Data protection

Fischbacher » Data protection

Privacy Policy

Introduction

With the following privacy policy, we would like to inform you about which types of your personal data (hereinafter also referred to as „data“) we process, for what purposes, and to what extent. This privacy policy 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, mobile devices, and within external online presences, such as our social media profiles (hereinafter collectively referred to as „online offering“).

The terms used are not gender-specific.

As of: 15.01.2022

Table of Contents

Person responsible

Fischbacher GmbH + Co. KG
Dessauerstraße 9
80992 Munich
Germany

Email-Adresse: info@fischbacher.de
Phone: +49-89-14 99 08-0
Imprint: https://fischbacher.de/imprint/

Contact Data Protection Officer

Fischbacher GmbH + Co. KG
Dessauerstraße 9
80992 Munich
Germany

E-mail address: info@fischbacher.de

Overview of processing

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

Types of data processed

  • Inventory data (e.g. names, addresses).
  • Content data (e.g. entries in online forms).
  • Contact details (e.g. email, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Location data (information about the geographical position of a device or person).
  • Contract data (e.g. subject matter of the contract, term, customer category).
  • Payment data (e.g. bank details, invoices, payment history).

Categories of affected individuals

  • Business and contractual partners.
  • Interested parties.
  • Communication partner.
  • Customers.
  • Users (e.g. website visitors, users of online services).

Purposes of processing

  • Assessment of creditworthiness and credit rating.
  • Provision of our online offering and user-friendliness.
  • Visit action analysis.
  • Office and organizational procedures.
  • Cross-device tracking (processing of user data across devices for marketing purposes).
  • Direct marketing (e.g. by email or post).
  • Interest-based and behavioral marketing.
  • Contact requests and communication.
  • Conversion measurement (measuring the effectiveness of marketing measures).
  • Profiling (creation of user profiles).
  • Remarketing.
  • Reach measurement (e.g. access statistics, recognition of recurring visitors).
  • Security measures.
  • Tracking (e.g. interest/behavior-based profiling, use of cookies).
  • Provision of contractual services and customer service.
  • Managing and responding to inquiries.
  • Target group building (determination of target groups relevant for marketing purposes or other output of content).

Automated decisions in individual cases

  • Credit report (decision based on a credit check).

Relevant legal bases

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

  • Consent (Article 6 (1) (a) GDPR) – The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
  • Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.
  • Legal obligation (Art. 6 (1) (c) GDPR) – Processing is necessary to fulfill a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 (1) (f) GDPR) – Processing is necessary to protect the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject which require protection of personal data prevail.

Security measures

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

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as the access, input, and transfer of data, ensuring its availability, and segregation. Furthermore, we have established procedures that ensure the exercise of data subjects‘ rights, the deletion of data, and responses to data threats. Furthermore, we consider the protection of personal data right from the development and selection of hardware, software, and processes in accordance with the principle of data protection, through technology design, and through data protection-friendly default settings.

SSL encryption (https): To protect the data you transmit via our online service, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in your browser’s address bar.

Transfer and disclosure of personal data

As part of our processing of personal data, it may happen that the data is transmitted to or disclosed to other bodies, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks, or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

Data processing in third countries

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

Subject to express consent or contractually or legally required transmission, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, if certifications or binding internal data protection regulations are in place (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

Use of cookies

Cookies are small text files or other storage devices that store information on end devices and read information from end devices. For example, they can store the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed, or the functions used in an online offering. Cookies can also be used for various purposes, such as ensuring the functionality, security, and convenience of online offerings, as well as creating analyses of visitor flows.

Notes on consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, unless this is not required by law. Consent is particularly unnecessary if the storage and retrieval of information, including cookies, is absolutely necessary to provide users with a telemedia service they have expressly requested (i.e., our online offering). The revocable consent will be clearly communicated to users and will contain information about the respective cookie usage.

Notes on data protection legal bases: The data protection legal basis 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 with the help of cookies is processed on the basis of our legitimate interests (e.g., in the commercial operation of our online offering and improving its usability) or, if this occurs within the scope of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We clarify 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 period: With regard to the storage period, 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 offering and closed their device (e.g. browser or mobile application).
  • Persistent cookies: Persistent cookies remain stored even after the 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, the user data collected through cookies can be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g., when obtaining consent), users should assume that cookies are permanent and can be stored for up to two years.

