Privacy Policy
Preamble
With the following privacy policy we would like to inform you which types of your personal data
(hereinafter
also abbreviated as "data") we process for which purposes and in which scope. The privacy statement
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 collectively referred to as "online services").
The terms used are not gender-specific.
Last Update: 2. November 2022
Table of contents
Controller
Bernhard Miller
Segnerstraße 5K
1100 Vienna, Austria
E-mail address:
bernhard@toxevo.com
Legal Notice:
https://www.toxevo.com/legal_notice.html
Overview of processing operations
The following table summarises the types of data processed, the purposes for which they are processed
and the
concerned data subjects.
Categories of Processed Data
- Inventory data.
- Payment Data.
- Contact data.
- Content data.
- Contract data.
- Usage data.
- Meta/communication data.
- Images and/ or video recordings.
- Event Data (Facebook).
Categories of Data Subjects
- Customers.
- Prospective customers.
- Communication partner.
- Users.
- Participants in sweepstakes and competitions.
- Business and contractual partners.
- Participants.
- Persons depicted.
Purposes of Processing
- Provision of contractual services and customer support.
- Contact requests and communication.
- Security measures.
- Direct marketing.
- Web Analytics.
- Targeting.
- Office and organisational procedures.
- Conversion tracking.
- Affiliate Tracking.
- Affiliate Tracking.
- Managing and responding to inquiries.
- Conducting sweepstakes and contests.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Custom Audiences.
- Provision of our online services and usability.
- Information technology infrastructure.
Legal Bases for the Processing
In the following, you will find an overview of the legal basis of the GDPR on which we base the
processing of
personal data. Please note that in addition to the provisions of the GDPR, national data protection
provisions of your or our country of residence or domicile may apply. If, in addition, more specific
legal
bases are applicable in individual cases, we will inform you of these in the data protection
declaration.
- Consent (Article 6 (1) (a) GDPR) - The data subject has given consent to the
processing
of his or her personal data for one or more specific purposes.
- Performance of a contract and prior requests (Article 6 (1) (b) GDPR) -
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.
- Compliance with a legal obligation (Article 6 (1) (c) GDPR) - Processing is
necessary
for compliance with a legal obligation to which the controller is subject.
- Legitimate Interests (Article 6 (1) (f) GDPR) - Processing is necessary for the
purposes of the legitimate interests pursued by the controller or by a third party, except where
such
interests are overridden by the interests or fundamental rights and freedoms of the data subject
which
require protection of personal data.
In addition to the data protection regulations of the General Data Protection Regulation, national
regulations apply to data protection in Austria. This includes in particular the Federal Act on the
Protection of Individuals with regard to the Processing of Personal Data (Data Protection Act -
DSG). In
particular, the Data Protection Act contains special provisions on the right of access,
rectification or
cancellation, processing of special categories of personal data, processing for other purposes and
transmission and automated decision making in individual cases.
Security Precautions
We take appropriate technical and organisational measures in accordance with the legal requirements,
taking
into account the state of the art, the costs of implementation and the nature, scope, context and
purposes
of processing as well as the risk of varying likelihood and severity for the rights and freedoms of
natural
persons, in order 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 to, input, transmission,
securing
and separation of the data. In addition, we have established procedures to ensure that data
subjects' rights
are respected, that data is erased, and that we are prepared to respond to data threats rapidly.
Furthermore, we take the protection of personal data into account as early as the development or
selection
of hardware, software and service providers, in accordance with the principle of privacy by design
and
privacy by default.
TLS encryption (https): To protect your data transmitted via our online services, we use TLS
encryption. You
can recognize such encrypted connections by the prefix https:// in the address bar of your
browser.
Transmission of Personal Data
In the context of our processing of personal data, it may happen that the data is transferred to
other
places, companies or persons or that it is disclosed to them. Recipients of this data may include,
for
example, service providers commissioned with IT tasks or providers of services and content that are
embedded
in a website. In such a case, the legal requirements will be respected and in particular
corresponding
contracts or agreements, which serve the protection of your data, will be concluded with the
recipients of
your data.
Data Processing in Third Countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic
Area
(EEA)) or the processing takes place in the context of the use of third party services or disclosure
or
transfer of data to other persons, bodies or companies, this will only take place in accordance with
the
legal requirements.
Subject to express consent or transfer required by contract or law, we process or have processed the
data
only in third countries with a recognised level of data protection, on the basis of special
guarantees, such
as a contractual obligation through so-called standard protection clauses of the EU Commission or if
certifications or binding internal data protection regulations justify the processing (Article 44 to
49
GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).
Erasure of data
The data processed by us will be erased in accordance with the statutory provisions as soon as their
processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this
data no
longer applies or they are not required for the purpose). If the data is not deleted because they
are
required for other and legally permissible purposes, their processing is limited to these purposes.
This
means that the data will be restricted and not processed for other purposes. This applies, for
example, to
data that must be stored for commercial or tax reasons or for which storage is necessary to assert,
exercise
or defend legal claims or to protect the rights of another natural or legal person. In the context
of our
information on data processing, we may provide users with further information on the deletion and
retention
of data that is specific to the respective processing operation.
Use of Cookies
Cookies are small text files or other data records that store information on end devices and read
information
from the end devices. For example, to store the login status in a user account, the contents of a
shopping
cart in an e-shop, the contents accessed or the functions used. Cookies can also be used for various
purposes, e.g. for purposes of functionality, security and convenience of online offers as well as
the
creation of analyses of visitor flows.
Information on consent: We use cookies in accordance with the statutory provisions.
Therefore, we obtain prior consent from users, except when it is not required by law. In particular,
consent
is not required if the storage and reading of information, including cookies, is strictly necessary
in order
to provide an information society service explicitly requested by the subscriber or user. The
revocable
consent will be clearly communicated to the user and will contain the information on the respective
cookie
use.
Information on legal bases under data protection law: The legal basis under data
protection
law on which we process users' personal data with the use of cookies depends on whether we ask users
for
consent. If users consent, the legal basis for processing their data is their declared consent.
Otherwise,
the data processed with the help of cookies is processed on the basis of our legitimate interests
(e.g. in a
business operation of our online services and improvement of its usability) or, if this is done in
the
context of the fulfillment of our contractual obligations, if the use of cookies is necessary to
fulfill our
contractual obligations. For which purposes the cookies are processed by us, we do clarify in the
course of
this privacy policy or in the context of our consent and processing procedures.
Retention period: With regard to the retention period, a distinction is drawn
between the
following types of cookies:
- Temporary cookies (also known as "session cookies"): Temporary cookies are
deleted at
the latest after a user has left an online service and closed his or her end device (i.e.
browser or
mobile application).
- Permanent cookies: Permanent cookies remain stored even after the terminal
device is
closed. For example, the login status can be saved, or preferred content can be displayed
directly when
the user visits a website again. Likewise, user data collected with the help of cookies can be
used for
reach measurement. Unless we provide users with explicit information about the type and storage
duration
of cookies (e.g., as part of obtaining consent), users should assume that cookies are permanent
and that
the storage period can be up to two years.
General information on revocation and objection (opt-out): Users can revoke the
consent they
have given at any time and also file an objection to processing in accordance with the legal
requirements in
Article 21 GDPR. Users can also declare their objection by means of the settings of their browser,
e.g. by
deactivating the use of cookies (whereby this may also limit 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 information on processing methods, procedures and services used:
- Processing Cookie Data on the Basis of Consent: We use a cookie management
solution in
which users' consent to the use of cookies, or the procedures and providers mentioned in the
cookie
management solution, can be obtained, managed and revoked by the users. The declaration of
consent is
stored so that it does not have to be retrieved again and the consent can be proven in
accordance with
the legal obligation. Storage can take place server-sided and/or in a cookie (so-called opt-out
cookie
or with the aid of comparable technologies) in order to be able to assign the consent to a user
or
and/or his/her device. Subject to individual details of the providers of cookie management
services, the
following information applies: The duration of the storage of the consent can be up to two
years. In
this case, a pseudonymous user identifier is formed and stored with the date/time of consent,
information on the scope of the consent (e.g. which categories of cookies and/or service
providers) as
well as the browser, system and used end device.
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 context of contractual and comparable legal
relationships
as well as associated actions and communication with the contractual partners or pre-contractually,
e.g. to
answer inquiries.
We process this data in order to fulfill our contractual obligations. These include, in particular,
the
obligations to provide the agreed services, any update obligations and remedies in the event of
warranty and
other service disruptions. In addition, we process the data to protect our rights and for the
purpose of
administrative tasks associated with these obligations and company organization. Furthermore, we
process the
data on the basis of our legitimate interests in proper and economical business management as well
as
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 as well as subcontractors, banks, tax and legal advisors, payment
service
providers or tax authorities). Within the framework of applicable law, we only disclose the data of
contractual partners to third parties to the extent that this is necessary for the aforementioned
purposes
or to fulfill legal obligations. Contractual partners will be informed about further forms of
processing,
e.g. for marketing purposes, within the scope of this privacy policy.
Which data are necessary for the aforementioned purposes, we inform the contracting partners before
or in the
context of the data collection, e.g. in online forms by special marking (e.g. colors), and/or
symbols (e.g.
asterisks or the like), or personally.
