Privacy policy
Introduction
With the following data protection declaration, we would like to inform you about which of your personal data (also referred to as “data”) we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us both in the context of 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.
Table of contents
- Introduction
- Responsible
- Overview of processing
- Relevant legal bases
- Security measures
- Transmission of personal data
- Data processing in third countries
- Deletion of data
- use of cookies
- Provision of the online offer and web hosting
- Blogs and publication media
- Contact and inquiry management
- Newsletter and electronic notifications
- Web analysis, monitoring and optimization
- Presence in social networks (social media)
- Plugins and embedded functions and content
- Modification and updating of the privacy policy
- Rights of the data subjects
- Definitions
Responsible
Hanseatic Logistic Solutions Deutschland GmbH
Hanseatenhof 6
D-28195 Bremen
Authorized representatives:
Marcus Schwarz
E-mail address: bremen@hlsgermany.com
Telefon: +49 421 478807-0
Impressum: https://hlsgermany.com/impressum/
Overview of 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.
- Location Data.
- Contact information.
- Content data.
- Usage Data.
- Meta/Communication Data.
Categories of persons concerned
- Communication partner.
- Users.
Purposes of the processing
- Provision of contractual services and customer service.
- Contact requests and communication.
- Security Measures.
- Direct Marketing.
- Reach Measurement.
- Tracking.
- Managing and responding to requests.
- Firewall.
- 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 (Article 6(1)(1)(a) GDPR) – The data subject has given his or her consent to the processing of personal data relating to him or her for a specific purpose or purposes.
- Contract performance and pre-contractual requests (Art. 6(1)(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.
- Legitimate interests (Article 6(1)(1)(f) DSGVO) – Processing is necessary for the purposes of the legitimate interests of the controller or 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.
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 as well as automated decision-making in individual cases including profiling. Furthermore, it regulates data processing for employment purposes (Section 26 BDSG), in particular with regard to the establishment, performance or termination of employment relationships as well as the consent of employees. Furthermore, state 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 law, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the different probabilities of occurrence and the level of risk to the rights and freedoms of natural persons.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, transfer, safeguarding of availability 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 already take the protection of personal data into account during 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.
IP address shortening: 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 called “IP masking”). In this case, the last two digits or the last part of the IP address after a period 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.
TLS encryption (https): To protect your data transmitted via our online offer, we use TLS 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, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.
Transfer of data within the organization: We may transfer or provide access to personal data to other entities within our organization. Where this transfer is for administrative purposes, the transfer of the data is based on our legitimate business and operational interests or is made where it is necessary for the performance of our contractual obligations or where there is consent from the data subjects or legal permission.
Data processing in third countries
Sofern wir Daten in einem Drittland (d.h., außerhalb der Europäischen Union (EU), des Europäischen Wirtschaftsraums (EWR)) verarbeiten oder die Verarbeitung im Rahmen der Inanspruchnahme von Diensten Dritter oder der Offenlegung bzw. Übermittlung von Daten an andere Personen, Stellen oder Unternehmen stattfindet, erfolgt dies nur im Einklang mit den gesetzlichen Vorgaben.
Vorbehaltlich ausdrücklicher Einwilligung oder vertraglich oder gesetzlich erforderlicher Übermittlung verarbeiten oder lassen wir die Daten nur in Drittländern mit einem anerkannten Datenschutzniveau, vertraglichen Verpflichtung durch sogenannte Standardschutzklauseln der EU-Kommission, beim Vorliegen von Zertifizierungen oder verbindlicher internen Datenschutzvorschriften verarbeiten (Art. 44 bis 49 DSGVO, Informationsseite der EU-Kommission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).
Löschung von Daten
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 will be limited to these purposes. That is, 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.
Our privacy notices may also contain further information on the retention and deletion of data, which will take precedence for the processing operations in question.
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 store the login status in a user account, a shopping cart content in an e-shop, the content accessed or functions used of 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, including cookies, is absolutely necessary 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 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 using cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in 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 fulfill our contractual obligations. We explain the purposes for which we process the cookies in the course of this privacy policy or as part of our consent and processing procedures.
Storage duration: In terms of 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 his end device (e.g. browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the terminal device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and 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 under which users’ consent 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. In this context, the declaration of consent is stored in order not to have to request it again 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 cookie management service providers, the following information applies: Consent may be stored for up to two years. A pseudonymous user ID is created and stored with the time of consent, information about 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 sharing with third parties; Website: https://complianz.io/; Privacy Policy: https://complianz.io/legal/; Other Information: An individual user ID, language, and types of consents and the time they were given are stored on the server side and in the cookie on the users’ device.
Provision of the online services 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; provision of contractual services and customer service; firewall.
Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
More information about processing, procedures and services:
- Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called “web hoster”); Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
- 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, on the one hand, for security purposes, e.g., to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their 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 period of 30 days and then deleted or anonymized. Data whose further storage is required for evidentiary purposes is exempt from deletion until 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 identifying 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 method is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server; 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 program scripts, can be delivered faster and more 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).
- 1&1 IONOS: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.ionos.de; Privacy policy: https://www.ionos.de/terms-gtc/terms-privacy; Order processing agreement: https://www.ionos.de/hilfe/datenschutz/allgemeine-informationen-zur-datenschutz-grundverordnung-dsgvo/auftragsverarbeitung/.
- WordPress.com: Hosting and software for the creation, provision and operation of websites, blogs and other online offerings; Service provider: Aut O’Mattic A8C Ireland Ltd, Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://wordpress.com; Privacy policy: https://automattic.com/de/privacy/; Order processing agreement: https://wordpress.com/support/data-processing-agreements/.
- Wordfence: Firewall and security and error detection functions; Service provider: Defiant, Inc, 800 5th Ave Ste 4100, Seattle, WA 98104, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.wordfence.com; Privacy policy: https://www.wordfence.com/privacy-policy/; Standard contractual clauses (ensuring level of data protection in case of processing in third countries): https://www.wordfence.com/standard-contractual-clauses/.
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data is 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; security measures.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further information on processing, procedures and services:
- Akismet Anti-Spam Check: Akismet Anti-Spam Check – We use the service “Akismet” based on our legitimate interests. With the help of Akismet, comments from real people are distinguished from spam comments. For this purpose, all comment details are sent to a server in the USA, where they are analysed and stored for four days for comparison purposes. If a comment has been classified as spam, the data is stored beyond this time. This information includes the name entered, the e-mail address, the IP address, the comment content, the referrer, information on the browser used as well as the computer system and the time of the entry. Users are welcome to use pseudonyms or to refrain from entering their name or email address. You can completely prevent the transmission of data by not using our commenting system. That would be a shame, but unfortunately we don’t see any alternatives that work as effectively; Service Provider: Aut O’Mattic A8C Ireland Ltd, Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://automattic.com; Privacy policy: https://automattic.com/privacy.
- Profile pictures from Gravatar: Profile pictures – We use the service Gravatar within our online offer and especially in the blog. Gravatar is a service where users can register and store profile pictures and their email addresses. If users leave posts or comments on other online presences (especially blogs) with the respective email address, their profile pictures can be displayed next to the posts or comments. For this purpose, the email address provided by users is transmitted to Gravatar in encrypted form for the purpose of checking whether a profile is stored for it. This is the sole purpose of transmitting the email address. It is not used for any other purpose, but is deleted afterwards. The use of Gravatar is based on our legitimate interests, as we use Gravatar to offer post and comment authors the opportunity to personalize their posts with a profile picture. By displaying the images, Gravatar obtains the IP address of users, as this is necessary for a communication between a browser and an online service. If users do not want a user image associated with their email address on Gravatar to appear in the comments, they should use an email address that is not on file with Gravatar to comment. We also note that it is also possible to use an anonymous email address or no email address at all if users do not want their email address to be sent to Gravatar. Users can completely prevent the transmission of data by not using our commenting system; service provider: Aut O’Mattic A8C Ireland Ltd, Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://automattic.com; Privacy policy: https://automattic.com/privacy.
- UpdraftPlus: backup software and backup storage; Service provider: Simba Hosting Ltd, 11, Barringer Way, St. Neots, Cambs., PE19 1LW, GB; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://updraftplus.com/; Privacy policy: https://updraftplus.com/data-protection-and-privacy-centre/.
Contact and inquiry management
When contacting us (e.g. by contact form, e-mail, telephone or via social media) as well as in the context of the existing user and business relationships, the information of the inquiring individuals is processed to the extent necessary to respond to the contact requests and any requested measures.
- 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 partners.
- Purposes of processing: contact requests and communication; managing and responding to requests; feedback (e.g. collecting feedback via online form); providing our online service and user experience.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) 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; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) DSGVO), Legitimate Interests (Art. 6 para. 1 sentence 1 lit. f) DSGVO).
Newsletters 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 context of a registration, they are decisive for the consent of the users. Apart from that, 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 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 e-mail addresses. The registrations to the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise, any changes to your data stored with the dispatch service provider are logged.
Deletion and restriction of processing: We may store unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that consent was previously given. Processing of this data will be limited to the purpose of possible defence of 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. 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 dispatch system.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 context of a registration, they are decisive for the consent of the users. Apart from that, 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 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 e-mail addresses. The registrations to the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise, any changes to your data stored with the dispatch service provider are logged.Deletion and restriction of processing: We may store unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that consent was previously given. Processing of this data will be limited to the purpose of possible defence of 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. 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 dispatch 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).
