This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) as part of the provision of our services and within our online offer and the websites, functions and content associated with it as well as external online presences, such as e.g our social media profile (hereinafter jointly referred to as “online offer”). With regard to the terms used, such as “processing” or “person responsible”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
Axel Ladner Hertlerweg 9 8274 Tägerwilen firstname.lastname@example.org Types of data processed – inventory data (e.g. personal master data, names or addresses). – Contact details (e.g., e-mail, telephone numbers). – Content data (e.g., text input, 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 (in the following we refer to the persons concerned collectively as “users”).
Purpose of processing
– Provision of the online offer, its functions and content. – Answering contact requests and communicating with users. – Safety measures. – Reach measurement/marketing
“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 means of assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special features, are an expression of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. “Processing” is any process or series of processes carried out with or without the aid of automated processes in connection with personal data. The term is broad and encompasses practically every handling of data. “Pseudonymization” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without the use of additional information, provided that this additional information is stored separately and is subject to technical and organizational measures that ensure that the personal data not assigned to an identified or identifiable natural person. “Profiling” any type of automated processing of personal data, which consists in using this personal data to evaluate certain personal aspects relating to a natural person, in particular aspects related to work performance, economic situation, health, personal Analyze or predict that natural person’s preferences, interests, reliability, behavior, whereabouts or relocation. The “responsible person” is the natural or legal person, authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data. “Processor” means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the person responsible.
Relevant legal bases
In accordance with Art. 13 GDPR, we will inform you of the legal basis for our data processing. The following applies to users from the scope of the General Data Protection Regulation (GDPR), i.e. the EU and the EEC, unless the legal basis is mentioned in the data protection declaration: The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR; The legal basis for processing to fulfill our services and carry out contractual measures as well as answering inquiries is Art. 6 Para. 1 lit. b GDPR; The legal basis for processing to fulfill our legal obligations is Art. 6 para. 1 lit. c GDPR; In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR as the legal basis. The legal basis for the processing required to perform a task that is in the public interest or in the exercise of official authority that has been transferred to the person responsible is Art. 6 para. 1 lit. e GDPR. The legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f GDPR. The processing of data for purposes other than those for which they were collected is determined by the provisions of Art 6 Para. 4 GDPR. The processing of special categories of data (according to Art. 9 Para. 1 DSGVO) is determined according to the specifications of Art. 9 Para. 2 GDPR.
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of the processing as well as the different probability of occurrence and severity of the risk for the rights and freedoms of natural persons to ensure a level of protection appropriate to the risk. The measures include, in particular, securing the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access, input, transfer, securing availability and their separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, deletion of data and reaction to data threats. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.
Cooperation with processors, joint controllers and third parties
If, as part of our processing, we disclose data to other people and companies (processors, joint controllers or third parties), transmit it to them or otherwise grant them access to the data, this is only done on the basis of legal permission (e.g. if a transmission of the data to third parties, such as payment service providers, is required to fulfill 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.). If we disclose or transmit data to other companies in our group of companies, or otherwise grant them access, this is done in particular for administrative purposes as a legitimate interest and, moreover, on a basis that corresponds 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 this within the scope of using third-party services or disclosure or transmission of data to other persons or companies If this happens, this will only happen if it is to fulfill our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or leave the data in a third country if the legal requirements are met. This means that the processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to that of the EU (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations.
Rights of data subjects
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 legal requirements. You have accordingly. In accordance with legal requirements, you have the right to request the completion of the data concerning you or the correction of incorrect data concerning you. In accordance with the legal requirements, you have the right to request that the data in question be deleted immediately, or alternatively to request a restriction of the processing of the data in accordance with the legal requirements. You have the right to request that you receive the data that you have provided to us in accordance with the legal requirements and to request that they be transmitted to other responsible parties. You also have the right, in accordance with the legal requirements, to lodge a complaint with the competent supervisory authority.
right of withdrawal
You have the right to revoke your consent with effect for the future.
Right to object
You can object to the future processing of the data concerning you at any time in accordance with the legal requirements. The objection can be made in particular against processing for direct marketing purposes.
Cookies and the right to object to direct advertising
deletion of data
The data processed by us will be deleted in accordance with the legal requirements 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 the deletion does not conflict with any statutory storage requirements. If the data is not deleted because it is required for other and legally permissible purposes, its 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 retained for commercial or tax reasons.
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 in 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.
