Introduction
With the following privacy policy we would like to inform you about the types of personal data (hereinafter also referred to as “data”) we process, for what purposes and to what extent, as part of the provision of our services and in particular on our websites, in mobile applications and within external online sites, such as our social media profiles (collectively referred to as “online offer”).
The terms used are not gender specific.
Contents
- Introduction
- Responsible Person
- Processing Overview
- Relevant Legal Terms
- Security Measures
- Submission and Disclosure of Personal Information
- Third-Party Data Processing
- Use of Cookies
- Commercial and Business Services
- Payment Service Provider
- Contact
- Provisioning d it online and web hosting
- Cloud Services
- Newsletter and Lateral Communication
- Web Analytics and Optimization
- Online Marketing
- Plugins and Embedded Features and Content
- Deleting Data
- Changing and Updating the Privacy Policy
- Rights of Affected Persons
- Definitions
Responsible Person
Lennart Guth
Email Address: [email protected]
Processing Overview
The following overview summarizes and references the types of data processed and the purposes of their processing the individuals involved.
Types of processed data
- Inventory data (e.g. names, addresses).
- Content data (e.g. text input, photographs, videos).
- Contact details (e.g. e-mail, telephone numbers).
- Meta /communication data (e.g. device information, IP addresses )
- Usage data (e.g. websites visited, interest in content, access times).
- Contract data (e.g. subject matter, term, Customer category).
- Payment details (e.g. bank details, invoices, payment history).
Affected person categories
- Employees (e.g. employees, applicants, former employees).
- Business and contractors.
- prospects.
- communication partner.
- customers.
- Users (e.g. website visitors, online service users).
Purposes of processing
- Affiliate tracking.
- Providing our online offering and usability.
- Visit action evaluation.
- Office and Organizational Procedures.
- Direct Marketing (e.g. by e-mail or by mail).
- Interest-based and behavioral marketing.
- Contact requests and communication.
- Conversion measurement (measurement of marketing effectiveness).
- Profiling (creating user profiles).
- Reach metering (eg, access statistics, recurring visitor detection).
- Security measures.
- Tracking (e.g. interest /behavioral profiling, use of cookies).
- Contractual Services and Service.
- Manage and respond to inquiries.
Relevant Legal Terms
Below We share the legal basis of the General Data Protection Regulation (DSGVO), on the basis of which we process the personal data. Please note that in addition to the provisions of the GDPR, the national data protection regulations may apply in your home or in our home country.
- Consent (Article 6 (1) (1) (a) GDPR) – The data subject has his /her consent to the processing of personal data relating to him or her for a specific purpose Purpose or several specific purposes.
- Performance of the contract and pre-contractual inquiries (Article 6 (1) (1) (b) GDPR) – The Processing is necessary for the performance of a contract to which the data subject is a party or for the performance of any pre-contractual action taken at the request of the data subject.
- Legal obligation ( Art. 6 (1) (1) (c) GDPR) – Processing is required to fulfill a legal obligation to which the person responsible is subject.
- Legitimate interests (Article 6 (1) sentence 1 lit. DSGVO) – The processing is for the protection of the legitimate interests of the person responsible or of a third party provided that the interests or fundamental rights and freedoms of the data subject requiring the protection of personal data do not predominate.
National Data Protection Regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection in Germany apply. This includes in particular the law on the protection against misuse of personal data in data processing (Bundesdatenschutzgesetz – BDSG). In particular, the BDSG contains special rules on the right of access, the right of cancellation, the right to object, the processing of special categories of personal data, processing for other purposes and for transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (§ 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states can be applied.
Security Measures
We will meet the legal requirements, taking into account the state of the art, the implementation costs and the way in which the extent, circumstances and purposes of the processing, as well as the different likelihood of occurrence and the extent of the threat to the rights and freedoms of natural persons, appropriate technical and organizational measures to ensure a level of protection commensurate with the risk.
Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling the physical and electronic access to, and the access, input, transfer, availability and disconnection of data. We have also set up procedures to ensure the enjoyment of data subject rights, the erasure of data and responses to the threat to data. Furthermore, we consider the protection of personal data already in the development or selection of hardware, software and procedures according to the principle of data protection, through technology design and through privacy-friendly default settings.
SSL Encryption (https): To protect your data transmitted via our online offering, we use SSL encryption. You recognize such encrypted connections with the prefix https:// in the address bar of your browser.
Transmission and Disclosure of Personal Information
As part of our processing of personal information, data may be transmitted to or transmitted to other entities, businesses, legally independent organizational units or individuals be disclosed. To the recipients of this data may e.g. Payment institutions involved in payment transactions, IT service providers or providers of services and content incorporated into a website. In such cases, we comply with the legal requirements and in particular conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.
