Privacy Policy
This privacy policy informs you about the type, scope, and purpose of processing personal data (hereinafter referred to as "data") within the provision of our services and within our online offer and the associated websites, functions, and content, as well as external online presences, such as our social media profiles (collectively referred to as "online offer"). With regard to the terms used, such as "processing" or "controller", we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
Controller
PeopleConnect
A brand of Unzola Consulting GmbH Albin-Köbis-Str. 12 51147 Cologne
E-mail: [email protected]
Responsible: Joséphine Unzola
Types of Data Processed
Categories of Data Subjects
Visitors and users of the online offer (hereinafter, we also refer to the data subjects as "users").
Purpose of Processing
Terminology Used
"Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, particularly by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie), or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
"Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically any handling of data.
"Pseudonymization" means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
"Profiling" means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
"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.
"Processor" means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
Relevant Legal Bases
In accordance with Article 13 of the GDPR, we inform you about the legal bases of our data processing. For users from the scope of the General Data Protection Regulation (GDPR), i.e., the EU and the EEA, the following applies if the legal basis is not specified in the privacy policy: The legal basis for obtaining consent is Article 6(1)(a) and Article 7 GDPR; The legal basis for processing to perform our services and carry out contractual measures as well as responding to inquiries is Article 6(1)(b) GDPR; The legal basis for processing to fulfill our legal obligations is Article 6(1)(c) GDPR; In the event that vital interests of the data subject or another natural person make the processing of personal data necessary, Article 6(1)(d) GDPR serves as the legal basis. The legal basis for the necessary processing to perform a task carried out in the public interest or in the exercise of official authority vested in the controller is Article 6(1)(e) GDPR. The legal basis for processing to safeguard our legitimate interests is Article 6(1)(f) GDPR. Processing for purposes other than those for which the data were collected is determined by the provisions of Article 6(4) GDPR. Processing of special categories of data (according to Article 9(1) GDPR) is determined by the provisions of Article 9(2) GDPR.
Security Measures
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, implementation costs, the nature, scope, context, and purposes of the processing, as well as the varying likelihood and severity of risks to the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk.
Measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as access, input, transfer, ensuring availability, and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, deletion of data, and response to data threats. We also consider the protection of personal data already during the development or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and data protection by default.
Cooperation with Processors, Joint Controllers, and Third Parties
If, in the course of our processing, we disclose data to other persons and companies (processors, joint controllers, or third parties), transmit data to them, or otherwise grant them access to the data, this will only be done based on a legal permission (e.g., if a transmission of the data to third parties, such as payment service providers, is necessary for the performance of a contract), users have consented, a legal obligation provides for this, or based on our legitimate interests (e.g., when using agents, web hosts, etc.).
If we disclose or transmit data to other companies in our group of companies or otherwise grant them access, this is done in particular for administrative purposes as a legitimate interest and, moreover, on a basis in compliance with the legal requirements.
Transfers to Third Countries
If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA), or the Swiss Confederation) or if this happens in the context of the use of services of third parties or disclosure, or transfer of data to other persons or companies, this will only be done if it is necessary to fulfill our (pre)contractual obligations, based on your consent, a legal obligation, or based on our legitimate interests. Subject to legal or contractual permissions, we process or allow the data to be processed in a third country only if the special requirements of Article 44 et seq. GDPR are met. This means that processing is based, for example, on special guarantees, such as the officially recognized determination of a data protection level corresponding to the EU or compliance with officially recognized specific contractual obligations.
Rights of Data Subjects
You have the right to request confirmation as to whether data concerning you are being processed and to information about these data, as well as to further information and a copy of the data in accordance with legal requirements.
You have the right, in accordance with legal requirements, to request the completion of data concerning you or the correction of inaccurate data concerning you.
You have the right, in accordance with legal requirements, to request that data concerning you be deleted immediately, or alternatively, in accordance with legal requirements, to request restriction of the processing of the data.
You have the right to request that data concerning you that you have provided to us be received in accordance with legal requirements and to request their transmission to other controllers.
You also have the right to lodge a complaint with the competent supervisory authority in accordance with legal requirements.
Right of Withdrawal
You have the right to revoke consent granted with effect for the future.
Right to Object
You may object at any time to the future processing of data concerning you in accordance with legal requirements. The objection may, in particular, be made against processing for direct marketing purposes.
