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”) 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: 19 August 2022

Responsible

OVALmedia Berlin GmbH

Zillestraße 11

10585 Berlin

Germany

Authorised representatives:

Managing Director Robert Cibis

E-mail address:

robert@oval.media

>> Imprint

Overview of the processing

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

Types of data processed

  • Inventory data.
  • Payment details.
  • Contact details.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta/communication data.

Categories of persons concerned

  • Customers.
  • Interested parties.
  • Communication partner.
  • Users.
  • Business and contractual partners.

Purposes of the processing

  • Provision of contractual services and customer service.
  • Contact requests and communication.
  • Safety measures.
  • Direct marketing.
  • Reach measurement.
  • Office and organisational procedures.
  • Conversion measurement.
  • Managing and responding to enquiries.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offer and user-friendliness.
  • Information technology infrastructure.

Relevant legal bases

Below you will find an overview of the legal basis of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. 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 sent. 1 lit. a) DSGVO) – The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
  • Contract 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 performance of pre-contractual measures taken at the data subject’s request.
  • Legal obligation (Art. 6 para. 1 p. 1 lit. c) DSGVO) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 (1) p. 1 lit. f) DSGVO) – Processing is necessary to protect the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

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, data protection laws of the individual federal states may apply.

Security measures

We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk 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.

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 segregation 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 already take the protection of personal data into account in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

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 observe the legal requirements and, in particular, conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.

Transfer of data within the organisation: We may transfer or provide access to personal data to other entities within our organisation. Where this transfer is for administrative purposes, the transfer of data is based on our legitimate corporate and business interests or is made where it is necessary for the performance of our contract-related obligations or where there is consent from the data subjects or legal permission.

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).

Data deletion

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose). If the data are not deleted because they are required for other and legally permissible purposes, their processing is 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.

As part of our privacy notices, we may provide users with further information on the deletion and retention of data specific to the processing operation.

Use of cookies

Cookies are small text files or other memory notes that store information on end devices and read information from the end devices. For example, to save the login status in a user account, the contents of a shopping basket in an e-shop, the contents called up or the functions used in an online offer. Cookies can also be used for various purposes, e.g. for the purpose of functionality, security and comfort of online offers as well as the creation of analyses of visitor flows.

Consent notices: We use cookies in accordance with the law. We therefore obtain prior consent from users, except where this is not required by law. In particular, consent is not required if the storage and reading of information, i.e. including cookies, is absolutely necessary in order to provide the user with a telemedia service (i.e. our online offer) expressly requested by the user. The revocable consent is clearly communicated to the users and contains the information on the respective cookie use.

Notes on legal bases under data protection law: The legal basis under data protection law on which we process users’ personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and improvement of its usability) or, if this is done in the context of the performance of our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. We explain the purposes for which we process the cookies in the course of this data protection declaration or as part of our consent and processing procedures.

Storage duration: With regard to the storage duration, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their end device (e.g. browser or mobile app).
  • Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used to measure reach. Unless we provide users with explicit information about the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that they can be stored for up to two years.

General information on revocation and objection (opt-out): Users can revoke the consents they have given at any time and also file an objection to processing in accordance with the legal requirements in Art. 21 DSGVO. Users can also declare their objection via their browser settings, e.g. by deactivating the use of cookies (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.

Further guidance on processing operations, procedures and services:

  • Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the consent of users to the use of cookies, or to 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.
  • Compliance: Cookie consent management; Service provider: Hosted locally on our server, no data transfer to third parties; Website: https://complianz.io/; Privacy policy: https://complianz.io/legal/; Further information: 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.

Business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer enquiries.

We process this data in order to fulfil our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. Furthermore, we process the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations as well as the company organisation. Furthermore, we process the data on the basis of our legitimate interests in proper and business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.

We inform the contractual partners of the data required for the above-mentioned purposes before or in the course of data collection, e.g. in online forms, by means of special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.

We delete the data after the expiry of statutory 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 retained for legal archiving reasons. The statutory retention period for documents relevant under tax law as well as for commercial books, inventories, opening balances, annual financial statements, the work instructions required to understand these documents and other organisational documents and accounting vouchers is ten years and for received commercial and business letters and reproductions of sent commercial and business letters six years. The period shall begin at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual accounts or the management report was drawn up, the commercial or business letter was received or sent or the accounting document was created, furthermore the recording was made or the other documents were created.