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke your consent or to object to the processing of your data using cookie technologies (collectively referred to as „opt-out“). You can initially declare your objection using your browser settings, e.g., by deactivating the use of cookies (although this may also limit the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared using a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. You can also obtain further objection notices within the framework of the information on the service providers and cookies used.

Processing of cookie data based on consent: We use a cookie consent management procedure within which users‘ consent to the use of cookies or the processing operations and providers named in the cookie consent management procedure can be obtained, managed and revoked by users. The declaration of consent is saved so that it does not have to be requested again and so that consent can be proven in accordance with legal obligations. 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 consent to a user or their device. Subject to individual information about the providers of cookie management services, the following information applies: Consent can be stored for up to two years. A pseudonymous user identifier is created and stored along with the time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and device used.

Cookie settings/opt-out option:

Commercial and business services

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

We process this data to fulfill our contractual obligations, to protect our rights, and for the purposes of the administrative tasks associated with this information, as well as for business organization. Within the framework of applicable law, we only pass on the data of our contractual partners to third parties to the extent necessary for the aforementioned purposes or to fulfill legal obligations, or with the consent of the data subjects (e.g., to participating telecommunications, transport, and other auxiliary services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Contractual partners will be informed about other forms of processing, e.g., for marketing purposes, in this privacy policy.

We will inform our contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.

We delete data after the expiration of statutory warranty and similar obligations, i.e., generally after four years, unless the data is stored in a customer account, e.g., for as long as it must be retained for legal archiving reasons (e.g., for tax purposes, usually for ten years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the terms of the order, generally after the end of the order.

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

Customer account: Contracting parties can create an account within our online offering (e.g., customer or user account, „customer account“ for short). If registration of a customer account is required, contracting parties will be informed of this, as well as the information required for registration. Customer accounts are not public and cannot be indexed by search engines. During registration, as well as subsequent logins and use of the customer account, we store the customer’s IP addresses along with the access times in order to verify registration and prevent any misuse of the customer account.

Once customers have terminated their account, the data relating to the account will be deleted, unless retention is required for legal reasons. It is the customer’s responsibility to back up their data upon termination of the account.

Economic analyses and market research: For business reasons and in order to identify market trends and the wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, inquiries, etc., whereby the group of data subjects may include contractual partners, interested parties, customers, visitors and users of our online offering.

The analyses are carried out for the purposes of business evaluations, marketing, and market research (e.g., to identify customer groups with different characteristics). We may, where available, consider the profiles of registered users, including their information, e.g., regarding services used. The analyses serve our sole purpose and are not disclosed externally unless they are anonymous analyses with summarized, i.e., anonymized values. Furthermore, we respect the privacy of users and process the data for analysis purposes pseudonymously and, where feasible, anonymously (e.g., as summarized data).

Shop and e-commerce: We process our customers‘ data to enable them to select, purchase, or order the selected products, goods, and related services, as well as to pay for and deliver them or execute them. If necessary to execute an order, we use service providers, in particular postal, forwarding, and shipping companies, to carry out delivery or execution for our customers. We utilize the services of banks and payment service providers to process payment transactions. The required information is marked as such within the ordering or similar purchase process and includes the information needed for delivery, provision, and billing, as well as contact information for any follow-up questions.

  • Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. email, telephone numbers), contract data (e.g. subject of the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: interested parties, business and contractual partners, customers.
  • Purposes of processing: Provision of contractual services and customer service, contact requests and communication, office and organizational procedures, administration and response to inquiries, security measures, visitor action analysis, interest-based and behavioral marketing, profiling (creation of user profiles).
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

Payment service providers

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

The data processed by the payment service providers includes inventory data, such as name and address, bank details such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, amount, and recipient-related information. This information is required to process the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account- or credit card-related information, only information confirming or rejecting the payment. Under certain circumstances, the payment service providers may transmit the data to credit agencies. This transmission is for the purpose of identity and credit checks. For more information, please refer to the terms and conditions and the privacy policy of the payment service providers.

Payment transactions are subject to the terms and conditions and privacy policy of the respective payment service providers, which are available on the respective websites or transaction applications. We also refer to these for further information and to assert your rights of withdrawal, information, and other data subjects.

  • Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: customers, interested parties.
  • Purposes of processing: Provision of contractual services and customer service.
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

Services and service providers used:

Credit check

If we make advance payments or assume comparable economic risks (e.g. when ordering on account), we reserve the right, in order to safeguard our legitimate interests, to obtain an identity and credit report from specialised service providers (credit agencies) for the purpose of assessing the credit risk on the basis of mathematical and statistical procedures.

We process the information received from credit agencies regarding the statistical probability of a payment default as part of a reasonable discretionary decision regarding the establishment, implementation, and termination of the contractual relationship. We reserve the right to refuse payment on account or any other advance payment in the event of a negative credit check result.

The decision as to whether we make advance payments is made in accordance with Art. 22 GDPR solely on the basis of an automated decision in the individual case, which our software makes on the basis of the information provided by the credit agency.

If we obtain express consent from contractual partners, the legal basis for the credit check and the transmission of the customer’s data to the credit agencies is their consent. If no consent is obtained, the credit check is based on our legitimate interest in ensuring the reliability of our payment claims.

  • 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 of the contract, term, customer category).
  • Affected persons: customers, interested parties.
  • Purposes of processing: Assessment of creditworthiness and credit rating.
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
  • Automated decisions in individual cases: Credit report (decision based on a credit check).

Services and service providers used:

Note: Remove the credit check section if you do not conduct a credit check. Review and amend the list of service providers as needed. Checking a customer’s creditworthiness is permissible if there is otherwise a risk of non-payment, i.e., if the goods are delivered without payment being received (i.e., if the customer chooses to purchase on account). However, there is no risk of non-payment if the customer chooses the prepayment option or makes the payment via a third-party provider, such as PayPal.

It should also be noted that obtaining an automated credit report constitutes an „automated decision in individual cases“ according to Art. 22 GDPR, i.e., a legal decision without human intervention. This is permissible if the customer has consented or if this decision is necessary for the conclusion of the contract. Whether the decision is necessary has not yet been conclusively clarified, but is often argued as a given, including by the author of this sample.

However, if you want to eliminate any risk, you should obtain consent. Consent is also required if the credit check is already being used to decide whether the „pay on account“ option should be displayed. It’s possible that the customer would have opted for prepayment or PayPal anyway, and the credit check would not have been necessary. Such consent could, for example, be as follows:

 I agree that a credit check will be conducted to determine, using an automated process (Article 22 GDPR), whether the option to purchase on account will be offered. Further information on the credit check, the credit agencies used, the process, and the options for objection can be found in our [Link]privacy policy[/Link].

Provision of the online offer and web hosting

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

The data processed in the context of providing the hosting service may include all information concerning the users of our online offering that arises during use and communication. This usually includes the IP address, which is necessary to deliver the content of online offerings to browsers, and all entries made within our online offering or on websites.

Email sending and hosting: The web hosting services we use also include the sending, receiving, and storing of emails. For these purposes, the addresses of the recipients and senders, as well as other information regarding the email sending (e.g., the providers involved), and the content of the respective emails are processed. The aforementioned data may also be processed for the purpose of detecting spam. Please note that emails are generally not sent encrypted over the Internet. Emails are generally encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We therefore cannot assume any responsibility for the transmission path of the emails between the sender and the recipient on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). Server log files may include the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user’s operating system, the referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider.

The server log files can be used for security purposes, e.g. to avoid overloading the servers (particularly in the case of abusive attacks, so-called DDoS attacks) and to ensure the utilization of the servers and their stability.

  • Types of data processed: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

Contact us

When you contact us (e.g. via contact form, email, telephone or social media), the information provided by the person making the inquiry will be processed to the extent necessary to answer the contact inquiries and any requested measures.

Contact requests within the framework of contractual or pre-contractual relationships are answered to fulfill our contractual obligations or to answer (pre-)contractual requests and, moreover, on the basis of our legitimate interests in answering the requests.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: communication partners, interested parties.
  • Purposes of processing: contact requests and communication, administration and response to inquiries.
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

Services and service providers used:

  • Contact form: If users contact us via our contact form, email, or other communication channels, we process the data provided to us in this context to process the communicated request. For this purpose, we process personal data within the framework of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfillment, and otherwise based on our legitimate interests as well as the interests of our communication partners in responding to the requests and our statutory retention periods.