Cookies and Right to Object to Direct Advertising
"Cookies" are small files that are stored on users' computers. Different information can be stored within the cookies. A cookie is primarily used to store the details of a user (or the device on which the cookie is stored) during or after their visit to an online offer. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online offer and closes their browser. In such a cookie, for example, the content of a shopping cart in an online store or a login status can be stored. "Permanent" or "persistent" cookies are cookies that remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. Likewise, in such a cookie, the interests of users can be stored, which are used for reach measurement or marketing purposes. "Third-party cookies" are cookies that are offered by providers other than the controller who operates the online offer (otherwise, if it is only their cookies, they are referred to as "first-party cookies").
We can use temporary and permanent cookies and clarify this in the context of our privacy policy.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
A general objection to the use of cookies used for online marketing purposes can be declared for a variety of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by switching them off in the settings of the browser. Please note that not all functions of this online offer may then be used.
Deletion of Data
The data processed by us will be deleted in accordance with legal requirements or their processing restricted. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer necessary for their purpose and the deletion does not conflict with any statutory retention obligations.
If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons.
Changes and Updates to the Privacy Policy
We ask you to regularly inform yourself about the content of our privacy policy. We adapt the privacy policy as soon as changes in the data processing carried out by us make this necessary. We inform you as soon as changes require your cooperation (e.g., consent) or other individual notification.
Business-Related Processing
In addition, we process
Order Processing in the Online Shop and Customer Account
We process the data of our customers in the context of the order processes in our online shop to enable them to select and order the chosen products and services, as well as their payment and delivery, or execution.
The processed data includes inventory data, communication data, contract data, payment data, and the persons affected by the processing include our customers, interested parties, and other business partners. The processing is carried out for the purpose of providing contractual services in the context of the operation of an online shop, billing, delivery, and customer services. Here we use session cookies to store the content of the shopping cart and permanent cookies to store the login status.
The processing is carried out on the basis of Article 6(1)(b) GDPR (execution of order processes) and Article 6(1)(c) GDPR (legally required archiving). The information marked as required is necessary for the establishment and fulfillment of the contract. We disclose the data to third parties only in the context of delivery, payment, or within the framework of legal permissions and obligations, as well as based on our legitimate interests, about which we inform you in the context of this privacy policy (e.g., to legal and tax advisors, financial institutions, freight companies, as well as authorities).
Users can optionally create a user account, in particular by being able to view their orders. During registration, the required mandatory information is communicated to the users. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data in respect of the user account will be deleted, subject to their retention is necessary for commercial or tax reasons. Information in the customer account remains until its deletion with subsequent archiving in the case of a legal obligation or our legitimate interests (e.g., in the case of legal disputes). It is the users' responsibility to save their data before the end of the contract if they cancel before the contract ends.
As part of the registration and renewed logins and use of our online services, we store the IP address and the time of the respective user action. The storage takes place based on our legitimate interests, as well as those of the users in protection against abuse and other unauthorized use. A transfer of this data to third parties does not take place, unless it is necessary for the pursuit of our claims or there is a legal obligation to do so in accordance with Article 6(1)(c) GDPR.
The deletion takes place after the expiry of statutory warranty and comparable obligations, the necessity of the storage of the data is reviewed every three years; in the case of statutory archiving obligations, the deletion takes place after their expiry.
Agency Services
We process the data of our customers in the context of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes/handling, server administration, data analysis/consulting services, and training services.
We process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter, term), payment data (e.g., bank details, payment history), usage and metadata (e.g., in the context of the evaluation and success measurement of marketing measures). We do not process special categories of personal data unless they are part of a commissioned processing. Data subjects include our customers, interested parties, and their customers, users, website visitors, or employees as well as third parties. The purpose of the processing is to provide contractual services, billing, and our customer service. The legal bases of the processing result from Article 6(1)(b) GDPR (contractual services), Article 6(1)(f) GDPR (analysis, statistics, optimization, security measures). We process data that is necessary for the establishment and fulfillment of the contractual services and indicate the necessity of their specification. Disclosure to external parties only takes place if it is required within the framework of an order. When processing the data provided to us within the scope of an order, we act in accordance with the instructions of the clients as well as the legal requirements of an order processing in accordance with Article 28 GDPR and process the data for no other purposes than those specified in the order.
