Almut von Wildheim

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Data protection

Privacy policy

Introduction

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

The terms used are not gender-specific.

Status: 02.01.2024

 

Table of contents

Responsible

Ulrich Huber / CLUSTA.Lamps GmbH
6020 Innsbruck
Austria

Authorized representatives: Ulrich Huber managing director/ owner

e-mail address: almut@vonwildheim.com

Legal notice: https://almutvonwildheim.com/impressum/

Contact data protection officer

Ulrich Huber / CLUSTA.Lamps GmbH
Schöpfstr. 19a, 6020
Innsbruck, Austria
office@vonwildheim.com

Overview of the processing operations

The following table summarises the types of data processed and the purposes of their processing, and refers to the data subjects.

 

Types of data processed

  • inventory data (e.g. names, addresses).
  • Content data (e.g. entries in online forms).
  • Contact details (e.g. e-mail, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Location data (information on the geographical position of a device or person).
  • Contract data (e.g. object of contract, duration, customer category).
  • Payment data (e.g. bank details, invoices, payment history).

Categories of data subjects

  • Business and contractual partners.
  • Interested parties.
  • Communication partner.
  • customers.
  • Users (e.g. website visitors, users of online services).

Purpose of processing

  • Assessment of creditworthiness and solvency.
  • Provision of our online offer and user-friendliness.
  • Visit action evaluation.
  • Office and organisational procedures.
  • Cross-device tracking (cross-device processing of user data for marketing purposes).
  • Direct marketing (e.g. by e-mail or by post).
  • Interest based and behavioral marketing.
  • Contact requests and communication.
  • Conversion measurement (measuring the effectiveness of marketing measures).
  • Profiling (creation of user profiles).
  • Remarketing.
  • Range measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures.
  • Tracking (e.g. interest/behavioural profiling, use of cookies).
  • Provision of contractual services and customer service.
  • Management and response to requests.
  • Target group formation (determination of target groups relevant for marketing purposes or other output of content).

Relevant legal bases

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

  • Consent (Art. 6 para. 1 sentence 1 letter a. FADP) - The data subject has given his or her consent to the processing of personal data relating to him or her for one or more specific purposes.
  • Fulfilment of a contract and pre-contractual requests (Art. 6 para. 1 sentence 1 lit. b. FADP) - The processing is necessary for the performance of a contract to which the data subject is party or for carrying out pre-contractual measures taken at the request of the data subject.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c. FADP) - The processing is necessary to fulfil a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. FADP) - The processing is necessary to protect the legitimate interests of the controller or of a third party unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data outweigh the processing.

Security measures

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

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

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

Transmission and disclosure of personal data

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

Data processing in third countries

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

Subject to express consent or transmission required by contract or by law, we process or allow the data to be processed only in third countries with a recognised level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the case of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

Use of cookies

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

The following cookie types and functions are distinguished:

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

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

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

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

Processing of cookie data based on consent: Before we process or have processed data in the context of the use of cookies, we ask users for their consent, which can be revoked at any time. Before consent has not been given, cookies are used if necessary, which are absolutely necessary for the operation of our online service.

Cookie settings/confirmation option:

Cookies

Cookies are small files that enable this website to store specific user-related information on the visitor's computer while they are visiting our website. Cookies help us to determine the frequency of use and the number of users of our website, as well as to make our services convenient and efficient for you. On the one hand, we use session cookies, which are only temporarily stored for the duration of your use of our website, and on the other hand, permanent cookies to record information about visitors who repeatedly access our website. The purpose of using these cookies is to offer an optimal user guidance as well as to recognize visitors and to be able to present an attractive website and interesting content in case of repeated use. The content of a permanent cookie is limited to an identification number. Name, IP address etc. are not stored. An individual profile of your usage behaviour is not created. A use of our offers is also possible without cookies. You can deactivate the storage of cookies in your browser, restrict it to certain websites or set your web browser (Chrome, IE, Firefox, ...) to notify you as soon as a cookie is sent. You can also delete cookies from your PC hard drive at any time. Please note, however, that in this case you must reckon with a restricted display of the page and with a restricted user guidance.

