Introduction
With the following privacy policy, we would like to inform you about which types of your personal data
(hereinafter also referred to as “data”) we process, for which purposes, and to what extent. This privacy policy
applies to all processing of personal data carried out by us, both in the context of providing our services and,
in particular, on our websites, in mobile applications, as well as within external online presences, such as our
social media profiles (hereinafter collectively referred to as the “Online Offering”).
The terms used are not gender-specific.
Status: April 8th, 2026
Table of Contents
Controller
auroraNet Enterprises UG (limited liability)
Dobrachstr. 16
95326 Kulmbach
Authorized representatives:
Kevin Blechschmidt
Email address:
[email protected]
Legal notice:
https://www.auroranet.io/impressum
Overview of Processing Activities
The following overview summarizes the types of data processed and the purposes of processing and refers to the
data subjects concerned.
Types of data processed
- Inventory data.
- Payment data.
- Contact data.
- Content data.
- Contract data.
- Usage data.
- Meta/communication data.
Categories of data subjects
- Customers.
- Prospects.
- Communication partners.
- Users.
- Sweepstakes and competition participants.
- Business and contractual partners.
- Participants.
Purposes of processing
- Provision of contractual services and customer service.
- Contact inquiries and communication.
- Security measures.
- Direct marketing.
- Reach measurement.
- Tracking.
- Office and organizational procedures.
- Conversion measurement.
- Administration and responding to inquiries.
- Conducting sweepstakes and competitions.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online offering and user-friendliness.
- Information technology infrastructure.
Relevant Legal Bases
Below you will find an overview of the legal bases under the GDPR on the basis of which we process personal data.
Please note that, in addition to the provisions of the GDPR, national data protection requirements may apply in
your and or our country of residence or establishment. If, in individual cases, more specific legal bases are
relevant, we will inform you of these in the privacy policy.
- Consent (Art. 6(1) sentence 1 lit. a GDPR) – The data subject has given consent to the
processing of personal data relating to them for one or more specific purposes.
- Performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1 lit. b GDPR)
– 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(1) sentence 1 lit. c GDPR) – Processing is necessary for
compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6(1) sentence 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 requiring
the protection of personal data.
In addition to the data protection provisions of the General Data Protection Regulation, national data protection
provisions apply in Germany. These include, in particular, the Act on Protection Against Misuse of Personal Data
in Data Processing (Federal Data Protection Act, Bundesdatenschutzgesetz, BDSG). The BDSG contains, in
particular, special provisions on the right of access, the right to erasure, the right to object, the processing
of special categories of personal data, processing for other purposes, and transfers, as well as automated
decision-making in individual cases including profiling. It also governs data processing for purposes of
employment relationships (Section 26 BDSG), in particular with regard to the establishment, performance, or
termination of employment relationships as well as employee consent. In addition, state data protection laws of
the individual German federal states may apply.
Security Measures
In accordance with legal requirements, taking into account the state of the art, implementation costs, and the
nature, scope, circumstances and purposes of processing, as well as the differing likelihood and severity of
risks to the rights and freedoms of natural persons, we take appropriate technical and organizational measures
to ensure a level of security appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by
controlling physical and electronic access to the data, as well as access, input, disclosure, ensuring
availability, and separation of data. Furthermore, we have established procedures that ensure the exercise of
data subject rights, deletion of data, and responses to risks to the data. In addition, we take the protection
of personal data into account already when developing and or selecting hardware, software, and procedures in
accordance with the principle of data protection by design and by default.
TLS encryption (https): To protect data transmitted via our online offering, we use TLS encryption. You can
recognize such encrypted connections by the prefix https:// in your browser’s address bar.
Transfer of Personal Data
In the context of our processing of personal data, it may occur that data is transferred to other entities,
companies, legally independent organizational units, or persons, or disclosed to them. Recipients of such data
may include, for example, service providers entrusted with IT tasks or providers of services and content
integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude
appropriate contracts and or agreements with the recipients of your data that serve to protect your data.
Data transfer within the organization: We may transfer personal data to other entities within our organization or
grant them access to such data. If this disclosure is for administrative purposes, the disclosure is based on
our legitimate entrepreneurial and business interests or occurs where it is necessary for the fulfillment of our
contractual obligations or where consent of the data subjects or statutory authorization exists.
Processing of Data in Third Countries
If we process data in a third country (i.e., outside the European Union (EU) and the European Economic Area
(EEA)) or processing occurs in the context of using third-party services or disclosing or transferring data to
other persons, entities, or companies, this is done only in compliance with the legal requirements.
Subject to express consent or transfer required by contract or by law, we process or have data processed only in
third countries with a recognized level of data protection, on the basis of contractual obligations through
so-called standard protection clauses of the European Commission, where certifications exist, or on the basis of
binding internal data protection rules (Art. 44 to 49 GDPR, information page of the European Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).
Deletion of Data
The data processed by us will be deleted in accordance with legal requirements as soon as any consents permitting
processing are withdrawn or other permissions cease to apply (e.g., if the purpose of processing has ceased to
apply or the data is no longer necessary for the purpose). If the data is not deleted because it is required for
other and legally permissible purposes, its processing will be restricted to those purposes. This means the data
will be blocked and not processed for other purposes. This applies, for example, to data that must be retained
for commercial or tax law reasons or whose storage is necessary for the assertion, exercise, or defense of legal
claims or for the protection of the rights of another natural or legal person.
Our privacy notices may also contain further information on the retention and deletion of data that takes
precedence for the respective processing activities.
Use of Cookies
Change
cookie settings
Cookies are small text files or other storage notes that store information on end devices and read information
from end devices. For example, to store the login status in a user account, the contents of a shopping cart in
an e-shop, the content accessed, or functions used in an online offering. Cookies can also be used for different
purposes, for example, for the functionality, security and convenience of online offerings and for creating
analyses of visitor flows.
Notes on consent: We use cookies in accordance with legal provisions. Therefore, we obtain prior
consent from users unless this is not legally required. Consent is not necessary in particular if the storage
and reading of information, including cookies, is strictly necessary in order to provide users with a telemedia
service (i.e., our online offering) expressly requested by them. The revocable consent is clearly communicated
to users and contains information on the respective use of cookies.
Notes on data protection legal bases: The data protection legal basis on which we process users’
personal data using cookies depends on whether we ask users for consent. If users consent, the legal basis for
processing their data is the declared consent. Otherwise, the data processed by means of cookies will be
processed on the basis of our legitimate interests (e.g., in the economic operation of our online offering and
improving its usability) or, if this is done in the context of fulfilling our contractual obligations, if the
use of cookies is necessary to fulfill our contractual obligations. We explain the purposes for which cookies
are processed by us in the course of this privacy policy or in the context of our consent and processing
procedures.