We delete the data after the expiry of statutory warranty and comparable obligations. The necessity of the storage of the data is reviewed every three years; in the case of statutory archiving obligations, the deletion takes place after their expiry (6 years, according to Section 257(1) HGB, 10 years, according to Section 147(1) AO). In the case of data disclosed to us within the scope of an order by the client, we delete the data according to the specifications of the order, generally after the end of the order.
Therapeutic Services and Coaching
We process the data of our clients and interested parties and other clients or contractual partners (collectively referred to as "clients") in accordance with Article 6(1)(b) GDPR, to provide them with our contractual or pre-contractual services. The data processed here, the nature, scope, and purpose and the necessity of their processing are determined by the underlying contractual relationship. The processed data includes inventory and master data of the clients (e.g., name, address, etc.), as well as the contact data (e.g., e-mail address, telephone, etc.), the contract data (e.g., services used, fees, names of contact persons, etc.), and payment data (e.g., bank details, payment history, etc.).
Within our services, we may also process special categories of data in accordance with Article 9(1) GDPR, in particular information about the health of clients, possibly with reference to their sex life or sexual orientation, ethnic origin, or religious or philosophical beliefs. For this purpose, we obtain, if necessary, explicit consent in accordance with Article 6(1)(a), Article 7, and Article 9(2)(a) GDPR and otherwise process the special categories of data for purposes of health care based on Article 9(2)(h) GDPR, Section 22(1)(1)(b) BDSG.
If required for the fulfillment of the contract or legally necessary, we disclose or transmit the data of the clients in the context of communication with other professionals, necessary or typically involved third parties in the fulfillment of the contract, such as billing offices or comparable service providers, as far as this serves the provision of our services in accordance with Article 6(1)(b) GDPR, legally required in accordance with Article 6(1)(c) GDPR, serves our or the clients' interests in efficient and cost-effective health care as a legitimate interest in accordance with Article 6(1)(f) GDPR, or is necessary to protect the vital interests of clients or another natural person in accordance with Article 6(1)(d) GDPR or based on consent in accordance with Article 6(1)(a), Article 7 GDPR.
The deletion of the data takes place when the data is no longer necessary for the fulfillment of contractual or statutory care obligations as well as handling any warranty and comparable obligations, whereby the necessity of the storage of the data is reviewed every three years; otherwise, the statutory retention obligations apply.
Contractual Services
We process the data of our contractual partners and interested parties as well as other clients, customers, clients, or contractual partners (collectively referred to as "contractual partners") in accordance with Article 6(1)(b) GDPR to provide them with our contractual or pre-contractual services. The data processed here, the nature, scope, and purpose and the necessity of their processing are determined by the underlying contractual relationship.
The processed data includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g., e-mail addresses and telephone numbers), as well as contract data (e.g., services used, contract content, contractual communication, names of contact persons) and payment data (e.g., bank details, payment history).
We do not process special categories of personal data unless they are part of a commissioned or contractual processing.
We process data that is necessary for the establishment and fulfillment of the contractual services and indicate the necessity of their specification, as far as these are not evident to the contractual partners. Disclosure to external persons or companies only takes place if it is required within the framework of a contract. When processing the data provided to us within the scope of an order, we act in accordance with the instructions of the clients as well as the legal requirements.
Within the scope of the use of our online services, we may store the IP address and the time of the respective user action. The storage takes place based on our legitimate interests, as well as those of the users in protection against abuse and other unauthorized use. A transfer of this data to third parties does not take place unless it is necessary for the pursuit of our claims in accordance with Article 6(1)(f) GDPR or there is a legal obligation to do so in accordance with Article 6(1)(c) GDPR.
The deletion of the data takes place when the data is no longer necessary for the fulfillment of contractual or statutory care obligations as well as handling any warranty and comparable obligations, whereby the necessity of the storage of the data is reviewed every three years; otherwise, the statutory retention obligations apply.
External Payment Service Providers
We use external payment service providers, through whose platforms users and we can carry out payment transactions (e.g., with a link to the privacy policy, PayPal [https://www.paypal.com/de/webapps/mpp/ua/privacy-full], Klarna [https://www.klarna.com/de/datenschutz/], Skrill [https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/], Giropay [https://www.giropay.de/rechtliches/datenschutz-agb/], Visa [https://www.visa.de/datenschutz], Mastercard [https://www.mastercard.de/de-de/datenschutz.html], American Express [https://www.americanexpress.com/de/content/privacy-policy-statement.html]).
