Privacy policy

Introduction

With the following data protection declaration we would like to inform you about the types of personal data (hereinafter also referred to as “data”) we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter also referred to collectively as “online offer”).

The terms used are not gender-specific.

Status: October 6, 2020

Responsible person

Betsa GmbH
Landsberger Straße 394
81241 München
Deutschland

Authorized Representatives: Vasyl Betsa, Geschäftsführer

E-Mail-Adresse: contact@betsa.de

Telefon: +49 89 90179802

Overview of the processing

Die nachfolgende Übersicht fasst die Arten der verarbeiteten Daten und die Zwecke ihrer Verarbeitung zusammen und verweist auf die betroffenen Personen.

Types of data processed

  • Stock data (e.g. names, addresses).
  • Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein,
  • such as cover letter, curriculum vitae, certificates and other information about a specific position or information voluntarily provided by applicants about their person or qualification).
  • Content data (e.g. text entries, photographs, videos).
  • Contact data (e.g. e-mail, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Location data (data indicating the location of an end user’s terminal device).
  • Contract data (e.g. subject of contract, duration, customer category).
  • Payment data (e.g. bank details, invoices, payment history).
  • Categories of affected persons
  • Applicants.
  • Business and contractual partners.
  • Interested parties.
  • communication partners.
  • members.
  • Users (e.g. website visitors, users of online services).

Aims of the processing

  • Provision of our online offer and user-friendliness.
  • Visitor action evaluation.
  • Application procedure (justification and possible later implementation as well as possible later termination of the employment relationship.)
  • Office and organizational procedures.
  • Direct marketing (e.g. by e-mail or by post).
  • Interest-based and behavioral marketing.
  • Contact inquiries and communication.
  • Profiling (creation of user profiles).
  • remarketing.
  • Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Tracking (e.g. interest/behavioral profiling, use of cookies).
  • Contractual performance and service.
  • Administration and answering of inquiries.

Applicable legal basis

In the following, we provide the legal basis of the Basic Data Protection Regulation (DSGVO), on the basis of which we process personal data. Please note that in addition to the regulations of the DSGVO, national data protection regulations may apply in your or our country of residence and domicile. Should more specific legal regulations apply in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 para. 1 sentence 1 letter a FADP) – The data subject has given his or her consent to the processing of personal data concerning him or her for one or more specific purposes.
  • Fulfilment of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 letter b. FADP) – Processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the request of the data subject.
  • Legal obligation (Art. 6 para. 1 sentence 1 letter c. DPA) – The processing is necessary for the performance of a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO) – The processing is necessary to safeguard the legitimate interests of the controller or of a third party, unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data outweigh these.
  • Art. 9 para. 1 sentence 1 lit. b DSGVO (application procedure as a pre-contractual or contractual relationship) (Insofar as special categories of personal data within the meaning of Art. 9 para. 1 DSGVO (e.g. health data, such as severely handicapped status or ethnic origin) are requested from applicants so that the responsible person or the data subject can exercise the rights arising to him or her from employment law and social security and social protection law and fulfil his or her obligations in this respect, their processing is carried out in accordance with Art. 9 Paragraph 2 letter b. DSGVO, in the case of protection of vital interests of applicants or other persons according to art. 9 par. 2 letter c. DSGVO or for the purposes of health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnosis, care or treatment in the health or social sector or for the management of systems and services in the health or social sector in accordance with Art. 9 para. 2 lit. h. DSGVO. In the case of communication of special categories of data based on voluntary consent, their processing is carried out on the basis of art. 9, paragraph 2, letter a. DSGVO) – .

National data protection regulations in Germany: In addition to the data protection regulations of the Basic Data Protection Regulation, national regulations on data protection apply in Germany. These include in particular the law on protection against misuse of personal data in data processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to deletion, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision making in individual cases including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (§ 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

Security measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

Such measures shall include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, security of availability and separation of data relating to them. Furthermore, we have established procedures to ensure that data subjects’ rights are exercised, data is deleted, and responses are made to any threats to the data. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes in accordance with the principle of data protection, by designing technology and by using data protection-friendly default settings.

SSL encryption (https): To protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.

