PRIVACY POLICY

We have written this privacy policy (version 29.09.2021-311841264) in order to explain to you, in accordance with the provisions of the General Data Protection Regulation (EU) 2016/679 and applicable national laws, which personal data (data for short) we as the controller – and the processors commissioned by us (e.g. providers) – process, will process in the future and what legal options you have. The terms used are to be considered as gender-neutral.
In short: We provide you with comprehensive information about any personal data we process about you.

Privacy policies usually sound very technical and use legal terminology. However, this privacy policy is intended to describe the most important things to you as simply and transparently as possible. So long as it aids transparency, technical terms are explained in a reader-friendly manner, links to further information are provided and graphics are used. We are thus informing in clear and simple language that we only process personal data in the context of our business activities if there is a legal basis for it. This is certainly not possible with brief, unclear and legal-technical statements, as is often standard on the Internet when it comes to data protection. I hope you find the following explanations interesting and informative. Maybe you will also find some information that you have not been familiar with.
If you still have questions, we would like to ask you to contact the responsible body named below or in the imprint, to follow the existing links and to look at further information on third-party sites. You can of course also find our contact details in the imprint.

Scope

This privacy policy applies to all personal data processed by our company and to all personal data processed by companies commissioned by us (processors). With the term personal data, we refer to information within the meaning of Article 4 No. 1 GDPR, such as the name, email address and postal address of a person. The processing of personal data ensures that we can offer and invoice our services and products, be it online or offline. The scope of this privacy policy includes:

all online presences (websites, online shops) that we operate
Social media presences and email communication
mobile apps for smartphones and other devices

In short: This privacy policy applies to all areas in which personal data is processed in a structured manner by the company via the channels mentioned. Should we enter into legal relations with you outside of these channels, we will inform you separately if necessary.

Legal bases

In the following privacy policy, we provide you with transparent information on the legal principles and regulations, i.e. the legal bases of the General Data Protection Regulation, which enable us to process personal data.
Whenever EU law is concerned, we refer to REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016. You can of course access the General Data Protection Regulation of the EU online at EUR-Lex, the gateway to EU law, at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679.

We only process your data if at least one of the following conditions applies:

Consent (Article 6 Paragraph 1 lit. a GDPR): You have given us your consent to process data for a specific purpose. An example would be the storage of data you entered into a contact form.
Contract (Article 6 Paragraph 1 lit. b GDPR): We process your data in order to fulfill a contract or pre-contractual obligations with you. For example, if we conclude a sales contract with you, we need personal information in advance.
Legal obligation (Article 6 Paragraph 1 lit. c GDPR): If we are subject to a legal obligation, we will process your data. For example, we are legally required to keep invoices for our bookkeeping. These usually contain personal data.
Legitimate interests (Article 6 Paragraph 1 lit. f GDPR): In the case of legitimate interests that do not restrict your basic rights, we reserve the right to process personal data. For example, we have to process certain data in order to be able to operate our website securely and economically. Therefore, the processing is a legitimate interest.

Other conditions such as making recordings in the interest of the public, the exercise of official authority as well as the protection of vital interests do not usually occur with us. Should such a legal basis be relevant, it will be disclosed in the appropriate place.

In addition to the EU regulation, national laws also apply:

In Austria this is the Austrian Data Protection Act (Datenschutzgesetz), in short DSG.
In Germany this is the Federal Data Protection Act (Bundesdatenschutzgesetz), in short BDSG.

Should other regional or national laws apply, we will inform you about them in the following sections.

Contact details of the data protection controller

If you have any questions about data protection, you will find the contact details of the responsible person or controller below:
Rolf Thiel e.K.
Dr.-Haußner-Strasse 15
67435 Neustadt an der Weinstrasse | Germany
Phone: 0 63 27/97 67 35

Authorised to represent:
Email: missing-pen@t-online.de
Phone: 06327-976735
Company details: https://www.missing-pen.com/imprint

Storage Period

It is a general criterion for us to store personal data only for as long as is absolutely necessary for the provision of our services and products. This means that we delete personal data as soon as any reason for the data processing no longer exists. In some cases, we are legally obliged to keep certain data stored even after the original purpose no longer exists, such as for accounting purposes.

If you want your data to be deleted or if you want to revoke your consent to data processing, the data will be deleted as soon as possible, provided there is no obligation to continue its storage.

We will inform you below about the specific duration of the respective data processing, provided we have further information.

Rights in accordance with the General Data Protection Regulation

You are granted the following rights in accordance with the provisions of the GDPR (General Data Protection Regulation) and the Austrian Data Protection Act (DSG):

right to rectification (article 16 GDPR)
right to erasure (“right to be forgotten“) (article 17 GDPR)
right to restrict processing (article 18 GDPR)
righ to notification – notification obligation regarding rectification or erasure of personal data or restriction of processing (article 19 GDPR)
right to data portability (article 20 GDPR)
Right to object (article 21 GDPR)
right not to be subject to a decision based solely on automated processing – including profiling – (article 22 GDPR)

If you think that the processing of your data violates the data protection law, or that your data protection rights have been infringed in any other way, you can lodge a complaint with your respective regulatory authority. For Austria this is the data protection authority, whose website you can access at https://www.data-protection-authority.gv.at/.

Rheinland-Pfalz Data protection authority

State Commissioner for Data Protection: Prof. Dr. Dieter Kugelmann
Address: Hintere Bleiche 34, 55116 Mainz
Phone number: 061 31/208 22 26
E-mail address: poststelle@datenschutz.rlp.de
Website: https://www.datenschutz.rlp.de/de/startseite/

Data transfer to third countries

We only transfer or process data to countries outside the EU (third countries) if you consent to this processing, if this is required by law or if it is contractually necessary. In any case, we generally only do so to the permitted extent. In most cases, your consent is the most important reason for data being processed in third countries. When personal data is being processed in third countries such as the USA, where many software manufacturers offer their services and have their servers located, your personal data may be processed and stored in unexpected ways.

We want to expressly point out, that according to the European Court of Justice, there is currently no adequate level of protection for data transfer to the USA. Data processing by US services (such as Google Analytics) may result in data processing and retention without the data having undergone anonymisation processes. Furthermore, US government authorities may be able to access individual data. The collected data may also get linked to data from other services of the same provider, should you have a user account with the respective provider. We try to use server locations within the EU, whenever this is offered and possible.

We will provide you with more details about data transfer to third countries in the appropriate sections of this privacy policy, whenever applicable.

Security of data processing operations

In order to protect personal data, we have implemented both technical and organisational measures. We encrypt or pseudonymise personal data wherever this is possible. Thus, we make it as difficult as we can for third parties to extract personal information from our data.

Article 25 of the GDPR refers to “data protection by technical design and by data protection-friendly default” which means that both software (e.g. forms) and hardware (e.g. access to server rooms) appropriate safeguards and security measures shall always be placed. If applicable, we will outline the specific measures below.

TLS encryption with https

The terms TLS, encryption and https sound very technical, which they are indeed. We use HTTPS (Hypertext Transfer Protocol Secure) to securely transfer data on the Internet.
This means that the entire transmission of all data from your browser to our web server is secured – nobody can “listen in”.

We have thus introduced an additional layer of security and meet privacy requirements through technology design Article 25 Section 1 GDPR). With the use of TLS (Transport Layer Security), which is an encryption protocol for safe data transfer on the internet, we can ensure the protection of confidential information.
You can recognise the use of this safeguarding tool by the little lock-symbol

, which is situated in your browser’s top left corner in the left of the internet address (e.g. examplepage.uk), as well as by the display of the letters https (instead of http) as a part of our web address.
If you want to know more about encryption, we recommend you to do a Google search for “Hypertext Transfer Protocol Secure wiki” to find good links to further information.