Inside the Organization: We may transfer personal information to, or grant access to, other sites within our organization. If this transfer is for administrative purposes, the transfer of the data is based on our legitimate commercial and business interests or takes place if it is necessary to fulfill our contractual obligations or if the parties have given their consent or a legal permit.
Data processing in third countries
Provided that we process data in a third country (ie, outside the European Union (EU), the European Economic Area (EEA)) or processing in the context of utilization third party services or the disclosure or transmission of data to other persons, bodies or companies, this is done only in accordance with legal requirements.
Except where expressly permitted or required by contract or by law, we process or disclose the data only in third countries with a recognized level of privacy, including those certified under the Privacy Shield, or on the basis of specific warranties, such as limited liability. Contractual obligation through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the European Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension -data-protection_en).
Use of Cookies
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 the information about a user during or after his visit to an online offer. The stored information may e.g. language settings on a web page, the login status, a shopping cart, or the location where a video was viewed. The term “cookies” also includes other technologies that perform the same functions as cookies (for example, when user information is stored using pseudonymous online identifiers, also referred to as “user IDs”)
The following cookie types and features are distinguished:
- Temporary cookies (also known as session or session cookies): Temporary cookies will be deleted at the latest after a user leaves an online offer and has closed their browser.
- Persistent cookies: Persistent cookies are also stored after closing the browser. For example, the login status can be saved or preferred content displayed directly when the user revisits a website. Likewise, the interests of users who are used to measure coverage or for marketing purposes may be stored in such a cookie.
- First-party cookies: First-party cookies are used by ourselves.
- Third party cookies (also known as third party cookies): Third party cookies are mainly used by advertisers (known as third parties) to process user information.
- Necessary (including essential or strictly required) cookies: Cookies may be required for the operation of a website (e.g. to save logins or other user input or for reasons of privacy) Security).
- Stats, Marketing and Personalization Cookies: In addition, cookies are typically used in the context of reach measurement and when a user’s interests or behavior ( e.g. viewing certain content, N utility of functions, etc.) are stored on individual web pages in a user profile. Such profiles serve to provide users with e.g. View content that matches your potential interests. This method is also referred to as “tracking,” that is, tracking the potential interests of users. , Insofar as we use cookies or “tracking” technologies, we will inform you separately in our privacy policy or in the context of obtaining consent.
Legal references: On which The legal basis for processing your personal data with the help of cookies depends on whether we ask for your 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 informed consent. Otherwise, the data processed by means of cookies will be processed on the basis of our legitimate interests (for example, in the course of a business operation of our online offer and its improvement) or, if the use of cookies is required, in order to fulfill our contractual obligations.
General notice on withdrawal and opposition (opt-out): Depending on whether the processing is based on a consent or legal permission, you have the opportunity at any time to revoke a given consent or the Processing of your data through cookie technologies (collectively referred to as “opt-out”). You may initially declare your disagreement through the settings of your browser, for example by disabling the use of cookies (which may also limit the functionality of our online offer). An objection to the use of cookies for online marketing purposes may also be made through a variety of services, especially in the case of tracking, via the web pages http://optout.aboutads.info and http://www.youronlinechoices.com/ be explained. In addition, you may receive further notice of objection in the context of the information on the service providers and cookies used.
Processing of cookie data based on consent: Before we process or process data in the context of the use of cookies, we ask the user for a revocable consent. Before consent has been given, cookies may be used that 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.
- Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta /communication data (e.g. device information, IP address).
- Affected persons: Users (e.g. website visitors, users of online services).
- Legal basis: Consent (Article 6 (1) (1) (a) GDPR), Legitimate interests (Article 6 (1) (1) (f) GDPR).
To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool “Real Cookie Banner”. Details on how “Real Cookie Banner” works can be found at https://devowl.io/rcb/data-processing/.
The legal basis for the processing of personal data in this context are Art. 6 (1) lit. c GDPR and Art. 6 (1) lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.
The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.
Commercial and Business Services
We process data of our contract and business partners, e.g. Customers and prospects (collectively referred to as “contractors”) in the context of contractual and comparable legal relationships and related measures and in the context of communication with the contractors (or pre-contractual), for example, to answer inquiries.
We process this data in order to fulfill our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with this information as well as the entrepreneurial organization. Within the scope of the applicable law, we only pass on the data of the contracting parties to third parties insofar as this is necessary for the aforementioned purposes or to fulfill legal obligations or with the consent of the contractual partners (e.g. to telecommunications, transport and other auxiliary services as well as subcontractors , Banks, tax and legal advisers, payment service providers or tax authorities). About other forms of processing, e.g. for marketing purposes, the contracting parties are informed in the context of this privacy policy.