In the context of fulfilling contracts, we use the payment service providers on the basis of Article 6(1)(b) GDPR. Otherwise, we use external payment service providers on the basis of our legitimate interests in accordance with Article 6(1)(f) GDPR to provide our users with effective and secure payment options.
The data processed by the payment service providers includes inventory data, such as the name and address, bank details, such as account numbers or credit card numbers, passwords, TANs, and checksums as well as the contract, sum, and recipient-related information. The information is required to carry out the transactions. However, the entered data is only processed by the payment service providers and stored by them. This means that we do not receive any account or credit card information, but only information with confirmation or negative information about the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit reporting agencies. This transmission aims at the identity and credit check. For this, we refer to the terms and conditions and privacy notices of the payment service providers.
For payment transactions, the terms and conditions and the privacy notices of the respective payment service providers apply, which are available within the respective websites or transaction applications. We refer to these for further information and the assertion of rights of revocation, information, and other data subject rights.
Administration, Financial Accounting, Office Organization, Contact Management
We process data in the context of administrative tasks as well as the organization of our operations, financial accounting, and compliance with legal obligations, such as archiving. We process the same data that we process in the context of providing our contractual services. The processing bases are Article 6(1)(c) GDPR, Article 6(1)(f) GDPR. Data subjects include customers, interested parties, business partners, and website visitors. The purpose and our interest in the processing lie in administration, financial accounting, office organization, archiving of data, i.e., tasks that serve the maintenance of our business activities, performance of our tasks, and provision of our services. The deletion of data in terms of contractual services and contractual communication corresponds to the information provided in these processing activities.
We disclose or transmit data to the tax authorities, consultants, such as tax advisors or auditors, as well as other fee offices and payment service providers.
Furthermore, based on our business interests, we store information about suppliers, organizers, and other business partners, e.g., for later contact. These mostly company-related data are stored permanently.
Business Analyses and Market Research
To run our business economically, to be able to recognize market trends, and to meet the wishes of our contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc. We process inventory data, communication data, contract data, payment data, usage data, and metadata on the basis of Article 6(1)(f) GDPR, whereby the data subjects include contractual partners, interested parties, customers, visitors, and users of our online offer.
The analyses are carried out for the purpose of business evaluations, marketing, and market research. We may include the profiles of registered users with information, e.g., on their services used, in our evaluations. The analyses serve us to increase user-friendliness, optimize our offer, and business efficiency. The analyses are solely for our use and are not disclosed externally unless they are anonymous analyses with summarized values.
If these analyses or profiles are personal, they will be deleted or anonymized with the termination of the users or otherwise after two years from the conclusion of the contract. In addition, the overall business analyses and general trend determinations are created anonymously wherever possible.
Participation in Affiliate Partner Programs
Within our online offer, we use tracking measures customary in the industry based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offer) in accordance with Article 6(1)(f) GDPR, provided that these are necessary for the operation of the affiliate system. Below we explain the technical background to users.
The services offered by our contractual partners can also be advertised and linked on other websites (so-called affiliate links or after-buy systems, e.g., if links or services of third parties are offered after the conclusion of a contract). The operators of the respective websites receive a commission if users follow the affiliate links and then take advantage of the offers.
In summary, it is necessary for our online offer that we can track whether users who are interested in affiliate links and/or the offers available from us subsequently perceive the offers at the instigation of the affiliate links or our online platform. For this purpose, the affiliate links and our offers are supplemented with certain values that can be a part of the link or otherwise, e.g., in a cookie. The values include, in particular, the origin 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, an online identifier of the user, as well as tracking-specific values, such as advertising material ID, partner ID, and categorizations.
The online identifiers used by us are pseudonymous values. This means that the online identifiers themselves do not contain any personal data, such as names or e-mail addresses. They help us only to determine whether the same user who clicked on an affiliate link or showed interest in an offer via our online offer perceived the offer, i.e., for example, concluded a contract with the provider. However, the online identifier is personal to the extent that the partner company and we have the online identifier together with other user data. Only in this way can the partner company inform us whether the user perceived the offer and we can, for example, pay out the bonus.