Newsletters and electronic notifications

We send newsletters, emails, and other electronic notifications (hereinafter „newsletters“) only with the recipient’s consent or legal permission. If the newsletter’s content is specifically described when registering for the newsletter, it is decisive for the user’s consent. Furthermore, our newsletters contain information about our services and us.

To subscribe to our newsletter, it is generally sufficient to provide your email address. However, we may ask you to provide a name for the purpose of addressing you personally in the newsletter, or other information if this is necessary for the purposes of the newsletter.

Double opt-in process: Registration for our newsletter is generally carried out using a so-called double opt-in process. This means that after registration, you will receive an email asking you to confirm your registration. This confirmation is necessary to prevent anyone from registering using someone else’s email address. Newsletter registrations are logged to provide evidence of the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation, as well as the IP address. Changes to your data stored by the shipping service provider are also logged.

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

The registration process is logged based on our legitimate interests for the purpose of demonstrating its proper execution. If we commission a service provider to send emails, this is done based on our legitimate interests in an efficient and secure delivery system.

Notes on legal bases: The newsletter is sent based on the recipient’s consent or, if consent is not required, on our legitimate interest in direct marketing, if and to the extent that this is permitted by law, e.g., in the case of advertising to existing customers. If we commission a service provider to send emails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to demonstrate that it was carried out in accordance with the law.

Content: Information about us, our services, promotions and offers.

Analysis and performance measurement: The newsletters contain a so-called „web beacon,“ i.e., a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from its server. During this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, is initially collected.

This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened, and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our aim nor, if used, that of the shipping service provider to observe individual users. Rather, the evaluations serve to identify the reading habits of our users and adapt our content to them or to send different content based on the interests of our users.

The evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the user, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves both our business interests and meets the expectations of the users.

Unfortunately, a separate revocation of the performance measurement is not possible; in this case, the entire newsletter subscription must be canceled or revoked.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
  • Data subjects: communication partners.
  • Purposes of processing: Direct marketing (e.g. by email or post).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
  • Opt-out: You can unsubscribe from our newsletter at any time, i.e., revoke your consent or object to further receipt. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or by using one of the contact options listed above, preferably email.

Services and service providers used:

Web analysis, monitoring and optimization

Web analytics (also known as „reach measurement“) is used to evaluate visitor traffic to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. Reach analysis allows us, for example, to determine when our online offering or its features or content are most frequently used or encourage reuse. Likewise, we can understand which areas require optimization.

In addition to web analysis, we can also use testing procedures to, for example, test and optimize different versions of our online offering or its components.

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

Users‘ IP addresses are also collected. However, we use an IP masking process (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no user data (such as email addresses or names) is stored for web analysis, A/B testing, and optimization; instead, pseudonyms are used. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: reach measurement (e.g. access statistics, recognition of recurring visitors), tracking (e.g. interest/behavior-related profiling, use of cookies), visit action analysis, profiling (creation of user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Services and service providers used:

Online marketing

We process personal data for the purposes of online marketing, which may include, in particular, the marketing of advertising space or the presentation of advertising and other content (collectively referred to as „content“) based on the potential interests of users and the measurement of their effectiveness.

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

Users‘ IP addresses are also collected. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no user data (such as email addresses or names) is stored as part of the online marketing process; instead, pseudonyms are used. This means that neither we nor the providers of the online marketing process know the actual identity of the users, only the information stored in their profiles.

The information in profiles is usually stored in cookies or similar processes. These cookies can generally also be read later on other websites that use the same online marketing process, analyzed for the purpose of displaying content, and supplemented with additional data and stored on the server of the online marketing process provider.

In exceptional cases, clear data may be assigned to profiles. This is the case, for example, if the users are members of a social network whose online marketing processes we use, and the network links the users‘ profiles with the aforementioned information. Please note that users may enter into additional agreements with the providers, e.g., by providing consent during registration.

We generally only receive access to aggregated information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. Conversion measurements are used solely to analyze the success of our marketing measures.

Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographical position of a device or person).
  • Data subjects: users (e.g. website visitors, users of online services), interested parties.
  • Purposes of processing: Tracking (e.g. interest/behavior-related profiling, use of cookies), remarketing, visitor action analysis, interest-based and behavior-related marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of recurring visitors), target group formation (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
  • Possibility of objection (Opt-Out): We refer to the privacy policies of the respective providers and the opt-out options provided for each provider. If no explicit opt-out option has been provided, you can disable cookies in your browser settings. However, this may limit the functionality of our online offering. We therefore recommend the following opt-out options, which are summarized for each region: a) Europe: https://www.youronlinechoices.eu.
    b) Canada: https://www.youradchoices.ca/choices.
    c) USA: https://optout.aboutads.info.
    d) Cross-regional: https://optout.aboutads.info.

Services and service providers used:

  • Facebook Pixel and Target Group Creation (Custom Audiences): With the help of the Facebook pixel (or comparable functions for transmitting event data or contact information via interfaces in apps), Facebook is able to determine visitors to our online offering as a target group for displaying advertisements (so-called „Facebook Ads“). Accordingly, we use the Facebook pixel to display the Facebook ads we place only to users on Facebook and within the services of partners cooperating with Facebook (so-called „Audience Network“ https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offering or who exhibit certain characteristics (e.g., interest in certain topics or products, which can be seen from the websites visited) that we transmit to Facebook (so-called „Custom Audiences“). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interests of users and are not annoying. With the help of the Facebook pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called „conversion measurement“). Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Standard contractual clauses (ensuring data protection levels when processing in third countries): The „Facebook EU Data Transfer Supplement“ (https://www.facebook.com/legal/EU_data_transfer_addendum) in the case of order processing by Facebook as the basis for the processing of event data of EU citizens in the USA and the inclusion in the „Facebook Platform Terms of Use“ (https://developers.facebook.com/terms) with regard to the independent processing of event data by Facebook in the context of advertising; Further information: The „Data Processing Conditions“ (https://www.facebook.com/legal/terms/dataprocessing/update) with regard to event data that Facebook processes on its behalf to provide companies with reports and analyses; Furthermore, the „Controller Addendum“ is considered a joint controllership agreement (Art. 26 (1) (3) GDPR), which is relevant in the case of Facebook’s independent processing of event data for the purposes of targeting, improving, and securing Facebook products.
  • Google Ad Manager: We use the „Google Marketing Platform“ (and services such as „Google Ad Manager“) to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.). The Google Marketing Platform is characterized by the fact that ads are displayed in real time based on the presumed interests of users. This allows us to display ads for and within our online offering more specifically, in order to present users only ads that potentially match their interests. If, for example, a user is shown ads for products in which they have shown interest on other online offerings, this is referred to as „remarketing.“ Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy Further information: Types of processing and the data processed: https://privacy.google.com/businesses/adsservices; Data processing terms for Google advertising products: Information about the services, data processing terms between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms; if Google acts as a processor, data processing terms for Google advertising products and standard contractual clauses for third country transfers of data: https://business.safety.google/adsprocessorterms.
  • Google Ads and conversion measurement: We use the online marketing process „Google Ads“ to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who are likely to be interested in the ads (so-called „conversion“). We also measure the conversion of the ads. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page with a so-called „conversion tracking tag.“ However, we do not receive any information that could be used to identify users. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Further information: Types of processing and the data processed: https://privacy.google.com/businesses/adsservices; Data processing terms for Google advertising products: Information about the services, data processing terms between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.

Presences in social networks (social media)

We maintain online presences within social networks and, in this context, process user data in order to communicate with the 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 could pose risks for users, for example, because it could make it more difficult to enforce their rights.

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of users. These user profiles can then 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 generally stored on users‘ computers, in which the user behavior and interests are stored. Furthermore, user profiles can also store data independent of the devices used by the users (particularly if the users are members of the respective platforms and are logged in to them).

For a detailed description of the respective processing methods and the options for opting out, please refer to the privacy policies 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 like to point out that these can be most effectively asserted with the providers. Only the providers have access to the user data and can directly take appropriate measures and provide information. If you still need assistance, please contact us.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: contact requests and communication, tracking (e.g. interest/behavior-based profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of recurring visitors).
  • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

Services and service providers used:

Plugins and embedded functions and content

We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as „third-party providers“). These may include, for example, graphics, videos, social media buttons, and posts (hereinafter collectively referred to as „content“).