Transmission and disclosure of personal data

In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. The recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

Data processing in third countries

If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of services of third parties or the disclosure or transfer of data to other persons, bodies or companies, this is only done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we process or have the data processed only in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, certification or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

Use of cookies

Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after his visit within an online offer. The stored information can include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was viewed. The term “cookies” also includes other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also referred to as “user IDs”)

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
  • Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The interests of users used for reach measurement or marketing purposes can also be stored in such a cookie.
  • First-party cookies: First-party cookies are set by us.
  • Third party cookies (also: third party cookies): Third party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or absolutely necessary) cookies: Cookies may be absolutely necessary for the operation of a website (e.g. to store logins or other user input or for security reasons).
  • Statistical, marketing and personalization cookies: Furthermore, cookies are usually also used in the context of range measurement and when the interests of a user or his or her behavior (e.g. viewing certain content, using functions, etc.) on individual web pages are stored in a user profile. Such profiles are used to show users e.g. content that corresponds to their potential interests. This procedure is also known as “tracking”, i.e. following the potential interests of users. If we use cookies or “tracking” technologies, we will inform you separately in our privacy policy or when you give your consent.

Notes on legal bases:

The legal basis on which we process your personal data using cookies depends on whether we ask you for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in a business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfil our contractual obligations.

Storage duration:

Unless we provide you with explicit information on the storage duration of permanent cookies (e.g. within the scope of a so-called cookie opt-in), please assume that the storage duration can be up to two years.

General information on revocation and opposition (opt-out):

Depending on whether the processing is based on consent or legal permission, you may at any time revoke any consent you have given or object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection by means of the settings of your browser, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online service). An objection to the use of cookies for online marketing purposes can also be declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further notices of objection in the context of the information on the service providers and cookies used.

Processing of cookie data based on consent:

Before we process or allow data to be processed in the context of the use of cookies, we ask users for their consent, which can be revoked at any time. Before consent is not given, cookies are used if necessary, which are absolutely necessary for the operation of our online offer.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Performing tasks in accordance with the articles of association or rules of procedure

We process the data of our members, supporters, interested parties, business partners or other persons (collectively “data subjects”), if we have a membership or other business relationship with them and if we perform our duties and are recipients of services and benefits. Otherwise, we process the data of Data Subjects on the basis of our legitimate interests, e.g. if administrative tasks or public relations work are involved.

The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying membership or contractual relationship, from which the necessity of any data information also arises (in other respects we refer to required data).

We delete data that is no longer necessary for the performance of our statutory and business purposes. This is determined according to the respective tasks and contractual relationships. We keep the data for as long as they may be relevant to the business transaction as well as with regard to any warranty or liability obligations based on our legitimate interest in their regulation. The necessity of storing the data is regularly reviewed; otherwise, the statutory storage obligations apply.

  • Processed data types: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of the contract, duration, customer category).
  • Persons concerned: Users (e.g. website visitors, users of online services), members, business and contractual partners.
  • Purposes of processing: contractual services and service, contact requests and communication, administration and answering of requests.
  • Legal basis: Fulfilment of contract and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Commercial and business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) within the scope of contractual and comparable legal relationships and associated measures and within the scope of communication with the contractual partners (or pre-contractual), e.g. to answer inquiries.

We process this data for the purpose of fulfilling our contractual obligations, securing our rights and for the purposes of the administrative tasks associated with this data as well as for business organization. Within the framework of the applicable law, we will only pass on the data of the contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations or with the consent of the persons concerned (e.g. to involved telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.

We will inform the contractual partners which data is required for the above-mentioned purposes before or within the scope of data collection, e.g. in online forms, by special marking (e.g. colors) or symbols (e.g. asterisks or similar), or personally.

We delete the data after expiration of legal warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g., as long as it must be kept for legal archiving reasons (e.g., for tax purposes usually 10 years). We will delete data that has been disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, generally after the end of the order.

If we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.

Architecture and planning 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 to pay for them and deliver them or execute them or provide them.

Consulting:

We process the data of our clients, clients as well as interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to provide them with our consulting services. The processed data, the nature, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship.

Craftsman services:

We process the data of our customers as well as 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 to pay for and deliver or execute or perform them.

The required information is identified as such within the scope of the order, purchase order or comparable contract conclusion and includes the information required for delivery and invoicing as well as contact information in order to be able to make any necessary arrangements.