Storage period: With regard to the storage period, the following types of cookies are
distinguished:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest
after a user leaves an online offering and closes their end device (e.g., browser or mobile application).
- Persistent cookies: Persistent cookies remain stored even after the end device is closed.
For example, the login status can be stored or preferred content can be displayed directly when the user
visits a website again. Likewise, the data collected from users using cookies can be used for reach
measurement. Unless we provide users with explicit information on the type and storage period of cookies
(e.g., when obtaining consent), users should assume that cookies are persistent and that the storage period
can be up to two years.
General notes on withdrawal and objection (opt-out): Users can withdraw their consents at any
time and also object to processing in accordance with the legal requirements of Art. 21 GDPR. Users can
also declare their objection via their browser settings, for example by deactivating the use of cookies
(although this may also restrict the functionality of our online services). An objection to the use of cookies
for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.
Further notes on processing operations, procedures and services:
- Processing of cookie data on the basis of consent: We use a cookie consent management
procedure, within the scope of which users’ consents to the use of cookies and or the processing operations
and providers named within the cookie consent management procedure can be obtained, managed, and withdrawn
by users. The consent declaration is stored so that it does not need to be requested again and so that
consent can be proven in accordance with the legal obligation. Storage may take place on the server side and
or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to
assign the consent to a user or their device. Subject to individual information on providers of cookie
management services, the following information applies: The consent may be stored for up to two years. A
pseudonymous user identifier is created and stored together with the time of consent, information on the
scope of consent (e.g., which categories of cookies and or service providers), as well as the browser,
system, and end device used.
Business Services
We process data of our contractual and business partners, e.g., customers and prospects (collectively referred to
as “contractual partners”), within the scope of contractual and comparable legal relationships and related
measures as well as within the scope of communication with the contractual partners (or pre-contractually),
e.g., in order to answer inquiries.
We process this data in order to fulfill our contractual obligations. This includes, in particular, obligations
to provide the agreed services, any update obligations, and remedies for warranty and other performance
disruptions. In addition, we process the data to safeguard our rights and for the purpose of administrative
tasks associated with these obligations as well as corporate organization. In addition, we process the data on
the basis of our legitimate interests in proper and economic business management and in security measures to
protect our contractual partners and our business operations from misuse, endangerment of their data, secrets,
information, and rights (e.g., for the involvement of telecommunications, transport, and other auxiliary
services and subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities).
Within the scope of applicable law, we pass on the data of contractual partners to third parties only insofar as
this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners are
informed of further forms of processing, e.g., for marketing purposes, within the scope of this privacy policy.
We inform contractual partners which data is required for the aforementioned purposes before or in the context of
data collection, e.g., in online forms, by special marking (e.g., colors) and or symbols (e.g., asterisks or
similar), or personally.
We delete the data after the expiry of statutory warranty and comparable obligations, i.e., as a rule after four
years, unless the data is stored in a customer account, e.g., as long as it must be retained for statutory
archiving reasons. The statutory retention period for tax-relevant documents, as well as for commercial books,
inventories, opening balance sheets, annual financial statements, the work instructions and other organizational
documents required to understand these documents, and accounting records is ten years, and for received
commercial and business letters and reproductions of sent commercial and business letters is six years. The
period begins at the end of the calendar year in which the last entry was made in the book, the inventory, the
opening balance sheet, the annual financial statements or the management report was prepared, the commercial or
business letter was received or sent, or the accounting record was created, furthermore the record was made or
the other documents were created.
Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and
privacy notices of the respective third-party providers or platforms apply in the relationship between users and
the providers.
- Types of data processed: Inventory data (e.g., names, addresses); payment data (e.g., bank
details, invoices, payment history); contact data (e.g., email, phone numbers); contract data (e.g., subject
matter of the contract, term, customer category); usage data (e.g., visited websites, interest in content,
access times); meta/communication data (e.g., device information, IP addresses).
- Data subjects: Customers; prospects; business and contractual partners.
- Purposes of processing: Provision of contractual services and customer service; security
measures; contact inquiries and communication; office and organizational procedures; administration and
responding to inquiries; conversion measurement (measurement of the effectiveness of marketing measures);
profiles with user-related information (creation of user profiles).
- Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1
lit. b GDPR); legal obligation (Art. 6(1) sentence 1 lit. c GDPR); legitimate interests (Art. 6(1) sentence
1 lit. f GDPR).
Further notes on processing operations, procedures and services:
- Customer account: Contractual partners can create an account within our online offering
(e.g., customer or user account, “customer account”). If registration of a customer account is required,
contractual partners will be informed accordingly as well as of the information required for registration.
Customer accounts are not public and cannot be indexed by search engines. In the course of registration as
well as subsequent logins and uses of the customer account, we store customers’ IP addresses along with the
times of access in order to prove registration and prevent possible misuse of the customer account.
If customers have terminated their customer account, the data relating to the customer account will be
deleted, subject to retention being required for legal reasons. It is the responsibility of customers to
back up their data when terminating the customer account; Legal bases: Performance of a
contract and pre-contractual inquiries (Art. 6(1) sentence 1 lit. b GDPR).
- Business analyses and market research: For business reasons and in order to be able to
identify market trends and the wishes of contractual partners and users, we analyze data available to us on
business transactions, contracts, inquiries, etc., whereby the group of data subjects may include
contractual partners, prospects, customers, visitors, and users of our online offering.
The analyses are carried out for the purpose of business evaluations, marketing, and market research (e.g.,
to determine customer groups with different characteristics). In doing so, we may, if available, take into
account the profiles of registered users including their information, e.g., on services used. The analyses
serve us alone and are not disclosed externally unless they are anonymous analyses with aggregated, i.e.,
anonymized values. Furthermore, we respect users’ privacy and process the data for analysis purposes as
pseudonymously as possible and, where feasible, anonymously (e.g., as aggregated data); Legal
bases: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).
- 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 performance. If necessary for the fulfillment of an order, we use service providers, in particular
postal, freight, and shipping companies, to carry out delivery or performance to our customers. For the
processing of payment transactions, we use the services of banks and payment service providers. The required
information is marked as such within the order or comparable acquisition process and includes information
necessary for delivery or provision and billing as well as contact information in order to be able to
communicate in case of questions; Legal bases: Performance of a contract and
pre-contractual inquiries (Art. 6(1) sentence 1 lit. b GDPR).