Integration always requires that the third-party providers of this content process the user’s IP address, as without the IP address they would not be able to send the content to their browser. The IP address is therefore required to display this content or functions. We endeavor 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. These „pixel tags“ can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, the time of visit and other information about the use of our online offering, as well as be linked to such information from other sources.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographical position of a device or person), content data (e.g. entries in online forms), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
  • Data subjects: users (e.g. website visitors, users of online services), communication partners.
  • Purposes of processing: Provision of our online offering and user-friendliness, provision of contractual services and customer service, contact requests and communication, tracking (e.g. interest/behavior-related profiling, use of cookies), interest-based and behavior-related marketing, profiling (creation of user profiles), security measures, administration and response to inquiries.
  • Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR), consent (Art. 6 (1) (a) GDPR), contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).

Services and service providers used:

  • Facebook plugins and content: Facebook social plugins and content – This can include, for example, content such as images, videos, or text and buttons that users can use to share content from this online offering within Facebook. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/ – We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt during a transmission (but not the further processing) of „event data“ that Facebook collects or receives during a transmission using the Facebook social plugins (and content embedding functions) that run on our online offering for the following purposes: a) Displaying content and advertising information that corresponds to the presumed interests of users; b) Delivery of commercial and transaction-related messages (e.g., addressing users via Facebook Messenger); c) Improving ad delivery and personalizing features and content (e.g., improving the recognition of which content or advertising information presumably corresponds to users‘ interests). We have concluded a special agreement with Facebook („Controller Addendum“, https://www.facebook.com/legal/controller_addendum), which specifically regulates the security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the rights of those affected (i.e., users can, for example, submit information or deletion requests directly to Facebook). Note: If Facebook provides us with metrics, analyses, and reports (which are aggregated, i.e., do not contain any information about individual users and are anonymous to us), this processing is not carried out within the framework of joint controllership, but on the basis of a data processing agreement („Data Processing Terms“, https://www.facebook.com/legal/terms/dataprocessing), the „Data Security Terms“ (https://www.facebook.com/legal/terms/data_security_terms), and, with regard to processing in the USA, on the basis of standard contractual clauses („Facebook EU Data Transfer Addendum“, https://www.facebook.com/legal/EU_data_transfer_addendum). Users‘ rights (in particular the right to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy.
  • Google Fonts: We integrate the fonts („Google Fonts“) of the provider Google. User data is used solely for the purpose of displaying the fonts in the user’s browser. This integration is based on our legitimate interests in the technically secure, maintenance-free, and efficient use of fonts, their consistent display, and taking into account possible licensing restrictions for their integration. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://fonts.google.com/; privacy policy: https://policies.google.com/privacy.
  • Google Maps: We integrate the maps of the „Google Maps“ service provided by Google. The data processed may include, in particular, IP addresses and location data of users, which, however, are not collected without their consent (usually implemented as part of the settings on their mobile devices). Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://mapsplatform.google.com; privacy policy: https://policies.google.com/privacy; opt-out option: opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • reCAPTCHA: We integrate the „reCAPTCHA“ function to be able to recognize whether entries (e.g. in online forms) are made by humans and not by automatically acting machines (so-called „bots“). The data processed may include IP addresses, information about operating systems, devices or browsers used, language settings, location, mouse movements, keyboard strokes, time spent on websites, previously visited websites, interactions with ReCaptcha on other websites, possibly cookies, and results of manual recognition processes (e.g. answering questions asked or selecting objects in images). Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://www.google.com/recaptcha/; privacy policy: https://policies.google.com/privacy; Opt-out option: Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • Twitter plugins and content: Twitter plugins and buttons – This can include, for example, content such as images, videos or texts and buttons with which users can share content from this online offer within Twitter; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, parent company: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Website: https://twitter.com/de; Privacy Policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
  • YouTube videos: video content; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://www.youtube.com; privacy policy: https://policies.google.com/privacy; opt-out option: opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.

Deletion of data

The data we process will be deleted in accordance with legal requirements as soon as the consent to processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or it is no longer required for the purpose).

Unless the data is deleted because it is required for other legally permissible purposes, its processing will be limited to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons, or whose storage is necessary to assert, exercise, or defend legal claims or to protect the rights of another natural or legal person.

Further information on the deletion of personal data can also be found in the individual data protection notices of this data protection declaration.