We process our customers’ data as part of our contractual services, which include conceptual and strategic advice, 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 input, photographs, videos), contract data (e.g. subject matter of the contract, term), payment data (e.g. Bank details, payment history), usage and metadata (e.g. in the context of evaluating and measuring the success of marketing measures). In principle, we do not process special categories of personal data, unless these are part of commissioned processing. Those affected include our customers, interested parties and their customers, users, website visitors or employees as well as third parties. The purpose of the processing is to provide contractual services, billing and our customer service. The legal basis for the processing results from Art. 6 para. 1 lit. b GDPR (contractual services), Art. 6 para. 1 lit. f GDPR (analysis, statistics, optimization, security measures). We process data that is required to justify and fulfill the contractual services and point out the necessity of their disclosure. Disclosure to external parties only takes place if it is required as part of an order. When processing the data provided to us as part of an order, we act in accordance with the instructions of the client and the legal requirements for order processing acc. Art. 28 GDPR and do not process the data for any purposes other than the purposes specified in the order. We delete the data after the statutory warranty and comparable obligations have expired. the need to keep the data is reviewed every three years; in the case of legal archiving obligations, the deletion takes place after their expiry (6 years, according to § 257 paragraph 1 HGB, 10 years, according to § 147 paragraph 1 AO). In the case of data disclosed to us by the client as part of an order, we delete the data in accordance with the specifications of the order, generally after the end of the order.
When contacting us (e.g. via contact form, e-mail, telephone or via social media), the information provided by the user is used to process the contact request and its processing in accordance with Article 6 (1) b. (in the context of contractual/pre-contractual relationships), Art. 6 (1) lit. f. (other inquiries) GDPR processed get saved. We delete the requests if they are no longer necessary. We review necessity every two years; Furthermore, the statutory archiving obligations apply.
Newsletter – shipping service provider
The newsletter is sent by the shipping service provider [NAME, ADDRESS, COUNTRY]. You can view the data protection regulations of the shipping service provider here:[LINK ZU DEN DATENSCHUTZBESTIMMUNGEN] . The shipping service provider is based on our legitimate interests acc. Art. 6 para. 1 lit. f. GDPR and an order processing contract acc. Art. 28 para. 3 sentence 1 GDPR. The shipping service provider can use the data of the recipients in pseudonymous form, ie without assignment to a user, to optimize or improve their own services, e.g. for technical optimization of the dispatch and the presentation of the newsletter or for statistical purposes. However, the shipping service provider does not use the data of our newsletter recipients to write to them themselves or to pass the data on to third parties.
Newsletter – measurement of success
The newsletters contain a so-called “web beacon”, ie a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from their server. As part 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 initially collected. This information is used to technically improve the services 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 the access times. The statistical surveys also include determining whether the 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. However, it is neither our aim nor, if used, that of the shipping service provider to monitor individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. Unfortunately, it is not possible to revoke the success measurement separately. In this case, the entire newsletter subscription must be cancelled.
hosting and email delivery
The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services that we use for the purpose of operating this online offer. In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data from customers, interested parties and visitors to this online offer on the basis of our legitimate interests in making this online offer available efficiently and securely in accordance with Art. Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of order processing contract).
Google Tag Manager
Google Tag Manager is a solution with which we can manage so-called website tags via an interface (and thus, for example, integrate Google Analytics and other Google marketing services into our online offer). The Tag Manager itself (which implements the tags) does not process any personal data of the users. With regard to the processing of users’ personal data, reference is made to the following information on Google services. Usage guidelines: https://www.google.com/intl/de/tagmanager/use-policy.html .
Google AdWords and conversion measurement
We use the services of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043 on the basis of our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. DSGVO). , United States, (“Google”). Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). We use the Google “AdWords” online marketing process to place ads on the Google advertising network (e.g. in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads. This allows us to display ads for and within our online offering in a more targeted manner in order to only present users with ads that potentially match their interests. If, for example, a user is shown ads for products that he was interested in on 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 accessed, a Google code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as ” referred to as “web beacons”) integrated into the website. With their help, an individual cookie, ie 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 which offers the user clicked on, as well as technical information on the browser and operating system, referring websites, visiting times and other information on the use of the online offer. We also receive an individual “conversion cookie”. The information obtained with the help of the cookie is used by Google to create conversion statistics for us. However, we only find out 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 information with which users can be personally identified. User data is processed pseudonymously within the framework of the Google advertising network. This means that Google does not store and process, for example, the name or e-mail address of the user, but processes the relevant data in relation to cookies within pseudonymous user profiles. This means that from Google’s point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie owner, regardless of who this cookie owner is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymization. The information collected about users is transmitted to Google and stored on Google’s servers in the USA. You can find more information on data use by Google, setting and objection options in Google’s data protection declaration ( https://policies.google.com/technologies/ads ) and in the settings for the display of advertisements by Google (https:// adssettings.google.com/authenticated ).
Facebook pixel, custom audiences and Facebook conversion
Online presence in social media
Integration of third-party services and content
We use content or service offers from third-party providers within our online offer on the basis of our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit Integrate services such as videos or fonts (hereinafter uniformly referred to as “content”). This always presupposes that the third-party providers of this content perceive the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is therefore required for the display of this content. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers can also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user’s device and contain, among other things, technical information about the browser and operating system, referring websites, visiting times and other information on the use of our online offer, as well as being linked to such information from other sources.
Typekit fonts from Adobe
On the basis of our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. f. DSGVO) we use external “Typekit” fonts from the provider Adobe Systems Software Ireland Limited, 4 -6 Riverwalk, Citywest Business Campus, Dublin 24, Republic of Ireland. Adobe is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000TNo9AAG&status=Active).
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