Privacy policy for the use of Google Analytics

This website uses Google Analytics, a web analysis service of Google Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. However, in the event that IP anonymisation is activated on this website, your IP address will be shortened by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area before this happens. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on the website activities and to provide further services to the website operator in connection with the use of the website and the Internet. The IP address transmitted by your browser within the framework of Google Analytics is not combined with other data from Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of the data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link(https://tools.google.com/dlpage/gaoptout?hl=de)

For more information on terms of use and data protection, please visit https://www.google.com/analytics/terms/de.html or https://support.google.com/analytics/answer/6004245?hl=de. We would like to point out that on this website Google Analytics has been extended by the code "gat._anonymizeIp();" in order to guarantee an anonymized collection of IP addresses (so-called IP-Masking).

 

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

Commercial and business services

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

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

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

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

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

customer account: Contractual partners can create an account within our online offer (e.g. customer or user account, short "customer account"). If the registration of a customer account is required, contractual partners are informed of this as well as of the information required for registration. The customer accounts are not public and cannot be indexed by search engines. Within the scope of registration and subsequent logins and use of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove the registration and prevent possible misuse of the customer account.

If customers have cancelled their customer account, the data relating to the customer account will be deleted, subject to the retention of such data for legal reasons. It is the responsibility of customers to back up their data when the customer account is cancelled.

Economic analyses and market research: For economic reasons and in order to be able to identify market trends, wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., whereby contractual partners, interested parties, customers, visitors and users of our online offer may fall into the group of persons concerned.

The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). If available, we can take into account the profiles of registered users and their details, e.g. the services they use. The analyses serve solely to serve us 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 feasible, anonymously (e.g. as summarized data).

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 execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, in order to carry out the delivery or execution for our customers. For the processing of payment transactions we use the services of banks and payment service providers. The required information is marked as such within the scope of the order or comparable acquisition process and includes the information required for delivery, or provision and invoicing, as well as contact information in order to be able to make any necessary arrangements.

  • Processed data types: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Interested parties, business and contractual partners, customers.
  • Purposes of the processing: provision of contractual services and customer service, contact requests and communication, office and organisational procedures, management and response to requests, security measures, visit action analysis, interest based and behavioural marketing, profiling (creation of user profiles).
  • Legal bases: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), Legal obligation (Art. 6 para. 1 sentence 1 lit. c. DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO)

Payment service provider

Within the scope of contractual and other legal relationships, due to legal obligations or otherwise based on our legitimate interests, we offer the persons concerned efficient and secure payment options and use other payment service providers in addition to banks and credit institutions (collectively "payment service providers").

The data processed by the payment service providers include inventory data, such as name and address, bank data, such as account or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient related information. These details are required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored by them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the payment service providers may transfer the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard we refer to the General Terms and Conditions and the data protection information of the payment service providers.

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

  • Processed data types: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Customers, interested parties.
  • Purpose of the processing: provision of contractual services and customer service.
  • Legal bases: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO)

Used services and service providers:

  • PayPal: payment services and solutions (e.g. PayPal, PayPal Plus, Braintree); service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; website: https://www.paypal.com/de; privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
  • Stripe: https://stripe.com/at/guides/general-data-protection-regulation
  • Amazon Pay: https://pay.amazon.de/help/82974

Provision of the online offer and web hosting

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

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

E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as other information concerning the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of SPAM detection. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but (unless an end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.

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

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

  • Processed data types: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Contact

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

The answering of contact enquiries within the framework of contractual or pre-contractual relations is made in order to fulfil our contractual obligations or to answer (pre)contractual enquiries and otherwise on the basis of the legitimate interest in answering the enquiries.

  • Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Communication partners, interested parties.
  • Purposes of processing: contact requests and communication, management and reply to requests.
  • Legal bases: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO)

Used services and service providers:

  • SevDesk: Management of invoices and customers
    https://sevdesk.at/lp-buchhaltungssoftware/?utm_medium=cpc&utm_campaign=AT_Generic_Buchhaltung&utm_source=adwords&utm_content=Buchhaltungssoftware&utm_term=buchhaltung%20software%20online&gclid=EAIaIQobChMI_5PX0qfr7AIVRPgYCh2M-QACEAAYASAAEgJKhPD_BwE

Newsletter and electronic notifications

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

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

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

Deletion and restriction of processing: We may store the deleted e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that we have previously given our consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time. In case of obligations to permanently observe contradictions, we reserve the right to store the e-mail address in a blacklist for this purpose alone.

