Privacy policy
Preamble
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” for short) 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 as part of the provision of our services and, in particular, on our websites, in mobile applications and 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: September 9, 2023
Table of contents
– Preamble
– Responsible party
– Overview of processing operations
– Relevant legal basis
– Security measures
– Transfer of personal data
– International data transfers
– Deletion of data
– Rights of the data subjects
– Use of cookies
– Business services
– Payment procedures
– Provision of the online offer and web hosting
– Registration, login and user account
– Blogs and publication media
– Video conferencing, online meetings, webinars and screen sharing
– Newsletter and electronic notifications
– Promotional communication via e-mail, mail, fax or telephone
– Web analytics, monitoring and optimization
– Digital badges
– Presence in social networks (social media)
– Plugins and embedded functions and content
– Modification and update of the privacy policy
– Definitions of terms
Responsible party
Michael Forbes
*Iyengar®Yoga-München.iYoga,
Michael Forbes – Margareta Eckl GbR*
*iYoga GmbH* (Geschäftsführerin: Margareta Eckl)
Waltherstr. 23
80337 München
Deutschland
E-Mail-Adresse:
info@iyoga.de
Telefon:
+49 89 537170
Impressum:
http:www.iyoga/impressum/
Applicable legal basis
Relevant legal grounds according to the DSGVO: The following is an overview of the legal groundsunder the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Furthermore, should more specific legal groundsbe relevant in individual cases, we will inform you of these in the data protection declaration.
– Consent (Art. 6 (1) p. 1 lit. a) DSGVO) – The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
– Performance of a contract and pre-contractual requests (Art. 6 (1) p. 1 lit. b) DSGVO) – Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures carried out at the data subject’s request.
– Legal obligation (Art. 6 (1) p. 1 lit. c) DSGVO) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
– Legitimate interests (Art. 6 (1) p. 1 lit. f) DSGVO) – Processing is necessary for the purposes of the legitimate interests of the controller or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – 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, processing for other purposes and transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may apply.
Applicable legal basis according to the Swiss Data Protection Act: If you are in Switzerland, we process your data on the basis of the Federal Data Protection Act (in short “Swiss DPA”). This also applies if our processing of your data otherwise affects you in Switzerland and you are affected by the processing. In principle, the Swiss DPA does not require (unlike the GDPR, for example) that a legal basis for the processing of personal data must be stated. We only process personal data if the processing is lawful, is carried out in good faith and is proportionate (Art. 6 (1) and (2) of the Swiss DPA). Furthermore, personal data is only obtained by us for a specific purpose that is recognizable to the data subject and is only processed in a way that is compatible with these purposes (Art. 6 para. 3 of the Swiss Data Protection Act).
Note on applicability DSGVO and Swiss DSG: This data protection notice serves to provide information in accordance with both the Swiss Federal Data Protection Act (Swiss DSG) and the General Data Protection Regulation (DSGVO). For this reason, we ask you to note that due to the broader spatial application and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms “processing” of “personal data”, “overriding interest” and “particularly sensitive personal data” used in the Swiss DPA, the terms “processing” of “personal data” as well as “legitimate interest” and “special categories of data” used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of its application.
Overview of processing operations
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
– Inventory data.
– Payment data.
– Location data.
– Contact data.
– Content data.
– Contract data.
– Usage data.
– Meta, communication and procedural data.
Special categories of data
– Health data.
– Sex life or sexual orientation data.
– Religious or ideological beliefs.
– Data revealing racial or ethnic origin.
Categories of data subjects
– Customers.
– Prospective customers.
– Communication partners.
– Users.
– Business and contractual partners.
– Pupils/ students/ participants.
– Persons depicted.
Purposes of processing
– Provision of contractual services and fulfillment of contractual obligations.
– Contact requests and communication.
– Security measures.
– Direct marketing.
– Range measurement.
– Office and organizational procedures.
– Managing and responding to inquiries.
– Feedback.
– Marketing.
– Profiles with user-related information.
– Provision of our online offer and user friendliness.
– Information technology infrastructure.
– Public relations and information purposes.
Security measures
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the 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, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, safeguarding 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. Furthermore, we have established procedures 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 during the development or selection of hardware, software as well as procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
TLS encryption (https): To protect your data transmitted via our online offer, we use TLS encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.
Transmission of personal data
In the course of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons or that it is disclosed to them. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.
Data transfer within the organization: We may transfer personal data to other bodies within our organization or grant them access to this data. Where this transfer is for administrative purposes, the transfer of data is based on our legitimate business and operational interests or is made where it is necessary to fulfill our contract-related obligations or where we have the consent of the data subjects or legal permission.
