other electronic notifications containing advertising information (hereinafter “newsletters”) only with the consent of the recipients or legal permission. If the contents of a newsletter are specifically described within the scope of a registration, they are decisive for the consent of the users. In addition, our newsletters contain information about our services and us.

Double opt-in and logging: Subscription to our newsletter takes place 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 no one can log in with other e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes the storage of the login and confirmation time, as well as the IP address. The changes to your data stored with the shipping service provider are also logged.

Credentials: To subscribe to the newsletter, simply enter your e-mail address. Optionally, we ask you to enter a name in the newsletter in order to address us personally.

The dispatch of the newsletter and the performance measurement associated with it are based on the recipient’s consent pursuant to 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 the basis of our legitimate interests in direct marketing pursuant to Art. 6 para. 1 lt. f. DSGVO in conjunction with Section 7 para. 3 UWG.

The registration procedure is recorded on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f DSGVO. We are interested in the use of a user-friendly and secure newsletter system that serves both our business interests and the expectations of users and also allows us to provide proof of 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 e-mail addresses we have unsubscribed 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 these data is limited to the purpose of a possible defense against claims. An individual application for cancellation is possible at any time, provided that at the same time, the former existence of a consent is confirmed.

Newsletter – ConvertKit

We use ConvertKit on our website, a service for our email marketing. The service provider is the American company ConvertKit LLC, 750 W Bannock Street 761, Boise, ID 83702, USA.

ConvertKit also processes data from you in the USA, among other places. We would like to point out that according to the opinion of the European Court of Justice, there is currently no adequate level of protection for the transfer of data to the USA. This may be accompanied by various risks to the lawfulness and security of data processing.

As a basis for data processing with recipients located in third countries (outside the European Union, Iceland, Liechtenstein, Norway, i.e. especially in the USA) or a data transfer there, ConvertKit uses so-called standard contractual clauses (= Art. 46. para. 2 and 3 DSGVO). Standard Contractual Clauses (SCC) are templates provided by the EU Commission and are intended to ensure that your data complies with European data protection standards even if it is transferred to third countries (such as the USA) and stored there. Through these clauses, ConvertKit undertakes to comply with the European level of data protection when processing your relevant data, even if the data is stored, processed and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding standard contractual clauses here, among other places: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de

More information about the standard contractual clauses at ConvertKit can be found at https://convertkit.com/security.

You can learn more about the data processed through the use of ConvertKit in the Privacy Policy at https://convertkit.com/privacy.

Newsletter – Performance Measurement

The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is downloaded from our server when the newsletter is opened or, if we use a shipping service provider, from whose server. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval are initially collected.

This information is used to technically improve the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or access times. The 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 endeavor nor, if used, that of the shipping 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.

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 delivery, security services, and technical maintenance services that we use for the purpose of operating this online offer.

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 according to Art. 6 Para. 1 lit. f DSGVO in conjunction with. Art. 28 DSGVO (conclusion of order processing contract).

Collection of access data and log files

We, or our hosting provider, collect the following data on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO data on each access to the server on which this service is located (so-called server log files). Access data includes the name of the accessed website, file, date and time of access, transferred data volume, notification of successful access, browser type, and version, the user’s operating system, referrer URL (the previously visited page), IP address, and the requesting provider.

Log file information is stored for a maximum of 7 days for security reasons (e.g. to investigate misuse or fraud) and then deleted. Data whose further storage is required for evidentiary purposes are excluded from deletion until the respective incident has been finally clarified.

Google Analytics

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) Google Analytics, a web analysis service of Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by users is generally transferred to a Google server in the USA and stored there.

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 to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services associated with the use of this online offer and the use of the Internet. Pseudonymous user profiles can be created from the processed data.

We use Google Analytics only with IP anonymization enabled. This means that Google will reduce the IP address of users within Member States of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted 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 setting their browser software accordingly; users can also prevent Google from collecting the data generated by the cookie and relating to their use of the online offer 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=en.

Further information on data use by Google, possible settings, and objections can be found in Google’s data protection declaration (https://policies.google.com/technologies/ads) and in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

Users’ personal data will be deleted or made anonymous after 14 months.