Amazon Affiliate Program
We are participants in the Amazon EU Affiliate Program, which was designed to provide a medium for websites to earn advertising fees by placing advertisements and links to Amazon.de (so-called affiliate system) based on our legitimate interests (i.e., interest in the economic operation of our online offer within the meaning of Article 6(1)(f) GDPR). This means that as an Amazon partner, we earn from qualified purchases.
Amazon uses cookies to be able to trace the origin of the orders. Among other things, Amazon can recognize that you have clicked the partner link on this website and subsequently purchased a product from Amazon.
For more information on Amazon's data usage and opt-out options, please see the company's privacy policy: https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010.
Note: Amazon and the Amazon logo are trademarks of Amazon.com, Inc. or one of its affiliated companies.
Digistore24 Affiliate Program
We are participants in the affiliate program of Digistore24 GmbH, St.-Godehard-Straße 32, 31139 Hildesheim, Germany, which was designed to provide a medium for websites to earn advertising fees by placing advertisements and links to Digistore24 (so-called affiliate system) based on our legitimate interests (i.e., interest in the economic operation of our online offer within the meaning of Article 6(1)(f) GDPR). Digistore24 uses cookies to be able to trace the origin of the contract conclusions. Among other things, Digistore24 can recognize that you have clicked the partner link on this website and subsequently concluded a contract at or via Digistore24.
For more information on Digistore24's data usage and opt-out options, please see the company's privacy policy: https://www.digistore24.com/page/privacyl.
Privacy Notices in the Application Process
We process applicant data only for the purpose and within the scope of the application process in accordance with legal requirements. The processing of applicant data takes place to fulfill our (pre)contractual obligations in the context of the application process in the sense of Article 6(1)(b) GDPR and Article 6(1)(f) GDPR if the data processing, e.g., in the context of legal procedures, becomes necessary for us (in Germany, Section 26 BDSG additionally applies).
The application process requires that applicants provide us with applicant data. The necessary applicant data are, if we offer an online form, marked, otherwise result from the job descriptions and generally include the information about the person, postal and contact addresses, and the documents related to the application, such as cover letter, curriculum vitae, and certificates. In addition, applicants can voluntarily provide us with additional information.
By submitting the application to us, applicants declare their agreement with the processing of their data for purposes of the application process in accordance with the type and scope set out in this privacy policy.
To the extent that special categories of personal data within the meaning of Article 9(1) GDPR are voluntarily provided in the context of the application process, their processing is additionally carried out in accordance with Article 9(2)(b) GDPR (e.g., health data, such as disability status or ethnic origin). To the extent that special categories of personal data within the meaning of Article 9(1) GDPR are requested from applicants in the context of the application process, their processing is additionally carried out in accordance with Article 9(2)(a) GDPR (e.g., health data if this is necessary for the exercise of the profession).
If provided, applicants can submit their applications using an online form on our website. The data will be transmitted to us encrypted in accordance with the state of the art. Applicants can also send us their applications via e-mail. However, please note that e-mails are generally not sent encrypted and applicants must ensure encryption themselves. We cannot therefore assume any responsibility for the transmission path of the application between the sender and the receipt on our server and therefore recommend using an online form or postal transmission. Instead of applying via the online form and e-mail, applicants can still send us their application by postal mail.
The data provided by the applicants can be further processed by us in the event of a successful application for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicants' data will be deleted. Applicants' data will also be deleted if an application is withdrawn, to which applicants are entitled at any time.
The deletion will take place, subject to a justified revocation by the applicants, after six months, so that we can answer any follow-up questions about the application and meet our obligations under the Equal Treatment Act. Invoices for any travel expense reimbursements are archived in accordance with tax regulations.
Registration Function
Users can create a user account. As part of the registration, the required mandatory information is communicated to the users and processed on the basis of Article 6(1)(b) GDPR for the purpose of providing the user account. The processed data includes, in particular, the login information (name, password, and e-mail address). The data entered during registration will be used for the purposes of using the user account and its purposes.
Users can be informed by e-mail about information relevant to their user account, such as technical changes. If users have terminated their user account, their data in respect of the user account will be deleted, subject to a statutory retention obligation. It is the users' responsibility to save their data before the end of the contract if they cancel before the contract ends. We are entitled to irretrievably delete all user data stored during the contract period.
