This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) in the context of the provision of our services and within our online offering and the websites, functions and content associated with it as well as external online presences, such as our Social Media Profile (hereinafter jointly referred to as “online offering”). With regard to the terms used, such as “processing” or “person responsible”, we refer you to the definitions in Art. 4 of the Data Protection Basic Regulation (DSGVO).
person in charge
+49 40 524 736 68
Types of data processed
– Inventory data (e.g., person master data, names or addresses).
– Contact data (e.g., e-mail, telephone numbers).
– Content data (e.g., text entries, photographs, videos).
– Usage data (e.g., websites visited, interest in content, access times).
– Meta/communication data (e.g., device information, IP addresses).
Categories of data subjects
Visitors and users of the online offer (hereinafter referred to collectively as “users”).
Purpose of processing
– Provision of the online offer, its functions and contents.
– Answering contact requests and communicating with users.
– Security measures.
– Range measurement/Marketing
“personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier (e.g. a cookie) or to one or more specific characteristics which express the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, is regarded as identifiable.
“processing” means any operation carried out with or without the aid of automated processes, or set of operations, involving personal data. The term is broad and covers practically every handling of data.
“pseudonymisation’ means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the provision of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures ensuring that the personal data are not attributed to an identified or identifiable natural person.
“Profiling” means any automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to the work performance, economic situation, health, personal preferences, interests, reliability, conduct, whereabouts or movements of that natural person.
The “controller” 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.
“processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Applicable legal bases
In accordance with Art. 13 DSGVO we inform you about the legal basis of our data processing. For users from the area of application of the data protection basic regulation (DSGVO), i.e. the EU and the EEC, the following applies, if the legal basis is not mentioned in the data protection explanation:
The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 DSGVO;
The legal basis for the processing for the fulfilment of our services and the implementation of contractual measures as well as the answering of inquiries is Art. 6 para. 1 lit. b DSGVO;
The legal basis for the processing for the fulfilment of our legal obligations is Art. 6 para. 1 lit. c DSGVO;
Art. 6 para. 1 lit. d DSGVO serves as the legal basis in the event that vital interests of the data subject or another natural person necessitate the processing of personal data.
The legal basis for the processing necessary to perform a task which is in the public interest or in the exercise of official authority entrusted to the data controller is Art. 6 para. 1 lit. e DSGVO.
The legal basis for the processing to safeguard our legitimate interests is Art. 6 para. 1 lit. f DSGVO.
The processing of data for purposes other than those for which they were collected is governed by the provisions of Art. 6 (4) DSGVO.
The processing of special categories of data (pursuant to Art. 9 (1) DSGVO) is governed by the provisions of Art. 9 (2) DSGVO.
We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, extent, circumstances and purposes of the processing, as well as the different probability of occurrence and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
Measures shall include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to, access to, inputting, disclosure, securing and separation of data. In addition, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data and the response to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and data protection-friendly default settings.
Cooperation with contract processors, joint managers and third parties
Insofar as we disclose data to other persons and companies (contract processors, jointly responsible persons or third parties) within the scope of our processing, transfer them to them or otherwise grant them access to the data, this shall only take place on the basis of legal permission (e.g. if a transfer of the data to third parties, such as payment service providers, is necessary for the fulfilment of the contract), users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
Insofar as we disclose, transmit or otherwise grant access to data to other companies of our group of companies, this is done in particular for administrative purposes as a legitimate interest and beyond that on a basis corresponding to the legal requirements.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this is done in the context of the use of third party services or disclosure or transfer of data to other persons or companies, this only occurs if it is done to fulfil our (pre)contractual obligations, on the basis of your consent, a legal obligation or on the basis of our legitimate interests. Subject to express consent or contractually required transfer, we will only process or allow the data to be processed in third countries with a recognised level of data protection, including US processors certified under the “Privacy Shield” or on the basis of special guarantees, such as a contractual obligation through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 bis 49 DSGVO, Information page of the EU Commission).
Rights of data subjects
You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law.
You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the inaccurate data concerning you.
In accordance with the statutory provisions, you have the right to demand that the data concerned be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
You have the right to demand that the data concerning you which you have made available to us be received in accordance with the statutory provisions and that it be transferred to other persons responsible.
They also have the right to file a complaint with the competent supervisory authority in accordance with the statutory provisions.
Right of withdrawal
You have the right to revoke any consent you have given with effect for the future.
Right of objection
You may object at any time to the future processing of the data concerning you in accordance with the statutory provisions. In particular, you may object to the processing of your data for the purposes of direct marketing.