Google Universal Analytics

We use Google Analytics in its design as “Universal Analytics”. “Universal Analytics” refers to a process by Google Analytics in which the user analysis is based on a pseudonymous user ID and a pseudonymous profile of the user with information from the use of various devices is created (so-called “cross-device tracking”).

Target group formation with Google Analytics

We use Google Analytics to display the ads placed by Google and its partners within advertising services only to users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products that are determined by the web pages visited) that we transmit to Google (so-called “remarketing” or “Google Analytics Audiences”). With the help of remarketing audiences, we would also like to ensure that our ads correspond to the potential interest of the 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 to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

We use the online marketing process Google “AdWords” to place ads in the Google Advertising Network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads. This allows us to display ads for and within our online offer more specifically in order to present users only ads that potentially correspond to their interests. For example, if a user is shown ads for products in which he is interested in other online offers, this is referred to as “remarketing”. For these purposes, when our and other websites on which the Google Advertising Network is active are accessed, Google directly executes a code from Google and (re)marketing tags (invisible graphics or code, also known as “web beacons”) are integrated into 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). In this file it is noted which websites the user visits, which contents he is interested in and which offers the user has clicked on, technical information on the browser and operating system, referring websites, visiting time, and further information on the use of the online offer.

We also receive an individual “conversion cookie”. The information collected with the help of cookies is used by Google to generate conversion statistics for us. However, we only see the total number of anonymous users who clicked on our ad and were redirected to a page with a conversion tracking tag. However, 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 names or e-mail addresses of users, but processes the relevant data cookie-related within pseudonymous user profiles. This means 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 this 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 the users is transmitted to Google and stored on Google’s servers in the USA.

Further information on data use by Google, possible settings, and objections can be found in Google’s data protection declaration (https://policies.google.com/technologies/ads) and in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

Facebook Pixel, Custom Audiences, and Facebook Conversion

Due to our legitimate interests in the analysis, optimization, and economic operation of our online offer and for these purposes the so-called “Facebook pixel” of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are based in the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), is used within our online offer.

Facebook 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=a2zt0000000GnywAAC&status=Active).

With the help of the Facebook pixel, Facebook is able to determine the visitors of our online offer as a target group for the presentation of ads (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads we post only to Facebook users who have also shown an interest in our online offering or who have certain features (e.g. interests in certain topics or products that are determined by the websites visited) that we transmit to Facebook (so-called “custom audiences”). We also want to use the Facebook pixel to ensure that our Facebook ads meet the potential interest of users and are not a nuisance. The Facebook pixel also helps us understand the effectiveness of Facebook ads for statistical and market research purposes by showing whether users have been redirected to our website after clicking on a Facebook ad (so-called “conversion”).

Facebook processes the data in accordance with Facebook’s Data Usage Policy. Accordingly, general information on the display of Facebook ads can be found in the Facebook Data Usage Policy: https://www.facebook.com/policy.php. For specific information and details about the Facebook pixel and how it works, please visit the Facebook Help section: https://www.facebook.com/business/help/651294705016616.

You can object to the collection by the Facebook pixel and use of your data to display Facebook ads. To set what types of ads you see within Facebook, you can visit the page set up by Facebook and follow the instructions on usage-based advertising settings: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.

You may also object to the use of cookies for range measurement and advertising purposes via the deactivation page of the network advertising initiative (http://optout.networkadvertising.org/) and additionally the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).

Bing Ads

Within our online offer, we make no representations or warranties of any kind based on 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 conversion and tracking tool “Bing Ads” of Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. Microsoft stores cookies on the user’s devices in order to enable an analysis of the use of our online offer by the user if users have accessed our online offer via a Microsoft Bing display (so-called “conversion measurement”). Microsoft and we can recognize in this way that someone who has clicked on an ad has been redirected to our online offer and has reached a previously defined target page (so-called “conversion page”). We only see the total number of users who clicked on a Bing ad and were then redirected to the conversion page. No IP addresses are stored. No personal information about the identity of the users is communicated.

Microsoft 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=a2zt0000000KzNaAAK&status=Active).

If users do not wish to participate in the Bing Ads tracking process, you can also deactivate the necessary setting of a cookie via browser settings or use Microsoft’s opt-out page: http://choice.microsoft.com/de-DE/opt-out.