Communications

Communications Overview

👥 Affected parties: Anyone who communicates with us via phone, email or online form

📓 Processed data: e. g. telephone number, name, email address or data entered in forms. You can find more details on this under the respective form of contact

🤝 Purpose: handling communication with customers, business partners, etc.

📅 Storage duration: for the duration of the business case and the legal requirements

⚖️ Legal basis: Article 6 (1) (a) GDPR (consent), Article 6 (1) (b) GDPR (contract), Article 6 (1) (f) GDPR (legitimate interests)

If you contact us and communicate with us via phone, email or online form, your personal data may be processed.

The data will be processed for handling and processing your request and for the related business transaction. The data is stored for this period of time or for as long as is legally required.

Affected persons

The above-mentioned processes affect all those who seek contact with us via the communication channels we provide.

Telephone

When you call us, the call data is stored in a pseudonymised form on the respective terminal device, as well as by the telecommunications provider that is being used. In addition, data such as your name and telephone number may be sent via email and stored for answering your inquiries. The data will be erased as soon as the business case has ended and the legal requirements allow for its erasure.

If you communicate with us via email, your data is stored on the respective terminal device (computer, laptop, smartphone, …) as well as on the email server. The data will be deleted as soon as the business case has ended and the legal requirements allow for its erasure.

Online forms

If you communicate with us using an online form, your data is stored on our web server and, if necessary, forwarded to our email address. The data will be erased as soon as the business case has ended and the legal requirements allow for its erasure.

Legal bases

Data processing is based on the following legal bases:

Art. 6 para. 1 lit. a GDPR (consent): You give us your consent to store your data and to continue to use it for the purposes of the business case;
Art. 6 para. 1 lit. b GDPR (contract): For the performance of a contract with you or a processor such as a telephone provider, or if we have to process the data for pre-contractual activities, such as preparing an offer;
Art. 6 para. 1 lit. f GDPR (legitimate interests): We want to conduct our customer inquiries and business communication in a professional manner. Thus, certain technical facilities such email programs, Exchange servers and mobile network operators are necessary to efficiently operate our communications.

Cookies Overview

👥 Affected parties: visitors to the website

🤝 Purpose: depending on the respective cookie. You can find out more details below or from the software manufacturer that sets the cookie.

📓 Processed data: Depending on the cookie used. More details can be found below or from the manufacturer of the software that sets the cookie.

📅 Storage duration: can vary from hours to years, depending on the respective cookie

⚖️ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What are cookies?

Our website uses HTTP-cookies to store user-specific data.
In the following we explain what cookies are and why they are used, so that you can better understand the following privacy policy.

Whenever you surf the Internet, you are using a browser. Common browsers are for example, Chrome, Safari, Firefox, Internet Explorer and Microsoft Edge. Most websites store small text-files in your browser. These files are called cookies.

It is important to note that cookies are very useful little helpers. Almost every website uses cookies. More precisely, these are HTTP cookies, as there are also other cookies for other uses. HTTP cookies are small files that our website stores on your computer. These cookie files are automatically placed into the cookie-folder, which is the “brain” of your browser. A cookie consists of a name and a value. Moreover, to define a cookie, one or multiple attributes must be specified.

Cookies store certain user data about you, such as language or personal page settings. When you re-open our website to visit again, your browser submits these “user-related” information back to our site. Thanks to cookies, our website knows who you are and offers you the settings you are familiar to. In some browsers, each cookie has its own file, while in others, such as Firefox, all cookies are stored in one single file.

The following graphic shows a possible interaction between a web browser such as Chrome and the web server. The web browser requests a website and receives a cookie back from the server. The browser then uses this again as soon as another page is requested.

There are both first-party cookies and third-party cookies. First-party cookies are created directly by our site, while third-party cookies are created by partner-websites (e.g. Google Analytics). Each cookie must be evaluated individually, as each cookie stores different data. The expiry time of a cookie also varies from a few minutes to a few years. Cookies are not software programs and do not contain viruses, trojans or other malware. Cookies also cannot access your PC’s information.

This is an example of how cookie-files can look:

Name: _ga
Value: GA1.2.1326744211.152311841264-9
Purpose: Differentiation between website visitors
Expiry date: after 2 years

A browser should support these minimum sizes:

At least 4096 bytes per cookie
At least 50 cookies per domain
At least 3000 cookies in total

Which types of cookies are there?

The exact cookies that we use, depend on the used services, which will be outlined in the following sections of this privacy policy. Firstly, we will briefly focus on the different types of HTTP-cookies.

There are 4 different types of cookies:

Essential cookies
These cookies are necessary to ensure the basic functions of a website. They are needed when a user for example puts a product into their shopping cart, then continues surfing on different websites and comes back later in order to proceed to the checkout. These cookies ensure the shopping cart does not get deleted, even if the user closes their browser window.

Purposive cookies
These cookies collect information about user behaviour and whether the user receives any error messages. Furthermore, these cookies record the website’s loading time as well as its behaviour in different browsers.

Target-orientated cookies
These cookies ensure better user-friendliness. Thus, information such as previously entered locations, fonts sizes or data in forms stay stored.

Advertising cookies
These cookies are also known as targeting cookies. They serve the purpose of delivering customised advertisements to the user. This can be very practical, but also rather annoying.

Upon your first visit to a website you are usually asked which of these cookie-types you want to accept. Furthermore, this decision will of course also be stored in a cookie.

If you want to learn more about cookies and do not mind technical documentation, we recommend https://tools.ietf.org/html/rfc6265, the Request for Comments of the Internet Engineering Task Force (IETF) called “HTTP State Management Mechanism”.

Purpose of processing via cookies

The purpose ultimately depends on the respective cookie. You can find out more details below or from the software manufacturer that sets the cookie.

Which data are processed?

Cookies are little helpers for a wide variety of tasks. Unfortunately, it is not possible to tell which data is generally stored in cookies, but in the privacy policy below we will inform you on what data is processed or stored.

Storage period of cookies

The storage period depends on the respective cookie and is further specified below. Some cookies are erased after less than an hour, while others can remain on a computer for several years.

You can also influence the storage duration yourself. You can manually erase all cookies at any time in your browser (also see “Right of objection” below). Furthermore, the latest instance cookies based on consent will be erased is after you withdraw your consent. The legality of storage will remain unaffected until then.

Right of objection – how can I erase cookies?

You can decide for yourself how and whether you want to use cookies. Regardless of which service or website the cookies originate from, you always have the option of erasing, deactivating or only partially accepting cookies. You can for example block third-party cookies but allow all other cookies.

If you want to find out which cookies have been stored in your browser, or if you want to change or erase cookie settings, you can find this option in your browser settings:

Chrome: Clear, enable and manage cookies in Chrome

Safari: Manage cookies and website data in Safari

Firefox: Clear cookies and site data in Firefox

Internet Explorer: Delete and manage cookies

Microsoft Edge: Delete cookies in Microsoft Edge

If you generally do not want cookies, you can set up your browser in a way to notify you whenever a cookie is about to be set. This gives you the opportunity to manually decide to either permit or deny the placement of every single cookie. This procedure varies depending on the browser. Therefore, it might be best for you to search for the instructions in Google. If you are using Chrome, you could for example put the search term “delete cookies Chrome” or “deactivate cookies Chrome” into Google.

Legal basis

The so-called “cookie directive” has existed since 2009. It states that the storage of cookies requires your consent (Article 6 Paragraph 1 lit. a GDPR). Within countries of the EU, however, the reactions to these guidelines still vary greatly. In Austria, however, this directive was implemented in Section 96 (3) of the Telecommunications Act (TKG). In Germany, the cookie guidelines have not been implemented as national law. Instead, this guideline was largely implemented in Section 15 (3) of the Telemedia Act (TMG).