What data is required for the above purposes, we inform the contractors or in the context of data collection, e.g. in online forms, by special marking (for example colors) or symbols (for example asterisks or the like), or in person with.
We delete the data after expiration of legal warranty and comparable obligations, ie basically after expiration of 4 years, unless the data are stored in a customer account, eg, as long as they have to be kept for legal reasons of archiving (e.g. for tax purposes usually 10 years). Data that has been disclosed to us as part of an order by the contracting party, we delete according to the specifications of the contract, in principle after the end of the contract.
To the extent that we use third-party vendors or platforms to provide our services, the terms and conditions and privacy notices of the respective third-party vendors or platforms apply to the relationship between the users and the vendors.
Customer account: Contractors can create an account within our online offer (e.g. customer or user account, in short “customer account”). If registration of a customer account is required, contractors will be notified as well as the information required for registration. The customer accounts are not public and can not be indexed by search engines. As part of the registration and subsequent registrations and uses of the customer account, we store the IP addresses of the customers along with the access times in order to prove the registration and to prevent any misuse of the customer account.
When customers cancel their customer account, the data relating to the customer account will be deleted, subject to retention being required by law. It is up to the customer to save their data upon termination of the customer account.
Economic analysis and market research: For economic reasons and in order to be able to recognize market trends, wishes of the contractors and users, we analyze the available data for business transactions, contracts, inquiries, etc., whereby in the Group of data subjects contractors, prospects, customers, visitors and users of our online offer may fall.
The analyzes are carried out for the purpose of business analysis, marketing and market research (for example, to determine customer groups with different characteristics). We can, if available, the profiles of registered users, including their details, e.g. to services used. The analyzes are for us alone and will not be disclosed externally unless they are anonymous analyzes with summarized, ie anonymised values. We also take into account the privacy of the users and process the data as a pseudonym and, if possible, anonymous (for example, as aggregated data) for analysis purposes.
Shop and E-Commerce: We process the data of our customers to enable them to select, purchase or order the products, goods and related services as well as their payment and delivery , or to allow execution.
The required information is marked as such within the scope of the order or comparable purchase transaction and includes the information required for delivery, provision and billing, as well as contact information, in order to be able to consult as much as possible.
IP Geolocation: Exclusively for EU tax reasons, we record the IP geolocation of the user on the page my.mailmergic.com/billing. In order to determine the correct taxability of the user, we record the IP geolocation and share it – in the case of a subscription to our software – with Stripe. To determine the Geolocation, the user’s IP is shared with https://ipapi.co. The privacy policy of ipapi.co can be found here: https://ipapi.co/privacy. The geolocation is then documented in Stripe.
Software and Platform Services Offering: We process the data of our users, registered and potential test users (collectively referred to as “Users”) in order to provide them with our contractual services and on a basis thereof legitimate interests in order to ensure the security of our offer and to develop it further. The required information is marked as such within the scope of the order, order or comparable contract conclusion and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations.
- Processed data types: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail , Telephone numbers), contract data (e.g. subject matter, term, customer category), usage data (e.g. visited websites, interest in content, access times), meta /communication data (e.g. device information, IP addresses).
- Affected Persons: Prospects, Business and Contractors, Customers.
- Purposes of Processing: Contractual services and service, contact requests and communication, office and organization procedures, inquiry management and response, security measures, visit action evaluation, interest and behavioral marketing, profiling (creating user profiles).
- Legal framework: Contracting and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), Legal Obligation (Article 6 (1) sentence 1 lit. c DSGVO), Legitimate Interests (Article 6 (1) sentence 1 lit. DSGVO).
Payment Service Provider
In the context of contractual and other legal relationships, due to legal obligations or otherwise based on our legitimate interests, we provide the persons concerned with efficient and secure payment options in addition to banks and credit institutions, there are other payment service providers (collectively “payment service providers”).
The data processed by our payment service provider, Stripe, includes inventory data, e.g. the name and the address, bank data, e.g. Account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, summary and recipient-related information. The information is required to complete the transactions. However, the data entered will only be processed and stored by Stripe. That is, we do not receive any account or credit card related information, but only information with confirmation or negative disclosure of the payment. The data may be transmitted by Stripe to credit reporting agencies. This transmission aims at the identity and credit check. For this we refer to the terms and conditions and the privacy policy of Stripe.
For the payment transactions, the terms and conditions and the privacy notices of the respective payment service providers apply, which can be accessed within the respective websites or transaction applications. We also refer to these for further information and assertion of rights of withdrawal, information and other data subjects.