- Betroffene Personen: Kommunikationspartner; Nutzer (z.B. Webseitenbesucher, Nutzer von Onlinediensten).
- Zwecke der Verarbeitung: Direktmarketing (z.B. per E-Mail oder postalisch); Erbringung vertraglicher Leistungen und Kundenservice.
- Rechtsgrundlagen: Einwilligung (Art. 6 Abs. 1 S. 1 lit. a) DSGVO).
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 shipping 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 whether you have clicked on certain links ; legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
- Prerequisite for the use of free services: Consent to receive mailings may be conditioned as a requirement to receive free services (e.g., access to certain content or participation in certain promotions). If users wish to take advantage of the free service without subscribing to the newsletter, please contact us.
Web analysis, monitoring and optimization
Web analytics (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify 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 require optimization.
In addition to web analysis, we may also use testing procedures, e.g. to test and optimize different versions of our online offer or its components.
Unless otherwise stated below, profiles, i.e. data summarized 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., pseudonymization by shortening the IP address) to protect users. In general, in the context of web analysis, A/B testing and optimization, no clear data of the users (such as e-mail addresses or names) are stored, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.
- 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).
- Betroffene Personen: Nutzer (z.B. Webseitenbesucher, Nutzer von Onlinediensten).
- Zwecke der Verarbeitung: Reichweitenmessung (z.B. Zugriffsstatistiken, Erkennung wiederkehrender Besucher); Profile mit nutzerbezogenen Informationen (Erstellen von Nutzerprofilen); Tracking (z.B. interessens-/verhaltensbezogenes Profiling, Nutzung von Cookies); Bereitstellung unseres Onlineangebotes und Nutzerfreundlichkeit.
- Sicherheitsmaßnahmen: IP-Masking (Pseudonymisierung der IP-Adresse).
Further guidance on processing operations, procedures and services:
- Google Optimize: Use of Google Analytics data for the purpose of improving areas of our online offering and better aligning our marketing efforts with potential user interests; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://optimize.google.com; Privacy policy: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms; Standard contractual clauses (ensuring level of data protection in case of processing in third countries): https://business.safety.google/adsprocessorterms; Further information: https://privacy.google.com/businesses/adsservices (types of processing as well as data processed).
- Google Analytics: Web analytics, reach measurement and measurement of user flows; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website:https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy:https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms; Standard contractual clauses (guaranteeing the level of data protection in the case of processing in third countries):https://business.safety.google/adsprocessorterms; 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; Further information:https://privacy.google.com/businesses/adsservices (types of processing and data processed).
- Google Analytics 4: We use Google Analytics to perform user analysis based on a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to an end device in order to identify which content users have accessed within one or various usage processes, which search terms they have used, have accessed again or have interacted with our online offer. Likewise, the time of use and its duration are stored, as well as the sources of users referring to our online offer and technical aspects of their end devices and browsers. In the process, pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used. In Analytics, higher level geographic location data is provided by collecting the following metadata based on IP search: ‘city’ (and the derived latitude and longitude of the city), ‘continent’, ‘country’, ‘region’, ‘subcontinent’ (and the ID-based equivalents). To ensure the protection of user data in the EU, Google receives and processes all user data via domains and servers within the EU. Users’ IP addresses are not logged and are truncated by the last two digits by default. The shortening of the IP address takes place on EU servers for EU users. In addition, all sensitive data collected from users in the EU is deleted before it is collected through EU domains and servers; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: consent (Art. 6 para. 1 sent. 1 lit. a) DSGVO); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms/; Standard contractual clauses (guaranteeing the level of data protection in the case of processing in third countries):https://business.safety.google/adsprocessorterms; Opt-Out: Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated; Further information: https://privacy.google.com/businesses/adsservices (types of processing and data processed).
- Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offer (please refer to further information in this data protection declaration). With the Tag Manager itself (which implements the tags), therefore, no profiles of users are created or cookies are stored. Google only learns the IP address of the user, which is necessary to run the Google Tag Manager; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) DSGVO); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms; Standard contractual clauses (guaranteeing the level of data protection in the case of processing in third countries):https://business.safety.google/adsprocessorterms; Further information: https://privacy.google.com/businesses/adsservices (types of processing and data processed).
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, 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 computers of the users, in which the usage behavior 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 also 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.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 computers of the users, in which the usage behavior 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 also 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).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).
- Betroffene Personen: Nutzer (z.B. Webseitenbesucher, Nutzer von Onlinediensten).
- Zwecke der Verarbeitung: Kontaktanfragen und Kommunikation; Feedback (z.B. Sammeln von Feedback via Online-Formular); Marketing.