For absolutely necessary cookies, even if no consent has been given, there are legitimate interests (Article 6 (1) (f) GDPR), which in most cases are of an economic nature. We want to offer our visitors a pleasant user experience on our website. For this, certain cookies often are absolutely necessary.

This is exclusively done with your consent, unless absolutely necessary cookies are used. The legal basis for this is Article 6 (1) (a) of the GDPR.

In the following sections you will find more detail on the use of cookies, provided the used software does use cookies.

Web hosting

Web hosting Overview

👥 Affected parties: visitors to the website

🤝 Purpose: professional hosting of the website and security of operations

📓 Processed data: IP address, time of website visit, browser used and other data. You can find more details on this below or at the respective web hosting provider.

📅 Storage period: dependent on the respective provider, but usually 2 weeks

⚖️ Legal basis: Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is web hosting?

Every time you visit a website nowadays, certain information – including personal data – is automatically created and stored, including on this website. This data should be processed as sparingly as possible, and only with good reason. By website, we mean the entirety of all websites on your domain, i.e. everything from the homepage to the very last subpage (like this one here). By domain we mean example.uk or examplepage.com.

When you want to view a website on a screen, you use a program called a web browser. You probably know the names of some web browsers: Google Chrome, Microsoft Edge, Mozilla Firefox, and Apple Safari.

The web browser has to connect to another computer which stores the website’s code: the web server. Operating a web server is complicated and time-consuming, which is why this is usually done by professional providers. They offer web hosting and thus ensure the reliable and flawless storage of website data.

Whenever the browser on your computer establishes a connection (desktop, laptop, smartphone) and whenever data is being transferred to and from the web server, personal data may be processed. After all, your computer stores data, and the web server also has to retain the data for a period of time in order to ensure it can operate properly.

Illustration:

Why do we process personal data?

The purposes of data processing are:

Professional hosting of the website and operational security
To maintain the operational as well as IT security
Anonymous evaluation of access patterns to improve our offer, and if necessary, for prosecution or the pursuit of claims.li>

Which data are processed?

Even while you are visiting our website, our web server, that is the computer on which this website is saved, usually automatically saves data such as

the full address (URL) of the accessed website (e. g. https://www.examplepage.uk/examplesubpage.html?tid=311841264)
browser and browser version (e.g. Chrome 87)
the operating system used (e.g. Windows 10)
the address (URL) of the previously visited page (referrer URL) (e. g. https://www.examplepage.uk/icamefromhere.html/)
the host name and the IP address of the device from the website is being accessed from (e.g. COMPUTERNAME and 194.23.43.121)
date and time
in so-called web server log files

How long is the data stored?

Generally, the data mentioned above are stored for two weeks and are then automatically deleted. We do not pass these data on to others, but we cannot rule out the possibility that this data may be viewed by the authorities in the event of illegal conduct.

In short: Your visit is logged by our provider (company that runs our website on special computers (servers)), but we do not pass on your data without your consent!

Legal basis

The lawfulness of processing personal data in the context of web hosting is justified in Art. 6 para. 1 lit. f GDPR (safeguarding of legitimate interests), as the use of professional hosting with a provider is necessary to present the company in a safe and user-friendly manner on the internet, as well as to have the ability to track any attacks and claims, if necessary.

Web Analytics

Web Analytics Privacy Policy Overview

👥 Affected parties: visitors to the website

🤝 Purpose: Evaluation of visitor information to optimise the website.

📓 Processed data: Access statistics that contain data such as access location, device data, access duration and time, navigation behaviour, click behaviour and IP addresses. You can find more details on this from the respective web analytics tool directly.

📅 Storage period: depending on the respective web analytics tool used

⚖️ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is Web Analytics?

We use software on our website, which is known as web analytics, in order to evaluate website visitor behaviour. Thus, data is collected, which the analytic tool provider (also called tracking tool) stores, manages and processes. Analyses of user behaviour on our website are created with this data, which we as the website operator receive. Most tools also offer various testing options. These enable us, to for example test which offers or content our visitors prefer. For this, we may show you two different offers for a limited period of time. After the test (a so-called A/B test) we know which product or content our website visitors find more interesting. For such testing as well as for various other analyses, user profiles are created and the respective data is stored in cookies.

Why do we run Web Analytics?

We have a clear goal in mind when it comes to our website: we want to offer our industry’s best website on the market. Therefore, we want to give you both, the best and most interesting offer as well as comfort when you visit our website. With web analysis tools, we can observe the behaviour of our website visitors, and then improve our website accordingly for you and for us. For example, we can see the average age of our visitors, where they come from, the times our website gets visited the most, and which content or products are particularly popular. All this information helps us to optimise our website and adapt it to your needs, interests and wishes.

Which data are processed?

The exact data that is stored depends on the analysis tools that are being used. But generally, data such as the content you view on our website are stored, as well as e. g. which buttons or links you click, when you open a page, which browser you use, which device (PC, tablet, smartphone, etc.) you visit the website with, or which computer system you use. If you have agreed that location data may also be collected, this data may also be processed by the provider of the web analysis tool.

Moreover, your IP address is also stored. According to the General Data Protection Regulation (GDPR), IP addresses are personal data. However, your IP address is usually stored in a pseudonymised form (i.e. in an unrecognisable and abbreviated form). No directly linkable data such as your name, age, address or email address are stored for testing purposes, web analyses and web optimisations. If this data is collected, it is retained in a pseudonymised form. Therefore, it cannot be used to identify you as a person.

The following example shows Google Analytics’ functionality as an example for client-based web tracking with JavaScript code.

The storage period of the respective data always depends on the provider. Some cookies only retain data for a few minutes or until you leave the website, while other cookies can store data for several years.

Duration of data processing

If we have any further information on the duration of data processing, you will find it below. We generally only process personal data for as long as is absolutely necessary to provide products and services. The storage period may be extended if it is required by law, such as for accounting purposes for example for accounting.

Right to object

You also have the option and the right to revoke your consent to the use of cookies or third-party providers at any time. This works either via our cookie management tool or via other opt-out functions. For example, you can also prevent data processing by cookies by managing, deactivating or erasing cookies in your browser.

Legal basis

The use of Web Analytics requires your consent, which we obtained with our cookie popup. According to Art. 6 para. 1 lit. a of the GDPR (consent), this consent represents the legal basis for the processing of personal data, such as by collection through Web Analytics tools.

In addition to consent, we have a legitimate interest in analysing the behaviour of website visitors, which enables us to technically and economically improve our offer. With Web Analytics, we can recognise website errors, identify attacks and improve profitability. The legal basis for this is Art. 6 para. 1 lit. f of the GDPR (legitimate interests). Nevertheless, we only use these tools if you have given your consent.

Since Web Analytics tools use cookies, we recommend you to read our privacy policy on cookies. If you want to find out which of your data are stored and processed, you should read the privacy policies of the respective tools.

If available, information on special Web Analytics tools can be found in the following sections.

Google Optimize Privacy Policy

On our website we use Google Optimize, which is a web optimisation tool. The provider of this service is the American company Google Inc. The responsible entity for the European region is the Irish company Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Irland).

Google also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.

Google uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Google to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847

You can find out more about Googles’ data processing in their privacy policy at https://policies.google.com/privacy?hl=en-US.

Facebook Pixel Privacy Policy

We use Facebook’s Facebook pixel on our website. For that, we have implemented a code on our website. The Facebook pixel is a segment of a JavaScript code, which, in case you came to our website via Facebook ads, loads an array or functions that enable Facebook to track your user actions. For example, if you buy a product on our website, the Facebook pixel is triggered and stores your actions on our website in one or more cookies. These cookies enable Facebook to match your user data (customer data such as IP address, user ID) with the data of your Facebook account. After that, Facebook deletes your data again. The collected data is anonymous as well as inaccessible and can only be used for ad placement purposes. If you are a Facebook user and you are logged in, your visit to our website is automatically assigned to your Facebook user account.