- Project and development services: We process the data of our customers and clients
(hereinafter uniformly referred to as “customers”) in order to enable them to select, purchase, or
commission the selected services or works and related activities as well as their payment and provision or
performance or delivery.
The required information is marked as such in the context of the contract, order, or comparable conclusion
of contract and includes information necessary for the provision of services and billing as well as contact
information in order to be able to coordinate if necessary. To the extent that we receive access to
information of end customers, employees, or other persons, we process it in accordance with legal and
contractual requirements; Legal bases: Performance of a contract and pre-contractual
inquiries (Art. 6(1) sentence 1 lit. b GDPR).
- Provision of software and platform services: We process the data of our users, registered
users and any test users (hereinafter uniformly referred to as “users”) in order to be able to provide our
contractual services to them and on the basis of legitimate interests in order to ensure the security of our
offering and to be able to further develop it. The required information is marked as such in the context of
the contract, order, or comparable conclusion of contract and includes information necessary for the
provision of services and billing as well as contact information in order to be able to coordinate if
necessary; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)
sentence 1 lit. b GDPR).
Payment Methods
In the context of contractual and other legal relationships, on the basis of legal obligations, or otherwise on
the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use
additional service providers alongside banks and credit institutions for this purpose (collectively “payment
service providers”).
The data processed by 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-related,
amount-related, and recipient-related information. This information is required in order to carry out the
transactions. However, the entered data is processed and stored only by the payment service providers. This
means that we do not receive any account or credit card related information, but only information confirming or
rejecting the payment. Under certain circumstances, the payment service providers may transfer data to credit
agencies. This transfer serves the purpose of identity and creditworthiness checks. For this, we refer to the
terms and conditions and privacy notices of the payment service providers.
The terms and conditions and privacy notices of the respective payment service providers apply to payment
transactions and can be accessed within the respective websites or transaction applications. We also refer to
these for further information and for asserting rights of withdrawal, information, and other data subject
rights.
- Types of data processed: Inventory data (e.g., names, addresses); payment data (e.g., bank
details, invoices, payment history); contract data (e.g., subject matter of the contract, term, customer
category); usage data (e.g., visited websites, interest in content, access times); meta/communication data
(e.g., device information, IP addresses).
- Data subjects: Customers; prospects.
- Purposes of processing: Provision of contractual services and customer service.
- Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1
lit. b GDPR).
Further notes on processing operations, procedures and services:
- Stripe: Payment services (technical integration of online payment methods); Service
provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal
bases: Performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1 lit. b
GDPR); Website: https://stripe.com;
Privacy policy: https://stripe.com/de/privacy.
Provision of the Online Offering and Web Hosting
We process users’ data in order to provide them with our online services. For this purpose, we process the user’s
IP address, which is necessary to transmit the content and functions of our online services to the users’
browser or device.
- Types of data processed: Usage data (e.g., visited websites, interest in content, access
times); meta/communication data (e.g., device information, IP addresses); content data (e.g., entries in
online forms).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of our online offering and user-friendliness; information
technology infrastructure (operation and provision of information systems and technical devices (computers,
servers, etc.)); security measures.
- Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).
Further notes on processing operations, procedures and services:
- Provision of the online offering on rented storage space: To provide our online offering,
we use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding
server provider (also called “web host”); Legal bases: Legitimate interests (Art. 6(1)
sentence 1 lit. f GDPR).
- Collection of access data and log files: Access to our online offering is logged in the
form of so-called “server log files”. The server log files may include the address and name of the accessed
websites and files, date and time of access, transferred amounts of data, message about successful access,
browser type and version, the user’s operating system, referrer URL (the previously visited page), and
usually IP addresses and the requesting provider.
The server log files can be used, on the one hand, for security purposes, e.g., to avoid server overload
(especially in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure server
utilization and stability; Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f
GDPR); Deletion of data: Log file information is stored for a maximum of 30 days and then
deleted or anonymized. Data whose further retention is required for evidentiary purposes is excluded from
deletion until the respective incident has been finally clarified.
- Email sending and hosting: The web hosting services we use also include sending, receiving,
and storing emails. For these purposes, the addresses of recipients and senders as well as further
information regarding email sending (e.g., the providers involved) and the content of the respective emails
are processed. The aforementioned data may also be processed for the purpose of SPAM detection. Please note
that emails on the internet are generally not sent encrypted. As a rule, emails are encrypted during
transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they
are sent and received. We therefore cannot assume responsibility for the transmission path of emails between
the sender and receipt on our server; Legal bases: Legitimate interests (Art. 6(1) sentence
1 lit. f GDPR).
- STRATO: Services in the area of providing information technology infrastructure and related
services (e.g., storage space and or computing capacities); Service provider: STRATO AG,
Pascalstraße 10,10587 Berlin, Germany; Legal bases: Legitimate interests (Art. 6(1)
sentence 1 lit. f GDPR); Website: https://www.strato.de; Privacy policy: https://www.strato.de/datenschutz;
Data processing agreement: Provided by the service provider.
Registration, Login, and User Account
Users can create a user account. As part of registration, users are informed of the required mandatory
information and it is processed for the purpose of providing the user account on the basis of fulfilling
contractual obligations. The processed data includes, in particular, login information (username, password, and
an email address).
In the context of using our registration and login functions as well as using the user account, we store the IP
address and the time of the respective user action. Storage takes place on the basis of our legitimate interests
as well as those of users in protection against misuse and other unauthorized use. Disclosure of this data to
third parties does not generally take place unless it is necessary to pursue our claims or there is a legal
obligation to do so.
Users may be informed by email about processes relevant to their user account, such as technical changes.
- Types of data processed: Inventory data (e.g., names, addresses); contact data (e.g.,
email, phone numbers); content data (e.g., entries in online forms); meta/communication data (e.g., device
information, IP addresses).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of contractual services and customer service; security
measures; administration and responding to inquiries; provision of our online offering and
user-friendliness.
- Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1
lit. b GDPR); legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).
Further notes on processing operations, procedures and services:
- Registration using real names: Due to the nature of our community, we ask users to use our
offering only using real names. This means the use of pseudonyms is not permitted; Legal
bases: Performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1 lit. b
GDPR).
- User profiles are public: User profiles are publicly visible and accessible; Legal
bases: Performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1 lit. b
GDPR).
- Deletion of data after termination: If users have terminated their user account, their data
with regard to the user account will be deleted, subject to statutory authorization, obligation, or user
consent; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)
sentence 1 lit. b GDPR).
- No retention obligation for data: It is the responsibility of users to back up their data
before the end of the contract when termination has occurred. We are entitled to irretrievably delete all
data stored during the term of the contract; Legal bases: Performance of a contract and
pre-contractual inquiries (Art. 6(1) sentence 1 lit. b GDPR).