We delete the data after expiry of statutory warranty and comparable obligations, i.e. in principle
after
expiry of 4 years, unless the data is stored in a customer account or must be kept for legal reasons
of
archiving. The statutory retention period for documents relevant under tax law as well as for
commercial
books, inventories, opening balance sheets, annual financial statements, the instructions required
to
understand these documents and other organizational documents and accounting records is ten years
and for
received commercial and business letters and reproductions of sent commercial and business letters
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 document was created,
furthermore
the record was made or the other documents were created.
If we use third-party providers or platforms to provide our services, the terms and conditions and
privacy
policies of the respective third-party providers or platforms shall apply in the relationship
between the
users and the providers.
- 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.
contract object, duration, customer category); Usage data (e.g. websites visited, interest in
content,
access times); Meta/communication data (e.g. device information, IP addresses).
- Data subjects: Customers; Prospective customers; Business and contractual
partners.
- Purposes of Processing: Provision of contractual services and customer support;
Security measures; Contact requests and communication; Office and organisational procedures;
Managing
and responding to inquiries; Conversion tracking (Measurement of the effectiveness of marketing
activities); Profiles with user-related information (Creating user profiles).
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b)
GDPR);
Compliance with a legal obligation (Article 6 (1) (c) GDPR); Legitimate Interests (Article 6 (1)
(f)
GDPR).
Further information on processing methods, procedures and services used:
- Customer Account: Contractual partners can create a customer or user account.
If the
registration of a customer account is required, contractual partnerswill be informed of this as
well as
of the details required for registration. The customer accounts are not public and cannot be
indexed by
search engines. In the course of registration and subsequent registration and use of the
customer
account, we store the IP addresses of the contractual partners along with the access times, in
order to
be able to prove the registration and prevent any misuse of the customer account.
If customers have terminated their customer account, their data will be deleted with regard to
the
customer account, subject to their retention is required for legal reasons. It is the
responsibility of
the customer to secure their data upon termination of the customer account; Legal
Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
- Economic Analyses and Market Research: For economic reasons and in order to be
able to
recognise market trends, wishes of contractual partners and users, we analyse the data available
to us
on business transactions, contracts, enquiries, etc., whereby the persons concerned may include
contractual partners, interested parties, customers, visitors and users of our online service.
The analyses are carried out for the purpose of business evaluations, marketing and market
research (for
example, to determine customer groups with different characteristics). If available, we can take
into
account the profiles of registered users with information, e.g. on the services they have used.
The
analyses serve us alone and are not disclosed externally unless they are anonymous analyses with
summarised, i.e. anonymised values. Furthermore, we respect the privacy of the users and process
the
data for analysis purposes as pseudonymously as possible and if possible anonymously (e.g. as
summarized
data); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
- Online Shop and E-Commerce: We process the data of our customers 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 of other services. If necessary for the execution of an
order, we
use service providers, in particular postal, freight and shipping companies, in order to carry
out the
delivery or execution to our customers. For the processing of payment transactions we use the
services
of banks and payment service providers. The required details are identified as such in the
course of the
ordering or comparable purchasing process and include the details required for delivery, or
other way of
making the product available and invoicing as well as contact information in order to be able to
hold
any consultation; Legal Basis: Performance of a contract and prior requests
(Article 6
(1) (b) GDPR).
- Agency Services: We process the data of our customers within the scope of our
contractual services, which may include e.g. conceptual and strategic consulting, campaign
planning,
software and design development / consulting or maintenance, implementation of campaigns and
processes,
handling, server administration, data analysis / consulting services and training services;
Legal
Basis: Performance of a contract and prior requests (Article 6 (1) (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, acquire or
commission the selected services or works as well as associated activities and to pay for and
make
available such services or works or to perform such services or works.
The required information is indicated as such within the framework of the conclusion of the
agreement,
order or equivalent contract and includes the information required for the provision of services
and
invoicing as well as contact information in order to be able to hold any consultations. Insofar
as we
gain access to the information of end customers, employees or other persons, we process it in
accordance
with the legal and contractual requirements; Legal Basis: Performance of a
contract and
prior requests (Article 6 (1) (b) GDPR).
- Software and Platform Services: We process the data of our users, registered
and any
test users (hereinafter uniformly referred to as "users") in order to provide them with our
contractual
services and on the basis of legitimate interests to ensure the security of our offer and to
develop it
further. The required details are identified as such within the context of the conclusion of the
agreement, order or comparable contract and include the details required for the provision of
services
and invoicing as well as contact information in order to be able to hold any further
consultations;
Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b)
GDPR).
- Technical and Engineering services: We process the data of our customers and
clients
(hereinafter uniformly referred to as "customers") in order to enable them to select, acquire or
commission the selected services or works as well as associated activities and to pay for and
make
available such services or works or to perform such services or works.
The required information is indicated as such within the framework of the conclusion of the
agreement,
order or equivalent contract and includes the information required for the provision of services
and
invoicing as well as contact information in order to be able to hold any consultations. Insofar
as we
gain access to the information of end customers, employees or other persons, we process it in
accordance
with the legal and contractual requirements; Legal Basis: Performance of a
contract and
prior requests (Article 6 (1) (b) GDPR).
Use of online platforms for listing and sales purposes
We offer our services on online platforms operated by other service providers. In addition to our
privacy
policy, the privacy policies of the respective platforms apply. This is particularly true with
regard to the
payment process and the methods used on the platforms for performance measuring and
behaviour-related
marketing.
- 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.
contract object, duration, customer category); Usage data (e.g. websites visited, 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);
Business and contractual partners.
- Purposes of Processing: Provision of contractual services and customer support;
Marketing; Provision of our online services and usability.
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b)
GDPR);
Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- shopify: Platform for offering and performing e-commerce services. The services
and
processes carried out in connection with them include, in particular, online stores, websites,
their
offers and content, community elements, purchase and payment transactions, customer
communication, as
well as analysis and marketing; Service provider: Shopify International
Limited,
Victoria Buildings, 2. Etage,1-2 Haddington Road, Dublin 4, D04 XN32, Ireland; Legal
Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.shopify.com/; Privacy
Policy: https://www.shopify.com/legal/privacy.
- Patreon: Internet platform for project financing via crowdfunding as well as
the sale
of subscriptions and memberships, billing as well as the provision of access and payment
procedures, for
the purposes of which cookies are used and the IP address, date, time and other technical data
about the
Internet browser used, the operating system as well as inventory, contract and payment data of
the users
are processed; Service provider: Patreon Ireland Limited, German Branch Revaler
Strasse
99, Hall 20, 2nd floor Rooms 3.19 and 3.25. 10245 Berlin-Friedrichshain, Germany; Legal
Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.patreon.com/; Privacy
Policy: https://privacy.patreon.com/policies.
Providers and services used in the course of business
As part of our business activities, we use additional services, platforms, interfaces or plug-ins
from
third-party providers (in short, "services") in compliance with legal requirements. Their use is
based on
our interests in the proper, legal and economic management of our business operations and internal
organization.
- 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); Content data
(e.g.
text input, photographs, videos); Contract data (e.g. contract object, duration, customer
category).
- Data subjects: Customers; Prospective customers; Users (e.g. website visitors,
users of
online services); Business and contractual partners.
- Purposes of Processing: Provision of contractual services and customer support;
Office
and organisational procedures.
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Payment Procedure
Within the framework of contractual and other legal relationships, due to legal obligations or
otherwise on
the basis of our legitimate interests, we offer data subjects efficient and secure payment options
and use
other service providers for this purpose in addition to banks and credit institutions (collectively
referred
to as "payment service providers").
The data processed by the payment service providers includes inventory data, such as the name and
address,
bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as
the
contract, total and recipient-related information. The information is required to carry out the
transactions. However, the data entered is only processed by the payment service providers and
stored with
them. I.e. we do not receive any account or credit card related information, but only information
with
confirmation or negative information of the payment. Under certain circumstances, the data may be
transmitted by the payment service providers to credit agencies. The purpose of this transmission is
to
check identity and creditworthiness. Please refer to the terms and conditions and data protection
information of the payment service providers.
The terms and conditions and data protection information of the respective payment service providers
apply to
the payment transactions and can be accessed within the respective websites or transaction
applications. We
also refer to these for further information and the assertion of revocation, information and other
data
subject rights.
- Processed data types: Inventory data (e.g. names, addresses); Payment Data
(e.g. bank
details, invoices, payment history); Contract data (e.g. contract object, duration, customer
category);
Usage data (e.g. websites visited, interest in content, access times); Meta/communication data
(e.g.
device information, IP addresses).
- Data subjects: Customers; Prospective customers.
- Purposes of Processing: Provision of contractual services and customer support.
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b)
GDPR).
Further information on processing methods, procedures and services used:
- Amazon Payments: Payment-Service-Provider (technical integration of
online-payment-methods);
Service provider: Amazon Payments Europe S.C.A. 38 avenue J.F. Kennedy, L-1855
Luxemburg;
Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b)
GDPR); Website:
https://pay.amazon.com; Privacy
Policy: https://pay.amazon.com/help/201212490.
- Apple Pay: Payment services provider; Service provider: Apple
Inc., Infinite
Loop, Cupertino, CA 95014, USA; Legal Basis: Performance of a contract and
prior requests
(Article 6 (1) (b) GDPR); Website: https://www.apple.com/apple-pay/;
Privacy Policy: https://www.apple.com/privacy/privacy-policy/.