We exclusively want to show our products or services to persons, who are interested in them. With the aid of the Facebook pixel, our advertising measures can get better adjusted to your wishes and interests. Therefore, Facebook users get to see suitable advertisement (if they allowed personalised advertisement). Moreover, Facebook uses the collected data for analytical purposes and for its own advertisements.

In the following we will show you the cookies, which were set on a test page with the Facebook pixel integrated to it. Please consider that these cookies are only examples. Depending on the interaction that is made on our website, different cookies are set.

Name: _fbp
Value: fb.1.1568287647279.257405483-6311841264-7
Purpose: Facebook uses this cookie to display advertising products.
Expiration date: after 3 months

Name: fr
Value: 0aPf312HOS5Pboo2r..Bdeiuf…1.0.Bdeiuf.
Purpose: This cookie is used for Facebook pixels to function properly.
Expiration date: after 3 months

Name: comment_author_50ae8267e2bdf1253ec1a5769f48e062311841264-3
Value: Name of the author
Purpose: This cookie saves the text and name of a user who e.g. leaves a comment.
Expiration date: after 12 months

Name: comment_author_url_50ae8267e2bdf1253ec1a5769f48e062
Value: https%3A%2F%2Fwww.testseite…%2F (URL of the author)
Purpose: This cookie saved the URL of the website that the user types into a text box on our website.
Expiration date: after 12 months

Name: comment_author_email_50ae8267e2bdf1253ec1a5769f48e062
Value: email address of the author
Purpose: This cookie saves the email address of the user, if they provided it on the website.
Expiration date: after 12 months

Note: The above-mentioned cookies relate to an individual user behaviour. Moreover, especially concerning the usage of cookies, changes at Facebook can never be ruled out.

If you are registered on Facebook, you can change the settings for advertisements yourself at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. If you are not a Facebook user, you can manage your user based online advertising at https://www.youronlinechoices.com/uk/your-ad-choices. You have the option to activate or deactivate any providers there.

We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfer to the USA. Data processing is done mainly through Facebook Pixel. This may lead to data not being anonymously processed and stored. Furthermore, US government authorities may get access to individual data. The data may also get linked to data from other Facebook services you have a user account with.

If you want to learn more about Facebook’s data protection, we recommend you the view the company’s in-house data policies at https://www.facebook.com/policy.php.

Along with Facebook’s pixel function, we have also activated Automatic Advanced Matching. This function allows us to send hashed emails, names, genders, cities, states, postcodes and dates of birth or telephone numbers as additional information to Facebook, provided you have made them available to us. This activation gives us the opportunity to customise advertising campaigns even better to persons who are interested in our services or products.

Google Analytics Privacy Policy

Google Analytics Privacy Policy Overview

👥 Affected parties: website visitors

🤝 Purpose: Evaluation of visitor information to optimise the website.

📓 Processed data: Access statistics that contain data such as the location of access, device data, access duration and time, navigation behaviour, click behaviour and IP addresses. You can find more details on this in the privacy policy below.

📅 Storage period: depending on the properties used

⚖️ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is Google Analytics?

We use the tracking and analysis tool Google Analytics (GA) of the US-American company Google LLC (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). Google Analytics collects data on your actions on our website. Whenever you click a link for example, this action is saved in a cookie and transferred to Google Analytics. With the help of reports which we receive from Google Analytics, we can adapt our website and our services better to your wishes. In the following, we will explain the tracking tool in more detail, and most of all, we will inform you what data is saved and how you can prevent this.

Google Analytics is a tracking tool with the purpose of conducting data traffic analysis of our website. For Google Analytics to work, there is a tracking code integrated to our website. Upon your visit to our website, this code records various actions you perform on your website. As soon as you leave our website, this data is sent to the Google Analytics server, where it is stored.

Google processes this data and we then receive reports on your user behaviour. These reports can be one of the following:

Target audience reports: With the help of target audience reports we can get to know our users better and can therefore better understand who is interested in our service.
Advertising reports: Through advertising reports we can analyse our online advertising better and hence improve it.
Acquisition reports: Acquisition reports provide us helpful information on how we can get more people enthusiastic about our service.
Behaviour reports: With these reports, we can find out how you interact with our website. By the means of behaviour reports, we can understand what path you go on our website and what links you click.
Conversion reports: A conversion is the process of leading you to carry out a desired action due to a marketing message. An example of this would be transforming you from a mere website visitor into a buyer or a newsletter subscriber. Hence, with the help of these reports we can see in more detail, if our marketing measures are successful with you. Our aim is to increase our conversion rate.
Real time reports: With the help of these reports we can see in real time, what happens on our website. It makes us for example see, we can see how many users are reading this text right now.

Why do we use Google Analytics on our website?

The objective of our website is clear: We want to offer you the best possible service. Google Analytics’ statistics and data help us with reaching this goal.

Statistically evaluated data give us a clear picture of the strengths and weaknesses of our website. On the one hand, we can optimise our page in a way, that makes it easier to be found by interested people on Google. On the other hand, the data helps us to get a better understanding of you as our visitor. Therefore, we can very accurately find out what we must improve on our website, in order to offer you the best possible service. The analysis of that data also enables us to carry out our advertising and marketing measures in a more individual and more cost-effective way. After all, it only makes sense to show our products and services exclusively to people who are interested in them.

What data is stored by Google Analytics?

With the aid of a tracking code, Google Analytics creates a random, unique ID which is connected to your browser cookie. That way, Google Analytics recognises you as a new user. The next time you visit our site, you will be recognised as a “recurring” user. All data that is collected gets saved together with this very user ID. Only this is how it is made possible for us to evaluate and analyse pseudonymous user profiles.

To analyse our website with Google Analytics, a property ID must be inserted into the tracking code. The data is then stored in the corresponding property. Google Analytics 4-property is standard for every newly created property. An alternative however, is the Universal Analytics Property. Depending on the property that is being used, data are stored for different periods of time.

Your interactions on our website are measured by tags such as cookies and app instance IDs. Interactions are all kinds of actions that you perform on our website. If you are also using other Google systems (such as a Google Account), data generated by Google Analytics can be linked with third-party cookies. Google does not pass on any Google Analytics data, unless we as the website owners authorise it. In case it is required by law, exceptions can occur.

The following cookies are used by Google Analytics:

Name: _ga
Value:2.1326744211.152311841264-5
Purpose: By deafault, analytics.js uses the cookie _ga, to save the user ID. It generally serves the purpose of differentiating between website visitors.
Expiration date: After 2 years

Name: _gid
Value:2.1687193234.152311841264-1
Purpose: This cookie also serves the purpose of differentiating between website users
Expiration date: After 24 hours

Name: _gat_gtag_UA_<property-id>
Value: 1
Verwendungszweck: It is used for decreasing the demand rate. If Google Analytics is provided via Google Tag Manager, this cookie gets the name _dc_gtm_ <property-id>.
Expiration date: After 1 minute

Name: AMP_TOKEN
Value: No information
Purpose: This cookie has a token which is used to retrieve the user ID by the AMP Client ID Service. Other possible values suggest a logoff, a request or an error.
Expiration date: After 30 seconds up to one year

Name: __utma
Value:1564498958.1564498958.1564498958.1
Purpose: With this cookie your behaviour on the website can be tracked and the site performance can be measured. The cookie is updated every time the information is sent to Google Analytics.
Expiration date: After 2 years

Name: __utmt
Value: 1
Purpose: Just like _gat_gtag_UA_<property-id> this cookie is used for keeping the requirement rate in check.
Expiration date: Afer 10 minutes

Name: __utmb
Value:3.10.1564498958
Purpose: This cookie is used to determine new sessions. It is updated every time new data or information gets sent to Google Analytics.
Expiration date: After 30 minutes

Name: __utmc
Value: 167421564
Purpose: This cookie is used to determine new sessions for recurring visitors. It is therefore a session cookie, and only stays stored until you close the browser again.
Expiration date: After closing the browser

Name: __utmz
Value: m|utmccn=(referral)|utmcmd=referral|utmcct=/
Purpose: This cookie is used to identify the source of the number of visitors to our website. This means, that the cookie stored information on where you came to our website from. This could be another site or an advertisement.
Expiration date: After 6 months

Name: __utmv
Value: No information
Purpose: The cookie is used to store custom user data. It gets updated whenever information is sent to Google Analytics.
Expiration date: After 2 years

Note: This list is by no means exhaustive, since Google are repeatedly changing the use of their cookies.