Cookies and right to object to direct advertising
Cookies” are small files that are stored on the user’s computer. Different data can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after the user’s visit to an online service. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. The content of a shopping basket in an online shop or a login status, for example, can be stored in such a cookie. Cookies are referred to as “permanent” or “persistent” and remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. The interests of the users who are used for range measurement or marketing purposes can also be stored in such a cookie. Third party cookies” are cookies that are offered by providers other than the person responsible for operating the online service (otherwise, if they are only the latter’s cookies, they are referred to as “first party cookies”).
If users do not wish cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
Furthermore, the storage of cookies can be achieved by switching them off in the browser settings. Please note that in this case not all functions of this online offer can be used.
Deletion of data
The data processed by us will be deleted in accordance with the statutory provisions or their processing will be restricted. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and there are no legal obligations to retain them.
If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons.
Changes and updates to the data protection declaration
We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as the changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
We process the data of our customers within the scope of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development / consulting or maintenance, implementation of campaigns and processes / handling, server administration, data analysis / consulting services and training services.
We process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter of contract, term), payment data (e.g., bank details, payment history), usage and metadata (e.g., within the scope of evaluating and measuring the success of marketing measures). We do not process any special categories of personal data, unless they are part of a commissioned processing. Affected parties include our customers, interested parties and their customers, users, website visitors or employees as well as third parties. The purpose of the processing is the provision of contractual services, billing and our customer service. The legal basis for the processing results from Art. 6 Para. 1 lit. b DSGVO (contractual services), Art. 6 Para. 1 lit. f DSGVO (analysis, statistics, optimisation, security measures). We process data which are necessary for the justification and fulfilment of the contractual services and point out the necessity of their specification. Disclosure to external parties shall only take place if it is necessary within the framework of an order. When processing the data provided to us within the framework of an order, we shall act in accordance with the instructions of the customer and the statutory requirements for order processing pursuant to Art. 28 DSGVO and shall not process the data for purposes other than those specified in the order.
We delete the data after expiration of legal warranty and comparable obligations. the necessity of the storage of the data is reviewed every three years; in the case of legal archiving obligations the deletion takes place after their expiration (6 J, according to § 257 Abs. 1 HGB, 10 J, according to § 147 Abs. 1 AO). In the case of data which has been disclosed to us by the client within the scope of an order, we delete the data in accordance with the specifications of the order, in principle after the end of the order.
Business analyses and market research
In order to run our business economically, to be able to recognise market trends, wishes of our contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., in order to identify the most suitable and appropriate solutions for your needs. We process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. DSGVO, whereby the persons concerned include contractual partners, interested parties, customers, visitors and users of our online services.
The analyses are carried out for the purpose of economic evaluations, marketing and market research. We can take into account the profiles of registered users with information, e.g. on the services they make use of. The analyses serve us to increase the user friendliness, the optimization of our offer and the business economy. The analyses serve us alone and are not disclosed externally unless they are anonymous analyses with summarized values.
If these analyses or profiles are person-related, they will be deleted or anonymised upon termination by the user, otherwise after two years from the conclusion of the contract. In all other respects, the macroeconomic analyses and general trend determinations are prepared anonymously wherever possible.
Google Cloud Services
We use the cloud and cloud software services offered by Google (the Software as a Service, for example, Google Suite) for the following purposes: storing and managing documents, managing calendars, sending email, spreadsheets and presentations, exchanging documents, content and information with specific recipients or publishing web pages, forms or other content and information, and chatting and participating in audio and video conferences.
The personal data of the users will be processed in this connection, insofar as these become part of the documents and content processed within the described services or are part of communication processes. This may include, for example, user master data and contact data, data on processes, contracts, other processes and their contents. Google also processes usage data and metadata used by Google for security purposes and service optimisation.
When using publicly accessible documents, websites or other content, Google may store cookies on the user’s computer for the purpose of web analysis or to remember user preferences.
We use the Google Cloud services on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f DSGVO in efficient and secure administrative and cooperation processes. Furthermore, processing is based on an order processing contract with Google (httpss://cloud.google.com/terms/data-processing-terms).
The Google Cloud Services are offered by Google Ireland Limited. As far as a transmission to the USA takes place, we refer to the certification of Google USA under the Privacy Shield(httpss://www.privacyshield.gov/participant?id=a2zt0000000000001L5AAI&status=Aktive) and standard protection clauses (httpss://cloud.google.com/terms/data-processing-terms).
Privacy Notice in the Application Process
We process the applicant data only for the purpose and within the framework of the application procedure in accordance with the legal requirements. The processing of the applicant data is carried out to fulfil our (pre)contractual obligations within the scope of the application procedure in the sense of Art. 6 Para. 1 lit. b. DSGVO Art. 6 para. 1 lit. f. DSGVO insofar as data processing becomes necessary for us, e.g. within the framework of legal proceedings (in Germany, § 26 BDSG additionally applies).
