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With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites as well as within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”). The terms used are not gender-specific.
Status: 30 January 2020
The terms used are not gender-specific.
Status: 30 January 2020
Susanne Liedtke
sisu health GmbH
Notkestraße 10
22607 Hamburg
Authorised representatives: Susanne Liedtke
E-Mail-Address: kontakt@nobodytoldme.com
The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects.
In the following, we inform you about the legal basis of the General Data Protection Regulation (GDPR) on the basis of 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.
National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Bundesdatenschutzgesetz – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, the processing for other purposes and the transmission and automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. Furthermore, data protection laws of the individual federal states may apply.
We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk 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.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. We also have procedures in place to ensure the exercise of data subjects’ rights, the deletion of data and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
Shortening of the IP address: If it is possible for us to do so or if it is not necessary to store the IP address, we will shorten your IP address or have it shortened. In the case of IP address shortening, also known as “IP masking”, the last octet, i.e. the last two numbers of an IP address, are deleted (in this context, the IP address is an identifier individually assigned to an internet connection by the online access provider). The shortening of the IP address is intended to prevent or make it significantly more difficult to identify a person by their IP address.
SSL encryption (https): In order to protect your data transmitted via our online offer, we use SSL encryption. You can recognise such encrypted connections by the prefix https:// in the address line of your browser.
Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after her visit within an online offer. The information stored may include, for example, language settings on a website, login status, a shopping cart or where a video was watched. The term cookies also includes other technologies that perform the same functions as cookies (e.g. when user details are stored using pseudonymous online identifiers, also known as “user IDs”).
The following cookie types and functions are distinguished:
Notes on legal basis: The legal basis on which we process your personal data with the help of cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for the processing of your data is the consent given. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and its improvement) or if the use of cookies is necessary to fulfil our contractual obligations.
General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the possibility at any time to revoke a given consent or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection by means of your browser settings, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can obtain further instructions on how to object in the context of the information on the service providers and cookies used.
Processing of cookie data on the basis of consent: Before we process or have data processed in the context of the use of cookies, we ask users for consent that can be revoked at any time. Before consent has been given, cookies are only used if they are necessary for the operation of our online offer. Their use is based on our interest and the interest of the users in the expected functionality of our online offer.
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 enquiries.
We process this data to fulfil our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as for business organisation. Within the framework of applicable law, we only disclose the data of the contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or with the consent of the contractual partners (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). The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.
We inform the contractual partners of the data required for the above-mentioned purposes before or during data collection, e.g. in online forms, by means of special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.
We delete the data after the expiry of legal warranty and comparable obligations, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. as long as it must be kept for legal archiving reasons (e.g. for tax purposes generally 10 years). We delete data disclosed to us by the contractual partners within the scope of an order in accordance with the specifications of the order, in principle after the end of the order.
If 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 in the relationship between the users and the providers.
Economic analyses and market research: For economic reasons and in order to be able to recognise market trends and the wishes of contractual partners and users, we analyse the data we have on business transactions, contracts, enquiries, etc., whereby the group of persons concerned may include contractual partners, interested parties, customers, visitors and users of our online offer.
The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). Where available, we may take into account the profiles of registered users together with their details, e.g. services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarised, i.e. anonymised values. Furthermore, we take the privacy of the users into consideration and process the data for the analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as summarised data).
Shop and e-commerce: We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and associated services, as well as their payment and delivery or execution.
The required information is marked as such in the context of the order or comparable purchase process and includes the information required for delivery or provision and invoicing as well as contact information in order to be able to contact you if necessary.
Health services: We process the data of our patients and interested parties and other clients or contractual partners (uniformly referred to as “patients”) in order to be able to provide our services to them. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and patient relationship.
Within the scope of our activities, we may also process special categories of data, in particular information on the health of patients, possibly with reference to their sex life or sexual orientation, as well as data revealing racial and ethnic origin, political opinions, religious or philosophical beliefs or trade union membership. For this purpose, we obtain the explicit consent of the patients, if necessary, and otherwise process the special categories of data for the purposes of preventive health care or to protect the vital interests of the patients.
If it is necessary for the fulfilment of our contract, for the protection of vital interests or required by law, or if the patient has given her consent, we disclose or transfer the client’s data to third parties or agents, such as public authorities, medical institutions, laboratories, billing offices and in the area of IT, office or comparable services, in compliance with the requirements of professional law.
Therapeutic services: We process the data of our clients and interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to be able to provide our services to them. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship.
In the course of our work, we may also process special categories of data, in particular information on the health of clients, possibly with reference to their sex life or sexual orientation, as well as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership. For this purpose, we obtain the explicit consent of the client, if necessary, and process the special categories of data otherwise if this serves the health of the client, the data are public or there are other legal permissions.