Technical services:

We process the data of our customers as well as 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 to pay for them and make them available or perform them.

The required information is identified as such within the scope of the order, purchase order or comparable contract conclusion and includes the information required for the provision of services and invoicing as well as contact information in order to be able to make any necessary arrangements. Insofar as we have access to information from end customers, employees or other persons, we process this information in accordance with the legal and contractual requirements.

  • Processed data types: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of the contract, duration, customer category).
  • Persons concerned: Interested parties, business and contractual partners.
  • Purposes of processing: Contractual performances and services, contact inquiries and communication, office and organizational procedures, administration and answering inquiries.
  • Legal basis: Fulfilment of the contract and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO),
  • Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Provision of the online offer and web hosting

In order to provide our online services securely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers managed by them) the online services can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security and technical maintenance services.

The data processed within the framework of the provision of the hosting offer may include all data relating to the users of our online offer, which are generated within the framework of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

Collection of access data and log files:

We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). Server log files may include the address and name of the web pages and files accessed, date and time of access, data volume transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the capacity utilization of the servers and their stability.

  • Processed data types: Content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
  • Kontaktaufnahme

When contacting us (e.g. via contact form, e-mail, telephone or social media), the data of the inquiring persons will be processed to the extent necessary to answer the contact inquiries and any requested measures.

The answering of contact inquiries within the scope of contractual or pre-contractual relations is carried out in order to fulfill our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of the legitimate interest in answering the inquiries.

  • Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos).
  • Persons concerned: communication partner.
  • Purposes of processing: contact requests and communication.
  • Legal basis: Fulfilment of contract and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Application procedure

The application procedure requires that applicants provide us with the data necessary for their assessment and selection. Which information is required can be found in the job description or, in the case of online forms, in the information provided there.

In principle, the required data includes personal information such as name, address, contact details and proof of the qualifications required for a position. Upon request, we will also be happy to provide you with information on what information is required.

If provided, applicants can send us their applications using an online form. The data will be encrypted according to the state of the art and transmitted to us. Applicants can also send us their applications by e-mail. Please note, however, that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received.

  • Types of data processed: Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, curriculum vitae, certificates and other information on the applicant’s person or qualification provided by the applicant with regard to a specific position or voluntarily).
  • Persons concerned: applicants.
  • Purposes of processing: Application procedure (justification and possible later implementation and possible later termination of the employment relationship.)
  • Legal basis: Art. 9 para. 1 sentence 1 lit. b DSGVO (application procedure as a pre-contractual or contractual relationship) (Insofar as special categories of personal data within the meaning of Art. 9 para. 1 DSGVO (e.g. health data, such as severely handicapped status or ethnic origin) are requested from applicants so that the responsible person or the data subject can exercise the rights arising to him or her from employment law and social security and social protection law and fulfil his or her obligations in this respect, their processing is carried out in accordance with Art. 9 Paragraph 2 letter b. DSGVO, in the case of protection of vital interests of applicants or other persons according to art. 9 par. 2 letter c. DSGVO or for the purposes of health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnosis, care or treatment in the health or social sector or for the management of systems and services in the health or social sector in accordance with Art. 9 para. 2 lit. h. DSGVO. In the case of communication of special categories of data based on voluntary consent, their processing is carried out on the basis of art. 9, paragraph 2, letter a. DSGVO).

Newsletter and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter referred to as “newsletters”) only with the consent of the recipients or a legal permission. If, in the course of registering for the newsletter, its contents are specifically described, they are decisive for the consent of the users. Furthermore, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name for the purpose of personal contact in the newsletter, or other information if this is necessary for the purposes of the newsletter.

Double-Opt-In procedure:

The registration to our newsletter is always done in a so-called double opt-in procedure. This means that you will receive an e-mail after registration asking you to confirm your registration. This confirmation is necessary so that nobody can register with foreign e-mail addresses. The newsletter registrations are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored by the shipping service provider are also logged.

Cancellation and limitation of processing:

We may store the unsubscribed e-mail addresses for up to three years based on our legitimate interests before we delete them to prove that we have previously given our consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list for this purpose alone (so-called “block list”).