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

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

Contents: Information about us, our services, actions and offers.

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

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

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

A separate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled or must be contradicted.

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

Used services and service providers:

online marketing

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

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

The IP addresses of users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect the users. In general, no clear user data (such as e-mail addresses or names) are stored in the context of the online marketing process, but pseudonyms. This means that we as well as the providers of the online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in the cookies or by similar methods. These cookies can later generally also be read out on other websites that use the same online marketing procedure, analysed for the purpose of presenting content and supplemented with additional data and stored on the server of the online marketing procedure provider.

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

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

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

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

Facebook pixel: With the help of the Facebook pixel, Facebook is on the one hand able to determine the visitors of our online offer as a target group for the presentation of ads (so-called "Facebook ads"). Accordingly, we use the Facebook pixel in order to display the Facebook ads placed by us only to those users on Facebook and within the services of partners cooperating with Facebook (so-called "Audience Network " https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offering or who exhibit certain characteristics (e.g. interest in certain topics or products that can be seen from 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 are not annoying. The Facebook Pixel also enables us to track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook ad (so-called "conversion measurement").

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographical position of a device or person).
  • Persons concerned: Users (e.g. website visitors, users of online services), interested parties.
  • Purposes of processing: Tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, visitor action evaluation, interest-based and behaviour-based marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors), target group formation (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
  • Possibility of objection (Opt-Out): We refer to the data protection information of the respective providers and the possibilities of objection (so-called "Opt-Out") indicated for the providers. If no explicit opt-out option has been specified, it is possible to deactivate cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary form for the respective areas:a) Europe: https://www.youronlinechoices.eu.
    (b) Canada: https://www.youradchoices.ca/choices.
    (c) USA: https://www.aboutads.info/choices.
    (d) Cross-territorial: https://optout.aboutads.info.

Used services and service providers:

  • 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 offering. The Tag Manager itself (which implements the tags) does not process any personal data of the users. With regard to the processing of users' personal data, please refer to the following information on Google's services. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy.
  • Google Analytics: online marketing and web analytics; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Opt-Out: Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Advertising Display Settings: https://adssettings.google.com/authenticated.
  • Google Ads and conversion measurement: We use the online marketing process "Google Ads" to place ads in the Google advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. We also measure the conversion of the ads. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page with a so-called "conversion tracking tag". We do not receive any information that can be used to identify users. Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy.
  • Google Ad Manager: We use the "Google Marketing Platform" (and services such as "Google Ad Manager") to place ads on the Google advertising network (e.g., in search results, in videos, on web pages, etc.). The Google Marketing Platform is characterised by the fact that ads are displayed in real time based on the presumed interests of users. This allows us to better target ads for and within our online offering to show users only ads that potentially match their interests. For example, if a user is shown ads for products that he or she has been interested in on other websites, this is called "remarketing". Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy.
  • Facebook pixels: Service provider: https://www.facebook.com, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; website: https://www.facebook.com; privacy policy: https://www.facebook.com/about/privacy; opt-out: https://www.facebook.com/settings?tab=ads.

Presence 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 point out that user data may be processed outside the European Union. This may result in risks for the users, because the enforcement of the users' rights could be made more difficult.

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

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

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

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

Used services and service providers:

 

Plugins and embedded functions and content

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

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

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

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographical position of a device or person), content data (e.g. entries in online forms), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
  • Persons concerned: Users (e.g. website visitors, users of online services), communication partners.
  • Purposes of processing: Provision of our online offer and user-friendliness, provision of contractual services and customer service, contact enquiries and communication, tracking (e.g. interest/behavioural profiling, use of cookies), interest-based and behavioural marketing, profiling (creation of user profiles), security measures, administration and answering of enquiries.
  • Legal bases: Leg itimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO), consent (Art. 6 para. 1 sentence 1 lit. a. DSGVO), performance of the contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO).

Used services and service providers:

deletion of data

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

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

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

Amendment and update of the privacy policy

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

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.