If it is necessary for the fulfilment of our contract, for the protection of vital interests or required by law, or if the client has given her consent, we disclose or transfer the client’s data to third parties or agents, such as public authorities, medical institutions, laboratories, accounting offices and in the field of IT, office or comparable services, in compliance with the requirements of professional law.
We offer our services on online platforms operated by other service providers. In this context, the data protection notices of the respective platforms apply in addition to our data protection notices. This applies in particular with regard to the reach measurement and interest-based marketing procedures used on the platforms.
Within the scope of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other payment service providers in addition to banks and credit institutions for this purpose (collectively “payment service providers”).
The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e. we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the terms and conditions and data protection information of the payment service providers.
The terms and conditions and data protection information of the respective payment service providers apply to the payment transactions and can be accessed within the respective websites or transaction applications. We also refer to these for further information and the assertion of revocation, information and other data subject rights.
Visa: Payment services; service provider: Visa Europe Services Inc., Zweigniederlassung London, 1 Sheldon Square, London W2 6TT, GB; Website: https://www.visa.de; Datenschutzerklärung: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html.
We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data are processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.
Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored on the basis of our legitimate interests. This is done for our security in case someone leaves unlawful content in comments and posts (insults, forbidden political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.
Furthermore, we reserve the right to process the user’s details for the purpose of spam detection on the basis of our legitimate interests.
On the same legal basis, we reserve the right to store the IP addresses of users for the duration of surveys and to use cookies in order to avoid multiple voting.
The personal information provided in the context of comments and contributions, any contact and website information as well as the content-related information will be permanently stored by us until the user objects.
When contacting us (e.g. via contact form, email, telephone or via social media), the information of the inquiring persons is processed to the extent that this is necessary to respond to the contact enquiries and any requested measures.
The response to contact enquiries in the context of contractual or pre-contractual relationships is carried out to fulfil our contractual obligations or to respond to (pre)contractual enquiries and otherwise on the basis of the legitimate interests in responding to the enquiries.
We use messenger services for communication purposes and therefore ask you to observe the following information on the functionality of the messenger, on encryption, on the use of the metadata of the communication and on your objection options.
You can also contact us in alternative ways, e.g. by phone or email. Please use the contact options provided to you or the contact options provided within our online offer.
In the case of end-to-end encryption of content (i.e. the content of your message and attachments), we would like to point out that the communication content (i.e. the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messenger with encryption enabled to ensure that the message content is encrypted.
However, we also point out to our communication partners that the messenger providers cannot see the content, but they can find out that and when communication partners communicate with us and that technical information about the device used by the communication partners and, depending on the settings of their devices, also location information (so-called metadata) is processed.
Notes on legal basis: If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and they contact us of their own accord, for example, we use Messenger in relation to our contractual partners and in the context of initiating a contract as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners for communication via Messenger. Furthermore, we would like to point out that we do not transmit the contact data provided to us to the messengers for the first time without your consent.
Revocation, objection and deletion: You can revoke your consent at any time and object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete the messages in accordance with our general deletion guidelines (i.e. e.g. as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information from the communication partner, if no reference to a previous conversation is to be expected and the deletion does not conflict with any legal retention obligations.
Reservation of reference to other communication channels: Finally, we would like to point out that we reserve the right not to answer enquiries via Messenger for reasons of your security. This is the case if, for example, contractual internals require special confidentiality or an answer via Messenger does not meet formal requirements. In such cases, we will refer you to more adequate communication channels.
We use platforms and applications of other providers (hereinafter referred to as “third party providers”) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings. When selecting the third-party providers and their services, we observe the legal requirements.
In this context, data of the communication participants are processed and stored on the servers of the third-party providers, insofar as these are part of communication processes with us. This data may include, in particular, registration and contact data, visual and vocal contributions as well as entries in chats and shared screen content.
Services used and service providers:
The surveys and questionnaires we conduct (hereinafter “surveys”) are evaluated anonymously. Personal data is only processed insofar as this is necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address in order to display the survey in the user’s browser or to enable a resumption of the survey with the help of a temporary cookie (session cookie)) or users have consented to this.
Notes on legal bases: If we ask participants for consent to process their data, this is the legal basis for the processing; otherwise, the processing of participants’ data is based on our legitimate interests in conducting an objective survey.
In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.
The data processed in the course of providing the hosting service may include all information relating to the user of our online service that is generated in the course of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.
E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of recognising SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption procedure is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.
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). The server log files may include the address and name of the web pages and files accessed, the date and time of the access, the amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.