The logging of the registration procedure is based on our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Notes on legal bases:

Newsletters are sent out on the basis of the consent of the recipients or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of advertising to existing customers. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process will be recorded on the basis of our legitimate interests in order to prove that it was carried out in accordance with the law.

Contents:

Information about us, our services, actions and offers.

Analysis and performance measurement:

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

This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined by means of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor, if used, that of the mailing service provider to observe individual users. Rather, the evaluations serve to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves our business interests and meets the expectations of the users.

Unfortunately, a separate revocation of the performance measurement is not possible. In this case, the entire newsletter subscription must be cancelled or objected to.

  • Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
  • Persons concerned: communication partner.
  • Purposes of processing: direct marketing (e.g. by e-mail or by post).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
  • Opt-out: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably e-mail.

Online marketing

We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the display of advertising and other content (collectively referred to as “Content”) based on the potential interests of users and the measurement of its effectiveness.

For these purposes, so-called user profiles are created and stored in a file (a so-called “cookie”) or similar procedures are used, by means of which user data relevant to the presentation of the aforementioned content is stored. This information may include, for example, the content viewed, web pages visited, online networks used, but also communication partners and technical details such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this data may also be processed.

The IP addresses of users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect the users. In general, no clear user data (such as e-mail addresses or names) are stored in the context of the online marketing process, 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.

As a rule, the information in the profiles is stored in the cookies or by means of similar procedures. These cookies can later be read out and analyzed for the purpose of presenting content on other websites that use the same online marketing procedure, and can also be supplemented with additional data and stored on the server of the online marketing procedure provider.

As an exception, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing procedure we use and the network links the user profiles with the aforementioned data. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.

As a matter of principle, we only receive access to summarized information about the success of our advertisements. However, we can check in the context of so-called conversion measurements which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyze the success of our marketing measures.

Unless otherwise stated, we ask you to assume that used cookies are stored for a period of two years.

Notes on legal bases:

If we ask the users for their consent to the use of the third party providers, the legal basis for the processing of data is the consent. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Processed data types: Usage data (e.g. websites visited, 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), interested parties.
  • Purposes of processing: Tracking (e.g. interest/behavioral profiling, use of cookies), remarketing, visitor action evaluation, interest-based and behavioral marketing, profiling (creation of user profiles), reach measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures: IP-Masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
  • Possibility of objection (Opt-Out): We refer to the data protection information of the respective providers and the possibilities of objection (so-called “Opt-Out”) indicated for the providers. If no explicit opt-out option has been specified, it is possible to deactivate cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary form for the respective areas: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Transnational: https://optout.aboutads.info.

Used services and service providers

Presence in social networks (social media)

We maintain online presences within social networks and in this context we process user data in order to communicate with the users active there or to offer information about us.

Please note that user data may be processed outside the European Union. This can result in risks for the users, because the enforcement of the users’ rights could be made more difficult.

Furthermore, user data within social networks are usually processed for market research and advertising purposes. For example, user profiles can be created on the basis of user behavior and the resulting interests of the users. The user profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behaviour and interests of the users are stored. Furthermore, data may also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).

For a detailed description of the respective forms of processing and the possibilities of objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.

Also in the case of requests for information and the assertion of data subject rights, we would like to point out that these can most effectively be asserted with the providers. Only the providers have access to the data of the users in each case and can directly take appropriate measures and provide information. Should you nevertheless require assistance, you can contact us.

Facebook:

We are jointly responsible with Facebook Ireland Ltd. for the collection (but not the further processing) of data of visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content users view or interact with, or the actions they take (see “Things You and Others Do and Provide” in the Facebook Data Policy: https://www.facebook.com/policy), and information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie information; see “Device Information” in the Facebook Data Policy Statement: https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How we use this information,” Facebook also collects and uses information to provide analytics services, known as “page insights,” to site operators to help them understand how people interact with their pages and with content associated with them. We have concluded a special agreement with Facebook (“Information on Page-Insights”, https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular the security measures that Facebook must observe and in which Facebook has agreed to fulfill the rights of the persons concerned (i.e. users can send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaints to the competent supervisory authority) are not limited by the agreements with Facebook. Further information can be found in the “Information on Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data).

  • Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: contact requests and communication, tracking (e.g. interest/behavioral profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
  • Legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Used services and service providers:

Plugins and embedded functions and content

We include in our online offer functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as “third party providers”). These can be, for example, graphics, videos or social media buttons and contributions (hereinafter referred to uniformly as “content”).

The integration always assumes that the third party providers of such content process the IP address of the users, as without the IP address they would not be able to send the content to their browsers. The IP address is therefore required for the display of these contents or functions. We make every effort to use only such content whose respective providers use the IP address only to deliver the content. Third party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain technical information about the browser and operating system, the websites to be linked, the time of visit and other details about the use of our online offer as well as being linked to such information from other sources.

Notes on legal bases:

If we ask the users for their consent to the use of the third party providers, the legal basis for the processing of data is the consent. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Processed data types: Usage data (e.g., web pages visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses), location data (data indicating the location of an end user’s end device).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness, contractual benefits and service.
  • Legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Used services and service providers:

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consent permitted for processing is revoked or other permissions cease to apply (e.g. if the purpose for which the data were processed ceases to apply or if they are not necessary for the purpose).

Unless the data are deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or that must be stored for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person.

Further information on the deletion of personal data may also be provided in the individual data protection notes of this privacy policy.

Amendment and update of the privacy policy

We kindly ask you to inform yourself regularly about the content of our privacy policy. We will adapt the data protection declaration as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes make it necessary for you to take action to cooperate (e.g. to give your consent) or to receive 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 check the information before contacting us.

Rights of the data subjects

As a data subject, you are entitled to various rights under the DSGVO, which result in particular from Art. 15 to 21 DSGVO:

  • Right of objection: You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you that is carried out pursuant to art. 6, paragraph 1, letter e or f of the DPA; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing, including profiling, insofar as it is linked to such direct marketing.
  • Right of revocation for consents: You have the right to revoke given consents at any time.
  • Right of access: You have the right to obtain confirmation as to whether or not data in question is being processed and to receive information about this data and other information and a copy of the data in accordance with legal requirements.
  • Right of rectification: In accordance with the law, you have the right to request the completion of the data concerning you or the rectification of incorrect data concerning you.
  • Right to deletion and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be deleted immediately, or alternatively, in accordance with the legal requirements, to demand a restriction of the processing of the data.
  • Right to data transferability: You have the right to receive data concerning you that you have provided to us in a structured, common, machine-readable format in accordance with the law, or to request that it be transferred to another responsible party.
  • Complaints to supervisory authorities: In accordance with the statutory provisions, you also 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 suspected infringement, if you believe that the processing of personal data relating to you is in breach of the DSGVO.

Definitions of terms

This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined above all in Art. 4 DSGVO. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.

  • Conversion tracking: Conversion tracking is a method of determining the effectiveness of marketing activities. For this purpose, a cookie is usually stored on the user’s device within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, we can use this to track whether the ads we have placed on other websites have been successful).
  • IP-Masking: “IP masking” is a method of deleting the last octet, i.e. the last two numbers of an IP address, so that the IP address can no longer be used to uniquely identify a person. IP-Masking is therefore a means of pseudonymizing processing methods, especially in online marketing
  • Interest-based and behavioral marketing: One speaks of interest-based and/or behavioral marketing when the potential interests of users in advertisements and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behavior (e.g. visiting and staying on certain websites, buying behavior or interaction with other users), which is stored in a so-called profile. As a rule, cookies are used for these purposes.
  • Personal data: “Personal data” shall mean any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
  • Profiling: “Profiling” is any automated processing of personal data that consists of using such personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information on age, gender, location and movement data, interaction with websites and their content, shopping behavior, social interactions with other people) (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.
  • Range measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behaviour or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, identify at what time visitors visit their website and what content they are interested in. This enables them to better adapt the contents of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis purposes in order to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
  • Remarketing: One speaks of “remarketing” or “retargeting”, for example, when it is noted for advertising purposes which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Tracking: One speaks of “tracking” when the behavior of users can be traced across several online offerings. As a rule, behavioral and interest information regarding the online offerings used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
  • Responsible person: Under “Responsible person” shall mean 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” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually all handling of data, be it collection, analysis, storage, transmission or deletion.

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