Data protection

Data protection

Preamble to the privacy policy

First things first: advertising is not a business model for us. Our access model is a subscription.

We do not sell ad space and we do not trade customer data, especially not with data brokers. Because our offerings are ad-free, we do not monitor your usage patterns, except to optimise our own offerings and those of participating newspapers.

We want to protect private data and use public data.

Introduction

With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as “data” for short) that 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 as part of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).

The terms used are not gender-specific.

Status: 9 February 2021

Content overview

Person responsible

Jochen Adler
Kompreno GmbH
Schleusenstr. 15
60327 Frankfurt/Main

Authorised representatives: Jochen Adler.

E-mail address: office@kompreno.eu.

Imprint: http://kompreno.eu/impressum.

Overview of processing

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The overview below 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 data (e.g. e-mail, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Use data (e.g. websites visited, interest in content, access times).
  • Location data (information on the geographical position of a device or person).

Categories of data subjects

  • Interested parties.
  • Communication partners.
  • Users (e.g. website visitors, users of online services).

Purposes of processing

  • Providing our online service and user experience.
  • Conversion measurement (measuring the effectiveness of marketing activities).
  • Content Delivery Network (CDN).
  • Direct marketing (e.g. by email or post).
  • Interest-based and behavioural marketing.
  • Contact enquiries and communication.
  • Profiling (creating user profiles).
  • Remarketing.
  • Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures.
  • Tracking (e.g. interest/behaviour-related profiling, use of cookies).
  • Provision of contractual services and customer service.
  • Managing and responding to enquiries.

Relevant legal bases

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

  • Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO) – The data subject has given consent to the processing of personal data relating to him or her for a specific purpose or purposes
  • Contractual performance and pre-contractual enquiries (Art. 6(1) p. 1 lit. b. DSGVO) – Processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the data subject’s request.
  • Rightful interests (Art. 6(1) p. 1 lit. f. DSGVO) – Processing is necessary for the purposes of protecting the legitimate interests of the controller or of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, the processing for other purposes and the transmission and automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. Furthermore, Land data protection laws of the individual Länder may apply.

Security measures

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

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access to, entry into, disclosure of, assurance of availability of and separation of the data. We also have procedures in place to ensure the exercise of data subjects’ rights, the deletion of data and responses to data compromise. Furthermore, we take into account the protection of personal data already during the development or selection of hardware, software as well as procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

Shortening of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not necessary, the IP address is shortened (also referred to as “IP masking”). In this process, the last two digits or the last part of the IP address after a full stop are removed or replaced by wildcards. The shortening of the IP address is intended to prevent or make it considerably more difficult to identify a person by their IP address.

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

Transmission of personal data

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

Data processing in third countries

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

Subject to express consent or contractually or legally required transfer, we only process or allow data to be processed in third countries with a recognised level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence 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 websites or domains visited and are stored by a browser on the user’s computer. The primary purpose of a cookie is to store information about a user during or after their visit within an online service. Stored information may include, for example, language settings on a website, login status, a shopping cart or where a video was watched. We also include in the term cookies other technologies that perform the same functions as cookies (e.g. where user details are stored using pseudonymous online identifiers, also known as “user IDs”).

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
  • Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users used for range measurement or marketing purposes can 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 may, on the one hand, be absolutely necessary for the operation of a website (e.g. in order to store logins or other user input or for security reasons)
  • Statistics, marketing and personalisation cookies: Furthermore, cookies are usually also used in the context of range measurement and when a user’s interests or behaviour (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that matches their potential interests. This procedure is also referred to as “tracking”, i.e. tracking the potential interests of users. Insofar as we use cookies or “tracking” technologies, we will inform you separately in our data protection declaration or in the context of obtaining consent.

Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is your declared consent. Otherwise, the data processed with the help of cookies is 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.

Duration of storage: If we do not provide you with explicit information on the duration of storage of permanent cookies (e.g. in the context of a so-called cookie opt-in), please assume that the storage period 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 option at any time to revoke any consent you have 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 your browser settings, e.g. by deactivating the use of cookies (whereby this may also restrict the functionality of our online offer). 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 obtain further instructions on how to object in the context of the information on the service providers and cookies used.

Processing of cookie data on the basis of consent: We use a cookie consent management procedure, in the context of which the consent of users to the use of cookies, or the processing and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users. The declaration of consent is stored in order not to have to repeat the request and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) and the browser, system and end device used.

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

Services used and service providers:

    • BorlabsCookie: cookie consent management; service provider: Borlabs; website: https://de.borlabs.io/borlabs-cookie/; An individual user ID, language as well as types of consents and the time of their submission are stored on the server side and in the cookie on the users’ device.

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Provision of the online offer and web hosting

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

The data processed in the course of providing the hosting service may include all information relating to the users of our online service that is generated in the course 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 sending and hosting: The web hosting services we use also include the sending, receiving and storing of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding 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 recognising SPAM. 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 a so-called end-to-end encryption procedure 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). The server log files may include the address and name of the web pages and files accessed, the date and time of access, the amount of data 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 may be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks) and to ensure the utilisation of the servers and their stability.