As part of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage takes place based on our legitimate interests, as well as those of the users in protection against abuse and other unauthorized use. A transfer of this data to third parties does not take place unless it is necessary for the pursuit of our claims or there is a legal obligation to do so in accordance with Article 6(1)(c) GDPR. The IP addresses will be anonymized or deleted after 7 days at the latest.
Contacting Us
When contacting us (e.g., via contact form, e-mail, telephone, or social media), the user's details are processed to handle the contact request and its processing in accordance with Article 6(1)(b) (within the framework of contractual/pre-contractual relationships), Article 6(1)(f) (other inquiries) GDPR. The user's details may be stored in a Customer Relationship Management System ("CRM System") or comparable inquiry organization.
We delete the inquiries if they are no longer necessary. We review the necessity every two years; further, the statutory archiving obligations apply.
Newsletter
With the following information, we inform you about the content of our newsletter as well as the registration, shipping, and statistical evaluation procedures and your rights of objection. By subscribing to our newsletter, you agree to receive it and the described procedures.
Content of the newsletter: We send newsletters, e-mails, and other electronic notifications with promotional information (hereinafter "newsletter") only with the consent of the recipients or a legal permission. If the content of the newsletter is specifically described in the context of a subscription, it is decisive for the consent of the users. Otherwise, our newsletters contain information about our services and us.
Double-Opt-In and logging: The registration for our newsletter takes place in a so-called double-opt-in procedure. This means you will receive an e-mail after registration in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other people's e-mail addresses. The registrations for the newsletter are logged to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and the confirmation time, as well as the IP address. Likewise, the changes to your data stored with the shipping service provider are logged.
Registration data: To subscribe to the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to provide a name for personal address in the newsletter.
The sending of the newsletter and the associated performance measurement is based on the consent of the recipients in accordance with Article 6(1)(a), Article 7 GDPR in conjunction with Section 7(2)(3) UWG or if consent is not required, based on our legitimate interests in direct marketing in accordance with Article 6(1)(f) GDPR in conjunction with Section 7(3) UWG.
The logging of the registration process takes place based on our legitimate interests in accordance with Article 6(1)(f) GDPR. Our interest lies in the use of a user-friendly and secure newsletter system that serves both our business interests and meets the expectations of the users and also allows us to provide proof of consent.
Cancellation/Revocation - You can cancel the receipt of our newsletter at any time, i.e., revoke your consents. A link to cancel the newsletter can be found at the end of each newsletter. We may store the unsubscribed e-mail addresses for up to three years based on our legitimate interests before we delete them to be able to prove a formerly given 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.
Newsletter - Shipping Service Provider
The sending of the newsletter is carried out by means of the shipping service provider [NAME, ADDRESS, COUNTRY]. The privacy policy of the shipping service provider can be viewed here: [LINK TO THE PRIVACY POLICY]. The shipping service provider is used based on our legitimate interests in accordance with Article 6(1)(f) GDPR and an order processing contract in accordance with Article 28(3)(1) GDPR.
The shipping service provider may use the data of the recipients in pseudonymous form, i.e., without assignment to a user, to optimize or improve their own services, e.g., for technical optimization of the shipment and the presentation of the newsletters or for statistical purposes. However, the shipping service provider does not use the data of our newsletter recipients to address them themselves or to pass the data on to third parties.
Newsletter - Performance Measurement
The newsletters contain a so-called "web-beacon", i.e., a pixel-sized file that is retrieved from our server when opening the newsletter or if we use a shipping service provider from their server. In the context of this retrieval, technical information such as information about the browser and your system, as well as your IP address and the time of retrieval are collected.
This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. The statistical surveys also include determining whether the newsletters are opened, when they are opened, and which links are clicked. This information can be assigned to the individual newsletter recipients for technical reasons. However, it is neither our endeavor nor, if used, that of the shipping service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
A separate revocation of the performance measurement is unfortunately not possible, in this case, the entire newsletter subscription must be canceled.
Hosting and E-Mail Delivery
The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space, and database services, e-mail delivery, security services, and technical maintenance services we use to operate this online offer.
Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties, and visitors to this online offer based on our legitimate interests in an efficient and secure provision of this online offer in accordance with Article 6(1)(f) GDPR in conjunction with Article 28 GDPR (conclusion of order processing contract).