Below we will give you an overview of the most important data that can be evaluated by Google Analytics:

Heatmaps: Google creates so-called Heatmaps an. These Heatmaps make it possible to see the exact areas you click on, so we can get information on what routes you make on our website.

Session duration: Google calls the time you spend on our website without leaving it session duration. Whenever you are inactive for 20 minutes, the session ends automatically.

Bounce rate If you only look at one page of our website and then leave our website again, it is called a bounce.

Account creation: If you create an account or make an order on our website, Google Analytics collects this data.

IP-Address: The IP address is only shown in a shortened form, to make it impossible to clearly allocate it.

Location: Your approximate location and the country you are in can be defined by the IP address. This process is called IP location determination.

Technical information: Information about your browser type, your internet provider and your screen resolution are called technical information.

Source: Both, Google Analytics as well as ourselves, are interested what website or what advertisement led you to our site.

Further possibly stored data include contact data, potential reviews, playing media (e.g. when you play a video on our site), sharing of contents via social media or adding our site to your favourites. This list is not exhaustive and only serves as general guidance on Google Analytics’ data retention.

How long and where is the data stored?

Google has servers across the globe. Most of them are in America and therefore your data is mainly saved on American servers. Here you can read detailed information on where Google’s data centres are located: https://www.google.com/about/datacenters/inside/locations/?hl=en

Your data is allocated to various physical data mediums. This has the advantage of allowing to retrieve the data faster, and of protecting it better from manipulation. Every Google data centre has respective emergency programs for your data. Hence, in case of a hardware failure at Google or a server error due to natural disasters, the risk for a service interruption stays relatively low.

The data retention period depends on the properties used. When using the newer Google Analytics 4-properties, the retention period of your user data is set to 14 months. For so-called event data, we have the option of choosing a retention period of either 2 months or 14 months.

Google Analytics has a 26 months standardised period of retaining your user data. After this time, your user data is deleted. However, we have the possibility to choose the retention period of user data ourselves. There are the following five options:

Deletion after 14 months
Deletion after 26 months
Deletion after 38 months
Deletion after 50 months
No automatical deletion

Additionally, there is the option for data to be deleted only if you no longer visit our website within a period determined by us. In this case, the retention period will be reset every time you revisit our website within the specified period.

As soon as the chosen period is expired, the data is deleted once a month. This retention period applies to any of your data which is linked to cookies, user identification and advertisement IDs (e.g. cookies of the DoubleClick domain). Any report results are based on aggregated information and are stored independently of any user data. Aggregated information is a merge of individual data into a single and bigger unit.

How can I delete my data or prevent data retention?

Under the provisions of the European Union’s data protection law, you have the right to obtain information on your data and to update, delete or restrict it. With the help of a browser add on that can deactivate Google Analytics’ JavaScript (ga.js, analytics.js, dc.js), you can prevent Google Analytics from using your data. You can download this add on at https://tools.google.com/dlpage/gaoptout?hl=en-GB. Please consider that this add on can only deactivate any data collection by Google Analytics.

If you generally want to deactivate, delete or manage all cookies (independently of Google Analytics), you can use one of the guides that are available for any browser:

Chrome: Clear, enable and manage cookies in Chrome

Safari: Manage cookies and website data in Safari

Firefox: Clear cookies and site data in Firefox

Internet Explorer: Delete and manage cookies

Microsoft Edge: Delete cookies in Microsoft Edge

Legal basis

The use of Google Analytics requires your consent, which we obtained via our cookie popup. According to Art. 6 para. 1 lit. a of the GDPR (consent) , this is the legal basis for the processing of personal data when collected via web analytics tools.

In addition to consent, we have legitimate interest in analysing the behaviour of website visitors, in order to technically and economically improve our offer. With Google Analytics, we can recognise website errors, identify attacks and improve profitability. The legal basis for this is Art. 6 para. 1 lit. f of the GDPR (legitimate interests) . Nevertheless, we only use Google Analytics if you have given your consent.

We hope we could provide you with the most important information about data processing by Google Analytics. If you want to find out more on the tracking service, we recommend these two links: https://marketingplatform.google.com/about/analytics/terms/gb/ and https://support.google.com/analytics/answer/6004245?hl=en.

Google Analytics IP Anonymisation

We implemented Google Analytics’ IP address anonymisation to this website. Google developed this function, so this website can comply with the applicable privacy laws and the local data protection authorities’ recommendations, should they prohibit the retention of any full IP addresses.
The anonymisation or masking of IP addresses takes place, as soon as they reach Google Analytics’ data collection network, but before the data would be saved or processed.

You can find more information on IP anonymisation at https://support.google.com/analytics/answer/2763052?hl=en.

Google Analytics Reports on demographic characteristics and interests

We have turned on Google Analytics’ functions for advertising reports. These reports on demographic characteristics and interests contain details about age, gender and interests. Through them we can get a better picture of our users – without being able to allocate any data to individual persons. You can learn more about advertising functions at auf https://support.google.com/analytics/answer/3450482?hl=en&amp%3Butm_id=ad.

You can terminate the use of your Google Account’s activities and information in “Ads Settings” at https://adssettings.google.com/authenticated via a checkbox.

Google Analytics Deactivation Link

By clicking on the following deactivation link you can prevent Google from tracking your further visits. Caution: The deletion of cookies, the use of your browser’s incognito/private mode or the use of a different browser may lead to your data being collected again.

Deactivate Google Analytics

Google Analytics‘ Data Processing Amendment

By accepting the amendment on data processing in Google Analytics, we entered a contract with Google concerning the use of Google Analytics.

You can find out more about the amendment on data processing for Google Analytics here: https://support.google.com/analytics/answer/3379636?hl=en&utm_id=ad

Google Analytics Google Signals Privacy Policy

We have activated Google signals in Google Analytics. Through this, any existing Google Analytics functions (advertising reports, remarketing, cross-device reports and reports on interests and demographic characteristics) are updated, to result in the summary and anonymisation of your data, should you have permitted personalised ads in your Google Account.

The special aspect of this is that it involves cross-device tracking. That means your data can be analysed across multiple devices. Through the activation of Google signals, data is collected and linked to the Google account. For example, it enables Google to recognise when you look at a product on a smartphone and later buy the product on a laptop. Due to activating Google signals, we can start cross-device remarketing campaigns, which would otherwise not be possible to this extent. Remarketing means, that we can show you our products and services across other websites as well.

Moreover, further visitor data such as location, search history, YouTube history and data about your actions on our website are collected in Google Analytics. As a result, we receive improved advertising reports and more useful information on your interests and demographic characteristics. These include your age, the language you speak, where you live or what your gender is. Certain social criteria such as your job, your marital status or your income are also included. All these characteristics help Google Analytics to define groups of persons or target audiences.