Community Features
The community features we provide enable users to engage in conversations with each other or otherwise to
exchange with one another. In this context, please note that use of the community features is permitted only in
compliance with applicable law, our terms and policies, as well as the rights of other users and third parties.
- Types of data processed: Usage data (e.g., visited websites, interest in content, access
times); meta/communication data (e.g., device information, IP addresses).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of contractual services and customer service; security
measures.
- Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1
lit. b GDPR).
Further notes on processing operations, procedures and services:
- User posts are public: The posts and content created by users are publicly visible and
accessible; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)
sentence 1 lit. b GDPR).
- Storage of data for security purposes: User posts and other entries are processed for the
purposes of the community and conversation features and, subject to legal obligations or statutory
authorization, are not disclosed to third parties. An obligation to disclose may arise in particular in the
case of unlawful posts for the purpose of legal prosecution. We point out that in addition to the content of
posts, their time and users’ IP addresses are stored. This is done in order to be able to take appropriate
measures to protect other users and the community; Legal bases: Performance of a contract
and pre-contractual inquiries (Art. 6(1) sentence 1 lit. b GDPR).
- Right to delete content and information: The deletion of posts, content, or user
information is permissible after an appropriate balancing of interests to the extent required if there are
specific indications that they represent a violation of legal rules, our requirements, or third-party
rights; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)
sentence 1 lit. b GDPR).
- Restricted deletion of conversation contributions: Out of consideration for other users, a
user’s conversation contributions remain stored even after termination and account deletion so that
conversations, comments, advice, or similar communications between and among users do not lose or reverse
their meaning. Usernames are deleted or pseudonymized unless they already constituted pseudonyms. Users can
assert the complete deletion of conversation contributions with us at any time; Legal
bases: Performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1 lit. b
GDPR).
- Protection of one’s own data: Users decide themselves which data they disclose about
themselves within our online offering. For example, if users provide information about themselves or
participate in conversations. We ask users to protect their data and to publish personal data only carefully
and only to the extent necessary. In particular, we ask users to note that they must protect their access
data especially well and use secure passwords (i.e., in particular combinations of characters that are as
long and random as possible); Legal bases: Performance of a contract and pre-contractual
inquiries (Art. 6(1) sentence 1 lit. b GDPR).
Contact and Inquiry Management
When contacting us (e.g., via contact form, email, telephone, or via social media), as well as within the scope
of existing user and business relationships, the information provided by the requesting persons is processed
insofar as this is necessary to answer the contact inquiries and any requested measures. To protect our forms
and online services against abusive automated input, spam, and bot-based attacks, we also use Google reCAPTCHA.
- Types of data processed: Contact data (e.g., email, phone numbers); content data (e.g.,
entries in online forms); usage data (e.g., visited websites, interest in content, access times, user
interactions); meta/communication data (e.g., device information, IP addresses, browser type, operating
system, referrer URL, date and time of access).
- Data subjects: Communication partners.
- Purposes of processing: Contact inquiries and communication; administration and responding
to inquiries; feedback (e.g., collecting feedback via online form); provision of our online offering and
user-friendliness; security measures; protection against abusive automated input, spam, and bot attacks.
- Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR); performance of a
contract and pre-contractual inquiries (Art. 6(1) sentence 1 lit. b GDPR).
Further notes on processing operations, procedures and services:
- Contact form: If users contact us via our contact form, email, or other communication
channels, we process the data provided to us in this context to handle the communicated request;
Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1
lit. b GDPR), legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).
- Google reCAPTCHA: We use Google reCAPTCHA v3 to protect our forms and online services
against abusive automated input, spam, and bot-based attacks. The provider is Google Ireland Limited, Gordon
House, Barrow Street, Dublin 4, Ireland. Google reCAPTCHA v3 is used to determine whether actions on our
website are carried out by a natural person or abusively by automated processing. For this purpose,
reCAPTCHA v3 may run in the background and analyze user interactions in order to generate a risk score used
to assess the respective request. In this context, data such as IP address, browser and operating system
information, referrer URL, date and time of access, mouse movements, keyboard input, time spent on the page,
user interactions, and other technical data required for risk analysis and abuse prevention may be
processed. In addition, the cookie
_GRECAPTCHA may be set. Processing is based on our
legitimate interests in ensuring the security, integrity, and availability of our website and in protecting
against spam, abusive automated data extraction, and attacks in accordance with Art. 6(1) sentence 1 lit. f
GDPR. Where personal data is transferred to third countries in the context of using Google reCAPTCHA v3,
this is done only in accordance with applicable legal requirements.
Newsletters and Electronic Notifications
We send newsletters, emails, and other electronic notifications (hereinafter “newsletter”) only with the consent
of the recipients or a statutory authorization. If, in the context of subscribing to the newsletter, its
contents are specifically described, they are decisive for users’ consent. Otherwise, our newsletters contain
information about our services and us.
To subscribe to our newsletters, it is generally sufficient to provide your email address. However, we may ask
you to provide a name for the purpose of personal address in the newsletter, or further information if this is
necessary for the purposes of the newsletter.
Double opt-in procedure: Subscription to our newsletter generally takes place using a so-called
double opt-in procedure. This means you will receive an email after subscribing in which you are asked to
confirm your subscription. This confirmation is necessary so that no one can subscribe using third-party email
addresses. Newsletter subscriptions are logged in order to be able to prove the subscription process in
accordance with legal requirements. This includes storing the subscription and confirmation time as well as the
IP address. Likewise, changes to your data stored by the shipping service provider are logged.
Deletion and restriction of processing: We may store unsubscribed email addresses for up to
three years on the basis of our legitimate interests before deleting them in order to be able to prove a
previously given consent. Processing of this data is restricted to the purpose of possible defense against
claims. An individual deletion request is possible at any time, provided the former existence of consent is
simultaneously confirmed. In the case of obligations to permanently observe objections, we reserve the right to
store the email address solely for this purpose in a blocking list (so-called “blocklist”).
Logging of the subscription procedure is carried out on the basis of our legitimate interests for the purpose of
proving its proper execution. Insofar as we commission a service provider with sending emails, this is done on
the basis of our legitimate interests in an efficient and secure dispatch system.
Content:
Information about us, our services, promotions and offers.
- Types of data processed: Inventory data (e.g., names, addresses); contact data (e.g.,
email, phone numbers); meta/communication data (e.g., device information, IP addresses); usage data (e.g.,
visited websites, interest in content, access times).