- Google Pay: Payment services provider; Service provider:
Google Ireland
Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis:
Performance of a contract
and prior requests (Article 6 (1) (b) GDPR); Website: https://pay.google.com/intl/en_uk/about/; Privacy
Policy: https://policies.google.com/privacy.
- Klarna / Sofortüberweisung: Payment-Service-Provider (technical
integration of
online-payment-methods); Service provider: Klarna Bank AB (publ), Sveavägen
46, 111 34
Stockholm, Sweden; Legal Basis: Performance of a contract and prior requests
(Article 6 (1) (b)
GDPR); Website: https://www.klarna.com;
Privacy Policy: https://www.klarna.com/de/datenschutz.
- PayPal: Payment-Service-Provider (technical integration of
online-payment-methods) (e.g.
PayPal, PayPal Plus, Braintree, Braintree); Service provider: PayPal (Europe)
S.à r.l. et Cie,
S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal Basis: Performance of a
contract and
prior requests (Article 6 (1) (b) GDPR); Website: https://www.paypal.com;
Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
- Shop Pay (Shopify): Payment-Service-Provider (technical integration of
online-payment-methods);
Service provider: Shopify International Limited, Victoria Buildings, 2.
Etage,1-2 Haddington
Road, Dublin 4, D04 XN32, Ireland; Legal Basis: Performance of a contract and
prior requests
(Article 6 (1) (b) GDPR); Website: https://www.shopify.com;
Privacy Policy: https://www.shopify.com/legal/privacy.
- Stripe: Payment-Service-Provider (technical integration of
online-payment-methods); Service
provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal
Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR);
Website:
https://stripe.com/de; Privacy
Policy: https://stripe.com/en-de/privacy.
Provision of online services and web hosting
We process user data in order to be able to provide them with our online services. For this purpose,
we
process the IP address of the user, which is necessary to transmit the content and functions of our
online
services to the user's browser or terminal device.
- Processed data types: Usage data (e.g. websites visited, interest in content,
access
times); Meta/communication data (e.g. device information, IP addresses); Content data (e.g. text
input,
photographs, videos).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of Processing: Provision of our online services and usability;
Information
technology infrastructure (Operation and provision of information systems and technical devices,
such as
computers, servers, etc.).); Security measures.
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Provision of online offer on rented hosting space: For the provision of our
online
services, we use storage space, computing capacity and software that we rent or otherwise obtain
from a
corresponding server provider (also referred to as a "web hoster"); Legal
Basis:
Legitimate Interests (Article 6 (1) (f) GDPR).
- Provision of online services on own/ dedicated server hardware: For the
provision of
our online services, we use server hardware operated by us as well as, the storage space,
computing
capacity and software associated with it; Legal Basis: Legitimate Interests
(Article 6
(1) (f) GDPR).
- Collection of Access Data and Log Files: The access to our online services is
logged in
the form of so-called "server log files". Server log files may include the address and name of
the web
pages and files accessed, the date and time of access, data volumes transferred, notification of
successful access, browser type and version, the user's operating system, referrer URL (the
previously
visited page) and, as a general 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 stability
and
optimal load balancing of the servers; Legal Basis: Legitimate Interests
(Article 6 (1)
(f) GDPR); Retention period: Log file information is stored for a maximum
period of 30
days and then deleted or anonymized. Data, the further storage of which is necessary for
evidence
purposes, are excluded from deletion until the respective incident has been finally clarified.
- E-mail Sending and Hosting: The web hosting services we use also include
sending,
receiving and storing e-mails. For these purposes, the addresses of the recipients and senders,
as well
as other information relating to the sending of e-mails (e.g. the providers involved) and the
contents
of the respective e-mails are processed. The above data may also be processed for SPAM detection
purposes. Please note that e-mails on the Internet are generally not sent in encrypted form. As
a rule,
e-mails are encrypted during transport, but not on the servers from which they are sent and
received
(unless a so-called end-to-end encryption method is used). We can therefore accept no
responsibility for
the transmission path of e-mails between the sender and reception on our server; Legal
Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
- Content-Delivery-Network: We use a so-called "Content Delivery Network" (CDN).
A CDN is
a service with whose help contents of our online services, in particular large media files, such
as
graphics or scripts, can be delivered faster and more securely with the help of regionally
distributed
servers connected via the Internet; Legal Basis: Legitimate Interests (Article
6 (1)
(f) GDPR).
- netcup: Services in the field of the provision of information technology
infrastructure
and related services (e.g. storage space and/or computing capacities); Service
provider:
netcup GmbH, Daimlerstraße 25, D-76185 Karlsruhe, Germany; Legal Basis:
Legitimate
Interests (Article 6 (1) (f) GDPR); Website: https://www.netcup.de/;
Privacy Policy: https://www.netcup.de/kontakt/datenschutzerklaerung.php;
Data Processing Agreement: https://www.netcup-wiki.de/wiki/Zusatzvereinbarung_zur_Auftragsverarbeitung.
- Contabo: Services in the field of the provision of information technology
infrastructure and related services (e.g. storage space and/or computing capacities); Service
provider: Contabo GmbH, Aschauer Straße 32a, 81549 München, Germany; Legal
Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://contabo.com; Privacy
Policy: https://contabo.com/de/legal/privacy;
Data Processing Agreement: Provided by the service provider
.
Special Notes on Applications (Apps)
We process the data of the users of our application to the extent necessary to provide the users with
the
application and its functionalities, to monitor its security and to develop it further. Furthermore,
we may
contact users in compliance with the statutory provisions if communication is necessary for the
purposes of
administration or use of the application. In addition, we refer to the data protection information
in this
privacy policy with regard to the processing of user data.
Legal basis: The processing of data necessary for the provision of the
functionalities of
the application serves to fulfil contractual obligations. This also applies if the provision of the
functions requires user authorisation (e.g. release of device functions). If the processing of data
is not
necessary for the provision of the functionalities of the application, but serves the security of
the
application or our business interests (e.g. collection of data for the purpose of optimising the
application
or security purposes), it is carried out on the basis of our legitimate interests. If users are
expressly
requested to give their consent to the processing of their data, the data covered by the consent is
processed on the basis of the consent.
- Processed data types: Inventory data (e.g. names, addresses);
Meta/communication data
(e.g. device information, IP addresses); Payment Data (e.g. bank details, invoices, payment
history);
Contract data (e.g. contract object, duration, customer category); Images and/ or video
recordings (e.g.
photographs or video recordings of a person).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of Processing: Provision of contractual services and customer support.
- Legal Basis: Consent (Article 6 (1) (a) GDPR); Performance of a contract and
prior
requests (Article 6 (1) (b) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Commercial use: We process the data of the users of our application, registered
and any
test users (hereinafter uniformly referred to as "users") in order to provide them with our
contractual
services and on the basis of legitimate interests to ensure the security of our application and
to
develop it further. The required details are identified as such within the scope of the
conclusion of a
contract for the use of the application, the conclusion of an order, an order or a comparable
contract
and may include the details required for the provision of services and any invoicing as well as
contact
information in order to be able to hold any consultations; Legal Basis:
Performance of
a contract and prior requests (Article 6 (1) (b) GDPR).
- Storage of the universally unique identifier (UUID): The application stores a
so-called
Universally Unique Identifier (UUID) for the purpose of analysing the use and functionality of
the
application and storing the user's settings. This identifier is generated when the application
is
installed (but is not connected to the device, so no device ID in this sense), remains stored
between
the start of the application and its updates and is deleted when users remove the application
from their
device.
- Storage of an own unique identifier: In order to provide the application and
ensure its
functionality, we use a pseudonymous identifier. The identifier is a mathematical value (i.e. no
clear
data such as names are used) that is assigned to a device and/or the installation of the
application
installed on it. This identifier is generated during the installation of the application,
remains stored
between the start of the application and its updates and is deleted when users remove the
application
from the device.
- Device authorizations for access to functions and data: The use of certain
functions of
our application may require access to the camera and the stored recordings of the users. By
default,
these authorizations must be granted by the user and can be revoked at any time in the settings
of the
respective devices. The exact procedure for controlling app permissions may depend on the user's
device
and software. Users can contact us if they require further explanation. We would like to point
out that
the refusal or revocation of the respective authorizations can affect the functionality of our
application.
- Accessing the camera and stored recordings: In the course of using our
application,
image and/or video recordings (whereby audio recordings are also included) of the users (and of
other
persons captured by the recordings) are processed by accessing the camera functions or stored
recordings. Access to the camera functions or stored recordings requires an authorization by the
user
that can be withdrawn at any time. The processing of the image and/or video recordings serves
only to
provide the respective functionality of our application, according to its description to the
users or
the typical and expectable functionality of the application.
Purchase of applications via Appstores
The purchase of our apps is done via special online platforms operated by other service providers
(so-called
"appstores"). In this context, the data protection notices of the respective appstores apply in
addition to
our data protection notices. This applies in particular with regard to the methods used on the
platforms for
webanalytics and for interest-related marketing as well as possible costs.
- 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.
contract object, duration, customer category); Usage data (e.g. websites visited, interest in
content,
access times); Meta/communication data (e.g. device information, IP addresses); Content data
(e.g. text
input, photographs, videos).
- Data subjects: Customers; Users (e.g. website visitors, users of online
services).
- Purposes of Processing: Provision of contractual services and customer support;
Marketing.