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

  • Types of data processed: 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 contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Customers; interested parties; business and contractual partners.
  • Purposes of processing: provision of contractual services and customer service; security measures; contact requests and communication; office and organisational procedures; managing and responding to requests; conversion measurement (measuring the effectiveness of marketing measures); profiles with user-related information (creating user profiles).
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legal obligation (Art. 6 para. 1 p. 1 lit. c) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Customer account: Contractual partners can create an account within our online offer (e.g. customer or user account, “customer account” for short). If registration of a customer account is required, contractual partners will be informed of this and 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 to prevent any misuse of the customer account.If customers have terminated their customer account, the data relating to the customer account will be deleted, subject to their retention being required for legal reasons. It is the responsibility of the customers to save their data when the customer account is terminated; legal basis: fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
  • Wishlist/ wish list: Customers may create a product/wish list. In this case, the products are stored as part of the fulfilment of our contractual obligations until the account is deleted, unless the product list entries are removed by the customer or we expressly inform the customer of different storage periods; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
  • Economic analyses and market research: For economic reasons and in order to be able to recognise market trends, wishes of contractual partners and users, we analyse the data we have on business transactions, contracts, enquiries, etc., whereby the group of persons concerned may include contractual partners, interested parties, customers, visitors and users of our online offer.The analyses are carried out for the purpose of economic evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we may, if available, take into account the profiles of registered users together with their details, e.g. on services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarised, i.e. anonymised values. Furthermore, we take the privacy of the users into consideration and process the data for the analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as summarised data); legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
  • 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 associated 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, 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 identified as such in the context of the order or comparable purchase process and includes the information required for delivery or provision and billing as well as contact information in order to be able to contact you; legal basis: contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Payment procedure

Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer efficient and secure payment options to data subjects and use other service providers in addition to banks and credit institutions for this purpose (collectively “payment service providers”).

The data processed by the payment service providers include inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, sum and recipient-related details. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e. we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the general terms and conditions and the data protection information of the payment service providers.

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

  • Types of data processed: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Customers; Interested parties.
  • Purposes of processing: provision of contractual services and customer service.
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Further guidance on processing operations, procedures and services:

  • PayPal: Payment services (technical connection of online payment methods) (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; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://www.paypal.com/de; Privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
  • Giropay: Payment services (technical connection of online payment methods); Service provider: giropay GmbH, An der Welle 4, 60322 Frankfurt, Germany; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://www.giropay.de; Privacy policy: https://www.giropay.de/rechtliches/datenschutzerklaerung/.
  • Coinbase Commerce: Coinbase Commere is a provider for the provision of crypto payments and their processing; Service provider: Provider:Coinbase Germany GmbH, Kurfürstendamm 12, 10719 Berlin ; Website: https://commerce.coinbase.com/; Privacy Policy: https://commerce.coinbase.com/legal/privacy-policy/.

Provision of the online offer and web hosting

We process users’ data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or terminal device.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses); content data (e.g. entries in online forms).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.).); security measures.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Provision of online offer on our own/ dedicated server hardware: For the provision of our online offer, we use server hardware operated by us as well as the associated storage space, computing capacity and software; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
  • Collection of access data and log files: Access to our online offer is logged in the form of 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 volume 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, for example, to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure server utilisation and stability; legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the final clarification of the respective incident.
  • 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 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; legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
  • 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, 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; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
  • OVHcloud: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacities); Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Order processing contract: https://www.ovh.de/schutz-personenbezogener-daten/; Service provider: OVH GmbH, St. Johanner Str. 41-43, 66111 Saarbrücken, Germany; Website: https://www.ovhcloud.com/de/; Privacy: https://www.ovh.de/schutz-personenbezogener-daten/.

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data are processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.

  • 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).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: provision of contractual services and customer service; feedback (e.g. collecting feedback via online form); provision of our online offer and user friendliness.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Contact and enquiry management

When contacting us (e.g. by contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed insofar as this is necessary to answer the contact enquiries and any requested measures.

The answering of contact enquiries as well as the administration of contact and enquiry data within the framework of contractual or pre-contractual relationships is carried out in order to fulfil our contractual obligations or to answer (pre)contractual enquiries and, moreover, on the basis of the legitimate interests in answering enquiries and maintaining user or business relationships.