Rights of data subjects

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

  • Right of objection: You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data relating to you which is carried out pursuant to Art. 6 (1) (e) or (f) DPA; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing, including profiling, insofar as it is linked to such direct marketing.
  • Right of revocation for consents: You have the right to revoke consents at any time.
  • Right of access: You have the right to obtain confirmation as to whether or not data in question are being processed and to obtain information on such data, as well as further information and a copy of the data in accordance with legal requirements.
  • Right of rectification: You have the right to ask for the completion of the data concerning you or the rectification of incorrect data concerning you, in accordance with the law.
  • Right to erasure and restriction of processing: You have the right to request that data concerning you be erased immediately in accordance with the law or, alternatively, to request restriction of processing of the data in accordance with the law.
  • Right to data transferability: You have the right to receive data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with the law, or to request that it be transferred to another responsible party.
  • Complaints to the supervisory authority: You also have the right, in accordance with the law, to lodge a complaint with a supervisory authority, in particular in the Member State in which you are habitually resident, your place of work or the place where the alleged infringement is committed, if you consider that the processing of personal data relating to you is in breach of the DPA.

Definitions of terms

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

  • Conversion tracking: Conversion tracking is a method of determining the effectiveness of marketing activities. For this purpose, a cookie is usually stored on the user's devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, we can use this to track whether the ads we have placed on other websites have been successful).
  • Credit information: Automated decisions are based on automatic data processing without human intervention (e.g. in the case of an automatic rejection of a purchase on account, an online credit application or an online application procedure without any human intervention. According to Art. 22 DPA, such automated decisions are only permissible if data subjects give their consent, if they are necessary for the performance of a contract or if national laws permit such decisions.
  • Cross-Device Tracking: Cross-Device Tracking is a form of tracking in which behavioral and interest information of the users is recorded across devices in so-called profiles by assigning the users an online identifier. This allows the user information to be analyzed for marketing purposes, regardless of the browser or device used (e.g. mobile phones or desktop computers). With most providers, the online identification is not linked to clear data, such as names, postal or e-mail addresses.
  • IP-Masking: IP-Masking is a method in which the last octet, i.e. the last two numbers of an IP address, are deleted so that the IP address can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymising processing methods, especially in online marketing
  • Interest-based and behavioral marketing: We speak of interest-based and/or behavioral marketing when the potential interests of users in ads and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behaviour (e.g. visiting and staying on certain websites, buying behaviour or interaction with other users), which is stored in a so-called profile. As a rule, cookies are used for these purposes.
  • Conversion measurement: Conversion measurement is a method to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users' devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this enables us to track whether the ads we have placed on other websites have been successful.
  • Personal data: 'personal data' shall mean any information relating to an identified or identifiable natural person (hereinafter referred to as 'data subject'); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, a location data, an online identifier (e.g. a cookie) or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
  • Profiling: 'profiling' is any automated processing of personal data which consists of using personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information on age, gender, location and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people) (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.
  • Reachmeasurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behaviour or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, identify at what time visitors visit their website and what content they are interested in. This enables them to better adapt the contents of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for the purpose of range analysis in order to recognise returning visitors and thus obtain more precise analyses of the use of an online offering.
  • Remarketing: We speak of "remarketing" or "retargeting" when, for example, it is noted for advertising purposes which products a user has been interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Location data: Location data is generated when a mobile device (or another device with the technical requirements for a location determination) connects to a radio cell, a WLAN or similar technical means and functions of location determination. Location data serve to indicate the geographically determinable position of the earth at which the respective device is located. Location data can be used, for example, to display map functions or other information dependent on a location.
  • Tracking: One speaks of "tracking" when the behaviour of users can be traced across several online offers. As a rule, behavioral and interest information regarding the online offers used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
  • Controller: 'Controller' shall mean the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data
  • Processing: 'processing' means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers practically all handling of data, whether it be collection, analysis, storage, transmission or deletion.
  • Target group formation: One speaks of target group formation (or "custom audiences") when target groups are determined for advertising purposes, e.g. insertion of advertisements. For example, based on a user's interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online shop where he/she viewed the products. Lookalike Audiences" (or similar target groups) are, in turn, when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used to create custom audiences and lookalike audiences.
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