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
Registration, Login and User Account
Users can create a user account. Within the scope of registration, the required mandatory information
is
communicated to the users and processed for the purposes of providing the user account on the basis
of
contractual fulfilment of obligations. The processed data includes in particular the login
information
(name, password and an e-mail address).
Within the scope of using our registration and login functions as well as the use of the user
account, we
store the IP address and the time of the respective user action. The storage is based on our
legitimate
interests, as well as the user's protection against misuse and other unauthorized use. This data
will not be
passed on to third parties unless it is necessary to pursue our claims or there is a legal
obligation to do
so.
Users may be informed by e-mail of information relevant to their user account, such as technical
changes.
- Processed data types: Inventory data (e.g. names, addresses); Contact data
(e.g.
e-mail, telephone numbers); Content data (e.g. text input, photographs, videos);
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 support;
Security measures; Managing and responding to inquiries; Provision of our online services and
usability.
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b)
GDPR);
Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Registration with pseudonyms: Users may use pseudonyms as user names instead of
real
names; Legal Basis: Performance of a contract and prior requests (Article 6 (1)
(b)
GDPR).
- Users' profiles are public: Users' profiles are publicly visible and
accessible;
Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b)
GDPR).
- No obligation to retain data: It is the responsibility of the users to secure
their
data before the end of the contract in the event of termination. We are entitled to
irretrievably delete
all user data stored during the term of the contract; Legal Basis: Performance
of a
contract and prior requests (Article 6 (1) (b) GDPR).
Community Functions
The community functions provided by us allow users to engage in conversations and other forms of
interaction
with each other. Please note that the use of the community functions is only permitted in compliance
with
the applicable legal situation, our terms and guidelines and the rights of other users and third
parties.
- 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).
- Purposes of Processing: Provision of contractual services and customer support;
Security measures.
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b)
GDPR).
Further information on processing methods, procedures and services used:
- User contributions are public: The posts and content created by users are
publicly
visible and accessible; Legal Basis: Performance of a contract and prior
requests
(Article 6 (1) (b) GDPR).
- Storage of data for security purposes: The posts and other entries of the users
are
processed for the purposes of the community and conversation functions and, subject to legal
obligations
or legal permission, are not disclosed to third parties. An obligation to disclosure may arise
in
particular in the case of unlawful posts for the purposes of legal prosecution. We would like to
point
out that, in addition to the content of the posts, their time and the IP address of the user are
also
stored. This is done in order to be able to take appropriate measures to protect other users and
the
community; Legal Basis: Performance of a contract and prior requests (Article 6
(1) (b)
GDPR).
- Right to delete content and information: The deletion of posts, content or
information
provided by users is permissible to the extent necessary after proper consideration if there are
concrete indications that they could represent a violation of legal regulations, our provisions
or the
rights of third parties; Legal Basis: Performance of a contract and prior
requests
(Article 6 (1) (b) GDPR).
- Restricted deletion of posts: Out of consideration for other users, the user's
contributions to conversations remain stored even after termination and account deletion, so
that
conversations, comments, advice and similar communications do not lose their meaning or become
inverted.This ensures that conversations, comments, advice or similar communication between and
among
users do not lose their meaning or become inverted. User names will be deleted or pseudonymised
if they
were not already pseudonyms.Users can request the complete deletion of their posts at any time;
Legal
Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
- Protection of own data: Users decide for themselves what data they disclose
about
themselves within our online services. For example, when users provide personal information or
participate in conversations. We ask users to protect their data and to publish personal data
only with
caution and only to the extent necessary. In particular, we ask users to note that they must
protect
their login credentials in particular and use secure passwords (preferably long and random
combinations
of characters); Legal Basis: Performance of a contract and prior requests
(Article 6
(1) (b) GDPR).
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter "publication
medium").
Readers' data will only be processed for the purposes of the publication medium to the extent
necessary for
its presentation and communication between authors and readers or for security reasons. For the
rest, we
refer to the information on the processing of visitors to our publication medium within the scope of
this
privacy policy.
- Processed data types: Inventory data (e.g. names, addresses); Contact data
(e.g.
e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data
(e.g.
websites visited, interest in content, access times); Meta/communication data (e.g. device
information,
IP addresses).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of Processing: Provision of contractual services and customer support;
Feedback (e.g. collecting feedback via online form); Provision of our online services and
usability;
Contact requests and communication; Managing and responding to inquiries; Security measures.
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Consent (Article 6
(1) (a)
GDPR).
Further information on processing methods, procedures and services used:
- Comment subscriptions: When users leave comments or other contributions, their
IP
addresses may be stored based on our legitimate interests. This is done for our safety, if
someone
leaves illegal contents (insults, forbidden political propaganda, etc.) in comments and
contributions.
In this case, we ourselves can be prosecuted for the comment or contribution and are therefore
interested in the author's identity.
Furthermore, we reserve the right to process user data for the purpose of spam detection on the
basis of
our legitimate interests.
On the same legal basis, in the case of surveys, we reserve the right to store the IP addresses
of users
for the duration of the surveys and to use cookies in order to avoid multiple votes.
The personal information provided in the course of comments and contributions, any contact and
website
information as well as the content information will be stored permanently by us until the user
objects;
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
- Comment subscriptions: Follow-up comments can be subscribed to by users with
their
consent. Users will receive a confirmation email to verify that they are the owner of the email
address
entered. Users can unsubscribe from current comment subscriptions at any time. The confirmation
email
will contain information on the cancellation options. For the purposes of proving the users'
consent, we
store the time of registration along with the users' IP address and delete this information when
users
unsubscribe from the subscription.
You can cancel the receipt of our subscription at any time, i.e. revoke your consent. We may
store the
unsubscribed email addresses for up to three years based on our legitimate interests before
deleting
them to provide evidence of prior consent. The processing of these data is limited to the
purpose of a
possible defense against claims. An individual deletion request is possible at any time,
provided that
the former existence of a consent is confirmed at the same time; Legal Basis:
Consent
(Article 6 (1) (a) GDPR).
Contact and Inquiry Management
When contacting us (e.g. via contact form, e-mail, telephone or via social media) as well as in the
context
of existing user and business relationships, the information of the inquiring persons is processed
to the
extent necessary to respond to the contact requests and any requested measures.
- Processed data types: Contact data (e.g. e-mail, telephone numbers); Content
data (e.g.
text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access
times);
Meta/communication data (e.g. device information, IP addresses); Payment Data (e.g. bank
details,
invoices, payment history); Contract data (e.g. contract object, duration, customer category).
- Data subjects: Communication partner (Recipients of e-mails, letters, etc.);
Users
(e.g. website visitors, users of online services); Business and contractual partners.
- Purposes of Processing: Contact requests and communication; Managing and
responding to
inquiries; Feedback (e.g. collecting feedback via online form); Provision of our online services
and
usability; Provision of contractual services and customer support; Marketing.
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Performance of a
contract
and prior requests (Article 6 (1) (b) GDPR).
Further information on processing methods, procedures and services used:
- Contact form: When users contact us via our contact form, e-mail or other
communication
channels, we process the data provided to us in this context to process the communicated
request;
Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b)
GDPR),
Legitimate Interests (Article 6 (1) (f) GDPR).
- Discord: Chat, audio and video broadcasting, instant messaging, and community
management; Service provider: Discord, Inc., 444 De Haro St, Suite 200, San
Francisco,
California 94107, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f)
GDPR);
Website: https://discordapp.com/;
Privacy Policy: https://discordapp.com/privacy.
- Patreon: Internet platform for project financing via crowdfunding as well as
the sale
of subscriptions and memberships, billing as well as the provision of access and payment
procedures, for
the purposes of which cookies are used and the IP address, date, time and other technical data
about the
Internet browser used, the operating system as well as inventory, contract and payment data of
the users
are processed; Service provider: Patreon Ireland Limited, German Branch Revaler
Strasse
99, Hall 20, 2nd floor Rooms 3.19 and 3.25. 10245 Berlin-Friedrichshain, Germany; Legal
Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.patreon.com/; Privacy
Policy: https://privacy.patreon.com/policies.
Push notifications
With the consent of the users, we can send the users so-called "push notifications". These are
messages that
are displayed on users' screens, devices or browsers, even if our online services are not being
actively
used.
In order to sign up for push messages, users must confirm that their browser or device has requested
to
receive push messages. This approval process is documented and stored. The storage is necessary to
recognize
whether users have consented to receive the push messages and to be able to prove their consent. For
these
purposes, a pseudonymous identifier of the browser (so-called "push token") or the device ID of a
terminal
device is stored.
The push messages may be necessary for the fulfilment of contractual obligations (e.g. technical and
organisational information relevant for the use of our online offer) and will otherwise be sent,
unless
specifically mentioned below, on the basis of user consent. Users can change the receipt of push
messages at
any time using the notification settings of their respective browsers or end devices.
- 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: Communication partner (Recipients of e-mails, letters, etc.).
- Purposes of Processing: Provision of our online services and usability.
- Legal Basis: Consent (Article 6 (1) (a) GDPR); Performance of a contract and
prior
requests (Article 6 (1) (b) GDPR).
Video Conferences, Online Meetings, Webinars and Screen-Sharing
We use platforms and applications of other providers (hereinafter referred to as "Conference
Platforms") for
the purpose of conducting video and audio conferences, webinars and other types of video and audio
meetings
(hereinafter collectively referred to as "Conference"). When using the Conference Platforms and
their
services, we comply with the legal requirements.