  • Types of data processed: 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).
  • Affected persons: Communication partner.
  • Purposes of processing: contact requests and communication; managing and responding to requests; feedback (e.g. collecting feedback via online form); providing our online offer and user experience; providing contractual services and customer service.
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context for the purpose of processing the communicated request. For this purpose, we process personal data in the context of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfilment and otherwise on the basis of our legitimate interests as well as the interests of the communication partners in responding to the concerns and our statutory retention obligations; legal bases: fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Newsletter and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. Insofar as the contents of the newsletter are specifically described in the course of registration, they are decisive for the consent of the users. Otherwise, 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 a personal address in the newsletter, or further details if these are required for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter is always carried out in a so-called double opt-in process. This means that after registration you will receive an e-mail asking you 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 on the basis of our legitimate interests before deleting them in order to be able to prove consent formerly given. The processing of this data will be 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 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 is carried out on the basis of 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.

Contents:

Information about us, our services, promotions and offers.

  • 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).
  • Affected persons: Communication partner.
  • Purposes of processing: direct marketing (e.g. by e-mail or post); reach measurement (e.g. access statistics, recognition of returning visitors).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
  • Possibility of objection (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 given above, preferably e-mail, for this purpose.

Further guidance on processing operations, procedures and services:

  • 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 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 measurement of the opening rates and the click rates as well as the storage of the measurement results in the profiles of the users as well as their further processing are based on the consent of the users. Unfortunately, a separate revocation of the performance measurement is not possible; in this case, the entire newsletter subscription must be cancelled or revoked. In this case, the stored profile information will be deleted; legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
  • SendinBlue: Email marketing platform; Service provider: SendinBlue SAS, 55, rue d’Amsterdam, 75008 Paris, France; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://de.sendinblue.com/; Privacy policy: https://www.sendinblue.com/legal/privacypolicy/; Order processing agreement: Provided by the service provider.

Web analysis, 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 testing procedures, e.g. to test and optimise different versions of our online offer or its components.

Unless otherwise stated below, profiles, i.e. data summarised for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and read from it. The information collected includes, in particular, websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed.

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 purpose of the respective procedures.

  • Types of data processed: 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: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (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).

Further guidance on processing operations, procedures and services:

  • Matomo: Matomo is software that is used for the purposes of web analysis and reach measurement. Within the scope of the use of Matomo, cookies are generated and stored on the end device of the user. The user data collected in the course of using Matomo is only processed by us and is not shared with third parties. The cookies are stored for a maximum period of 13 months: https://matomo.org/faq/general/faq_146/; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Deletion of data: The cookies have a maximum storage period of 13 months.
  • WP Statistics: This is a WordPress plugin for analysis and statistics, DSGVO compatible. It anonymises IP addresses and does not store personal data, see here: https://wp-statistics.com/2018/08/16/wp-statistics-gdpr/; Service provider: Provider is Verona Labs, Tatari 64, 10134, Tallinn, Estonia; Website: https://veronalabs.com/.

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 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, 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. 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: 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).
  • Data subjects: Users (e.g. website visitors, users of online services); communication partners.
  • Purposes of processing: contact requests and communication; feedback (e.g. collecting feedback via online form); marketing; direct marketing (e.g. by email or post).
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
  • Facebook pages: Profiles within the Facebook social network – We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (known as a “Fan Page”). This data includes information about the types of content users view or interact with, or the actions they take (see under “Things You and Others Do and Provide” in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices users use (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under “Device Information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, called “Page Insights”, to Page operators to provide them with insights into how people interact with their Pages and with the content associated with them. We have entered into a special agreement with Facebook (“Page Insights Information”, https://www.facebook.com/legal/terms/page_controller_addendum), which in particular regulates which security measures Facebook must observe and in which Facebook has agreed to fulfil the data subject rights (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information on Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data); service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Further information: Shared responsibility agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data. Joint accountability is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of the data to the parent company Meta Platforms, Inc. in the US (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.)
  • LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Order processing agreement: https://legal.linkedin.com/dpa; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://legal.linkedin.com/dpa; Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • Twitter: social network; service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, parent company: Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Privacy policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
  • Telegram Broadcasts: Telegram Broadcasts – Messenger with end-to-end encryption; Service provider: Telegram, Dubai; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://telegram.org/; Privacy policy: https://telegram.org/privacy.
  • YouTube: Soziales Netzwerk und Videoplattform; Dienstanbieter: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland, Mutterunternehmen: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Rechtsgrundlagen: Berechtigte Interessen (Art. 6 Abs. 1 S. 1 lit. f) DSGVO); Datenschutzerklärung: https://policies.google.com/privacy; Widerspruchsmöglichkeit (Opt-Out): https://adssettings.google.com/authenticated.