The application procedure requires that applicants provide us with the applicant data. If we offer an online form, the necessary applicant data is marked, otherwise it results from the job descriptions and basically includes the personal details, postal and contact addresses and the documents belonging to the application, such as cover letter, curriculum vitae and certificates. In addition, applicants may voluntarily provide us with additional information.
By submitting their application to us, applicants consent to the processing of their data for the purposes of the application procedure in accordance with the type and scope set out in this data protection declaration.
If special categories of personal data within the meaning of Art. 9 Para. 1 DSGVO are voluntarily provided as part of the application process, they will also be processed in accordance with Art. 9 Para. 2 lit. b DSGVO (e.g. health data, such as severely disabled status or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 para. 1 DSGVO are requested from applicants as part of the application procedure, their processing will also be carried out in accordance with Art. 9 para. 2 lit. a DSGVO (e.g. health data if they are required for the exercise of a profession).
Where made available, applicants may submit their applications via an online form on our website. The data will be transmitted to us encrypted according to the state of the art.
Applicants can also send us their applications by e-mail. Please note, however, that e-mails are generally not sent in encrypted form and the applicants themselves must ensure that they are encrypted. We therefore cannot assume any responsibility for the transmission path of the application between the sender and the reception on our server and therefore recommend using an online form or postal dispatch. Instead of applying using the online form and e-mail, applicants still have the option of sending their application by post.
In the event of a successful application, the data provided by the applicants can be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicant’s data will be deleted. Applicant data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time.
Subject to justified revocation by the applicants, the data will be deleted after a period of six months so that we can answer any follow-up questions regarding the application and meet our obligations to provide evidence under the Equal Treatment Act. Invoices for any reimbursement of travel expenses will be archived in accordance with the provisions of tax law.
When contacting us (e.g. via contact form, e-mail, telephone or via social media), the user’s details are used to process the contact enquiry and to process it in accordance with Art. 6 Para. 1 lit. b. of the German Data Protection Act. (within the framework of contractual/pre-contractual relationships), Art. 6 Para. 1 lit. f. (other inquiries) DSGVO processed… The user data can be stored in a customer relationship management system (“CRM system”) or comparable inquiry organization.
We delete the requests if they are no longer necessary. We check the necessity every two years; furthermore, the legal archiving obligations apply.
With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures and your rights of objection. By subscribing to our newsletter, you declare your agreement with the receipt and the described procedures.
Content of the newsletter: We send newsletters, e-mails and other electronic notifications containing advertising information (hereinafter “newsletter”) only with the consent of the recipient or a legal permission. If the contents of the newsletter are specifically described within the scope of registration, they are decisive for the consent of the user. In addition, our newsletters contain information about our services and us.
Double-Opt-In and logging: The registration to our newsletter takes place in a so-called Double-Opt-In procedure. I.e. after registration you will receive an e-mail in which you will be asked to confirm your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address. Likewise the changes of your data stored with the Versanddienstleister are logged.
Registration data: To subscribe to the newsletter, it is sufficient to enter your e-mail address. Optionally, we ask you to enter a name in the newsletter for the purpose of addressing you personally.
The dispatch of the newsletter and the performance measurement associated with it are based on the consent of the recipients pursuant to Art. 6 para. 1 lit. a, Art. 7 DSGVO in conjunction with § 7 para. 2 no. 3 UWG or, if consent is not required, on our legitimate interests in direct marketing pursuant to Art. 6 para. 1 as per f. DSGVO in connection with § 7 Abs. 3 UWG.
The registration procedure is recorded on the basis of our legitimate interests pursuant to Art. 6 Para. 1 lit. f DSGVO. Our interest is directed towards the use of a user-friendly and secure newsletter system that serves our business interests as well as the expectations of the users and furthermore allows us to provide evidence of consent.
Cancellation/revocation – You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to provide evidence of a previously given consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time.
Newsletter – Dispatch service provider
The dispatch service provider can use the data of the recipients in pseudonymous form, i.e. without allocation to a user, to optimise or improve its own services, e.g. for technical optimisation of dispatch and presentation of the newsletter or for statistical purposes. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.
Newsletter – Measurement of success
The newsletters contain a so-called “web-beacon”, i.e. a file the size of a pixel, which is retrieved from our server when the newsletter is opened or, if we use a dispatch service provider, from its server. Within the scope of this retrieval, technical information such as information about the browser and your system, as well as your IP address and time of retrieval are first collected.
This information is used for the technical improvement of the services on the basis of technical data or target groups and their reading behaviour on the basis of their retrieval points (which can be determined with the help of the IP address) or access times. Statistical surveys also include determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. It is, however, neither our endeavour nor, if used, that of the dispatch service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our contents to them or to send different contents according to the interests of our users.
A separate cancellation of the performance measurement is unfortunately not possible, in which case the entire newsletter subscription must be cancelled.
