With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both 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. Status: August 2, 2023
Relevant legal basis according to the GDPR: Below you will find an overview of the legal basis of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.
Consent (Art. 6 (1) p. 1 lit. a) GDPR) – The data subject has given consent to the processing of personal data relating to him or her for a specific purpose or purposes.
Performance of a contract and pre-contractual enquiries (Art. 6(1)(1)(b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures carried out at the data subject’s request.
Legal obligation (Art. 6(1)(c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
Legitimate interests (Art. 6 (1) p. 1 lit. f) GDPR) – 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.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, 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, state data protection laws of the individual federal states may apply. Note on the applicability of the GDPR and the Swiss GDPR: This data protection notice serves to provide information in accordance with both the Swiss Federal Data Protection Act (Swiss GDPR) and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that due to the broader spatial application and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms “processing” of “personal data”, “overriding interest” and “personal data requiring special protection” used in the Swiss DPA, the terms “processing” of “personal data” as well as “legitimate interest” and “special categories of data” used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of its application.
Overview of the processing operations
The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
Inventory data
Payment data
Contact data
Content data
Contract data
Usage data
Meta, communication and procedural data
Special categories of data
Health data
Data relating to sex life or sexual orientation
Religious or philosophical beliefs
Data revealing racial or ethnic origin
Categories of data subjects
Customers
Employees
Interested parties
Communication partners
Users
Business and contractual partners
Persons depicted
Purposes of data processing
Provision of contractual services and fulfilment of contractual obligations
Contact requests and communication
Security measures
Reach measurement
Office and organisational procedures
Managing and responding to enquiries
Feedback
Marketing
Profiles with user-related information
Provision of our online services and user experience
Information technology infrastructure
Security measures
We take appropriate technical and organisational measures in accordance with the law, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the level of threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.. The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access to, entry into, disclosure of, assurance of availability of and segregation of the data. We also have procedures in place to ensure the exercise of data subjects’ rights, the deletion of data and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development or selection of hardware, software as well as procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings. Shortening of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not necessary, the IP address is shortened (also referred to as “IP masking”). In this process, the last two digits or the last part of the IP address after a full stop are removed or replaced by wildcards. The shortening of the IP address is intended to prevent or make it considerably more difficult to identify a person by their IP address. TLS encryption (https): In order 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.
International data transfers
Data processing in third countries: If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this is only done in accordance with the legal requirements. Subject to express consent or contractually or legally required transfer (see Art. 49 of the GDPR), we only process or allow the processing of data in third countries with a recognised level of data protection (Art. 45 of the GDPR), in the presence of and compliance with contractual obligations through so-called standard protection clauses of the EU Commission (Art. 46 of the GDPR) or in the presence of certifications or binding internal data protection regulations (see Art. 44 to 49 of the GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de). EU-US Trans-Atlantic Data Privacy Framework: Within the framework of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognised the level of data protection for certain companies from the USA as secure within the framework of the adequacy decision of 10 July 2023. The list of certified companies as well as further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/. Within the scope of the data protection information, we inform you which service providers we use are certified under the Data Privacy Framework. Disclosure of personal data abroad: In accordance with the Swiss Data Protection Act (DPA), we only disclose personal data abroad if adequate protection of the data subjects is guaranteed (Art. 16 Swiss DPA). If the Federal Council does not determine adequate protection, we take alternative security measures. These may include international agreements, specific guarantees, data protection clauses in contracts, standard data protection clauses approved by the Swiss Federal Data Protection and Information Commissioner (FDPIC) or internal company data protection regulations recognised in advance by the FDPIC or a competent data protection authority in another country. According to Art. 16 of the Swiss DPA, exceptions may be allowed for the disclosure of data abroad if certain conditions are met, including consent of the data subject, performance of a contract, public interest, protection of life or physical integrity, data made public or data from a register provided for by law. These disclosures are always made in accordance with legal requirements.
Deletion of data
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 for processing this data has ceased to apply or it is not required for the purpose). If the data are not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes; i.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person. Within the framework of our data protection notices, we may provide users with further information on the deletion as well as on the retention of data that applies specifically to the respective processing operations.