Changes and updates to the privacy policy

We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g., consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting us.

Rights of data subjects

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

  • Right of objection: You have the right to object at any time to the processing of personal data concerning you based on Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw consent at any time.
  • Right to information: You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: You have the right, in accordance with the statutory provisions, to request that the data concerning you be completed or that inaccurate data concerning you be corrected.
  • Right to erasure and restriction of processing: You have the right, in accordance with the statutory provisions, to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
  • Right to data portability: You have the right to receive the data concerning 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 transmitted to another controller.
  • Complaint to a supervisory authority: You also have the right, in accordance with the statutory provisions, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you believe that the processing of personal data concerning you violates the GDPR.

Definitions of terms

This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined primarily in Art. 4 GDPR. The legal definitions are binding. The following explanations, however, are primarily intended to facilitate understanding. The terms are sorted alphabetically.

  • Conversion tracking: „Conversion tracking“ is a process used to determine the effectiveness of marketing measures. This typically involves storing a cookie on the user’s device within the websites where the marketing measures are carried out and then retrieving it on the target website. For example, this allows us to track whether the ads we place on other websites were successful.
  • Credit report: Automated decisions are based on automatic data processing without human intervention (e.g., in the case of an automatic rejection of a purchase on account, an online credit application, or an online application process without any human intervention). According to Art. 22 GDPR, such automated decisions are only permissible if the data subject consents, if they are necessary for the performance of a contract, or if national law permits these decisions.
  • Cross-device tracking: Cross-device tracking is a form of tracking in which user behavior and interest information is collected across devices in so-called profiles by assigning users an online identifier. This allows user information to be analyzed for marketing purposes, regardless of the browser or device used (e.g., mobile phones or desktop computers). For most providers, the online identifier is not linked to clear data such as names, postal addresses, or email addresses.
  • IP masking: „IP masking“ is a method in which the last octet, i.e., the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing procedures, especially in online marketing.
  • Interest-based and behavioral marketing: Interest-based and/or behavioral marketing refers to the process of determining users‘ potential interests in advertisements and other content as precisely as possible. This is done based on information about their previous behavior (e.g., visiting and staying on certain websites, purchasing behavior, or interactions with other users), which is stored in a so-called profile. Cookies are typically used for these purposes.
  • Conversion measurement: Conversion measurement is a method used to determine the effectiveness of marketing measures. This typically involves storing a cookie on users‘ devices within the websites where the marketing measures are carried out and then retrieving it on the target website. For example, this allows us to understand whether the ads we place on other websites were successful.
  • Personal data: „Personal data“ means any information relating to an identified or identifiable natural person (hereinafter „data subject“); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiling: „Profiling“ refers to any form of automated processing of personal data consisting of the use of personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information relating to age, gender, location and movement data, interaction with websites and their content, purchasing behavior, social interactions with other people) (e.g., interests in certain content or products, click behavior on a website, or location). Cookies and web beacons are often used for profiling purposes.
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate visitor traffic to an online offering and can include visitor behavior or interest in specific information, such as website content. With the help of reach analysis, website owners can, for example, identify when visitors visit their website and what content they are interested in. This allows them to better adapt the website content to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
  • Remarketing: „Remarketing“ or „retargeting“ is the term used when, for advertising purposes, the products a user was interested in on a website are noted in order to remind the user of these products on other websites, e.g. in advertisements.
  • Location data: Location data is generated when a mobile device (or other device with the technical capabilities for location determination) connects to a cell tower, a Wi-Fi network, or similar technical intermediaries and location determination functions. Location data is used to indicate the geographically identifiable position of the respective device on Earth. Location data can be used, for example, to display map functions or other location-dependent information.
  • Tracking: „Tracking“ refers to the tracking of user behavior across multiple online offerings. Typically, behavioral and interest information related to the online offerings used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
  • Controller: The “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of the processing of personal data.
  • Processing: „Processing“ is any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, whether it involves collecting, analyzing, storing, transmitting, or deleting.
  • Target group creation: Target group creation (or „custom audiences“) is the process of defining target groups for advertising purposes, e.g., displaying advertisements. For example, based on a user’s interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which they viewed the products. „Lookalike audiences“ (or similar target groups), on the other hand, are the process of displaying content deemed suitable to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used to create custom audiences and lookalike audiences.