Further guidance on processing operations, procedures and services:
- Facebook-pages: Profiles within the social network Facebook – 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 (so-called “Fanpage”). 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 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 (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 USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- LinkedIn: Soziales Netzwerk; Dienstanbieter: LinkedIn Irland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Irland; Rechtsgrundlagen: Berechtigte Interessen (Art. 6 Abs. 1 S. 1 lit. f) DSGVO); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Order processing contract: https://legal.linkedin.com/dpa; Standard contractual clauses (guaranteeing the level of data protection in the case of processing in third countries): https://legal.linkedin.com/dpa; Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
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 functionality. We endeavour to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, 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.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 functionality. We endeavour to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, 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.
- 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); location data (information on the geographical position of a device or a person).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: provision of our online offer and user-friendliness.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Google Fonts (provision on own server): Provision of font files for the purpose of a user-friendly presentation of our online offer; Service provider: The Google Fonts are hosted on our server, no data is transmitted to Google; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
- Google Fonts (sourcing from Google server): Obtaining fonts (and symbols) for the purpose of technically secure, maintenance-free and efficient use of fonts and symbols in terms of timeliness 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 that are necessary for the provision of the fonts depending on the devices used and the technical environment. This data may be processed on a server of the provider of the fonts in the USA – When visiting our online offer, users’ browsers send their browser HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving fonts). The Google Fonts Web API provides users with Google Fonts’ cascading style sheets (CSS) and then with the fonts specified in the CCS. These HTTP requests include (1) the IP address used by each user to access the Internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user agent describing the browser and operating system versions of the website visitors, as well as the referral URL (i.e., the web page where the Google font is to be displayed). IP addresses are not logged or stored on Google servers and they are not analyzed. The Google Fonts Web API logs details of HTTP requests (requested URL, user agent, and referring URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must match the font that is generated for the particular browser type. The user agent is logged primarily for debugging purposes and is used to generate aggregate usage statistics that measure the popularity of font families. These aggregate usage statistics are published on Google Fonts’ Analytics page. Finally, the referral URL is logged so that the data can be used for production maintenance and to generate an aggregate report on top integrations based on the number of font requests. Google says it does not use any of the information collected by Google Fonts to profile end users or serve targeted ads; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; 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; Further information: https://developers.google.com/fonts/faq/privacy?hl=de.
- Google Maps: We integrate the maps of the service “Google Maps” of the provider Google. The processed data may include, in particular, IP addresses and location data of the users; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy.
- YouTube-Videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; 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.
- YouTube-Videos: Video content; YouTube videos are integrated via a special domain (recognizable by the component “youtube-nocookie”) in the so-called “extended data protection mode”, whereby no cookies on user activities are collected in order to personalize video playback. Nevertheless, information on user interaction with the video (e.g. remembering the last playback point), may be stored; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; 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.
Modification and updating of the privacy policy
We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration 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.
We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration 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.
Rights of the data subjects
As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 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 is processed for the purposes of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.
- Widerrufsrecht bei Einwilligungen: Sie haben das Recht, erteilte Einwilligungen jederzeit zu widerrufen.
- Auskunftsrecht: Sie haben das Recht, eine Bestätigung darüber zu verlangen, ob betreffende Daten verarbeitet werden und auf Auskunft über diese Daten sowie auf weitere Informationen und Kopie der Daten entsprechend den gesetzlichen Vorgaben.
- Recht auf Berichtigung: Sie haben entsprechend den gesetzlichen Vorgaben das Recht, die Vervollständigung der Sie betreffenden Daten oder die Berichtigung der Sie betreffenden unrichtigen Daten zu verlangen.
- Recht auf Löschung und Einschränkung der Verarbeitung: Sie haben nach Maßgabe der gesetzlichen Vorgaben das Recht, zu verlangen, dass Sie betreffende Daten unverzüglich gelöscht werden, bzw. alternativ nach Maßgabe der gesetzlichen Vorgaben eine Einschränkung der Verarbeitung der Daten zu verlangen.
- Recht auf Datenübertragbarkeit: Sie haben das Recht, Sie betreffende Daten, die Sie uns bereitgestellt haben, nach Maßgabe der gesetzlichen Vorgaben in einem strukturierten, gängigen und maschinenlesbaren Format zu erhalten oder deren Übermittlung an einen anderen Verantwortlichen zu fordern.
Definitions
This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are mainly defined in Art. 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily for better understanding. The terms are listed in alphabetical order.
- Firewall: A firewall is a security system that protects a computer network or a single computer from unwanted network access.
- 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. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any type of automated processing of personal data that consists in using such personal data to analyze, evaluate or to predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
- Reach measurement: Reach measurement (also referred to as web analytics) is used to evaluate the flow of visitors to an online offering and can include visitors’ behavior or interests in certain information, such as website content. 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 the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
- Location data: Location data is generated when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, a WLAN or similar technical means and functions for 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.
- Controller: “Controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
- 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 deletion.
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