Those reports also help us to better assess your behaviour, as well as your wishes and interests. As a result, we can optimise and customise our products and services for you. By default, this data expires after 26 months. Please consider, that this data is only collected if you have agreed to personalised advertisement in your Google Account. The retained information is always exclusively summarised and anonymous data, and never any data on individual persons. You can manage or delete this data in your Google Account.

Google Site Kit Privacy Policy

Google Site Kit Privacy Policy Overview

👥 Affected parties: website visitors

🤝 Purpose: Evaluation of visitor information to optimise the website.

📓 Processed data: Access statistics that contain data such as access location, device data, access duration and time, navigation behaviour, click behaviour and IP addresses. More details can be found below and in Google Analytics’ privacy policy.

📅 Storage period: depending on the properties used

⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is Google Site Kit?

We have integrated the WordPress plugin Google Site Kit of the American company Google Inc. to our website. For Europe, Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland) is responsible for all Google services. With Google Site Kit, we can quickly and easily view statistics of various Google products such as Google Analytics directly on our WordPress dashboard. The in Google Site Kit integrated tools also collect your personal data. In this privacy policy we will explain why we use Google Site Kit, how long and where your data is stored, and which other privacy policies may be relevant to you in this context.

Google Site Kit is a plugin for the WordPress content management system. With this plugin we can view important website analysis statistics directly in our dashboard. These are statistics that are collected by other Google products – primarily by Google Analytics. In addition to Google Analytics, the services Google Search Console, Page Speed Insight, Google AdSense, Google Optimize and Google Tag Manager can also be linked to Google Site Kit.

Why do we use Google Site Kit on our website?

As a service provider, it is our job to offer you the best possible experience on our website. You should feel comfortable on our website. Moreover, you should be able to quickly and easily find exactly what you are looking for. Statistical evaluations help us to get to know you better and to adapt our offer to your wishes and interests. We use various Google tools for these evaluations. Site Kit makes our work a lot easier because we can view and analyse the statistics of Google products on its dashboard. Therefore, we must no longer register for using the respective tools. Site Kit always provides a good overview of the most important analysis data.

What data are stored by Google Site Kit?

If you have consented to the use of tracking tools in the cookie notice (also called script or banner), cookies will be set by Google products such as Google Analytics. Also, on about you, such as your user behaviour, will be sent to Google, where it is stored and processed. This also includes personal data such as your IP address.

You can find more detailed information on the individual services in the respective separate sections of this privacy policy. In our privacy policy on Google Analytics for example, you will be able to view information on the exact types of data that are collected. You will also learn how long Google Analytics stores, manages and processes data, what cookies can be used and how you can prevent data retention. We also have respective comprehensive privacy policies for other Google services such as Google Tag Manager or Google AdSense.

In the following, we will show you exemplary Google Analytics cookies that may be set in your browser if you have consented to Google’s data processing. Please note that this list contains only a selection of potential cookies:

Name: _ga
Value:2.1326744211.152311841264-2
Purpose:Usually analytics.js uses the _ga cookie to store the user ID. Therefore, it can differentiate between website visitors.
Expiry date: after 2 years

Name: _gid
Value:2.1687193234.152311841264-7
Purpose: This cookie does also differentiate between website visitors.
Expiry date: after 24 hours

Name: _gat_gtag_UA_<property-id>
Value: 1
Purpose: This cookie is used to lower the request rate.
Expiry date: after 1 minute

How long and where are the data stored?

Google stores the collected data on its own servers, which are distributed all around the world. Most servers are in the United States, so your data may likely be stored there. At https://www.google.com/about/datacenters/inside/locations/?hl=uk you can see exactly where the company provides servers.

Data that is collected by Google Analytics is stored for a standard period of 26 months. After this time, your user data will be deleted. This retention period applies to any data linked to cookies, user identification and advertising IDs.

How can I delete my data or prevent data retention?

You always reserve the right to either receive information about your data, or to have your data deleted, rectified, or reduced. You can also deactivate, delete, or manage cookies in your browser at any time. In the following we will show you the respective instructions to do this in the most common browsers:

Chrome: Clear, enable and manage cookies in Chrome

Safari: Manage cookies and website data in Safari

Firefox: Clear cookies and site data in Firefox

Internet Explorer: Delete and manage cookies

Microsoft Edge: Delete cookies in Microsoft Edge

Please note that when using this tool, your data may also be stored and processed outside the EU. Under current European data protection law most third countries (including the USA) are not considered secure for this matter. Data must not be transferred to, stored and processed in such insecure third countries, unless there are suitable guarantees (such as EU standard contractual clauses) between us and the non-European service provider.

Legal basis

The use of Google Site Kit requires your consent, which we obtained via our cookie popup. According to Art. 6 para. 1 lit. a GDPR (consent), this consent is the legal basis for processing personal data, such as when it is collected by web analytics tools.

In addition to consent, we have a legitimate interest in analysing the behaviour of website visitors, and thus technically and economically improving our offer. With the help of Google Site Kit, we can recognise website errors, identify attacks and improve profitability. The legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests). Nevertheless, we only use Google Site Kit if you have given us your consent.

To find out more about data processing by Google, we recommend Google’s comprehensive privacy policy at https://policies.google.com/privacy?hl=en-GB

Google Tag Manager Privacy Policy

Google Tag Manager Privacy Policy Overview

👥 Affected parties: website visitors

🤝 Purpose: Organisation of individual tracking tools

📓 Processed data: Google Tag Manager itself does not store any data. The data record tags of the web analytics tools used.

📅 Storage period: depending on the web analytics tool used

⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is Google Tag Manager?

We use Google Tag Manager by the company Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA) for our website.
This Tag Manager is one of Google’s many helpful marketing products. With it, we can centrally integrate and manage code sections of various tracking tools, that we use on our website.

In this privacy statement we will explain in more detail, what Google Tag Manager does, why we use it and to what extent your data is processed.

Google Tag Manager is an organising tool with which we can integrate and manage website tags centrally and via a user interface. Tags are little code sections which e.g. track your activities on our website. For this, segments of JavaScript code are integrated to our site’s source text. The tags often come from Google’s intern products, such as Google Ads or Google Analytics, but tags from other companies can also be integrated and managed via the manager. Since the tags have different tasks, they can collect browser data, feed marketing tools with data, embed buttons, set cookies and track users across several websites.

Why do we use Google Tag Manager for our website?

Everybody knows: Being organised is important! Of course, this also applies to maintenance of our website. In order to organise and design our website as well as possible for you and anyone who is interested in our products and services, we rely on various tracking tools, such as Google Analytics.
The collected data shows us what interests you most, which of our services we should improve, and which other persons we should also display our services to. Furthermore, for this tracking to work, we must implement relevant JavaScript Codes to our website. While we could theoretically integrate every code section of every tracking tool separately into our source text, this would take too much time and we would lose overview. This is the reason why we use Google Tag Manager. We can easily integrate the necessary scripts and manage them from one place. Additionally, Google Tag Manager’s user interface is easy to operate, and requires no programming skills. Therefore, we can easily keep order in our jungle of tags.

What data is stored by Google Tag Manager?

Tag Manager itself is a domain that neither uses cookies nor stores data. It merely functions as an “administrator“ of implemented tags. Data is collected by the individual tags of the different web analysis tools. Therefore, in Google Tag Manager the data is sent to the individual tracking tools and does not get saved.

However, with the integrated tags of different web analysis tools such as Google Analytics, this is quite different. Depending on the analysis tool used, various data on your internet behaviour is collected, stored and processed with the help of cookies. Please read our texts on data protection for more information on the articular analysis and tracking tools we use on our website.