Rights of the persons concerned
Data subjects’ rights under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
Right of revocation for consents: You have the right to revoke any consent you have given at any time.
Right of access: You have the right to request confirmation as to whether data in question is being processed and to be informed about this data and to receive further information and a copy of the data in accordance with the legal requirements.
Right to rectification: In accordance with the law, you have the right to request that data concerning you be completed or that inaccurate data concerning you be rectified.
Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data relating to you be erased immediately or, alternatively, to request restriction of the processing of the data in accordance with the law.
Right to data portability: You have the right to receive data relating to you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transferred to another responsible person.
Complaint to the supervisory authority: In accordance with the law and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you usually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
Rights of persons concerned under the Swiss DPA: As a concerned person, you are entitled to the following rights in accordance with the provisions of the Swiss DPA:
Right of access: You have the right to request confirmation as to whether personal data concerning you is being processed and to receive the information necessary to enable you to exercise your rights under this law and to ensure transparent data processing.
Right to data disclosure or transfer: ou have the right to request the disclosure of your personal data that you have disclosed to us in a commonly used electronic format.
Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
Right to object, erasure and destruction: You have the right to object to the processing of your data and to request that the personal data concerning you be erased or destroyed.
Use of cookies
Cookies are small text files or other memory notes that store information on end devices and read information from the end devices. For example, to save the login status in a user account, the contents of a shopping basket in an e-shop, the contents viewed or the functions used in an online offer. Cookies can also be used for various purposes, e.g. for the purpose of functionality, security and comfort of online offers as well as the creation of analyses of visitor flows. Consent notices: We use cookies in accordance with the law. We therefore obtain prior consent from users, except where this is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide the user with a telemedia service (i.e. our online offer) expressly requested by the user. Cookies that are strictly necessary usually include cookies with functions that serve the display and operability of the online offer, load balancing, security, storage of users’ preferences and choices or similar purposes related to the provision of the main and secondary functions of the online offer requested by users. The revocable consent will be clearly communicated to the users and will contain the information on the respective cookie use. Notes on legal bases under data protection law: The legal basis under data protection law on which we process users’ personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and improvement of its usability) or, if this is done in the context of the performance of our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. We explain the purposes for which we process cookies in the course of this data protection declaration or as part of our consent and processing procedures. Storage duration: With regard to the storage duration, the following types of cookies are distinguished:
Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his end device (e.g. browser or mobile application).
Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used to measure reach. Unless we provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that they can be stored for up to two years.
General information on revocation and objection (so-called “opt-out”): Users can revoke the consent they have given at any time and object to processing in accordance with the legal requirements. For this purpose, users can, among other things, restrict the use of cookies in the settings of their browser (whereby this may also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.
Types of data processed: Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
Persons concerned: Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of our online offer and user-friendliness.
Further information on processing operations, procedures and services:
Processing of cookie data based on consent: We use a cookie consent management procedure, in the context of which the consent of users to the use of cookies, or the processing and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users. The declaration of consent is stored in order not to have to repeat the request and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. In this case, a pseudonymous user identifier is formed and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used; legal basis; legal basis: consent (Art. 6 para. 1 lit. a DSGVO).
We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer enquiries. We process this data in order to fulfil our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. Furthermore, we process the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations as well as the company organisation. Furthermore, we process the data on the basis of our legitimate interests in proper and business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration. We inform the contractual partners which data is required for the aforementioned purposes before or in the course of data collection, e.g. in online forms, by means of special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person. We delete the data after the expiry of statutory warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons. The statutory retention period for documents relevant under tax law as well as for commercial books, inventories, opening balances, annual financial statements, the work instructions required to understand these documents and other organisational documents and accounting vouchers is ten years and for received commercial and business letters and reproductions of sent commercial and business letters six years. The period shall commence at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was prepared, the commercial or business letter was received or sent or the accounting document was created, furthermore the recording was made or the other documents were created. Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms shall apply in the relationship between the users and the providers.
Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. e-mail, telephone numbers). Contract data (e.g. subject matter of contract, term, customer category).
Special categories of personal data: Health data; data relating to sex life or sexual orientation; religious or philosophical beliefs. Data revealing racial or ethnic origin.