- Data subjects: Communication partners; users (e.g., website visitors, users of online
services).
- Purposes of processing: Direct marketing (e.g., via email or post); provision of
contractual services and customer service.
- Legal bases: Consent (Art. 6(1) sentence 1 lit. a GDPR); legitimate interests (Art. 6(1)
sentence 1 lit. f GDPR).
- Right to object (opt-out): You can cancel receipt of our newsletter at any time, i.e.,
withdraw your consent or object to further receipt. You will find a link to cancel the newsletter either at
the end of each newsletter or can otherwise use one of the contact options provided above, preferably email,
for this purpose.
Further notes on processing operations, procedures and services:
- Measurement of open and click rates: The newsletters contain a so-called “web beacon”,
i.e., a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a
shipping service provider, from their server. As part of this retrieval, technical information, such as
information about the browser and your system, as well as your IP address and the time of retrieval, is
collected.
This information is used to technically improve our newsletter based on 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. Legal bases: Consent (Art. 6(1) sentence 1 lit. a GDPR).
- Condition for the use of free services: Consent to the sending of mailings may be made a
condition for the use of free services (e.g., access to certain content or participation in certain
promotions). If users wish to use the free service without subscribing to the newsletter, we ask you to
contact us.
- Dispatch via SMS: Electronic notifications may also be sent as SMS text messages (or are
sent exclusively via SMS if the authorization to send, e.g., a consent, only covers dispatch via SMS);
Legal bases: Consent (Art. 6(1) sentence 1 lit. a GDPR).
- Mailchimp: Email dispatch and email marketing platform; Service provider:
Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Legal
bases: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR); Website: https://mailchimp.com; Privacy policy:
https://mailchimp.com/legal/; Data
processing agreement: https://mailchimp.com/legal/; Standard contractual clauses (ensuring an
adequate level of data protection in third countries): Included in the data processing
agreement; Further information: Special security measures: https://mailchimp.com/help/Mailchimp-european-data-transfers/.
Advertising Communication via Email, Post, Fax, or Telephone
We process personal data for purposes of advertising communication, which can be carried out via various
channels, such as email, telephone, post, or fax, in accordance with legal requirements.
Recipients have the right to withdraw consents given at any time or to object to advertising communication at any
time.
After withdrawal or objection, we store the data necessary to prove the previous authorization for contact or
dispatch for up to three years after the end of the year of withdrawal or objection on the basis of our
legitimate interests. Processing of this data is restricted to the purpose of possible defense against claims.
On the basis of the legitimate interest in permanently observing users’ withdrawal or objection, we also store
the data necessary to prevent renewed contact (e.g., depending on the communication channel, the email address,
telephone number, name).
- Types of data processed: Inventory data (e.g., names, addresses); contact data (e.g.,
email, phone numbers).
- Data subjects: Communication partners.
- Purposes of processing: Direct marketing (e.g., via email or post).
- Legal bases: Consent (Art. 6(1) sentence 1 lit. a GDPR); legitimate interests (Art. 6(1)
sentence 1 lit. f GDPR).
Sweepstakes and Competitions
We process personal data of participants in sweepstakes and competitions only in compliance with the relevant
data protection provisions, insofar as processing is contractually necessary for providing, conducting, and
handling the sweepstakes, participants have consented to processing, or processing serves our legitimate
interests (e.g., in the security of the sweepstakes or protecting our interests against misuse through possible
collection of IP addresses when submitting sweepstakes entries).
If, in the context of sweepstakes, participants’ contributions are published (e.g., as part of a vote or
presentation of the sweepstakes entries or winners or reporting on the sweepstakes), we point out that
participants’ names may also be published in this context. Participants can object to this at any time.
If the sweepstakes takes place within an online platform or a social network (e.g., Facebook or Instagram,
hereinafter referred to as “online platform”), the terms of use and data protection provisions of the respective
platforms also apply. In these cases, we point out that we are responsible for the information provided by
participants within the scope of the sweepstakes and that inquiries regarding the sweepstakes should be directed
to us.
Participants’ data will be deleted as soon as the sweepstakes or competition has ended and the data is no longer
required in order to inform winners or because inquiries about the sweepstakes are to be expected. As a rule,
participants’ data will be deleted no later than six months after the end of the sweepstakes. Winners’ data may
be retained longer in order, for example, to answer questions about prizes or to fulfill prize services. In this
case, the retention period depends on the type of prize and is, for example, up to three years for items or
services in order to be able to handle warranty cases. Furthermore, participants’ data may be stored longer, for
example in the form of reporting on the sweepstakes in online and offline media.
If data was also collected for other purposes in the context of the sweepstakes, its processing and retention
period are governed by the privacy notices for such use (e.g., in the case of newsletter subscription in the
context of a sweepstakes).
- Types of data processed: Inventory data (e.g., names, addresses); content data (e.g.,
entries in online forms); meta/communication data (e.g., device information, IP addresses).
- Data subjects: Sweepstakes and competition participants.
- Purposes of processing: Conducting sweepstakes and competitions.
- Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1
lit. b GDPR).
Surveys and Questionnaires
We conduct surveys and questionnaires in order to collect information for the respectively communicated survey or
questionnaire purpose. The surveys and questionnaires conducted by us (hereinafter “surveys”) are evaluated
anonymously. Personal data is processed only insofar as this is necessary for providing and technically carrying
out the surveys (e.g., processing the IP address in order to display the survey in the user’s browser or to
enable resuming the survey using a cookie).
- Types of data processed: Contact data (e.g., email, phone numbers); content data (e.g.,
entries in online forms); usage data (e.g., visited websites, interest in content, access times);
meta/communication data (e.g., device information, IP addresses).
- Data subjects: Communication partners; participants.
- Purposes of processing: Feedback (e.g., collecting feedback via online form).
- Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).
Web Analytics, Monitoring and Optimization
Web analytics (also referred to as “reach measurement”) serves to evaluate visitor flows of our online offering
and can include behavior, interests, or demographic information about visitors, such as age or gender, as
pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online
offering or its functions or content are used most frequently or invite reuse. Likewise, we can track which
areas require optimization.
In addition to web analytics, we may also use testing procedures, for example to test and optimize different
versions of our online offering or its components.
Unless stated otherwise below, profiles, i.e., data summarized for a usage process, can be created and
information can be stored in a browser or end device and read from it for these purposes. The collected
information includes, in particular, visited websites and elements used there, as well as technical information,
such as the browser and computer system used and information on usage times. If users have consented to the
collection of their location data toward us or toward the providers of the services we use, location data may
also be processed.