Die Serverlogfiles können zum einen zu Zwecken der Sicherheit eingesetzt werden, z.B., um eine Überlastung der Server zu vermeiden (insbesondere im Fall von missbräuchlichen Angriffen, sogenannten DDoS-Attacken) und zum anderen, um die Auslastung der Server und ihre Stabilität sicherzustellen.
We use the hosting and analytics services of the service providers listed below to provide our audio content for listening or downloading and to obtain statistical information about the retrieval of the audio content.
We use software services accessible via the Internet and running on the servers of their providers (so-called “cloud services”, also referred to as “software as a service”) for the following purposes: document storage and management, calendar management, sending e-mails, spreadsheets and presentations, exchanging documents, content and information with specific recipients or publishing web pages, forms or other content and information, as well as chats and participation in audio and video conferences.
In this context, personal data may be processed and stored on the servers of the providers to the extent that these are part of communication processes with us or are otherwise processed by us as set out in the context of this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents. The cloud service providers also process usage data and metadata used by them for security purposes and service optimisation.
If we use the cloud services to provide other users or publicly accessible websites with forms or other documents and content, the providers may store cookies on the user’s devices for the purpose of web analysis or to remember the user’s settings (e.g. in the case of media control).
Notes on legal bases: If we ask for consent to use the cloud services, the legal basis of the processing is consent. Furthermore, their use may be a component of our (pre)contractual services, provided that the use of the cloud services has been agreed within this framework. Otherwise, the users’ data is processed on the basis of our legitimate interests (i.e., interest in efficient and secure administrative and collaboration processes).
We only send newsletters, e-mails and other electronic notifications (hereinafter referred to as “newsletter”) with the consent of the recipients or with legal permission. If the contents of the newsletter are specifically described in the registration, they are decisive for the consent of the user. In addition, our newsletters contain information about our services and us.
In order to subscribe to our newsletters, it is generally sufficient to provide your email address. However, we may ask you to provide a name, for the purpose of a personal address in the newsletter, or further details, if these are necessary for the purposes of the newsletter.
Double opt-in procedure: The registration for our newsletter is always carried out in a so-called double opt-in process. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other email addresses. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored with the dispatch service provider are also logged.
Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove consent previously given. The processing of this data will be 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 consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a blacklist for this purpose alone.
The logging of the registration process is carried out on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.
Notes on legal basis: Newsletters are sent on the basis of the recipients’ consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and insofar as this is permitted by law, e.g. in the case of advertising to existing customers. Insofar as we commission a service provider to send e-mails, 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 has been carried out in accordance with the law.
Content: Information on health topics, our products and services.
Performance measurement: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file which is retrieved from our server or, if we use a dispatch service provider, from their server when the newsletter is opened. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and the time of the retrieval, are initially collected.
This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the 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 the individual newsletter recipients. However, it is neither our intention nor, if used, that of the dispatch service provider to observe individual users. The analyses serve us rather to recognise 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.
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 the expectations of the user.
A separate revocation of the performance measurement is unfortunately not possible; in this case, the entire newsletter subscription must be cancelled or revoked.
Option to object (Opt-Out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably e-mail, for this purpose.
We process personal data for the purpose of promotional communication, which may take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.
The recipients have the right to revoke consent given at any time or to object to the promotional communication at any time.
After revocation or objection, we may store the data required to prove consent for up to three years based on our legitimate interests before deleting it. The processing of this data is limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.
We process personal data of participants in competitions and contests only in compliance with the relevant data protection provisions, insofar as the processing is contractually necessary for the provision, implementation and handling of the competition, the participants have consented to the processing or the processing serves our legitimate interests (e.g. in the security of the competition or the protection of our interests against abuse through possible collection of IP addresses when submitting competition entries).
If entries from participants are published as part of the competitions (e.g. as part of a vote or presentation of the competition entries or the winners or reporting on the competition), we would like to point out that the names of the participants may also be published in this context. Participants may object to this at any time.
If the competition takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as “online platform”), the usage and data protection provisions of the respective platforms shall also apply. In these cases, we would like to point out that we are responsible for the information provided by the participants in the context of the competition and that enquiries with regard to the competition should be addressed to us.
The participants’ data will be deleted as soon as the competition or contest has ended and the data is no longer required to inform the winners or because queries about the competition are to be expected. In principle, the participants’ data will be deleted no later than 6 months after the end of the competition. Winners’ data may be retained for longer, e.g. in order to answer queries about the prizes or to be able to fulfil the prize obligations; in this case, the retention period depends on the type of prize and is up to three years, e.g. in the case of goods or services, in order to be able to process warranty claims, for example. Furthermore, the participants’ data may be stored for a longer period, e.g. in the form of reporting on the competition in online and offline media.
If data was also collected for other purposes within the scope of the competition, its processing and the retention period shall be governed by the data protection information on this use (e.g. in the case of a registration for the newsletter within the scope of a competition).