- Processed data types: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. contract object, term , Customer category), usage data (e.g. visited websites, interest in content, access times), meta /communication data (e.g. device information, IP addresses).
- Affected People: Customers, prospects.
- Purposes of processing: Contact requests and communication, affiliate tracking.
- Legal basis:Performance of contract and pre-contractual inquiries (Article 6 (1) sentence 1 (b) GDPR), entitled interests (Article 6 (1) (1) lit. f. DSGVO).
Contact
When contacting us (e.g. via contact form, e-mail, telephone or via social media) the details of the requesting persons are processed, as far as d This is necessary to answer the contact requests and any action requested.
Responding to contact requests in the context of contractual or pre-contractual relationships is to fulfill our contractual obligations or to respond to (pre) contractual requests and otherwise based on legitimate interests in responding to requests.
Support Widget: For purposes of communication and response to inquiries, we offer a support widget within our online offering. Entries made by users within the chat will be processed for the purpose of responding to their requests. This website uses Help Scout, a live chat solution provided by Help Scout. Like most internet-service operators, Help Scout collects non-personally-identifying information of the sort that web browsers, apps and servers typically make available, such as the browser type, language preference, geographical location, referring site, and the date and time of each visitor request. Help Scout’s purpose in collecting non-personally identifying information is to better understand how Help Scout’s visitors use its services, and to provide Help Scout users the ability to understand how their visitors use their services. From time to time, Help Scout may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its services. Help Scout does not collect personally identifiable information except for that information you expressly give us. Help Scout uses cookies to collect this information. For more information on Help Scout and the types of cookies it uses, visit the Help Scout Privacy Policy: helpscout.com/company/legal/privacy.
- Processed data types: Contact data (e.g. e-mail), usage data (e.g. visited websites, interest in content, access times), meta /communication data (e.g. device information, IP addresses).
- Affected People: Communication partners, prospects.
- Purposes of processing: Contact requests and communication, administration and response to inquiries.
- Legal basis: Performance of contract and pre-contractual requests (Article 6 (1) sentence 1 (b) GDPR), entitled interests (Article 6 (1) p. 1 lit. fs. DSGVO).
Providing Online Services and Web Hosting
In order to provide our online services safely and efficiently, We take the services of one or more web hosting providers claiming from their servers (or managed by them) the online offer can be retrieved. For these purposes, we may use infrastructure and platform services, computing capacity, disk space and database services, as well as security and technical maintenance services.
The data processed in the provision of the hosting offer may include all information relating to the use and communication of the users of our online offer. This includes, on a regular basis, the IP address necessary to deliver the content of online content to browsers, and any input made within our website or web pages.
E-mail delivery and hosting: The web hosting services we use also include the sending, receiving and storing of e-mail. For these purposes the addresses of the recipients as well as sender as well as further information concerning the e-mail dispatch (for example the participating providers) as well as the contents of the respective e-mails are processed. The aforementioned data may also be processed for purposes of SPAM detection. We ask you to note that e-mails on the Internet are generally not encrypted. As a rule, e-mails are encrypted on the transport route, but (if no so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore take no responsibility for the transmission of emails between the sender and the recipient.
Collection of access data and log files: We ourselves (or our web hosting provider) collect data for every access to the server (so-called server log files). The server logfiles can contain the address and name of the retrieved web pages and files, the date and time of the retrieval, transferred data volumes, notification of successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses. Addresses and the requesting provider include.
The server log files can be used for security purposes, for example to avoid overloading the server (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure server utilization and stability .
- Processed data types: Content data (e.g. text input, photographs, videos), usage data (e.g. visited websites, interest in content, access times), meta – /communication data (e.g. device information, IP addresses).
- Affected persons: Users (e.g. website visitors, users of online services).
- Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. of the GDPR).
Cloud Services
We use software services accessible via the Internet and running on their providers’ servers (so-called “Cloud Services”, also referred to as “Software as a Service “) for the following purposes: document storage and management, calendar management, e-mailing, spreadsheets and presentations, exchange of documents, content and information with specific recipients or publication of web pages, forms or other content and information, as well as chats and participation in audio and video conferencing.
Within this framework, personal information may be processed and stored on the providers’ servers as far as they are part of our communications or otherwise processed by us as set out in 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 that they use for security and service optimization purposes.
If we use the cloud services for other users or publicly available web pages forms o.a. To provide documents and content, providers may store cookies on users ‘devices for web analytics purposes or to remember users’ preferences (e.g., in the case of media control).