Users’ IP addresses are also stored. However, we use an IP masking procedure (i.e., pseudonymization by
truncating the IP address) to protect users. In general, in the context of web analytics, A/B testing, and
optimization, no clear data of users (such as email addresses or names) is stored, but pseudonyms. This means
that we as well as the providers of the software used do not know the actual identity of the users, but only the
information stored in their profiles for the purposes of the respective procedures.
- Types of data processed: Usage data (e.g., visited websites, interest in content, access
times); meta/communication data (e.g., device information, IP addresses).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g., access statistics, recognition of
returning visitors); profiles with user-related information (creation of user profiles).
- Security measures: IP masking (pseudonymization of the IP address).
Further information on processing operations, procedures and services:
-
Google Analytics 4: Where users have given their consent, we use Google Analytics 4, a web
analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google
Analytics 4 enables us to analyze the use of our online offering, in particular through the collection of
page
views, duration of visits, interactions, approximate location data, technical information about the device
and
browser used, as well as usage events. Cookies may be used and information may be stored on or read from the
user’s end device. According to Google, the IP address is not logged or stored in full and is truncated
before
storage, or only transmitted in exceptional cases to Google servers in the USA and shortened there. The data
processed by Google Analytics may be transferred to servers of Google in the USA. Processing is carried out
exclusively on the basis of the user’s consent in accordance with Art. 6 (1) lit. a GDPR. Users can revoke
their consent at any time with effect for the future, in particular via the cookie settings of our online
offering. Further information: https://policies.google.com/privacy.
-
Google Tag Manager: We use Google Tag Manager, a service provided by Google Ireland
Limited,
Gordon House, Barrow Street, Dublin 4, Ireland. Google Tag Manager is a tool that allows website tags to be
managed via an interface. According to Google, Google Tag Manager itself does not process personal data and
does not set cookies. It merely triggers other tags, which in turn may collect data. Where services
requiring
consent are integrated via Google Tag Manager, their use is based exclusively on the user’s consent in
accordance with Art. 6 (1) lit. a GDPR. Further information: https://policies.google.com/privacy.
-
Google Search Console: We use Google Search Console, a service provided by Google Ireland
Limited, Gordon House, Barrow Street, Dublin 4, Ireland, to monitor, analyze and technically optimize the
visibility of our online offering in Google search results. The use of Google Search Console is limited to
the
administrative area and is carried out exclusively by us as the website operator. As a rule, no independent
processing of personal data of visitors to our online offering takes place in this context. Further
information: https://policies.google.com/privacy.
Online Marketing
We process personal data for purposes of online marketing, which may include, in particular, marketing of
advertising space or displaying advertising and other content (collectively referred to as “content”) based on
users’ potential interests, as well as measuring its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar
procedures are used by means of which information relevant to the display of the aforementioned content is
stored about the user. This information may include, for example, content viewed, visited websites, used online
networks, but also communication partners and technical information such as the browser used, the computer
system used as well as information about usage times and functions used. If users have consented to the
collection of their location data, this may also be processed.
Users’ IP addresses are also stored. However, we use available IP masking procedures (i.e., pseudonymization by
truncating the IP address) to protect users. In general, within the scope of online marketing procedures, no
clear data of users (such as email addresses or names) is stored, but pseudonyms. This means that we as well as
the providers of the online marketing procedures do not know the actual identity of the users, but only the
information stored in their profiles.
The information in the profiles is generally stored in cookies or by means of similar procedures. These cookies
can later generally also be read on other websites that use the same online marketing procedure and analyzed for
the purpose of displaying content as well as supplemented with further data and stored on the server of the
online marketing procedure provider.
Exceptionally, clear data may be assigned to the profiles. This is the case if users, for example, are members of
a social network whose online marketing procedure we use and the network links the users’ profiles with the
aforementioned information. Please note that users may enter into additional agreements with the providers, for
example through consent in the context of registration.
As a rule, we only gain access to aggregated information about the success of our advertisements. However, in the
context of so-called conversion measurements, we can check which of our online marketing procedures led to a
so-called conversion, i.e., for example, to the conclusion of a contract with us. Conversion measurement is used
solely to analyze the success of our marketing measures.
Unless stated otherwise, please assume that cookies used are stored for a period of two years.
- Types of data processed: Usage data (e.g., visited websites, interest in content, access
times); meta/communication data (e.g., device information, IP addresses).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g., access statistics, recognition of
returning visitors); tracking (e.g., interest-based and or behavior-based profiling, use of cookies);
marketing; profiles with user-related information (creation of user profiles).
- Security measures: IP masking (pseudonymization of the IP address).
- Right to object (opt-out): We refer to the privacy notices of the respective providers and
the objection options (so-called “opt-out”) provided for the providers. If no explicit opt-out option is
specified, there is, on the one hand, the possibility that you can disable cookies in your browser settings.
However, this may restrict functions of our online offering. We therefore additionally recommend the
following opt-out options, which are offered in summary for respective regions:
a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://www.youradchoices.ca/choices.
c) USA: https://www.aboutads.info/choices.
d) Cross-region: https://optout.aboutads.info.
Customer Reviews and Rating Procedures
We participate in review and rating procedures to evaluate, optimize, and promote our services. If users rate us
via the involved rating platforms or procedures or otherwise provide feedback, the general terms and conditions
or terms of use and privacy notices of the providers also apply. As a rule, rating also requires registration
with the respective providers.
To ensure that the rating persons have actually used our services, we transmit, with the customers’ consent, the
data required for this purpose with regard to the customer and the service used to the respective rating
platform (including name, email address, and order number or item number). This data is used solely to verify
the authenticity of the user.
- Types of data processed: Contract data (e.g., subject matter of the contract, term,
customer category); usage data (e.g., visited websites, interest in content, access times);
meta/communication data (e.g., device information, IP addresses).
- Data subjects: Customers; users (e.g., website visitors, users of online services).
- Purposes of processing: Feedback (e.g., collecting feedback via online form); marketing.
- Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).
Further notes on processing operations, procedures and services:
- Rating widget: We integrate so-called “rating widgets” into our online offering. A widget
is a functional and content element integrated into our online offering that displays changeable
information. It can, for example, be displayed in the form of a seal or comparable element, sometimes also
called a “badge”. While the respective content of the widget is displayed within our online offering, it is
retrieved at that moment from the servers of the respective widget provider. Only in this way can the
current content always be displayed, especially the current rating. For this purpose, a data connection must
be established from the website accessed within our online offering to the server of the widget provider and
the widget provider receives certain technical data (access data, including IP address) necessary for the
widget content to be delivered to the user’s browser.