Web analytics (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the reach analysis, we can, for example, recognise at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimisation.
In addition to web analysis, we may also use test procedures, e.g. to test and optimise different versions of our online offer or its components.
For these purposes, so-called user profiles may be created and stored in a file (so-called “cookie”) or similar procedures may be used with the same purpose. This information may include, for example, content viewed, web pages 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.
The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored in the context of web analysis, A/B testing and optimisation, but pseudonyms. This means that we as well as the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.
Notes on legal basis: If we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, the users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
We process personal data for online marketing purposes, 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 its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which the information on the user relevant to the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also 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 can also be processed.
The IP addresses of the users are also stored. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear data of the users (such as e-mail addresses or names) are stored within the scope of the online marketing procedure, but pseudonyms. This means that we as well as the providers of the online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is usually stored in cookies or by means of similar procedures. These cookies can generally also be read later on other websites that use the same online marketing procedure and analysed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.
Exceptionally, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing procedure we use and the network links the profiles of the users in the aforementioned data. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.
In principle, we only receive access to summarised information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to a conclusion of a contract with us. The conversion measurement is used solely to analyse 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 basis: If we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, the users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Target group formation with Google Analytics: We use Google Analytics to display the ads placed within advertising services of Google and its partners only to those users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited), which we transmit to Google (so-called “Remarketing Audiences”, or “Google Analytics Audiences”). With the help of Remarketing Audiences, we also want to ensure that our advertisements correspond to the potential interest of the users.
Facebook pixel: With the help of the Facebook pixel, it is possible for Facebook to determine the visitors to our online offer as a target group for the display of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel in order to display Facebook ads placed by us only to such 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 offer or who have certain characteristics (e.g. interest in certain topics or products that are evident 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 interest of the users and do not have a harassing effect. With the help of the Facebook pixel, we can also track the effectiveness of the 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”).
Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the objection options given to the providers (so-called \”opt-out\”). If no explicit opt-out option has been specified, you have the option of deactivating cookies in your browser settings. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for the respective areas: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-territorial: https://optout.aboutads.info.
We include so-called affiliate links or other references (which may include, for example, discount codes) to the offers and services of third-party providers (collectively referred to as “affiliate links”) in our online offer. If users follow the Affiliate Links or subsequently take advantage of the offers, we may receive a commission or other benefits from those third parties (collectively, “Commission”).
In order to be able to track whether the users have taken advantage of the offers of an affiliate link used by us, it is necessary that the respective third-party providers learn that the users have followed an affiliate link used within our online offer. The assignment of the affiliate links to the respective business transactions or to other actions (e.g. purchases) serves the sole purpose of commission accounting and will be cancelled as soon as it is no longer necessary for the purpose.
For the purposes of the aforementioned allocation of the affiliate links, the affiliate links may be supplemented by certain values which are a component of the link or may be stored elsewhere, e.g. in a cookie. The values may include in particular the source website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer and an online identifier of the user.
Notes on legal basis: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Furthermore, their use may be a component of our (pre-)contractual services, provided that the use of the third-party providers was agreed in this context. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
We maintain online presences within social networks in order to communicate with the users active there or to offer information about us there.
We would like to point out that user data may be processed outside the European Union. This can result in risks for the users, because it could, for example, make it more difficult to enforce the rights of the users. With regard to US providers that are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we point out that they thereby undertake to comply with the data protection standards of the EU.
Furthermore, the data of users within social networks are usually processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behaviour and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behaviour and the interests of the users are stored. Furthermore, data can also be stored in the user profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
For a detailed description of the respective forms of processing and the options to object (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of information requests and the assertion of data subject rights, we also point out that these can be asserted most effectively with the providers. Only the providers have access to the user’s data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These can be, for example, graphics, videos or social media buttons as well as posts (hereinafter uniformly referred to as “content”).
The integration always requires that the third-party providers of this content process the IP address of the user, as without the IP address they would not be able to send the content to the user’s browser. The IP address is thus required for the presentation of these contents or functions. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to analyse information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as being linked to such information from other sources.
Notes on legal basis: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-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.
The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose for processing this data has ceased to apply or it is not required for the purpose).
If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.
Further information on the deletion of personal data can also be found in the individual data protection notices of this data protection declaration.
We encourage you to periodically review the content of our Privacy Policy. We adapt the data protection declaration as soon as changes in 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.
Where we provide addresses and contact details of companies and organisations in this privacy statement, please note that the addresses may change over time and please check the details before contacting us.
This section provides you with an overview of the terms used in this privacy statement. Many of the terms are taken from the law and are defined in particular in Art. 4 DSGVO. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.
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