Persons concerned: Prospective customers. Business and contractual partners.
Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; contact requests and communication; office and organisational procedures. Administration and response to enquiries.
Legal grounds: Contractual performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 p. 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).
Further information on processing, procedures and services:
Coaching: We process the data of our clients as well as interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to be able to provide our services to them. The data processed, the nature, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship. In the course of our activities, we may also process special categories of personal data, in particular information on the health of clients, possibly with reference to their sex life or sexual orientation, as well as data revealing racial and ethnic origin, political opinions, religious or ideological beliefs or trade union membership. For this purpose, we obtain the explicit consent of the client, if required, and process the special categories of personal data otherwise if this serves the health of the client, the data are public or other legal permissions exist.If it is necessary for the fulfilment of our contract, for the protection of vital interests or required by law, or if the consent of the client exists, we disclose or transfer the client’s data to third parties or agents, e.g. authorities, billing offices and in the area of IT, office or comparable services, in compliance with the requirements of professional law; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) GDPR).
Consulting: We process the data of our clients, customers as well as interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to be able to provide them with our advisory services. The data processed, the type, scope, purpose and necessity of its processing are determined by the underlying contractual and client relationship. If it is necessary for the fulfilment of our contract, for the protection of vital interests or required by law, or if the clients have given their consent, we disclose or transfer the clients’ data to third parties or agents, such as authorities, subcontractors or in the area of IT, office or comparable services, in compliance with the requirements of professional law; Legal basis: fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) GDPR).
Providers and services used in the course of business activities
In the course of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers (“services”) in compliance with legal requirements. Their use is based on our interests in the proper, lawful and economic management of our business operations and our internal organisation.
Types of data processed: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms). Contract data (e.g. subject matter of the contract, term, customer category).
Persons concerned: Customers; interested parties; users (e.g. website visitors, users of online services). Business and contractual partners.
Purposes of processing: provision of contractual services and fulfilment of contractual obligations. Office and organisational procedures.
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 end device.
Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status); content data (e.g. entries in online forms).
Persons concerned: 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 equipment (computers, servers, etc.)); security measures.
Further information on processing processes, procedures and services::
Provision of online offer on rented storage space: or 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 bases: legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).
Collection of access data and log files: Access to our online offer is logged in the form of so-called “server log files”. The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.The server log files may be used for security purposes, for example, to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilisation of the servers and their stability; Legal bases: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the final clarification of the respective incident.
E-Mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of recognising SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption procedure is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server; Legal bases: legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).
ALL-INKL: Services in the field of provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: ALL-INKL.COM – Neue Medien Münnich, Owner: René Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany; Legal bases: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR); Website:https://all-inkl.com/; Privacy policy:https://all-inkl.com/datenschutzinformationen/. Order processing contract: Provided by the service provider.
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data are processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. Beyond this, 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 and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
Persons concerned: Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; feedback (e.g. collecting feedback via online form); provision of our online offer and user-friendliness; security measures; administration and response to enquiries.
Further guidance on processing operations, procedures and services:
Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests.
This is done for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author. Furthermore, we reserve the right, based on our legitimate interests, to process the information of users for the purpose of spam detection. On the same legal basis, we reserve the right, in the case of surveys, to store the IP addresses of users for their duration and to use cookies to avoid multiple voting. The personal information provided in the context of comments and contributions, any contact and website information as well as the content-related information will be permanently stored by us until the user objects; Legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).
When contacting us (e.g. by post, contact form, email, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any measures requested.
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 and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
Concerned persons: Communication partners.
Purpose of processing: contact requests and communication; managing and responding to requests; feedback (e.g. collecting feedback via online form). Provision of our online offer and user friendliness.
Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO). Contract fulfillment and pre-contractual enquiries (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 fulfillment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) GDPR); legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).