Furthermore, the widget provider receives information that users have visited our online offering. This
information can be stored in a cookie and used by the widget provider to recognize which online offerings
participating in the rating procedure have been visited by the user. The information can be stored in a user
profile and used for advertising or market research purposes; Legal bases: Legitimate
interests (Art. 6(1) sentence 1 lit. f GDPR).
Presences on Social Networks (Social Media)
We maintain online presences within social networks and, in this context, process users’ data in order to
communicate with users active there or to offer information about us.
We point out that users’ data may be processed outside the European Union. This may result in risks for users, as
enforcement of users’ rights could be made more difficult, for example.
Furthermore, users’ data within social networks is generally processed for market research and advertising
purposes. For example, usage profiles can be created based on users’ usage behavior and resulting interests. The
usage profiles may in turn be used, for example, to place advertisements within and outside the networks that
presumably correspond to users’ interests. For these purposes, cookies are generally stored on users’ computers
in which users’ usage behavior and interests are stored. Furthermore, data may also be stored in the usage
profiles independent of the devices used by users (in particular if users are members of the respective
platforms and are logged in to them).
For a detailed presentation of the respective processing forms and objection options (opt-out), we refer to the
privacy policies and information provided by the operators of the respective networks.
Also in the case of requests for information and assertion of data subject rights, we point out that these can be
most effectively asserted with the providers. Only the providers have access to users’ data and can directly
take appropriate measures and provide information. If you nevertheless need help, you can contact us.
- Types of data processed: Contact data (e.g., email, phone numbers); content data (e.g.,
entries in online forms); usage data (e.g., visited websites, interest in content, access times);
meta/communication data (e.g., device information, IP addresses).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Contact inquiries and communication; feedback (e.g., collecting
feedback via online form); marketing.
- Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).
Further notes on processing operations, procedures and services:
- Instagram: Social network; Service provider: Meta Platforms Ireland
Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal bases:
Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR); Website: https://www.instagram.com; Privacy
policy: https://instagram.com/about/legal/privacy.
- Facebook Pages: Profiles within the social network Facebook – We are jointly responsible
with Meta Platforms Ireland Limited for the collection (but not the further processing) of data of visitors
to our Facebook page (so-called “fan page”). This data includes information on the types of content users
view or interact with, or actions they take (see under “Things you and others do and provide” in the
Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by
users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see under “Device
information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under
“How do we use this information?”, Facebook collects and uses information also to provide analytics
services, so-called “Page Insights”, for page operators so that they can gain insights into how people
interact with their pages and the content associated with them. We have concluded a special agreement with
Facebook (“Page Insights Information”, https://www.facebook.com/legal/terms/page_controller_addendum) which regulates, in
particular, which security measures Facebook must observe and in which Facebook has agreed to fulfill data
subject rights (i.e., users can, for example, direct requests for information or deletion directly to
Facebook). Users’ rights (in particular to access, deletion, objection, and complaint to the competent
supervisory authority) are not restricted by the agreements with Facebook. Further information can be found
in the “Page Insights Information” (https://www.facebook.com/legal/terms/information_about_page_insights_data);
Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal
Harbour, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f
GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Standard contractual clauses
(ensuring an adequate level of data protection in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Further
information: Joint controllership agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data. Joint
controllership is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a
company established in the EU. The further processing of the data lies in the sole responsibility of Meta
Platforms Ireland Limited, which in particular concerns the transfer of data to the parent company Meta
Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta
Platforms Ireland Limited and Meta Platforms, Inc.).
- LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited
Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal bases: Legitimate interests
(Art. 6(1) sentence 1 lit. f GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Data processing
agreement: https://legal.linkedin.com/dpa; Standard contractual clauses (ensuring an
adequate level of data protection in third countries): https://legal.linkedin.com/dpa; Objection option (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Snapchat: Social network; Service provider: Snap Inc., 3000 31st Street,
Santa Monica, California 90405 USA; Legal bases: Legitimate interests (Art. 6(1) sentence 1
lit. f GDPR); Website: https://www.snapchat.com/; Privacy policy: https://www.snap.com/de-DE/privacy/privacy-policy, Cookie policy: https://www.snap.com/de-DE/cookie-policy; Standard contractual clauses
(ensuring an adequate level of data protection in third countries): https://www.snap.com/en-US/terms/standard-contractual-clauses.
- TikTok: Social network / video platform; Service provider: TikTok
Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland; Legal bases:
Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR); Website: https://www.tiktok.com; Privacy
policy: https://www.tiktok.com/de/privacy-policy.
- Twitter: Social network; Service provider: Twitter International Company,
One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, parent company: Twitter Inc., 1355 Market
Street, Suite 900, San Francisco, CA 94103, USA; Legal bases: Legitimate interests (Art.
6(1) sentence 1 lit. f GDPR); Privacy policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
- YouTube: Social network and video platform; Service provider: Google
Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate
interests (Art. 6(1) sentence 1 lit. f GDPR); Privacy policy: https://policies.google.com/privacy;
Objection option (opt-out): https://adssettings.google.com/authenticated.
Plugins and Embedded Functions and Content
We integrate functional and content elements into our online offering that are obtained from the servers of their
respective providers (hereinafter referred to as “third-party providers”). These may be, for example, graphics,
videos, or maps (hereinafter uniformly referred to as “content”).
Integration always requires that the third-party providers of such content process the users’ IP address, as they
could not otherwise send the content to users’ browsers without the IP address. The IP address is therefore
necessary for the display of this content or functions. We strive to use only content whose respective providers
use the IP address solely for delivering the content. Third-party providers may also use so-called pixel tags
(invisible graphics, also referred to 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 users’ devices and may contain, among other things, technical
information about the browser and operating system, referring websites, time of visit, and other information
about the use of our online offering, and may also be linked with such information from other sources.
- Types of data processed: Usage data (e.g., visited websites, interest in content, access
times); meta/communication data (e.g., device information, IP addresses).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of our online offering and user-friendliness; provision
of contractual services and customer service; marketing; profiles with user-related information (creation of
user profiles).
- Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).
Further notes on processing operations, procedures and services:
- Integration of third-party software, scripts, or frameworks (e.g., jQuery): We integrate
software into our online offering that we retrieve from servers of other providers (e.g., function libraries
that we use for the purpose of presentation or user-friendliness of our online offering). In doing so, the
respective providers collect users’ IP addresses and may process them for the purposes of transmitting the
software to users’ browsers and for purposes of security, as well as for evaluating and optimizing their
offering. – We integrate software into our online offering that we retrieve from servers of other providers
(e.g., function libraries that we use for the purpose of presentation or user-friendliness of our
online offering). In doing so, the respective providers collect users’ IP addresses and may process them for
the purposes of transmitting the software to users’ browsers and for purposes of security, as well as for
evaluating and optimizing their offering; Legal bases: Legitimate interests (Art. 6(1)
sentence 1 lit. f GDPR).