Data processed by Conference Platforms: In the course of participation in a
Conference, the
Data of the participants listed below are processed. The scope of the processing depends, on the one
hand,
on which data is requested in the context of a specific Conference (e.g., provision of access data
or clear
names) and which optional information is provided by the participants. In addition to processing for
the
purpose of conducting the conference, participants' Data may also be processed by the Conference
Platforms
for security purposes or service optimization. The processed Date includes personal information
(first name,
last name), contact information (e-mail address, telephone number), access data (access codes or
passwords),
profile pictures, information on professional position/function, the IP address of the internet
access,
information on the participants' end devices, their operating system, the browser and its technical
and
linguistic settings, information on the content-related communication processes, i.e. entries in
chats and
audio and video data, as well as the use of other available functions (e.g. surveys). The content of
communications is encrypted to the extent technically provided by the conference providers. If
participants
are registered as users with the Conference Platforms, then further data may be processed in
accordance with
the agreement with the respective Conference Provider.
Logging and recording: If text entries, participation results (e.g. from surveys) as
well as
video or audio recordings are recorded, this will be transparently communicated to the participants
in
advance and they will be asked - if necessary - for their consent.
Data protection measures of the participants: Please refer to the data privacy
information
of the Conference Platforms for details on the processing of your data and select the optimum
security and
data privacy settings for you within the framework of the settings of the conference platforms.
Furthermore,
please ensure data and privacy protection in the background of your recording for the duration of a
Conference (e.g., by notifying roommates, locking doors, and using the background masking function,
if
technically possible). Links to the conference rooms as well as access data, should not be passed on
to
unauthorized third parties.
Notes on legal bases: Insofar as, in addition to the Conference Platforms, we also
process
users' data and ask users for their consent to use contents from the Conferences or certain
functions (e.g.
consent to a recording of Conferences), the legal basis of the processing is this consent.
Furthermore, our
processing may be necessary for the fulfillment of our contractual obligations (e.g. in participant
lists,
in the case of reprocessing of Conference results, etc.). Otherwise, user data is processed on the
basis of
our legitimate interests in efficient and secure communication with our communication partners.
- Processed data types: Inventory data (e.g. names, addresses); Contact data
(e.g.
e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data
(e.g.
websites visited, interest in content, access times); Meta/communication data (e.g. device
information,
IP addresses).
- Data subjects: Communication partner (Recipients of e-mails, letters, etc.);
Users
(e.g. website visitors, users of online services); Persons depicted.
- Purposes of Processing: Provision of contractual services and customer support;
Contact
requests and communication; Office and organisational procedures.
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Discord: Chat, audio and video broadcasting, instant messaging, and community
management; Service provider: Discord, Inc., 444 De Haro St, Suite 200, San
Francisco,
California 94107, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f)
GDPR);
Website: https://discordapp.com/;
Privacy Policy: https://discordapp.com/privacy.
Newsletter and Electronic Communications
We send newsletters, e-mails and other electronic communications (hereinafter referred to as
"newsletters")
only with the consent of the recipient or a legal permission. Insofar as the contents of the
newsletter are
specifically described within the framework of registration, they are decisive for the consent of
the user.
Otherwise, our newsletters contain information about our services and us.
In order to subscribe to our newsletters, it is generally sufficient to enter your e-mail address. We
may,
however, ask you to provide a name for the purpose of contacting you personally in the newsletter or
to
provide further information if this is required for the purposes of the newsletter.
Double opt-in procedure: The registration to our newsletter takes place in general
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 no one can register with
external
e-mail addresses.
The registrations for the newsletter are logged in order to be able to prove the registration process
according to the legal requirements. This includes storing the login and confirmation times as well
as the
IP address. Likewise the changes of your data stored with the dispatch service provider are
logged.
Deletion and restriction of processing: We may store the unsubscribed email
addresses for up
to three years based on our legitimate interests before deleting them to provide evidence of prior
consent.
The processing of these data is limited to the purpose of a possible defense against claims. An
individual
deletion request is possible at any time, provided that the former existence of a consent is
confirmed at
the same time. In the case of an obligation to permanently observe an objection, we reserve the
right to
store the e-mail address solely for this purpose in a blocklist.
The logging of the registration process takes place on the basis of our legitimate interests for the
purpose
of proving its proper course. 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.
- 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).
- Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
- Purposes of Processing: Direct marketing (e.g. by e-mail or postal).
- Legal Basis: Consent (Article 6 (1) (a) GDPR); Legitimate Interests (Article 6
(1) (f)
GDPR).
- 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 otherwise use one of the contact options listed above, preferably
e-mail.
Further information on processing methods, procedures and services used:
- Measurement of opening rates and click rates: The newsletters contain a
so-called
"web-beacon", i.e. a pixel-sized file, which is retrieved from our server when the newsletter is
opened
or, if we use a mailing service provider, from its server. Within the scope of this retrieval,
technical
information such as information about the browser and your system, as well as your IP address
and time
of retrieval are first collected.
This information is used for the technical improvement of our newsletter on the basis of
technical data
or target groups and their reading behaviour on the basis of their retrieval points (which can
be
determined with the help of the IP address) or access times. This analysis also includes
determining
whether newsletters are opened, when they are opened and which links are clicked. This
information is
assigned to the individual newsletter recipients and stored in their profiles until the profiles
are
deleted. The evaluations serve us much more to recognize the reading habits of our users and to
adapt
our content to them or to send different content according to the interests of our users.
The measurement of opening rates and click rates as well as the storage of the measurement
results in
the profiles of the users and their further processing are based on the consent of the users.
A separate objection to the performance measurement is unfortunately not possible, in this case
the
entire newsletter subscription must be cancelled or objected to. In this case, the stored
profile
information will be deleted; Legal Basis: Consent (Article 6 (1) (a) GDPR).
- Mailjet: Email distribution and email marketing platform; Service
provider: Mailjet SAS,13-13 bis, rue de l’Aubrac, 75012 Paris, France; Legal
Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.mailjet.com; Privacy
Policy: https://www.mailjet.com/privacy-policy/.
Commercial communication by E-Mail, Postal Mail, Fax or Telephone
We process personal data for the purposes of promotional communication, which may be carried out via
various
channels, such as e-mail, telephone, post or fax, in accordance with the legal requirements.
The recipients have the right to withdraw their consent at any time or to object to the advertising
communication at any time.
After revocation or objection, we store the data required to prove the past authorization to contact
or send
up to three years from the end of the year of revocation or objection on the basis of our legitimate
interests. The processing of this data is limited to the purpose of a possible defense against
claims. Based
on the legitimate interest to permanently observe the revocation, respectively objection of the
users, we
further store the data necessary to avoid a renewed contact (e.g. depending on the communication
channel,
the e-mail address, telephone number, name).
- Processed data types: Inventory data (e.g. names, addresses); Contact data
(e.g.
e-mail, telephone numbers).
- Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
- Purposes of Processing: Direct marketing (e.g. by e-mail or postal).
- Legal Basis: Consent (Article 6 (1) (a) GDPR); Legitimate Interests (Article 6
(1) (f)
GDPR).
Sweepstakes and Contests
We process the personal data of participants in We process personal data of participants in
competitions,
contents, raffles, prize-draws or sweepstakes (hereinafter referred to as "competitions") only in
compliance
with the relevant data protection regulations and if the processing is contractually necessary for
the
provision, execution and handling of the competition, the participants have consented to the
processing or
the processing serves our legitimate interests (e.g. in the security of the competition or the
protection of
our interests against misuse by possible recording of IP addresses when submitting entries to the
competition.
In the event that entries are published as part of the competitions (e.g. as part of a vote or
presentation
of the competition entries, or the winner or reporting on the competition), we would like to point
out that
the names of participants may also be published in this context. The participants can object to this
at any
time.
If the competitions take place within an online platform or a social network (e.g. Facebook or
Instagram,
hereinafter referred to as "online platform"), the usage and data protection provisions of the
respective
online platforms also apply. In such cases, we would like to point out that we are responsible for
the
information provided by the participants as part of the competition and that we must be contacted
with
regard to the competitions.
The data of the participants will be deleted as soon as the competition has ended and the data is no
longer
required to inform the winners or because questions about the competition can be expected. In
general, the
data of the participants will be deleted at the latest 6 months after the end of the competition.
Winners'
data can be retained for a longer period of time, e.g. in order to answer questions about the prizes
or to
fulfil the prizes; in this case, the retention period depends on the type of prize and is up to
three years
for items or services, e.g. in order to be able to process warranty claims. Furthermore, the
participants'
data may be stored for longer, e.g. in the form of coverage of the competition in online and offline
media.
Insofar as data was collected for other purposes as part of the competition, its processing and
storage
period shall be governed by the privacy information for this use (e.g. in the case of registration
for a
newsletter as part of a competition).
- Processed data types: Inventory data (e.g. names, addresses); Content data
(e.g. text
input, photographs, videos); Meta/communication data (e.g. device information, IP addresses).
- Data subjects: Participants in sweepstakes and competitions.
- Purposes of Processing: Conducting sweepstakes and contests.
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b)
GDPR).
Surveys and Questionnaires
We conduct surveys and interviews to gather information for the survey purpose communicated in each
case. The
surveys and questionnaires ("surveys") carried out by us are evaluated anonymously. Personal data is
only
processed insofar as this is necessary for the provision and technical execution of the survey (e.g.
processing the IP address to display the survey in the user's browser or to enable a resumption of
the
survey with the aid of a cookie).