Content Delivery Network: We use a “Content Delivery Network” (CDN). A CDN is a service with the help of which the content of an online offer, especially large media files such as graphics or programme scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet.

  • Types of data processed: 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).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Content Delivery Network (CDN).
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

Registration, login and user account

Users can create a user account. As part of the registration process, users are provided with the required mandatory data and processed for the purposes of providing the user account on the basis of contractual obligation fulfilment. The processed data includes in particular the login information (name, password and an e-mail address). The data entered during registration is used for the purposes of using the user account and its purpose.

Users may be informed by e-mail about processes relevant to their user account, such as technical changes.

As part of the use of our registration and login functions and the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorised use. As a matter of principle, this data is not passed on to third parties unless it is necessary for the prosecution of our claims or there is a legal obligation to do so.

Community functions

The community functions provided by us allow users to enter into conversations or other exchanges with each other. Please note that the use of the community functions is only permitted in compliance with the applicable legal situation, our terms and guidelines and the rights of other users and third parties.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
  • People concerned: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Providing contractual services and customer service, security measures, managing and responding to requests.
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Contractual performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Contacting us

When contacting us (e.g. via contact form, email, telephone or via social media), the information of the inquiring persons is processed insofar as this is necessary to answer the contact requests and any requested measures.

The response to contact requests in the context of contractual or pre-contractual relationships is made in order to fulfil our contractual obligations or to respond to (pre)contractual requests and otherwise on the basis of the legitimate interests in responding to the requests.

  • Types of data processed: 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).
  • People concerned: Communication partners.
  • Purposes of processing: Contact requests and communication.
  • Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Newsletters and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter “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, they are decisive for the consent of the users. In addition, our newsletters contain information about our services and us.

In order 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 a personal address in the newsletter, or further details, if these are necessary for the purposes of the newsletter.

Double opt-in procedure: The registration for our newsletter is always carried out in a so-called double opt-in procedure. This means that after registration you will receive an e-mail 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 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 with the dispatch service provider are also logged.

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

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Notes on legal bases: The newsletter is sent on the basis of the recipients’ consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and insofar as this is permitted by law, e.g. in the case of advertising to existing customers. Insofar as 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, promotions and offers.

Measurement of opening and click-through rates: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a dispatch 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, are initially collected.

This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help 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. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. The analyses help 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 measurement of opening rates and click rates as well as the storage of the measurement results in the users’ profiles and their further processing are based on the users’ consent.

Unfortunately, a separate revocation of the performance measurement is not possible; in this case, the entire newsletter subscription must be cancelled or revoked. In this case, the stored profile information will be deleted.

  • Types of data processed: 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).
  • People concerned: Communication partners.
  • Purposes of processing: Direct marketing (e.g. by e-mail or post).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
  • Opt-out: You can cancel receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the above contact options, preferably e-mail, for this purpose.

Web analytics, monitoring and optimisation

Web analytics (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the reach analysis, we can, for example, recognise at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimisation.

In addition to web analysis, we may also use test procedures, e.g. to test and optimise different versions of our online offer or its components.

For these purposes, so-called user profiles may be created and stored in a file (so-called “cookie”) or similar procedures may be used with the same purpose. This information may include, for example, content viewed, websites visited and elements used there and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed, depending on the provider.

The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimisation, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

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

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • People concerned: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behaviour-based profiling, use of cookies), conversion measurement (measurement of the effectiveness of marketing measures), profiling (creation of user profiles).
  • Security measures: IP masking (pseudonymisation of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

  • Google Analytics: Reach measurement 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.
  • 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 offer (reference is made to further details in this data protection declaration). The Tag Manager itself (which implements the tags) does not create user profiles or store cookies. Google only learns the user’s IP address, which is necessary to run the Google Tag Manager. 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.

Online marketing

We process personal data for online marketing purposes, which may include, in particular, marketing advertising space or displaying promotional and other content (collectively, “content”) based on users’ potential interests and measuring its effectiveness.

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

The IP addresses of users are also stored. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored within the scope 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 means of similar procedures. These cookies can generally also be read later on other websites that use the same online marketing procedure and analysed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.

Exceptionally, clear data can be assigned to the profiles. This is the case if, for example, the users are members of a social network whose online marketing procedure we use and the network links the users’ profiles with the aforementioned data. We ask you to note that users may enter into additional agreements with the providers, e.g. by giving their consent as part of the registration process.

In principle, we only receive access to summarised information about the success of our advertisements. However, within the framework 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 a 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 will be stored for a period of two years.

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

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • People 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, conversion measurement (measurement of the effectiveness of marketing measures), interest-based and behavioural marketing, profiling (creation of user profiles), reach measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures: IP masking (pseudonymisation of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
  • Opt-out: We refer to the data protection information of the respective providers and the opt-out options given for the providers. If no explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. 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 regions:a) Europe: https://www.youronlinechoices.eu.
    b) Canada: https://www.youradchoices.ca/choices.
    c) USA: https://www.aboutads.info/choices.
    d) Cross-territory: https://optout.aboutads.info.