Legal Considerations: If we ask for your consent to the use of the Cloud Services, the legal basis of the processing is your consent. Furthermore, their use may be part of our (pre-) contractual services, provided that the use of the cloud services has been agreed within this framework. Otherwise, users’ data will be processed based on our legitimate interests (i.e., interest in efficient and secure administrative and collaboration processes)
- Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text input, photographs) , Videos), usage data (e.g. visited websites, interest in content, access times), meta /communication data (e.g. device information, IP addresses).
- Affected Persons: Customers, employees (e.g. employees, applicants, former employees), prospects, communication partners.
- Purposes of processing: Office and organizational procedures.
- Legal basis: Consent (Article 6 (1) (1) (a) DSGVO), performance of the contract and pre-contractual inquiries (Art. 6 (1) sentence 1 (b) GDPR), entitled interests (Article 6 (1) sentence 1 lit. of the GDPR).
Deployed services and service providers:
- Google Cloud Services: Cloud Storage Services, Provider of the Computing Environment: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent Company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://cloud.google.com/; Privacy Policy: https://www.google.com/policies/privacy, Security Advisories: https://cloud.google.com/security/privacy; Privacy Shield (Data protection privacy level in the US): https: //www.privacyshield ? .gov /participant id=a2zt0000000000001L5AAI & status=Active code; Standard Contract Terms (Ensuring Data Protection Level for Third-Country Processing):https://cloud.google.com/terms /data-processing-terms code; Additional privacy information:https://cloud.google.com/terms/data-processing- terms
- Mailgun: Platform for sending transactional Emails; Service Provider: Mailgun, 112 E Pecan St. #1135, San Antonio, TX 78205, United States, Website: https://www.mailgun.com/; Privacy Policy: https://www.mailgun.com/privacy-policy/
- OpenAI: Large Language Model; Service Provider: OpenAI Ireland Ltd, 1st Floor, The Liffey Trust Centre, 117-126 Sheriff Street Upper, Dublin 1, D01 YC43, Ireland, Website: https://openai.com/; Privacy Policy: https://openai.com/policies/row-privacy-policy/
Newsletters and Latitude Communication
We will send you newsletters, e-mails and other electronic notifications (hereinafter ” Newsletter “) only with the consent of the recipients or a legal permission. Where in the context of an application to the newsletter whose contents are specifically described, they are authoritative for the consent of the users. Otherwise, our newsletters contain information about our services and us. p>
In order to subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name for personal address in the newsletter, or other information as required for the purpose of the newsletter.
Double opt-in procedure: Registration for our newsletter is generally done in a so-called double-opt-in procedure. This means that after signing up you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. Registration for the newsletter will be logged in order to prove the registration process according to the legal requirements. This includes saving the login and confirmation times as well as the IP address. Likewise, changes to your data stored with the shipping service provider will be logged.
Deletion and Limitation of Processing: We may save the email addresses discharged for up to three years on the basis of our legitimate interests before we delete them in order to provide evidence of prior consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for cancellation is possible at any time, provided that at the same time the former existence of a consent is confirmed. In the case of obligations to permanently observe contradictions, we reserve the sole purpose of storing the e-mail address for this purpose in a blacklist.
The logging of the registration process is based on our legitimate interests for the purpose of proving its proper course. Insofar as we commission a service provider with the dispatch of e-mails, this is done on the basis of our legitimate interests in an efficient and secure shipping system.
Legal notice: The distribution of the newsletter is based on the consent of the recipient or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and as far as legally permitted, e.g. in the case of existing customer advertising. Insofar as we entrust a service provider with the sending of e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests in order to prove that it has been performed in accordance with the law.
Content: Information about us, our services, promotions and offers.
Performance Measurement: The newsletters contain a so-called “web-beacon”, ie a pixel-sized file that is available from our server when the newsletter is opened or, if we use a shipping service provider, from our server This request will initially collect technical information, such as browser and system information, as well as your IP address and time of retrieval.
This information is used to improve the technicality of our newsletter, based on the technical data or the target groups and their reading habits, based on their retrieval locations (which can be determined using the IP address) or access times. This analysis also includes determining if 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 goal nor, if used, that of the shipping service provider to observe individual users. The evaluations serve to recognize the reading habits of our users and to adapt our content to them or to send different contents according to the interests of our users.
The evaluation of the newsletter and the performance measurement, subject to the express consent of the Users, shall be made on the basis of our legitimate interests for the purposes of using a user-friendly and secure newsletter system which serves both our business interests and the users’ expectations.
A separate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be terminated, or it must be contradicted.
- Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta- /communication data (e.g. Device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
- Affected persons: Communication partners.
- Purposes of processing: Direct marketing (e.g. by e-mail or by post).
- Legal basis: Consent (Article 6 (1) (1) (a) GDPR), Legitimate interests (Article 6 (1) (1) (f) GDPR).