- Processed data types: Contact data (e.g. e-mail, telephone numbers); Content
data (e.g.
text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access
times);
Meta/communication data (e.g. device information, IP addresses).
- Data subjects: Communication partner (Recipients of e-mails, letters, etc.);
Participants.
- Purposes of Processing: Feedback (e.g. collecting feedback via online form).
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Web Analysis, Monitoring and Optimization
Web analysis is used to evaluate the visitor traffic on our website and may include the behaviour,
interests
or demographic information of users, such as age or gender, as pseudonymous values. With the help of
web
analysis we can e.g. recognize, at which time our online services or their functions or contents are
most
frequently used or requested for repeatedly, as well as which areas require optimization.
In addition to web analysis, we can also use test procedures, e.g. to test and optimize different
versions of
our online services or their components.
Unless otherwise stated below, profiles, i.e. data aggregated for a usage process, can be created for
these
purposes and information can be stored in a browser or in a terminal device and read from it. The
information collected includes, in particular, websites visited and elements used there as well as
technical
information such as the browser used, the computer system used and information on usage times. If
users have
agreed to the collection of their location data from us or from the providers of the services we
use,
location data may also be processed.
Unless otherwise stated below, profiles, that is data summarized for a usage process or user, may be
created
for these purposes and stored in a browser or terminal device (so-called "cookies") or similar
processes may
be used for the same purpose. The information collected includes, in particular, websites visited
and
elements used there as well as technical information 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 or
profiles to
us or to the providers of the services we use, these may also be processed, depending on the
provider.
The IP addresses of the users are also stored. However, we use any existing IP masking procedure
(i.e.
pseudonymisation by shortening the IP address) to protect the user. In general, within the framework
of web
analysis, A/B testing and optimisation, no user data (such as e-mail 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
processes.
- 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).
- Purposes of Processing: Web Analytics (e.g. access statistics, recognition of
returning
visitors); Profiles with user-related information (Creating user profiles); Targeting (e.g.
profiling
based on interests and behaviour, use of cookies); Provision of our online services and
usability.
- Security measures: IP Masking (Pseudonymization of the IP address).
- Legal Basis: Consent (Article 6 (1) (a) GDPR).
Further information on processing methods, procedures and services used:
- Google Analytics: Web analytics, reach measurement and measurement of user
traffic;
Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin
4,
Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR);
Website: https://marketingplatform.google.com/intl/en/about/analytics/;
Privacy Policy: https://policies.google.com/privacy;
Data Processing Agreement: https://business.safety.google/adsprocessorterms/;
Standard Contractual Clauses (Safeguarding the level of data protection when processing
data in
third countries): https://business.safety.google/adsprocessorterms;
Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en,
Settings for the Display of Advertisements: https://adssettings.google.com/authenticated;
Further Information: https://privacy.google.com/businesses/adsservices
(Types of processing and data processed).
- Google Tag Manager: Google Tag Manager is a solution with which we can manage
so-called
website tags via an interface and thus integrate other services into our online services (please
refer
to further details in this privacy policy). With the Tag Manager itself (which implements the
tags), for
example, no user profiles are created or cookies are stored. Google only receives the IP address
of the
user, which is necessary to run the Google Tag Manager; Service provider:
Google
Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis:
Consent
(Article 6 (1) (a) GDPR); Website: https://marketingplatform.google.com;
Privacy Policy: https://policies.google.com/privacy;
Data Processing Agreement: https://business.safety.google/adsprocessorterms;
Standard Contractual Clauses (Safeguarding the level of data protection when processing
data in
third countries): https://business.safety.google/adsprocessorterms;
Further Information: https://privacy.google.com/businesses/adsservices
(Types of processing and data processed).
- Matomo: Matomo is software that is used for the purposes of web analysis and
reach
measurement. As part of the use of Matomo, cookies are generated and stored on the user's
terminal
device. User data collected through the use of Matomo is processed only by us and is not shared
with
third parties. The cookies are stored for a maximum period of 13 months: https://matomo.org/faq/general/faq_146/;
Legal Basis: Consent (Article 6 (1) (a) GDPR); Retention
period: The
cookies have a maximum storage period of 13 months.
Online Marketing
We process personal data for the purposes of online marketing, 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 their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or
similar
procedure in which the relevant user information for the display of the aforementioned content is
stored.
This information may include, for example, content viewed, websites visited, online networks used,
communication partners and technical information such as the browser used, computer system used and
information on usage times and used functions. If users have consented to the collection of their
sideline
data, these can also be processed.
The IP addresses of the users are also stored. However, we use provided IP masking procedures (i.e.
pseudonymisation by shortening the IP address) to ensure the protection of the user's by using a
pseudonym.
In general, within the framework of the online marketing process, no clear user data (such as e-mail
addresses or names) is secured, but pseudonyms. This means that we, as well as the providers of
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 usually stored in the cookies or similar memorizing procedures.
These
cookies can later, generally also on other websites that use the same online marketing technology,
be read
and analyzed for purposes of content display, as well as supplemented with other data and stored on
the
server of the online marketing technology provider.
Exceptionally, 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 technology we use and the network links the
profiles of
the users in the aforementioned data. Please note that users may enter into additional agreements
with the
social network providers or other service providers, e.g. by consenting as part of a registration
process.
As a matter of principle, we only gain access to summarised information about the performance of our
advertisements. However, within the framework of so-called conversion measurement, we can check
which of our
online marketing processes have led to a so-called conversion, i.e. to the conclusion of a contract
with us.
The conversion measurement is used alone for the performance analysis of our marketing
activities.
Unless otherwise stated, we kindly ask you to consider that cookies used will be stored for a period
of two
years.
- Processed data types: Content data (e.g. text input, photographs, videos);
Usage data
(e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device
information, IP addresses); Event Data (Facebook) ("Event Data" is data that can be transmitted
from us
to Facebook, e.g. via Facebook pixels (via apps or other means) and relates to persons or their
actions;
the data includes, for example, information about visits to websites, interactions with content,
functions, installations of apps, purchases of products, etc.; Event data is processed for the
purpose
of creating target groups for content and advertising information (Custom Audiences); Event Data
does
not include the actual content (such as written comments), login information, and Contact
Information
(such as names, email addresses, and phone numbers). Event Data is deleted by Facebook after a
maximum
of two years, the Custom Audiences created from them with the deletion of our Facebook account).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of Processing: Web Analytics (e.g. access statistics, recognition of
returning
visitors); Targeting (e.g. profiling based on interests and behaviour, use of cookies);
Conversion
tracking (Measurement of the effectiveness of marketing activities); Affiliate Tracking;
Marketing;
Profiles with user-related information (Creating user profiles); Custom Audiences (Selection of
relevant
target groups for marketing purposes or other output of content); Provision of our online
services and
usability.
- Security measures: IP Masking (Pseudonymization of the IP address).
- Legal Basis: Consent (Article 6 (1) (a) GDPR).
- Opt-Out: We refer to the privacy policies of the respective service providers
and the
possibilities for objection (so-called "opt-out"). 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 collectively for each area:
a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://www.youradchoices.ca/choices.
c) USA: https://www.aboutads.info/choices.
d) Cross-regional: https://optout.aboutads.info.
Further information on processing methods, procedures and services used:
- Facebook Pixel and Custom Audiences (Custom Audiences): With the help of the
Facebook
pixel (or equivalent functions, to transfer Event-Data or Contact Information via interfaces or
other
software in apps), Facebook is on the one hand able to determine the visitors of our online
services as
a target group for the presentation of ads (so-called "Facebook ads"). Accordingly, we use
Facebook
pixels to display Facebook ads placed by us only to Facebook users and within the services of
partners
cooperating with Facebook (so-called "audience network" https://www.facebook.com/audiencenetwork/
) who have shown an interest in our online services or who have certain characteristics (e.g.
interests
in certain topics or products that are determined on the basis of the websites visited) that we
transmit
to Facebook (so-called "custom audiences"). With the help of Facebook pixels, we also want to
ensure
that our Facebook ads correspond to the potential interest of users and do not appear annoying.
The
Facebook pixel also enables us to track the effectiveness of Facebook ads for statistical and
market
research purposes by showing whether users were referred to our website after clicking on a
Facebook ad
(known as "conversion tracking"); Service provider: Meta Platforms Ireland
Limited, 4
Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal Basis:
Consent
(Article 6 (1) (a) GDPR); Website: https://www.facebook.com;
Privacy Policy: https://www.facebook.com/about/privacy;
Data Processing Agreement: https://www.facebook.com/legal/terms/dataprocessing;
Further Information: User event data, i.e. behavioral and interest data, is
processed
for the purposes of targeted advertising and audience building on the basis of the joint
controllership
agreement ("Controller Addendum", https://www.facebook.com/legal/controller_addendum).
The joint controllership is limited to the collection and transfer of the data to Meta Platforms
Ireland
Limited, a company located in the EU. Further processing of the data is the sole responsibility
of Meta
Platforms Ireland Limited, which concerns in particular the transfer of the data to the parent
company
Meta Platforms, Inc. in the USA (on the basis of standard contractual clauses concluded between
Meta
Platforms Ireland Limited and Meta Platforms, Inc.).