We allowed Google via the account settings for the Tag Manager to receive anonymised data from us. However, this exclusively refers to the use of our Tag Manager and not to your data, which are saved via code sections. We allow Google and others, to receive selected data in anonymous form. Therefore, we agree to the anonymised transfer of our website data. However, even after extensive research we could not find out what summarised and anonymous data it is exactly that gets transmitted. What we do know is that Google deleted any info that could identify our website. Google combines the data with hundreds of other anonymous website data and creates user trends as part of benchmarking measures. Benchmarking is a process of comparing a company’s results with the ones of competitors. As a result, processes can be optimised based on the collected information.

How long and where is the data stored?

When Google stores data, this is done on Google’s own servers. These servers are located all over the world, with most of them being in America. At https://www.google.com/about/datacenters/inside/locations/?hl=en you can read in detail where Google’s servers are.

In our individual data protection texts on the different tools you can find out how long the respective tracking tools store your data.

How can I delete my data or prevent data retention?

Google Tag Manager itself does not set any cookies but manages different tracking websites’ tags. In our data protection texts on the different tracking tools you can find detailed information on how you can delete or manage your data.

Please note that when using this tool, your data may also be stored and processed outside the EU. Most third countries (including the USA) are not considered secure under current European data protection law. Data must not be transferred, stored and processed to insecure third countries, unless there are suitable guarantees (such as EU standard contractual clauses) between us and the non-European service provider.

Legal basis

The use of the Google Tag Manager requires your consent, which we obtained via our cookie popup. According to Art. 6 para. 1 lit. a GDPR (consent), this consent is the legal basis for personal data processing, such as when it is collected by web analytics tools.

In addition to consent, we have a legitimate interest in analysing the behaviour of website visitors and thus technically and economically improving our offer. With the help of Google Tag Managers we can also improve profitability. The legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests). We only use Google Tag Manager if you have given us your consent.

If you want to learn more about Google Tag Manager, we recommend their FAQs at https://support.google.com/tagmanager/?hl=en#topic=3441530.

Email-Marketing

Email Marketing Overview

👥 Affected parties: newsletter subscribers

🤝 Purpose: direct marketing via email, notification of events that are relevant to the system

📓 Processed data: data entered during registration, but at least the email address. You can find more details on this in the respective email marketing tool used.

📅 Storage duration: for the duration of the subscription

⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is Email-Marketing?

We use email marketing to keep you up to date. If you have agreed to receive our emails or newsletters, your data will be processed and stored. Email marketing is a part of online marketing. In this type of marketing, news or general information about a company, product or service are emailed to a specific group of people who are interested in it.

If you want to participate in our email marketing (usually via newsletter), you usually just have to register with your email address. To do this, you have to fill in and submit an online form. However, we may also ask you for your title and name, so we can address you personally in our emails.

The registration for newsletters generally works with the help of the so-called “double opt-in procedure”. After you have registered for our newsletter on our website, you will receive an email, via which you can confirm the newsletter registration. This ensures that you own the email address you signed up with, and prevents anyone to register with a third-party email address. We or a notification tool we use, will log every single registration. This is necessary so we can ensure and prove, that registration processes are done legally and correctly. In general, the time of registration and registration confirmation are stored, as well as your IP address. Moreover, any change you make to your data that we have on file is also logged.

Why do we use Email-Marketing?

Of course, we want to stay in contact with you and keep you in the loop of the most important news about our company. For this, we use email marketing – often just referred to as “newsletters” – as an essential part of our online marketing. If you agree to this or if it is permitted by law, we will send you newsletters, system emails or other notifications via email. Whenever the term “newsletter” is used in the following text, it mainly refers to emails that are sent regularly. We of course don’t want to bother you with our newsletter in any way. Thus, we genuinely strive to offer only relevant and interesting content. In our emails you can e.g. find out more about our company and our services or products. Since we are continuously improving our offer, our newsletter will always give you the latest news, or special, lucrative promotions. Should we commission a service provider for our email marketing, who offers a professional mailing tool, we do this in order to offer you fast and secure newsletters. The purpose of our email marketing is to inform you about new offers and also to get closer to our business goals.

Which data are processed?

If you subscribe to our newsletter via our website, you then have to confirm your membership in our email list via an email that we will send to you. In addition to your IP and email address, your name, address and telephone number may also be stored. However, this will only be done if you agree to this data retention. Any data marked as such are necessary so you can participate in the offered service. Giving this information is voluntary, but failure to provide it will prevent you from using this service. Moreover, information about your device or the type of content you prefer on our website may also be stored. In the section “Automatic data storage” you can find out more about how your data is stored when you visit a website. We record your informed consent, so we can always prove that it complies with our laws.

Duration of data processing

If you unsubscribe from our e-mail/newsletter distribution list, we may store your address for up to three years on the basis of our legitimate interests, so we can keep proof your consent at the time. We are only allowed to process this data if we have to defend ourselves against any claims.

However, if you confirm that you have given us your consent to subscribe to the newsletter, you can submit an individual request for erasure at any time. Furthermore, if you permanently object to your consent, we reserve the right to store your email address in a blacklist. But as long as you have voluntarily subscribed to our newsletter, we will of course keep your email address on file.

Withdrawal – how can I cancel my subscription?

You have the option to cancel your newsletter subscription at any time. All you have to do is revoke your consent to the newsletter subscription. This usually only takes a few seconds or a few clicks. Most of the time you will find a link at the end of every email, via which you will be able to cancel the subscription. Should you not be able to find the link in the newsletter, you can contact us by email and we will immediately cancel your newsletter subscription for you.

Legal basis

Our newsletter is sent on the basis of your consent (Article 6 (1) (a) GDPR). This means that we are only allowed to send you a newsletter if you have actively registered for it beforehand. Moreover, we may also send you advertising messages on the basis of Section 7 (3) UWG (Unfair Competition Act), provided you have become our customer and have not objected to the use of your email address for direct mail.

If available – you can find information on special email marketing services and how they process personal data, in the following sections.

Push Messages

Push Messages Overview

👥 Affected parties: subscribers to push messages

🤝 Purpose: to notify you about interesting events that are relevant to the system

📓 Processed data: data that was entered during registration, usually also location data. You can find more details on this at the respective push notification tool.

📅 Storage period: data are usually stored for as long as is necessary for the service provision.

⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. b GDPR (contract)

What are push notifications?

We use so-called push notification services on our website, which help us to keep our users up to date. Thus, if you have agreed to the use of such push notifications, we can send you short news using a software tool. Push messages are text messages that appear on your smartphone or on other devices such as tablets or PCs, provided you have registered for them. You can also receive these messages if you are not on our website at this point in time, or are not actively using our offer. Moreover, data about your location and your user behaviour may also be collected and stored.

Why do we use push notifications?

On the one hand, we use push notifications to be able to fully provide the services we have contractually agreed to with you. On the other hand, they are helpful to our online marketing. This is because we can show you our services or products better with them. Thus, we can inform you immediately if there is e.g. any news in our company. We also want to get to know our users’ preferences and habits as well as possible, in order to continuously improve our offer.

Which data are processed?

For you to receive push notifications, you must confirm that you want to receive them. Any data accumulated during the process of confirming your consent is stored, managed and processed. This is necessary to recognise and proof users’ consent to receiving push notifications. Hence, a so-called device token or push token is stored in your browser. Along with this, your location data or the location of your device are usually also retained.

We also statistically evaluate how you handle our messages, so we can always send you push messages that are important and interesting. Thus, we can e.g. see when you open a message. With this knowledge we can adapt our communication strategy to your wishes and interests. Although this stored data could be assigned to you, we do not want to screen you as an individual. Rather, we are interested in the collected data from all our users so we can optimise further. In the privacy policies of the respective service providers, you can find out which data is stored exactly.