- Opt-out: You can cancel the receipt of our newsletter at any time, ie Revoke your consent, or object to further reception. You can find a link to cancel the newsletter either at the end of each newsletter or else you can use one of the above-mentioned contact options, preferably e-mail.
Used Services and service providers:
- Mailgun: Platform for sending transactional Emails; Service Provider: Mailgun, 112 E Pecan St. #1135, San Antonio, TX 78205, United States, Website: https://www.mailgun.com/; Privacy Policy: https://www.mailgun.com/privacy-policy/
Web Analytics and Optimization
Web Analytics (also known as “Reach measurement” refers to the evaluation of the flow of visitors to our online offer and may be behavior, interests or demographic information about the visitors, such as the age or gender, as pseudonymous values include. With the help of range analysis we can e.g. recognize when our online offer or its features or content are used most frequently or are invited to reuse. Likewise, we can understand which areas need optimization.
In addition to web analytics, we can also use test methods e.g. to test and optimize different versions of our online offering or components.
For these purposes so-called user profiles can be created and stored in a file (so-called “cookie”) or similar methods with the same purpose can be used. To this information can e.g. content viewed, web pages visited and elements used there, and technical information such as the browser used, the computer system used, user sessions (incl. mouse movements, key strokes etc.) and times of use. If users have consented to the collection of their location data, these can also be processed, depending on the provider.
The IP addresses of the users are also saved. However, we use an IP masking method (i.e., pseudonymization by truncating the IP address) to protect users. In general, in the context of web analysis, A /B-testing and optimization, some data of the users are stored. That is, 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 purposes of the respective procedures.
Legal advice: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is their consent. Otherwise, users’ data will be processed based on our legitimate interests (i.e., interest in efficient, economical 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.
- Affected persons: Users (e.g. website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest /behavioral profiling, use of cookies), visitor action evaluation, profiling (creating user profiles).
- Security measures: IP-Masking, masking of text and form elements, exclusion of password and payment elements
Consent (Article 6 (1) (1) (a) GDPR), Legitimate interests (Article 6 (1) (1) (f) of the GDPR).
Service providers:
- Bugsnag: Monitoring App Health and Stability Platform; Service Provider: Bugsnag Inc., Level 5, The Old Malthouse, 18 Clarence St, Bath BA1 5NS, United Kingdom, Website: https://www.bugsnag.com/; Privacy Policy: https://docs.bugsnag.com/legal/privacy-policy/
- Microsoft Clarity: User Behavior Analytics Tool; Service Provider: Microsoft Ireland Operations Limited (MIOL), One Microsoft Place, South County Business Park, Leopardstown, Dublin 18 D18 P521, Ireland; Website: https://www.microsoft.com/; Privacy Policy: https://privacy.microsoft.com/en-US/privacystatement
- PostHog: User Behavior Analytics Tool; Service Provider: PostHog, Inc., 2261 Market Street #4008, San Francisco, CA 94114, United States; Website: https://posthog.com/; Privacy Policy: https://posthog.com/privacy
- Mailgun: Platform for sending transactional Emails; Service Provider: Mailgun, 112 E Pecan St. #1135, San Antonio, TX 78205, United States, Website: https://www.mailgun.com/; Privacy Policy: https://www.mailgun.com/privacy-policy/
Online Marketing
We process personal data for the purposes of online marketing, including in particular the marketing of advertising space or presentation of advertising and other content (collectively referred to as “content”) based on potential interests of users as well as d The measurement of their effectiveness may fall.
For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar methods are used, by means of which the information relevant to the presentation of the aforementioned contents to the user is stored. To this information can e.g. content viewed, websites visited, online networks used, as well as communication partners and technical information, such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, these can also be processed.
The IP addresses of the users are also saved. However, we use available IP masking techniques (i.e., pseudonymization by truncating the IP address) to protect users. In general, the online marketing process does not store user data (such as e-mail addresses or names) but pseudonyms. That is, we as well as the providers of online marketing methods do not know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles are usually stored in the cookies or similar procedures. These cookies can later generally also be read on other websites using the same online marketing method, analyzed and analyzed for purposes of displaying content, and supplemented with other data and stored on the server of the online marketing process provider.
By way of exception, clear data can be assigned to the profiles. This is the case when users are e.g. Members of a social network whose online marketing process we use and the network connects the profiles of users in the aforementioned information. We kindly ask you to note that users have additional agreements with the providers, e.g. through consent as part of the registration process.
We basically only have access to aggregated information about the success of our advertisements. However, in the context of so-called conversion measurements, we can examine which of our online marketing methods led to a so-called conversion, i. for example, to a contract with us. The conversion measurement is used solely to analyze the success of our marketing efforts.