- Instagram plugins and content: Instagram plugins and content – These may include, for
example, content such as images, videos, or texts and buttons with which users can share content of this
online offering within Instagram. – We are jointly responsible with Meta Platforms Ireland Limited for the
collection or receipt in the context of a transfer (but not the further processing) of “event data” that
Facebook collects by means of Instagram functions (e.g., embedding functions for content) that are executed
on our online offering or receives in the context of a transfer for the following purposes: a) Display of
content as well as advertising information that corresponds to the presumed interests of users; b) Delivery
of commercial and transaction-related messages (e.g., addressing users via Facebook Messenger); c)
Improvement of ad delivery and personalization of functions and content (e.g., improving the recognition of
which content or advertising information presumably corresponds to users’ interests). We have concluded a
special agreement with Facebook (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum), which regulates in particular
which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has
agreed to fulfill data subject rights (i.e., users can, for example, direct requests for information or
deletion directly to Facebook). Note: If Facebook provides us with metrics, analyses, and reports (which are
aggregated, i.e., contain no information about individual users and are anonymous for us), this processing
does not take place in the context of joint responsibility, but on the basis of a data processing agreement
(“Data Processing Terms”, https://www.facebook.com/legal/terms/dataprocessing), the “Data Security Terms” (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to
processing in the USA, on the basis of standard contractual clauses (“Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). Users’ rights (in
particular to access, deletion, objection, and complaint to the competent supervisory authority) are not
restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland
Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal bases:
Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR); Website: https://www.instagram.com; Privacy
policy: https://instagram.com/about/legal/privacy.
- OpenStreetMap: We integrate the maps of the “OpenStreetMap” service, which are offered on
the basis of the Open Data Commons Open Database License (ODbL) by the OpenStreetMap Foundation (OSMF).
Users’ data is used by OpenStreetMap exclusively for the purpose of displaying the map functions and for
caching the selected settings. This data may include, in particular, users’ IP addresses and location data,
which, however, is not collected without their consent (as a rule, within the settings of their mobile
devices); Service provider: OpenStreetMap Foundation (OSMF); Legal bases:
Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR); Website: https://www.openstreetmap.de; Privacy
policy: https://wiki.osmfoundation.org/wiki/Privacy_Policy.
Amendment and Updating of the Privacy Policy
We ask you to regularly inform yourself about the contents of our privacy policy. We adjust the privacy policy as
soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the
changes require an act of cooperation on your part (e.g., consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, please
note that the addresses may change over time and please verify the information before contacting.
Rights of the Data Subjects
As data subjects, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:
- Right to object: You have the right, on grounds relating to your particular situation, to object at
any time to the processing of personal data concerning you which is based on Article 6(1) lit. e or f
GDPR; this also applies to profiling based on these provisions. Where personal data concerning you is
processed for direct marketing purposes, you have the right to object at any time to the processing of
personal data concerning you for such marketing; this also applies to profiling to the extent that it is
related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw consents granted at any time.
- Right of access: You have the right to request confirmation as to whether data concerning
you is being processed and to obtain access to such data, as well as further information and a copy of the
data in accordance with legal requirements.
- Right to rectification: In accordance with legal requirements, you have the right to
request completion of data concerning you or correction of inaccurate data concerning you.
- Right to erasure and restriction of processing: In accordance with legal requirements, you
have the right to request that data concerning you be erased without undue delay or, alternatively, to
request restriction of processing of the data in accordance with legal requirements.
- Right to data portability: You have the right to receive data concerning you that you have
provided to us, in a structured, commonly used, and machine-readable format in accordance with legal
requirements, or to request its transmission to another controller.
- Complaint with a supervisory authority: Without prejudice to any other administrative or
judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the
Member State of your habitual residence, place of work, or place of the alleged infringement, if you
consider that the processing of personal data concerning you infringes the requirements of the GDPR.
Definitions
In this section you will find an overview of the terminology used in this privacy policy. Many of the terms are
taken from the law and are defined primarily in Article 4 GDPR. The legal definitions are binding. The following
explanations, on the other hand, are intended primarily to aid understanding. The terms are listed
alphabetically.
- Conversion measurement: Conversion measurement (also referred to as “visit action
evaluation”) is a procedure used to determine the effectiveness of marketing measures. For this purpose, as
a rule, a cookie is stored on users’ devices within the websites on which the marketing measures take place
and then retrieved again on the target website. For example, we can use this to track whether the ads we
placed on other websites were successful.
- Personal data: “Personal data” means any information relating to an identified or
identifiable natural person (hereinafter “data subject”); a natural person is considered identifiable if
they can be identified, directly or indirectly, in particular by reference to an identifier such as a name,
an identification number, location data, an online identifier (e.g., cookie) or to one or more factors
specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that
natural person.
- Profiles with user-related information: The processing of “profiles with user-related
information”, or “profiles” for short, includes any kind of automated processing of personal data consisting
of the use of such personal data to evaluate certain personal aspects relating to a natural person
(depending on the type of profiling, this may include different information relating to demography,
behavior, and interests, such as interaction with websites and their content, etc.) to analyze, evaluate, or
predict them (e.g., interests in certain content or products, click behavior on a website, or location).
Cookies and web beacons are often used for profiling purposes.
- Reach measurement: Reach measurement (also referred to as web analytics) serves to evaluate
the visitor flows of an online offering and can include the behavior or interests of visitors in certain
information, such as content of websites. With the help of reach analysis, website operators can, for
example, recognize at what time visitors visit their website and which content they are interested in. This
enables them, for example, to better adapt the content of the website to the needs of their visitors. For
purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning
visitors and thus obtain more precise analyses of the use of an online offering.
- Tracking: “Tracking” refers to the ability to trace the behavior of users across multiple
online offerings. As a rule, behavioral and interest information is stored in cookies or on servers of the
providers of tracking technologies with regard to the online offerings used (so-called profiling). This
information can then be used, for example, to display advertisements to users that are likely to correspond
to their interests.
- Controller: The “controller” is the natural or legal person, public authority, agency, or
other body which, alone or jointly with others, determines the purposes and means of the processing of
personal data.
- Processing: “Processing” is any operation or set of operations which is performed on
personal data, whether or not by automated means. The term is broad and encompasses practically any handling
of data, be it collection, evaluation, storage, transmission, or deletion.