Hosting and e-mail dispatch
The hosting services used by us serve the provision of the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services which we use for the purpose of operating this online service.
Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors to this online service on the basis of our legitimate interests in the efficient and secure provision of this online service in accordance with Art. 6 Para. 1 lit. f DSGVO in connection with Art. 28 DSGVO (conclusion of an order processing contract).
Collection of access data and log files
We, and/or our Hostinganbieter, raise on basis of our entitled interests in the sense of the art. 6 Abs. 1 lit. f. DSGVO collects data on each access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Logfile-Informationen werden aus Sicherheitsgründen (z.B. zur Aufklärung von Missbrauchs- oder Betrugshandlungen) für die Dauer von maximal 7 Tagen gespeichert und danach gelöscht. Daten, deren weitere Aufbewahrung zu Beweiszwecken erforderlich ist, sind bis zur endgültigen Klärung des jeweiligen Vorfalls von der Löschung ausgenommen.
Google Universal Analytics
We use Google Analytics in the form of “universal analytics”. “Universal Analytics” refers to a Google Analytics procedure in which user analysis is performed on the basis of a pseudonymous user ID and a pseudonymous profile of the user is thus created with information from the use of various devices (so-called “cross-device tracking”).
Google AdWords and conversion measurement
We use the Google “AdWords” online marketing method to place ads on the Google advertising network (e.g., in search results, videos, websites, etc.) so that they are displayed to users who have an alleged interest in the ads. This allows us to display ads for and within our online offerings in a more targeted manner in order to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products in which he or she is interested in other online offers, this is referred to as “remarketing”. For these purposes, when our and other websites on which the Google Advertising Network is active are called up, a Google code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also referred to as “web beacons”) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). This file records which websites the user visits, what content he is interested in and what offers the user has clicked, as well as technical information on the browser and operating system, referring websites, visit times and other information on the use of the online service.
Furthermore, we receive an individual “conversion cookie”. The information obtained with the help of the cookie is used by Google to compile conversion statistics for us. However, we only know the anonymous total number of users who clicked on our ad and were redirected to a page with a conversion tracking tag. However, we do not receive any personally identifiable information.
User information is processed pseudonymously within the Google Advertising Network. This means, for example, that Google does not store and process the user’s name or e-mail address, but processes the relevant data cookie-related within pseudonymous user profiles. This means that, from Google’s point of view, the ads are not administered and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymisation. The information collected about users is transmitted to Google and stored on Google’s servers in the United States.
If we ask the users for their consent (e.g. in the context of a cookie consent), the legal basis for this processing is Art. 6 Para. 1 lit. a. DSGVO. Otherwise, the personal data of the user will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online service as defined in Art. 6 Para. 1 lit. f. of the German Data Protection Act). DSGVO).
As far as data is processed in the USA, we point out that Google is certified under the Privacy Shield Agreement and thereby assures compliance with European data protection law (httpss://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Further information on the use of data by Google, setting and objection options can be found in Google’s data protection declaration (httpss://policies.google.com/technologies/ads) and in the settings for the display of advertising by Google (httpss://adssettings.google.com/authenticated).
Facebook Pixel, Custom Audiences and Facebook Conversion
Within our online offer, the so-called “Facebook pixel” of the social network Facebook, which is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), is used.
With the help of the Facebook pixel, Facebook is on the one hand able to determine the visitors of our online offer as a target group for the presentation of ads (so-called “Facebook ads”). Accordingly, we use Facebook pixels to display Facebook ads placed by us only to those Facebook users who have shown an interest in our online offering or who have certain features (e.g., interests in certain topics or products that are determined on the basis of the websites visited) that we transmit to Facebook (so-called “custom audiences”). Using Facebook pixels, we also want to ensure that our Facebook ads match the potential interest of users and are not annoying. Using Facebook pixels, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing if users were referred to our website after clicking on a Facebook ad (known as “conversion”).
Facebook processes the data in accordance with Facebook’s data usage policy. Accordingly, general information about the presentation of Facebook ads is provided in Facebook’s data usage policy: httpss://www.facebook.com/policy. Specific information and details about Facebook pixels and how they work can be found in the Facebook help section: httpss://www.facebook.com/business/help/651294705016616.
If we ask the users for their consent (e.g. in the context of a cookie consent), the legal basis for this processing is Art. 6 Para. 1 lit. a. DSGVO. Otherwise, the personal data of the user will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online service within the meaning of Art. 6 Para. 1 lit. f. of the German Data Protection Act). DSGVO).
Facebook is certified under the Privacy Shield Agreement and thereby assures compliance with European data protection law (httpss://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
You can object to the collection by Facebook pixels and the use of your data to display Facebook ads. To set what types of ads you see within Facebook, you can visit the page set up by Facebook and follow the instructions on the settings for usage-based ads: httpss://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.