Legal advice: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is their consent. Otherwise, users’ data will be processed based on our legitimate interests (i.e., interest in efficient, economical 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.
- Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta /communication data (e.g. device information, IP
- Affected Persons: Users (e.g. website visitors, online service users), prospects.
- Purposes of Processing: Tracking (e.g. Interesting /Behavioral Profiling, Use of Cookies), Visitor Action Evaluation, Interest Based and Behavioral Marketing, Profiling (Creating User Profiles), Conversion Measurement (Measurement of Effectiveness of marketing measures), range measurement (e.g. access statistics, recognition of returning visitors).
- Security Measures: IP-Masking (Pseudonymization of the IP-Address).
- Legal basis: Consent (Article 6 (1) sentence 1 (a) GDPR), entitled interest n (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
- Opposition possibility (opt-out): We refer to the privacy statements of the respective providers and the contradictory possibilities stated to the providers (so-called ” opt-Out “). Unless an explicit opt-out option has been specified, there is the possibility that you disable cookies in the settings of your browser. However, this can restrict functions of our online offer. We therefore also recommend the following opt-out options, which are offered in summary for specific areas: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Territorial: http://optout.aboutads.info.
Deployed services and service providers:
- Google Analytics: online marketing and web analytics; Service Providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent Company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/en/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (Data protection privacy level when processing US data): https: //www.privacyshield .gov /participant id=a2zt000000001L5AAI & status=Active code?; Opt-out plug-in:http://tools.google. com /dlpage /gaoptout? hl=en, ad insertion settings:https: //adssettings. google.com/authenticated.
- Google Ads & Conversions: We use the Google Ads online marketing process to run Google ads. Advertising network (eg, in search results, in videos, on websites, etc.), so that they are displayed to users who have a suspected interest in the ads. We also measure the conversion of the ads. However, we only hear about 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 information that identifies users. Service Providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Data protection: https://policies.google.com/privacy; Privacy Shield (Data protection privacy level when processing US data): https: //www.privacyshield .gov /participant? id=a2zt000000001L5AAI & status=Active.
Plugins and Embedded Features and Content
We’re Binding include in our online offering feature and content elements sourced from the servers of their respective providers (hereafter referred to as “Third Party Providers”), such as graphics, videos, social media buttons, and posts (hereafter referred to as “unified”) as “content”).
Involvement always requires that third-party content providers process the users’ IP address, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents or functions. We endeavor to use only those content whose respective providers use the IP address only for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to 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 may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and the operating system, websites to be referenced, time of visit, and other information regarding the use of our online offer.
Legal advice: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is their consent. Otherwise, users’ data will be processed based on our legitimate interests (i.e., interest in efficient, economical 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.
- Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta /communication data (e.g. device information, IP
- Affected persons: Users (e.g. website visitors, users of online services).
- Purposes of Processing: Providing our online offering and usability, contractual services and service.
- Legal basis: Eligible interests ( Art. 6 para. 1 sentence 1 lit. DSGVO).
Deployed services and service providers:
- Google Fonts: We incorporate the fonts (“Google Fonts”) of Google, whereby the users’ data are solely for the purpose of displaying the fonts be used in the browser of the users. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their consistent presentation and taking into account possible licensing restrictions for their integration. Service Providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent Company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (Data Protection Privacy Processing in the US): https: //www.privacyshield .gov /participant? id=a2zt0000000TRkEAAW & status=Active.
Deleting Data
The data we process will be deleted in accordance with the legal requirements as soon as their consent for processing is revoked or other authorizations cease to exist (eg, if the purpose of the processing of this data has been omitted or they are not necessary for the purpose).
Unless the data is deleted because it is necessary for other and legitimate purposes, its processing is limited to these purposes. That is, the data is locked and not processed for other purposes. This applies, for example for data that must be kept for commercial or tax reasons or that is required to be stored in order to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.
Further information on the deletion of personal data may also be provided in the context of the individual data protection notices of this privacy policy.
Changing and Updating the Privacy Policy
We ask that you regularly check the content of our Privacy Policy. We will adjust the Privacy Policy as soon as the changes to the data processing we make require it. We will inform you as soon as the changes require your participation (e.g. consent) or other individual notification.
Rights of data subjects
You are entitled to various rights under DSGVO, in particular from Articles 15 to 18 and 21 GDPR:
- Right to object: You have the right at any time, for reasons that arise from your particular situation, against the processing of your personal data, which, on the basis of Art. 6 para. 1 lit. e or f DSGVO takes an objection; this also applies to profiling based on these provisions. If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling, insofar as it is associated with such direct mail.