Plugins and embedded functions and content

We integrate functional and content elements into our online offer 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 offering, as well as being linked to such information from other sources.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses); inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: provision of our online offer and user-friendliness; feedback (e.g. collecting feedback via online form).
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Google Fonts (obtained from the Google server): Obtaining fonts (and symbols) for the purpose of a technically secure, maintenance-free and efficient use of fonts and symbols with regard to up-to-dateness and loading times, their uniform presentation and consideration of possible restrictions under licensing law. The provider of the fonts is informed of the user’s IP address so that the fonts can be made available in the user’s browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) are transmitted which are necessary for the provision of the fonts depending on the devices used and the technical environment; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy.
  • Instagram-Plugins und -Content: Instagram plugins and content – This may include, for example, content such as images, videos or text and buttons that allow users to share content from this online offering within Instagram. – We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt in connection with a transmission (but not the further processing) of “Event Data” that Facebook collects or receives in connection with a transmission through Instagram features (e.g., content embedding features) running on our Online Offer for the purposes of: a) displaying content and promotional information that is relevant to users’ perceived interests; b) delivering commercial and transactional messages (e.g., targeting users via Facebook Messenger) to users of our Online Offer. (c) improving ad delivery and personalising features and content (e.g., improving the ability to identify which content or promotional information is likely to be of interest to users). We have entered into a specific agreement with Facebook (“Responsible Party Addendum”,https://www.facebook.com/legal/controller_addendum),which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to comply with data subjects’ rights (i.e. users can, for example, provide information or make deletion requests directly to Facebook). Note: When Facebook provides us with metrics, analytics and reports (which are aggregated, i.e. do not receive details of individual users and are anonymous to us), this processing is not carried out under shared responsibility, but on the basis of a commissioned processing agreement (“Data Processing Conditions “, https://www.facebook.com/legal/terms/dataprocessing) , der “Datensicherheitsbedingungen” (https://www.facebook.com/legal/terms/data_security_terms) sowie im Hinblick auf die Verarbeitung in den USA auf Grundlage von Standardvertragsklauseln (“Facebook-EU-Datenübermittlungszusatz, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Irland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO);Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
  • reCAPTCHA: We integrate the “reCAPTCHA” function to be able to recognise whether entries (e.g. in online forms) are made by humans and not by automatically acting machines (so-called “bots”). The data processed may include IP addresses, information on operating systems, devices or browsers used, language settings, location, mouse movements, keyboard strokes, time spent on websites, previously visited websites, interactions with ReCaptcha on other websites, possibly cookies as well as results of manual recognition processes (e.g. answering questions asked or selecting objects in images). The data processing is based on our legitimate interest to protect our online offer from abusive automated crawling and spam; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland, Mutterunternehmen: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.google.com/recaptcha/; Privacy policy: https://policies.google.com/privacy; Possibility of objection (Opt-Out): Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • Shariff: We use the privacy-safe “Shariff” buttons. “Shariff” was developed to enable more privacy on the net and to replace the usual “share” buttons of the social networks. In this process, it is not the user’s browser but the server on which this online offer is located that establishes a connection with the server of the respective social media platforms and queries, for example, the number of likes. The user remains anonymous. More information on the Shariff project can be found at the developers of the magazine c’t: https://www.heise.de/ct/artikel/Shariff-Social-Media-Buttons-mit-Datenschutz-2467514.html; Service provider: Heise Medien GmbH & Co. KG, Karl-Wiechert-Allee 10, 30625 Hannover, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.heise.de/ct/artikel/Shariff-Social-Media-Buttons-mit-Datenschutz-2467514.html; Privacy policy: https://www.heise.de/Datenschutzerklaerung-der-Heise-Medien-GmbH-Co-KG-4860.html.
  • YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Opt-out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • Peertube: We operate a Peertube instance. The aim of the instance is to make video files available to you in accordance with data protection regulations. We have activated the peer function by default for our posted videos. Therefore, through the P2P technique, data is stored on your computer or personal data is shared in the P2P network. A notice about this function is displayed on Peertube before the video is played. This data is not shared until the video is started. However, we do not make automated decisions in individual cases, including profiling.

Rights of the 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 Article 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 of revocation for consents: You have the right to revoke any consent you have 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 be informed about this data and to receive further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the law, you have the right 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 relating to you be erased immediately or, alternatively, to request restriction of the processing of the data in accordance with the law.
  • Right to data portability: You have the right to receive data relating to you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transferred to another controller.
  • Complaint to the supervisory authority: In accordance with the law and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you usually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.