Video conferencing, online meetings, webinars and screen sharing
We use platforms and applications from other providers (hereinafter referred to as “conferencing platforms”) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as “conference”). When selecting the conference platforms and their services, we observe the legal requirements. Data processed by conference platforms:In the context of participation in a conference, the conference platforms process the personal data of the participants mentioned below. The scope of the processing depends, on the one hand, on which data is requested in the context of a specific conference (e.g., provision of access data or clear names) and which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants’ data may also be processed by the conference platforms for security purposes or service optimization. The processed data includes personal data (first name, last name), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the Internet access, information on the participants’ end devices, their operating system, the browser and its technical and language settings, information on the content of communications, i.e. entries in chats and audio and video data, as well as the use of other available functions (e.g. surveys). Contents of communications are encrypted to the extent technically provided by the conference providers. If the participants are registered as users with the conference platforms, then further data may be processed in accordance with the agreement with the respective conference provider. Logging and recordings: If text entries, participation results (e.g., from surveys), and video or audio recordings are logged, this will be transparently communicated to participants in advance and they will be asked for consent – if necessary. Data protection measures of the participants: Please note the details of the processing of your data by the conference platforms in their data protection notices and select the security and data protection settings that are optimal for you within the framework of the settings of the conference platforms. Furthermore, please ensure data and privacy protection in the background of your recording for the duration of a videoconference (e.g., by notifying roommates, locking doors, and using the background obscuring function, if technically possible). Links to the conference rooms as well as access data, must not be passed on to unauthorized third parties. Notes on legal basis: If, in addition to the conference platforms, we also process users’ data and ask users for their consent to use the conference platforms or certain functions (e.g., consent to a recording of conferences), the legal basis for the processing is this consent. Furthermore, our processing may be necessary for the fulfillment of our contractual obligations (e.g. in lists of participants, in the case of reprocessing of call results, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.
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 and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
Persons concerned: Communication partners; users (e.g., website visitors, users of online services); persons depicted.
Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; contact requests and communication; office and organizational procedures.
We use software services accessible via the Internet and running on the servers of their providers (so-called “cloud services”, also referred to as “software as a service”) for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with certain recipients or publication of content and information). In this context, personal data may be processed and stored on the servers of the providers to the extent that these are part of communication processes with us or are otherwise processed by us as set out in the context of this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents. The cloud service providers also process usage data and metadata used by them for security purposes and service optimisation. If we use the cloud services to provide forms or other documents and content to other users or publicly accessible websites, the providers may store cookies on the users’ devices for the purposes of web analysis or to remember the users’ settings (e.g. in the case of media control).
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 and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
Persons concerned: Customers; employees (e.g. employees, applicants, former employees); interested parties. Communication partners.
Purpose of processing: Office and organisational procedures. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.).
Nextcloud (hosted on own server): Cloud storage service where the operation and storage of processed data takes place on a server managed by us; Service provider: Nextcloud GmbH, Hauptmannsreute 44a, 70192 Stuttgart, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR) Website:https://nextcloud.com/de/. Privacy policy:https://nextcloud.com/de/privacy/.
Web analysis, monitoring and optimisation
Web analysis (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the reach analysis, we can, for example, recognise at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimisation. In addition to web analysis, we may also use test procedures, for example, to test and optimise different versions of our online offer or its components. Unless otherwise stated below, profiles, i.e. data summarised for a usage process, can be created for these purposes and information can be stored in a browser or in an end device and read from it. The information collected includes, in particular, websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed. The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimisation, but pseudonyms. This means that we as well as the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.
Types of data processed: Usage data (e.g. web pages visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
Persons concerned: Users (e.g. website visitors, users of online services).
Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors). Profiles containing user-related information (creation of user profiles).
Security measures: IP masking (pseudonymisation of the IP address).
Further information on processing, procedures and services:
Matomo (without cookies): Matomo is a data protection-friendly web analysis software that is used without cookies and in which the recognition of returning users is carried out with the help of a so-called “digital fingerprint”, which is stored anonymously and changed every 24 hours; with the “digital fingerprint”, user movements within our online offer are recorded with the help of pseudonymised IP addresses in combination with user-side browser settings in such a way that conclusions about the identity of individual users are not possible. The user data collected in the context of the use of Matomo is only processed by us and is not shared with third parties; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR). Website:https://matomo.org/.