Services used and service providers:.

Presence on social networks (social media)

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

We would like to point out that user data may be processed outside the European Union. This may result in risks for the users because, for example, it could make it more difficult to enforce the rights of the users.

Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behaviour and resulting interests of the users. The usage 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 the interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (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 options to object (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

  • Types of data processed: 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)
  • People 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.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

Plugins and embedded functions as well as content

We incorporate into 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 city maps (hereinafter uniformly referred to as “content”).

The integration always requires that the third-party providers of this content process the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is thus required for the display of this content or function. We endeavour to only use content whose respective providers only use the IP address 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 analyse 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, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer as well as be linked to such information from other sources.

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

  • Types of data processed: Usage data (e.g. web pages 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 a person).
  • People concerned: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user experience, provision of contractual services and customer service.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

  • Google Fonts: We integrate the fonts (“Google Fonts”) of the provider Google, whereby the users’ data is used solely for the purpose of displaying the fonts in the users’ browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform display and taking into account possible licensing restrictions for their integration. 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://fonts.google.com/; privacy policy: https://policies.google.com/privacy.
  • Google Maps: We integrate the maps of the “Google Maps” service of the provider Google. The data processed may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually executed within the framework of the settings of their mobile devices); 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://cloud.google.com/maps-platform; Privacy policy: https://policies.google.com/privacy; Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de; Ad display settings: https://adssettings.google.com/authenticated.

Deletion of data

The data we process will be deleted in accordance with the law as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose for processing this data has ceased to apply or it is not necessary for the purpose).

If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. I.e. 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 whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of 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 notices of this privacy policy.

Modifying and updating the Privacy Notice

We encourage you to periodically review the content of our Privacy Policy. We adapt the privacy statement as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organisations in this data protection declaration, please note that the addresses may change over time and please check the information before contacting us.

Rechte der betroffenen Personen

Ihnen stehen als Betroffene nach der DSGVO verschiedene Rechte zu, die sich insbesondere aus Art. 15 bis 21 DSGVO ergeben:

Rights of data subjects

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

      • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(e) or (f) DSGVO; 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; this also applies to profiling insofar as it is related to such direct marketing.
      • Right to withdraw consent: You have the right to withdraw consent given at any time.
      • Right of access: You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
      • Right to rectification: You have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be rectified.
      • Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data concerning you be erased without delay, or alternatively, in accordance with the law, to request restriction of the processing of the data.
      • Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements, or to demand that it be transferred to another person responsible.
      • Complaint to 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 of your habitual residence, your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Definitions of terms

This section provides you with an overview of the terms used in this privacy notice. Many of the terms are taken from the law and defined primarily in Art. 4 GDPR. 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.

    • Content Delivery Network (CDN): A “Content Delivery Network” (CDN) is a service with the help of which the content of an online offer, in particular large media files such as graphics or programme scripts, can be delivered more quickly and securely with the help of regionally distributed servers connected via the Internet.
    • IP masking: “IP masking” is a method in which the last octet, i.e., the last two numbers of an IP address, is deleted so that the IP address can no longer serve to uniquely identify a person. Therefore, IP masking is a means of pseudonymising processing procedures, especially in online marketing
    • Interest-based and behavioural marketing: We speak of interest-based and/or behavioural marketing when potential interests of users in advertisements and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behaviour (e.g. visiting certain websites and staying on them, buying behaviour or interaction with other users), which is stored in a so-called profile. Cookies are usually used for these purposes.
    • Conversion measurement: Conversion measurement (also known as “visit action evaluation”) is a procedure with which the effectiveness of marketing measures can be determined. 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 allows us to track whether the ads we have placed on other websites have been successful.
    • Personal data: “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, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or an IP address. (e.g. cookie) or to one or more particular characteristics that are an expression of that natural person’s physical, physiological, genetic, mental, economic, cultural or social identity.
    • Profiling: “Profiling” is any form of automated processing of personal data which consists of using such personal data to analyse, evaluate or, depending on the type of profiling, to predict certain personal aspects relating to a natural person (e.g. age, gender, location data 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.
    • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behaviour or interests of visitors in certain information, such as the content of web pages. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
    • Remarketing: We speak of “remarketing” or “retargeting” when, for example, for advertising purposes, it is noted which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
    • Location data: Location data is created when a mobile device (or another device with the technical requirements of location determination) connects to a radio cell, a WLAN or similar technical means and functions of location determination. Location data is used to indicate the geographically determinable position on 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: We speak of “tracking” when the behaviour of users can be traced across several online offers. As a rule, behavioural and interest information is stored in cookies or on servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can subsequently be used, for example, to display advertisements to users that are likely to correspond to their interests.
    • Controller: A “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
    • Processing: “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data, be it collection, analysis, storage, transmission or erasure.