- Right of Withdrawal: You have the right to revoke your consent at any time.
- Right to information: You have the right to ask for confirmation of whether the data in question is being processed and to provide information about it, as well as further information and copies of the data in accordance with legal requirements.
- Right of rectification: You have the legal right to request the completion of the data concerning you or the correction of incorrect data concerning you.
- Right to delete and limit processing: You have the right, in accordance with the statutory provisions, to demand that data relating to you be deleted without delay, or, alternatively, in accordance with statutory provisions
- Right to Data Portability: You have the right to receive data relating to you that you have provided to us in accordance with the law Structured, common and machine-readable format or to request that it be forwarded to another person in charge.
- Complaint to the supervisory authority: You also have the right, in accordance with legal requirements, to consult a supervisory authority in particular in the Member State of your usual place of residence, employment or the place of the alleged infringement, if you consider that the processing of your personal data infringes the GDPR.
Term Definitions
This section provides an overview of the terminology used in this Privacy Policy. Many of the terms are taken from the law and defined above all in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended above all to aid understanding. The terms are sorted alphabetically.
- Affiliate Tracking: Affiliate tracking logs links that use linking websites to direct users to Web pages of product or other offerings. The operators of the respective linking websites can receive a commission if users follow these so-called affiliate links and subsequently take advantage of the offers (for example, buying goods or using services). For this, it is necessary that the providers can track whether users who are interested in certain offers, then perceive this on the occasion of the affiliate links. Therefore, the operability of affiliate links requires that they be supplemented with certain values that become part of the link or otherwise, e.g. stored in a cookie. The values 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, an online identifier of the user as well as tracking-specific values , such as Ad ID, affiliate ID, and categorizations.
- Visit Action Evaluation: “Conversion Tracking” is a method of determining the effectiveness of marketing activities. As a rule, a cookie is stored on the devices of the users within the websites on which the marketing measures take place, and then retrieved again on the destination website. For example, we can see if the ads we show on other websites have been successful).
- IP Masking: IP masking is a method of deleting the last octet, the last two digits of an IP address IP-Masking is a means of pseudonymizing processing techniques, especially in online marketing
- Interest-Based and Behavioral Marketing: From Interest and /or behavioral marketing is when potential interests of users in ads and other content are predicted as accurately as possible, based on information about their behavior (e.g. visiting certain websites and staying on top of them, buying behavior or interaction with other users ), which are stored in a so-called profile. Cookies are generally used for these purposes.
- Conversion measurement: The conversion method ssung is a process that can be used to determine the effectiveness of marketing activities. As a rule, a cookie is stored on the devices of the users within the websites on which the marketing measures take place, and then retrieved again on the destination website. For example, we can see if the ads we show on other websites have been successful.
- Personal information: “Personal information” means any information relating to an identified or identifiable natural person (hereinafter the “data subject”); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (e.g. cookie) or to one or more special features, are the expression of the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.
- Profiling: “Profiling” refers to any type of automated processing of personal data that involves the use of that personal information in order to identify certain personal aspects pertaining to a person natural person (depending on the type of profiling, this includes analyzing, assessing or predicting information about age, gender, location and movement data, interaction with websites and their content, shopping behavior, social interactions with other people) (e.g. the interests in certain content or products, the click behavior on a website or the whereabouts.) For purposes of profiling, cookies and web beacons are frequently used.
- Reach measurement: The range measurement (also referred to as Web Analytics) is used to evaluate the flow of visitors to an online offer and the behavior or interests of visitors to certain information, such as. Content of web pages. With the help of range analysis, website owners can e.g. Recognize at what time visitors visit their website and what content they are interested in. Thereby they can e.g. to better tailor the contents of the website to the needs of its visitors. For purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors for more accurate analysis of how to use an online offer.
- Remarketing: Remarketing or retargeting is when, for example, For advertising purposes, it is noted for which products a user has been interested in a web page in order to provide the user on other web pages with these products, e.g. in advertisements, to remember.
- Tracking: “Tracking” is when the behavior of users across multiple online offerings can be tracked. Usually, behavioral and interest information in regards to the online offerings used is in Cookies or stored on servers of the providers of tracking technologies (so-called profiling) .This information can then be used, for example, to show users advertisements that are likely to serve their interests.
- Responsible: ‘Responsible person’ means the natural or legal person, public authority, body or body which, alone or in concert with others, decides on the purposes and means of processing personal data.
- Processing: “Processing” means any process or series of operations associated with personal information, whether performed with or without the aid of automated procedures. The term covers a wide range and covers practically every handling of data, be it collection, evaluation, storage, transfer or deletion.
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