Users can find further information on data protection and the cookies used at Microsoft Bing Ads in Microsoft’s data protection declaration: https://privacy.microsoft.com/de-de/privacystatement.

Online presence in social media

We maintain an online presence within social networks and platforms in order to communicate with active customers, interested parties, and users and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and the data processing guidelines of their respective operators apply.

Unless otherwise stated in our privacy policy, we process the data of users who communicate with us within social networks and platforms, e.g. write articles on our websites or send us messages.

Integration of third-party services and content

Within our online offer, we make no representations or warranties of any kind based on 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) content or service offerings of third parties to incorporate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).

This always presupposes that the third-party providers of this content perceive the IP address of the users since without the IP address they could not send the content to their browser. The IP address is therefore required for the display of this content. We make every effort to use only those contents whose respective providers use the IP address only for the delivery of the contents. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring websites, visiting time, and other information about the use of our online offer, as well as be linked to such information from other sources.

Youtube

We integrate the videos of the platform “YouTube” of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Google Fonts

We integrate the fonts (“Google Fonts”) of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Google ReCaptcha

We integrate the function for the recognition of bots, e.g. for entries in online forms (“ReCaptcha”) of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Google Maps

We integrate the maps of the service “Google Maps” of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The processed data may include in particular IP addresses and location data of the users, which, however, are not collected without their consent (as a rule within the framework of the settings of their mobile devices). The data can be processed in the USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Using Facebook Social Plugins

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) Social Plugins (“Plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The plugins can display interaction elements or content (e.g. videos, graphics or text contributions) and are identified by one of the Facebook logos (white “f” on blue tile, the terms “like”, “like” or a “thumbs up” sign) or are marked with the addition “Facebook Social Plugin”. The list and appearance of Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/.

Facebook 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=a2zt0000000GnywAAC&status=Active).

When a user calls up a function of this online offer that contains such a plugin, his device establishes a direct connection to the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated into the online offer. The processed data can be used to create user profiles. We, therefore, have no influence on the amount of data Facebook collects with the help of this plugin and therefore inform users according to our level of knowledge.

By integrating the plugins, Facebook receives information that a user has called up the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to his Facebook account. When users interact with the plugins, such as by pressing the Like button or posting a comment, the information is sent directly from their device to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to obtain and store their IP address. According to Facebook, only an anonymized IP address is stored in Germany.

The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the relevant rights and setting options for the protection of users’ privacy, can be found in Facebook’s data protection information: https://www.facebook.com/about/privacy/.

If a user is a Facebook member and does not want Facebook to collect data about him via this online offer and link it to his membership data stored on Facebook, he must log out of Facebook before using our online offer and delete his cookies. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US page http://www.aboutads.info/choices/ or the EU page http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.

Twitter

Functions and contents of the Twitter service, offered by Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, can be integrated into our online offering. This may include, for example, content such as images, videos, or texts and buttons with which users can express their appreciation of the content, subscribe to the authors of the content, or our contributions. If the users are members of the Twitter platform, Twitter can assign calling up the above content and functions to the users’ profiles there. Twitter 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=a2zt0000000TORzAAO&status=Active). Privacy Policy: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization.

Instagram

Within our online offer, functions, and contents of the Instagram service, offered by Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA, can be integrated. This may include, for example, content such as images, videos, or texts and buttons with which users can express their appreciation of the content, subscribe to the authors of the content, or our contributions. If the users are members of the Instagram platform, Instagram can assign the call of the above contents and functions to the profiles of the users there. Instagram Privacy Policy: http://instagram.com/about/legal/privacy/.

Pinterest

Within our online offer, functions, and contents of the Pinterest service, offered by Pinterest Inc. 635 High Street, Palo Alto, CA, 94301, USA, can be integrated. This may include, for example, content such as images, videos, or texts and buttons with which users can express their appreciation of the content, subscribe to the authors of the content, or our contributions. If the users are members of the Pinterest platform, Pinterest can assign the call of the above contents and functions to the profiles of the users there. Pinterest’s privacy policy: https://about.pinterest.com/de/privacy-policy.