- Facebook Ads: Placement of ads within the Facebook platform and analysis of ad
results;
Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand
Canal
Harbour, Dublin 2, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR);
Website:
https://www.facebook.com; Privacy
Policy: https://www.facebook.com/about/privacy;
Opt-Out: Wir verweisen auf die Datenschutz- und Werbeeinstellungen im Profil
des
Nutzers auf der Facebook-Plattform sowie auf das Einwilligungsverfahren von Facebook und die
Kontaktmöglichkeiten von Facebook zur Ausübung von Informations- und sonstigen
Betroffenenrechten in der
Datenschutzerklärung von Facebook; Further Information: User event data, i.e.
behavioral and interest data, is processed for the purposes of targeted advertising and audience
building on the basis of the joint controllership agreement ("Controller Addendum", https://www.facebook.com/legal/controller_addendum).
The joint controllership is limited to the collection and transfer of the data to Meta Platforms
Ireland
Limited, a company located in the EU. Further processing of the data is the sole responsibility
of Meta
Platforms Ireland Limited, which concerns in particular the transfer of the data to the parent
company
Meta Platforms, Inc. in the USA (on the basis of standard contractual clauses concluded between
Meta
Platforms Ireland Limited and Meta Platforms, Inc.).
- Google Ads and Conversion Tracking: We use the Google "Ads" online marketing
method to
place ads on the Google advertising network (e.g., in search results, videos, websites, etc.) so
that
they are displayed to users who have an alleged interest in the ads. We also measure the
conversion of
the ads (so called "Konversion"). However, we only know the anonymous total number of users who
clicked
on our ad and were redirected to a page tagged with a conversion tracking tag. However, we
ourselves do
not receive any information that can be used to identify users; Service
provider:
Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal
Basis:
Consent (Article 6 (1) (a) GDPR); Website: https://marketingplatform.google.com; Privacy
Policy: https://policies.google.com/privacy; Further
Information:
Types of processing and data processed: https://privacy.google.com/businesses/adsservices;
Google Ads Controller-Controller Data Protection Terms and standard contractual clauses for data
transfers to third countries: https://business.safety.google/adscontrollerterms.
- Enhanced Conversions for Google Ads: When customers click on our Google ads and
subsequently use the advertised service (so-called "conversion"), data entered by the user, such
as the
email address, name, home address or phone number, may be transmitted to Google. However, the
data is
not transmitted clearly, but in the form of a mathematical numerical value (so-called "hash
value").The
hash values are then matched with existing Google accounts of users in order to better evaluate
as well
as improve the interaction of users with the advertisements (e.g. clicks or views) and thus
their
performance; Legal Basis: Consent (Article 6 (1) (a) GDPR);
Website:
https://support.google.com/google-ads/answer/9888656.
Affiliate-Programms und Affiliate-Links
Within our online services, we include so-called affiliate links or other references (which for
example may
include search forms, widgets or discount codes) to the offers and services of third parties
(collectively
referred to as "affiliate links"). When users follow affiliate links or subsequently take advantage
of
offers, we may receive commission or other benefits (collectively referred to as "commission") from
these
third parties.
In order to be able to track whether the users have followed the offers of an affiliate link used by
us, it
is necessary for the respective third party to know that the users have followed an affiliate link
used
within our online services. The assignment of affiliate links to the respective business
transactions or
other actions (e.g., purchases) serves the sole purpose of commission settlement and is removed as
soon as
it is no longer required for this purpose.
For the purposes of the aforementioned affiliate link assignment, the affiliate links may be
supplemented by
certain values that may be a component of the link or otherwise stored, for example, in a cookie.
The values
may include in particular the source website (referrer), time, an online identifier of the operator
of the
website on which the affiliate link was located, an online identifier of the respective offer, the
type of
link used, the type of offer and an online identifier of the user.
Information on legal basis: If we ask the users for their consent to the use of
third party
providers, the legal basis of the processing is consent. Otherwise, user data will be processed on
the basis
of our legitimate interests (i.e. interest in efficient, economic and recipient friendly services).
In this
context, we would also like to refer you to the information on the use of cookies in this privacy
policy.
- Processed data types: Contract data (e.g. contract object, duration, customer
category); 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: Affiliate Tracking.
- Legal Basis: Consent (Article 6 (1) (a) GDPR); Legitimate Interests (Article 6
(1) (f)
GDPR).
Profiles in Social Networks (Social Media)
We maintain online presences within social networks and process user data in this context in order to
communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may
entail risks
for users, e.g. by making it more difficult to enforce users' rights.
In addition, user data is usually processed within social networks for market research and
advertising
purposes. For example, user profiles can be created on the basis of user behaviour and the
associated
interests of users. The user profiles can then be used, for example, to place advertisements within
and
outside the networks which are presumed to correspond to the interests of the users. For these
purposes,
cookies are usually stored on the user's computer, in which the user's usage behaviour and interests
are
stored. Furthermore, data can be stored in the user profiles independently of the devices used by
the users
(especially if the users are members of the respective networks or will become members later
on).
For a detailed description of the respective processing operations and the opt-out options, please
refer to
the respective data protection declarations and information provided by the providers of the
respective
networks.
Also in the case of requests for information and the exercise of rights of data subjects, we point
out that
these can be most effectively pursued with the providers. Only the providers have access to the data
of the
users and can directly take appropriate measures and provide information. If you still need help,
please do
not hesitate to contact us.
- Processed data types: Contact data (e.g. e-mail, telephone numbers); Content
data (e.g.
text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access
times);
Meta/communication data (e.g. device information, IP addresses).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of Processing: Contact requests and communication; Feedback (e.g.
collecting
feedback via online form); Marketing.
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Instagram: Social network; Service provider: Meta Platforms
Ireland
Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal
Basis:
Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.instagram.com; Privacy
Policy: https://instagram.com/about/legal/privacy.
- Facebook-Seiten: Profiles within the social network Facebook - We are jointly
responsible (so called "joint controller") with Meta Platforms Ireland Limited for the
collection (but
not the further processing) of data of visitors to our Facebook page. This data includes
information
about the types of content users view or interact with, or the actions they take (see "Things
that 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: 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 about 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 access or
deletion requests directly to Facebook). The rights of users (in particular to access to
information,
erasure, objection and complaint to the competent supervisory authority) are not restricted by
the
agreements with Facebook. Further information can be found in the "Information about Page
Insights" (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 Basis: Legitimate Interests (Article 6 (1)
(f) GDPR);
Website: https://www.facebook.com; Privacy
Policy: https://www.facebook.com/about/privacy;
Standard Contractual Clauses (Safeguarding the level of data protection when processing
data 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.
The joint controllership is limited to the collection and transfer of the data to Meta Platforms
Ireland
Limited, a company located in the EU. Further processing of the data is the sole responsibility
of Meta
Platforms Ireland Limited, which concerns in particular the transfer of the data to the parent
company
Meta Platforms, Inc. in the USA (on the basis of standard contractual clauses concluded between
Meta
Platforms Ireland Limited and Meta Platforms, Inc.).
- Snapchat: Social network; Service provider: Snap Inc., 3000
31st
Street, Santa Monica, California 90405, USA; Legal Basis: Legitimate Interests
(Article
6 (1) (f) GDPR); Website: https://www.snapchat.com/;
Privacy Policy: https://www.snap.com/en-US/privacy/privacy-policy,
Cookie-Richtlinie: Cookie-Policy: https://www.snap.com/en-US/cookie-policy;
Standard Contractual Clauses (Safeguarding the level of data protection when processing
data in
third countries): https://www.snap.com/en-US/terms/standard-contractual-clauses.
- TikTok: Social network / video plattform; Service provider:
TikTok
Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland; Legal
Basis:
Legitimate Interests (Article 6 (1) (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 Basis:
Legitimate
Interests (Article 6 (1) (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 Basis:
Legitimate Interests (Article 6 (1) (f) GDPR); Privacy Policy: https://policies.google.com/privacy; Opt-Out: https://adssettings.google.com/authenticated.
Plugins and embedded functions and content
Within our online services, we integrate functional and content elements that are obtained from the
servers
of their respective providers (hereinafter referred to as "third-party providers"). These may, for
example,
be graphics, videos or city maps (hereinafter uniformly referred to as "Content").
The integration always presupposes that the third-party providers of this content process the IP
address of
the user, since they could not send the content to their browser without the IP address. The IP
address is
therefore required for the presentation of these contents or functions. We strive to use only those
contents, whose respective offerers use the IP address only for the distribution of the contents.
Third
parties 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 include technical information about the browser and operating system, referring websites, visit
times
and other information about the use of our website, as well as may be linked to such information
from other
sources.
- Processed data types: Usage data (e.g. websites visited, interest in content,
access
times); Meta/communication data (e.g. device information, IP addresses); Inventory data (e.g.
names,
addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input,
photographs,
videos).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of Processing: Provision of our online services and usability.
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Integration of third-party software, scripts or frameworks: We incorporate into
our
online services software which we retrieve from servers of other providers (e.g. function
libraries
which we use for the purpose of displaying or user-friendliness of our online services). The
respective
providers collect the user's IP address and can process it for the purposes of transferring the
software
to the user's browser as well as for security purposes and for the evaluation and optimisation
of their
services; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
- Google Fonts (Provision on own server): Obtaining fonts ("Google Fonts") for
the
purpose of a user-friendly appearance of our online services; Service provider:
The
Google Fonts are hosted on our server, no data is transmitted to Google; Legal
Basis:
Legitimate Interests (Article 6 (1) (f) GDPR).