Customer reviews and rating procedures
We participate in review and rating procedures in order to evaluate, optimise and promote our services. If users rate us or otherwise provide feedback via the participating rating platforms or procedures, the General Terms and Conditions of Business or Use and the data protection information of the providers also apply. As a rule, the rating also requires registration with the respective providers. In order to ensure that the persons rating have actually used our services, we transmit, with the consent of the customers, the data required with regard to the customer and the service used to the respective rating platform (including name, e-mail address and order number or item number). This data is used solely to verify the authenticity of the user.
Types of data processed: Contract data (e.g. subject matter of contract, term, customer category); usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
Further guidance on processing operations, procedures and services:
Google customer reviews: Service for obtaining and/or displaying customer satisfaction and customer opinions; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR); General Terms and Conditions:https://support.google.com/merchants/topic/7259129?hl=de&ref_topic=7257954; Privacy Policy:https://policies.google.com/privacy; Basis for third country transfer: EU-US Data Privacy Framework (DPF); Further information: In the context of obtaining customer reviews, an identification number as well as the time for the business transaction to be evaluated are processed. In the case of review requests sent directly to customers, the customer’s email address as well as their country of residence information as well as the review information itself are processed; further information on the types of processing as well as the data processed: https://privacy.google.com/businesses/adsservices. Data processing conditions for Google advertising products: Information on services Data processing terms and conditions between data controllers and standard contractual clauses for third country transfers of data: : https://business.safety.google/adscontrollerterms.
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 within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behaviour and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behaviour and the interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them). For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks. In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
Types of data processed: Contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
Persons concerned: Users (e.g. website visitors, users of online services).
Purposes of processing: Contact requests and communication; feedback (e.g. collecting feedback via online form).
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 presentation of these contents or functions. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to analyse information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offering, as well as being linked to such information from other sources.
Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms).
Persons concerned: Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of our online offer and user-friendliness. Feedback (e.g. collecting feedback via online form)
Further information on processing, 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) GDPR).
We use services, platforms and software from other providers (hereinafter referred to as “third-party providers”) for the purposes of organising, managing, planning and providing our services. When selecting the third-party providers and their services, we observe the legal requirements. In this context, personal data may be processed and stored on the servers of the third-party providers. This may involve various data which we process in accordance with this data protection declaration. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents. If users are referred to the third-party providers or their software or platforms in the course of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimisation or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.
Types of data processed: Content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status); inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers).
Persons concerned: Communication partners; users (e.g. website visitors, users of online services).
Purposes of processing: Contact requests and communication; provision of contractual services and fulfilment of contractual obligations; office and organisational procedures.
Trello: Project management tool; Service provider: Trello Inc., 55 Broadway New York, NY 10006, USA, Parent company: Atlassian Inc. (San Francisco, Harrison Street Location), 1098 Harrison Street, San Francisco, California 94103, USA; Legal basis: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) GDPR); Website:https://trello.com/; Privacy policy:https://trello.com/privacy; Third country transfer basis: EU-US Data Privacy Framework (DPF), Standard contractual clauses (provided by the service provider). Further information: Data Transfer Impact Assessment: https://www.atlassian.com/legal/data-transfer-impact-assessment.
WeTransfer: Transfer of files over the Internet; Service provider: WeTransfer BV, Oostelijke Handelskade 751, Amsterdam, 1019 BW, The Netherlands; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR); Website:https://wetransfer.com. Privacy policy:https://wetransfer.com/legal/privacy.
Amendment and updating of the data protection declaration
We kindly 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. Where we provide addresses and contact details of companies and organisations in this privacy statement, please note that the addresses may change over time and please check the details before contacting us.
Definitions
This section provides you with an overview of the terms used in this privacy statement. Where terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to help you understand them.
Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject” or “person concerned”); 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 of using these personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
Reach measurement: Reach measurement (also referred to as web analytics) is used to evaluate the visitor flows of an online offer and can include the behaviour or interests of visitors 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 reach analysis purposes, pseudonymous cookies and web beacons are often used to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
Controller: Controller: “Controller” (also refereed to as “responsible person”) is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
Processing: “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and encompasses virtually any handling of data, be it collection, analysis, storage, transmission or erasure.