Duration of data processing

The duration of data processing and retention depends primarily on the tool we use. Below you can find out more about data processing of the individual tools. The providers’ privacy policies usually state exactly which data is stored and processed and for how long. Generally, personal data is only processed for as long as is necessary for the provision of our services. If data is stored in cookies, the storage duration can vary greatly. On the one hand, this data may be deleted immediately after leaving a website, and on the other hand it may get stored for several years. Therefore, if you want to know more about data storage, you should look at each individual cookie in detail. In most cases, you will also find informative information on individual cookies in the privacy policies of the respective providers.

Legal basis

It may be possible, that push messages may be necessary for us to be able to fulfill certain obligations in a contract. An example would be us notifying you about technical or organisational news. In this case, the legal basis is Art. 6 paragraph 1 lit. b of the GDPR.

Should this not be the case, push notifications will only be sent on the basis of your consent. Our push messages may particularly include advertising content. Furthermore, push notifications may also be sent depending on your location displayed on your device. The above-mentioned analytical evaluations are also based on your consent to their receipt. The legal basis for this is Article 6 (1) (a) of the GDPR. Of course, you can either revoke your consent at any time in the settings, or change various settings.

Online Marketing

Online Marketing Privacy Policy Overview

👥 Affected parties: visitors to the website

🤝 Purpose: Evaluation of visitor information for website optimisation

📓 Processed data: Access statistics containing data such as access location, device data, access duration and time, navigation behaviour, click behaviour and IP addresses. Personal data such as name or email address may also be processed. You can find more details on this from the respective Online Marketing tool.

📅 Storage period: depending on the Online Marketing tools used

⚖️ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is Online Marketing?

Online Marketing refers to all measures that are carried out online to achieve marketing goals, such as increasing brand awareness or doing business transactions. Furthermore, our Online Marketing measures aim to draw people’s attention to our website. In order to be able to show our offer to many interested people, we do Online Marketing. It mostly is about online advertising, content marketing or search engine optimisation. For this, personal data is also stored and processed, to enable us to use Online Marketing efficiently and targeted. On the one hand, the data help us to only show our content to people who are interested in it. On the other hand, it helps us to measure the advertising success of our Online Marketing measures.

Why do we use Online Marketing tools?

We want to show our website to everyone who is interested in our offer. We are aware that this is not possible without conscious measures being taken. That is why we do Online Marketing. There are various tools that make working on our Online Marketing measures easier for us. These also provide suggestions for improvement via data. Thus, we can target our campaigns more precisely to our target group. The ultimate purpose of these Online Marketing tools is to optimise our offer.

Which data are processed?

For our Online Marketing to work and to measure its success, user profiles are created and data are e.g. stored in cookies (small text files). With the help of this data, we can not only advertise in the traditional way, but also present our content directly on our website in the way you prefer. There are various third-party tools that offer these functions and thus collect and store your data accordingly. The aforementioned cookies e.g. store the pages you visit on our website, how long you view these pages, which links or buttons you click or which website you came from. What is more, technical information may also be stored. This may include e.g. your IP address, the browser and device you use to visit our website or the time you accessed our website as well as the time you left. If you have agreed for us to determine your location, we can also store and process it.

Your IP address is stored in pseudonymised form (i.e. shortened). What is more, distinct data that directly identify you as a person, such as your name, address or email address, are only stored in pseudonymised for advertising and Online Marketing purposes. With this data we cannot identify you as a person and only retain the pseudonymised information that is stored in your user profile.

Under certain circumstances, cookies may also be utilised, analysed and used for advertising purposes on other websites that use the same advertising tools. Thus, your data may then also be stored on the servers of the respective provider of the advertising tool.

In rare exceptions, unique data (name, email address, etc.) may also be stored in the user profiles. This can happen, if you are for example a member of a social media channel that we use for our Online Marketing measures and if the network connects previously received data with the user profile.

We only ever receive summarised information from the advertising tools we use that do store data on their servers. We never receive data that can be used to identify you as an individual. What is more, the data only shows how well-placed advertising measures have worked. For example, we can see what measures have caused you or other users to visit our website and purchase a service or product. Based on these analyses we can improve our advertising offer in the future and adapt it more precisely to the needs and wishes of people who are interested.

Duration of data processing

Below we will inform you on the duration of data processing, provided we have this information. In general, we only process personal data for as long as is absolutely necessary to provide our services and products. Data stored in cookies are retained for different lengths of time. Some cookies are deleted after you leave a website, while others may be stored in your browser for a number of years. However, in the respective privacy policies of the respective provider, you will usually find detailed information on the individual cookies this provider uses.

Right of withdrawal

You also retain the right and the option to revoke your consent to the use of cookies or third-party providers at any time. This can be done either via our cookie management tool or via other opt-out functions. You can for example also prevent data collection by cookies if you manage, deactivate or erase cookies in your browser. The legality of the processing remains unaffected to the point of revocation.

Since Online Marketing tools usually use cookies, we also recommend you to read our privacy policy on cookies. If you want to find out which of your data is stored and processed, you should read the privacy policies of the respective tools.

Legal basis

If you have consented to the use of third-party providers, then this consent is the legal basis for the corresponding data processing. According to Art. 6 para. 1 lit. a GDPR (consent) , this consent is the legal basis for personal data processing, as may be done when data is collected by online marketing tools.

Moreover, we have a legitimate interest in measuring our online marketing activities in anonymised form, in order to use this data for optimising our offer and our Marketing. The corresponding legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests) . Nevertheless, we only use these tools if you have given your consent.

Information on special online marketing tools can be found in the following sections, provided this information is available.

AdSpirit Privacy Policy

On our website we use AdSpirit, an ad server technology. The provider of this service is the German company AdSpirit GmbH, Niedstrasse 40-41, D-12159 Berlin, Germany. You can find out more about the data that is processed by using AdSpirit in their Privacy Policy at https://www.adspirit.com/en/privacy-statement/.

Facebook Conversions API Privacy Policy

On our website we use Facebook Conversions API, which is an event tracking tool. The provider of this service is the American company Facebook Inc. The company also has Irish headquarters at 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Facebook also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.

Facebook uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway, and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Facebook to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847

You can find out more about the data that is processed by using Facebook in their Privacy Policy at https://www.facebook.com/about/privacy.

Facebook Custom Audiences Privacy Policy

On our website we use Facebook Custom Audiences, a event tracking tool. The provider of this service is the American company Facebook Inc. The company also has Irish headquarters at 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland.

You can find out more about the data that is processed by using Facebook in their Privacy Policy at https://www.facebook.com/about/privacy.

Google AdMob privacy policy

On our website, we use Google AdMob, a tool for mobile advertising. The provider of this service is the American company Google Inc. The responsible entity for the European region is the Irish company Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Irland).

Google uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway, and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Google to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847

You can find out more about Googles’ data processing in their privacy policy at https://policies.google.com/privacy?hl=en-US.

PayPal Marketing Solutions Privacy Policy

On our website, we use PayPal Marketing Solutions, which is a sales optimisation tool. The provider of this service is the American company PayPal Pte. Ltd, 2211 North First Street, San Jose, California 95131, USA.

PayPal also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.

PayPal uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway, and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige PayPal to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847

You can find out more about PayPal’s data processing in their privacy policy at https://www.paypal.com/c2/webapps/mpp/ua/privacy-full.

Google Ads (Google AdWords) Conversion Tracking Privacy Policy

Google Ads (Google AdWords) Conversion Tracking Privacy Policy Overview

👥 Affected parties: visitors to the website

🤝 Purpose: economic success and service optimisation.

📓 Processed data: Access statistics that contain data such as access location, device data, access duration and time, navigation behaviour, click behaviour and IP addresses. Personal data such as name or email address may also be processed.

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PRIVACY POLICY