- Font Awesome (Provision on own server): Display of fonts and symbols; Service
provider: The Font Awesome icons are hosted on our server, no data is transmitted to
the
provider of Font Awesome; Legal Basis: Legitimate Interests (Article 6 (1) (f)
GDPR).
- reCAPTCHA: We integrate the "reCAPTCHA" function to be able to recognise
whether entries (e.g. in online forms) are made by humans and not by automatically operating
machines (so-called "bots"). The data processed may include IP addresses, information on
operating systems, devices or browsers used, language settings, location, mouse movements,
keystrokes, time spent on websites, previously visited websites, interactions with ReCaptcha on
other websites, possibly cookies and results of manual recognition processes (e.g. answering
questions asked or selecting objects in images). The data processing is based on our legitimate
interest to protect our online services from abusive automated crawling and spam; Service
provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, ,
parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal
Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.google.com/recaptcha/;
Privacy Policy: https://policies.google.com/privacy;
Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en,
Settings for the Display of Advertisements: https://adssettings.google.com/authenticated.
- YouTube videos: Video contents; Service provider: Google
Ireland
Limited, Gordon House, Barrow Street, Dublin 4, Ireland, , parent company: Google LLC, 1600
Amphitheatre
Parkway, Mountain View, CA 94043, USA; Legal Basis: Legitimate Interests
(Article 6 (1)
(f) GDPR); Website: https://www.youtube.com;
Privacy Policy: https://policies.google.com/privacy;
Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en,
Settings for the Display of Advertisements: https://adssettings.google.com/authenticated.
Management, Organization and Utilities
We use services, platforms and software from other providers (hereinafter referred to as "
third-party
providers") for the purposes of organizing, administering, planning and providing our services. When
selecting third-party providers and their services, we comply with the legal requirements.
Within this context, personal data may be processed and stored on the servers of third-party
providers. This
may include various data that we process in accordance with this privacy policy. This data may
include in
particular master data and contact data of users, data on processes, contracts, other processes and
their
contents.
If users are referred to the third-party providers or their software or platforms in the context of
communication, business or other relationships with us, the third-party provider processing may
process
usage data and metadata that can be processed by them for security purposes, service optimisation or
marketing purposes. We therefore ask you to read the data protection notices of the respective third
party
providers.
- Processed data types: Content data (e.g. text input, photographs, videos);
Usage data
(e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device
information, IP addresses).
- Data subjects: Communication partner (Recipients of e-mails, letters, etc.);
Users
(e.g. website visitors, users of online services).
- Purposes of Processing: Contact requests and communication; Provision of
contractual
services and customer support; Office and organisational procedures.
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Trello: Project management tool; Service provider: Trello
Inc., 55
Broadway New York, NY 10006, USA, parent company: Atlassian Inc. (San Francisco, Harrison Street
Location), 1098 Harrison Street, San Francisco, California 94103, USA; Legal
Basis:
Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://trello.com/;
Privacy Policy: https://trello.com/privacy;
Standard Contractual Clauses (Safeguarding the level of data protection when processing
data in
third countries): Part of the Data Processing Agreement; Further
Information: Data Transfer Impact Assessment: https://www.atlassian.com/legal/data-transfer-impact-assessment.
- WeTransfer: Transferring files over the Internet; Service
provider:
WeTransfer BV, Oostelijke Handelskade 751, Amsterdam, 1019 BW, Netherlands; Legal
Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://wetransfer.com; Privacy
Policy: https://wetransfer.com/legal/privacy.
Changes and Updates to the Privacy Policy
We kindly ask you to inform yourself regularly about the contents of our data protection declaration.
We will
adjust the privacy policy as changes in our data processing practices make this necessary. We will
inform
you as soon as the changes require your cooperation (e.g. consent) or other individual
notification.
If we provide addresses and contact information of companies and organizations in this privacy
policy, we ask
you to note that addresses may change over time and to verify the information before contacting
us.
Rights of Data Subjects
As data subject, you are entitled to various rights under the GDPR, which arise in particular from
Articles
15 to 21 of the GDPR:
- Right to Object: You have the right, on grounds arising from your particular situation,
to
object at any time to the processing of your personal data which is based on letter (e) or (f)
of
Article 6(1) GDPR, including profiling based on those provisions. Where personal data are
processed for
direct marketing purposes, you have the right to object at any time to the processing of the
personal
data concerning you for the purpose of such marketing, which includes profiling to the extent
that it is
related to such direct marketing.
- Right of withdrawal for consents: You have the right to revoke consents at any
time.
- Right of access: You have the right to request confirmation as to whether the
data in
question will be processed and to be informed of this data and to receive further information
and a copy
of the data in accordance with the provisions of the law.
- Right to rectification: You have the right, in accordance with the law, to
request the
completion of the data concerning you or the rectification of the incorrect data concerning you.
- Right to Erasure and Right to Restriction of Processing: In accordance with the
statutory provisions, you have the right to demand that the relevant data be erased immediately
or,
alternatively, to demand that the processing of the data be restricted in accordance with the
statutory
provisions.
- Right to data portability: You have the right to receive data concerning you
which you
have provided to us in a structured, common and machine-readable format in accordance with the
legal
requirements, or to request its transmission to another controller.
- Complaint to the supervisory authority: In accordance with the law and without
prejudice to any other administrative or judicial remedy, you also have the right to lodge a
complaint
with a data protection supervisory authority, in particular a supervisory authority in the
Member State
where you habitually reside, the supervisory authority of your place of work or the place of the
alleged
infringement, if you consider that the processing of personal data concerning you infringes the
GDPR.
Supervisory authority competent for us:
Österreichische Datenschutzbehörde
Barichgasse 40-42,
1030
Vienna, Austria
https://www.dsb.gv.at/
Terminology and Definitions
This section provides an overview of the terms used in this privacy policy. Many of the terms are
drawn from
the law and defined mainly in Article 4 GDPR. The legal definitions are binding. The following
explanations,
on the other hand, are intended above all for the purpose of comprehension. The terms are sorted
alphabetically.
- Affiliate Tracking: Affiliate tracking logs links that the linking websites use
to
refer users to websites with products or other offers. The owners of the respective linked
websites can
receive a commission if users follow these so-called "affiliate links" and subsequently take
advantage
of the offers (e.g. buy goods or use services). To this end, it is necessary for providers to be
able to
track whether users who are interested in certain offers subsequently follow the affiliate
links. It is
therefore necessary for the functionality of affiliate links that they are supplemented by
certain
values that become part of the link or are otherwise stored, e.g. in a cookie. The values
include in
particular the source website (referrer), time, an online identification of the owner of the
website on
which the affiliate link was located, an online identification of the respective offer, an
online
identifier of the user, as well as tracking specific values such as advertising media ID,
partner ID and
categorizations
- Controller: "Controller" means 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.
- Conversion tracking: Conversion tracking is a method used to evaluate the
effectiveness
of marketing measures. For this purpose, a cookie is usually stored on the devices of the users
within
the websites on which the marketing measures take place and then called up again on the target
website
(e.g. we can thus trace whether the advertisements placed by us on other websites were
successful).
- Custom Audiences: Target group formation (or "custom audiences") is the term
used when
target groups are determined for advertising purposes, e.g. display of advertisements. For
example, a
user's interest in certain products or topics on the Internet may be used to infer that that
user is
interested in advertisements for similar products or the online store in which they viewed the
products.
Lookalike Audiences" (or similar target groups) is the term used to describe content that is
viewed as
suitable by users whose profiles or interests presumably correspond to the users for whom the
profiles
were created. Cookies are generally used for the purposes of creating custom audiences and
lookalike
audiences. Target groups can be created by processing visitors of an online service or can be
uploaded
to the provider of an online marketing technology by means of uploading (which is usually done
pseudonymised).
- Personal Data: "personal data" means any information relating to an identified
or
identifiable natural person ("data subject"); an identifiable natural 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 or to one or more factors specific to
the
physical, physiological, genetic, mental, economic, cultural or social identity of that natural
person.
- Processing: The term "processing" covers a wide range and practically every
handling of
data, be it collection, evaluation, storage, transmission or erasure.
- 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 that
consists of using these personal data to analyse, evaluate or predict certain personal aspects
relating
to a natural person (depending on the type of profiling, this may include different information
concerning demographics, behaviour and interests, such as interaction with websites and their
content,
etc.) (e.g. interests in certain content or products, click behaviour on a website or location).
Cookies
and web beacons are often used for profiling purposes.
- Targeting: "Tracking" is the term used when the behaviour of users can be
traced across
several websites. As a rule, behavior and interest information with regard to the websites used
is
stored in cookies or on the servers of the tracking technology providers (so-called profiling).
This
information can then be used, for example, to display advertisements to users presumably
corresponding
to their interests.
- Web Analytics: Web Analytics serves the evaluation of visitor traffic of online
services and can determine their behavior or interests in certain information, such as content
of
websites. With the help of web analytics, website owners, for example, can recognize at what
time
visitors visit their website and what content they are interested in. This allows them, for
example, to
optimize the content of the website to better meet the needs of their visitors. For purposes of
web
analytics, pseudonymous cookies and web beacons are frequently used in order to recognise
returning
visitors and thus obtain more precise analyses of the use of an online service.