Collection of Access Data and Log Files
We, or our hosting provider, collect data based on our legitimate interests in the sense of Article 6(1)(f) GDPR about every access to the server on which this service is located (so-called server log files). The access data include the name of the retrieved website, file, date and time of retrieval, transferred data volume, message about successful retrieval, browser type including version, the operating system of the user, referrer URL (the previously visited page), IP address, and the requesting provider.
Logfile information is stored for security reasons (e.g., to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Data that needs to be retained for further evidence purposes is exempted from deletion until the final clarification of the respective incident.
Google Analytics
We use Google Analytics, a web analytics service provided by Google LLC ("Google"), based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offer within the meaning of Article 6(1)(f) GDPR). Google uses cookies. The information generated by the cookie about the use of the online offer by the users is usually transmitted to a Google server in the USA and stored there.
Google is certified under the Privacy Shield agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online offer by the users, to compile reports on the activities within this online offer, and to provide us with other services related to the use of this online offer and the internet. Pseudonymous usage profiles of the users can be created from the processed data.
We use Google Analytics only with IP anonymization activated. This means that the IP address of the users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user's browser will not be merged with other data from Google. Users can prevent the storage of cookies by adjusting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offer to Google as well as the processing of this data by Google by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
Further information on data use by Google, settings, and opt-out options can be found in Google's privacy policy (https://policies.google.com/privacy) as well as in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
The personal data of the users will be deleted or anonymized after 14 months.
Google AdSense with Personalized Ads
We use the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google") based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offer within the meaning of Article 6(1)(f) GDPR).
Google is certified under the Privacy Shield agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
We use the AdSense service, which displays advertisements on our website and we receive remuneration for their display or other use. For these purposes, usage data such as the click on an advertisement and the IP address of the users are processed, with the IP address being shortened by the last two digits. Therefore, the data of the users are processed pseudonymously.
We use AdSense with personalized ads. Hereby, Google draws conclusions about the interests of users based on the websites or apps they visit and the user profiles created in this way. Advertisers use this information to tailor their campaigns to these interests, which benefits both users and advertisers alike. For Google, ads are personalized if recorded or known data determines or influences the ad selection. This includes, but is not limited to, previous search queries, activities, website visits, app usage, demographic and location information. In detail, this includes demographic targeting, targeting on interest categories, remarketing, and targeting on lists for customer match and audience lists uploaded in DoubleClick Bid Manager or Campaign Manager.
Further information on data use by Google, settings, and opt-out options can be found in Google's privacy policy (https://policies.google.com/technologies/ads) as well as in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
Facebook Pixel, Custom Audiences, and Facebook Conversion
Within our online offer, the so-called "Facebook Pixel" of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"), is used based on our legitimate interests in analysis, optimization, and economic operation of our online offer and for these purposes.
Facebook is certified under the Privacy Shield agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
With the help of the Facebook pixel, it is possible for Facebook to determine the visitors of our online offer as a target group for the display of advertisements (so-called "Facebook ads"). Accordingly, we use the Facebook pixel to display the Facebook ads we have placed only to those Facebook users who have also shown an interest in our online offer or who exhibit certain characteristics (e.g., interests in certain topics or products, which are determined based on the websites visited) that we transmit to Facebook (so-called "Custom Audiences"). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of the users and do not appear to be annoying. With the help of the Facebook pixel, we can also track the effectiveness of the Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called "conversion").
The processing of the data by Facebook takes place within the framework of Facebook's data usage policy. Accordingly, general information on the display of Facebook ads is provided in Facebook's data usage policy: https://www.facebook.com/policy. For specific information and details about the Facebook pixel and how it works, please visit the Facebook help section: https://www.facebook.com/business/help/651294705016616.
You can object to the collection by the Facebook pixel and the use of your data to display Facebook ads. To set which types of ads are shown to you within Facebook, you can go to the page set up by Facebook and follow the instructions on the settings for usage-based advertising: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, meaning they apply to all devices, such as desktop computers or mobile devices.
You can also object to the use of cookies for reach measurement and advertising purposes via the deactivation page of the Network Advertising Initiative (http://optout.networkadvertising.org/) and additionally the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).
Created with Datenschutz-generator.de by RA Dr. Thomas Schwenke
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