International data transfers
Data processing in third countries: if we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies, this is only done in accordance with the legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 DSGVO), this serves as the basis for the data transfer. Otherwise, data transfers will only take place if the level of data protection is otherwise ensured, in particular by standard contractual clauses (Art. 46(2)(c) DSGVO), explicit consent or in the case of contractual or legally required transfer (Art. 49(1) DSGVO). In all other respects, we will inform you of the basis for third-country transfers in the case of individual providers from the third country, with the adequacy decisions taking precedence as the basis. Information on third country transfers and existing adequacy decisions can be found in the EU Commission’s information offer: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de.
EU-US Trans-Atlantic Data Privacy Framework: Within the framework of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the level of data protection for certain companies from the USA as safe within the framework of the adequacy decision of July 10, 2023. The list of certified companies as well as further information on the DPF can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/ . We will inform you in the privacy notice which service providers we use are certified under the Data Privacy Framework.
Disclosure of personal data abroad: In accordance with the Swiss Data Protection Act (DSG), we only disclose personal data abroad if adequate protection of the data subjects is guaranteed (Art. 16 Swiss DSG). If the Federal Council has not determined adequate protection (list: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html ), we take alternative security measures. These may include international treaties, specific guarantees, data protection clauses in contracts, standard data protection clauses approved by the Swiss Federal Data Protection and Information Commissioner (FDPIC), or internal company data protection regulations recognized in advance by the FDPIC or a competent data protection authority in another country.
According to Art. 16 of the Swiss FADP, exceptions may be allowed for the disclosure of data abroad if certain conditions are met, including consent of the data subject, performance of a contract, public interest, protection of life or physical integrity, data made public or data from a register provided for by law. These disclosures are always made in accordance with legal requirements.
Deletion of data
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 of processing this data has ceased to apply or it is not necessary 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. That is, 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 defense of legal claims or to protect the rights of another natural or legal person. As part of our privacy notices, we may provide users with further information regarding the deletion as well as the retention of data that is specific to the processing operation in question.
Rights of the data subjects
Data subjects’ rights under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:
– Right to object: you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
– Right to withdraw consent: You have the right to revoke any consent given at any time.
– Right to information: You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with legal requirements.
– Right to rectification: In accordance with the legal requirements, you have the right to request that the data concerning you be completed or that the incorrect data concerning you be rectified.
– Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be erased without delay or, alternatively, to demand restriction of the processing of the data in accordance with the legal requirements.
– Right to data portability: you have the right to receive data relating to you that you have provided to us in a structured, common and machine-readable format, or to request that it be transferred to another controller, in accordance with the law.
– Complaint to supervisory authority: In accordance with the law and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you usually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
Rights of data subjects under the Swiss DPA:
As a data subject, you are entitled to the following rights in accordance with the requirements of the Swiss DPA:
– Right of access: you have the right to request confirmation as to whether personal data relating to you is being processed and to receive such information as is necessary to enable you to exercise your rights under this Act and to ensure transparent data processing.
– Right to obtain the release or transfer of data: you have the right to request the release of your personal data that you have disclosed to us in a commonly used electronic format.
– Right to rectification: you have the right to request the rectification of inaccurate personal data concerning you.
– Right to object, erasure and destruction: you have the right to object to the processing of your data, as well as to request that the personal data concerning you be erased or destroyed.
Use of cookies
Cookies are small text files, or other memory notes, which store information on end devices and read information from the end devices. For example, to store the login status in a user account, a shopping cart content in an e-shop, the content accessed or used functions of an online offer. Cookies can further be used for various purposes, e.g. for purposes of functionality, security and comfort of online offers as well as the creation of analyses of visitor flows.
Notes on consent: We use cookies in accordance with legal requirements. Therefore, we obtain prior consent from users except where it is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary to provide a telemedia service (i.e., our online offering) expressly requested by users. The strictly necessary cookies usually include cookies with functions related to the display and operability of the online offer , load balancing, security, storage of users’ preferences and choices or similar purposes related to the provision of the main and secondary functions of the online offer requested by the users. The revocable consent is clearly communicated to the users and contains the information about the respective cookie use.
Notes on legal grounds under data protection law: the legal basis under data protection law on which we process users’ personal data using cookies depends on whether we ask users for consent. If users consent, the legal basis for the processing of their data is the declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in a business operation of our online offer and improvement of its usability) or, if this is done in the context of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. For what purposes the cookies are processed by us, we clarify in the course of this privacy policy or in the context of our consent and processing procedures.
Storage duration: With regard to the storage duration, the following types of cookies are distinguished:
– Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his end device (e.g. browser or mobile application).
– Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., as part of obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.
General information on revocation and objection (so-called “opt-out”): Users can revoke the consents they have given at any time and object to the processing in accordance with the legal requirements. For this purpose, users can, among other things, restrict the use of cookies in the settings of their browser (whereby 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 via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ .
– Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO). Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
Further notes on processing processes, procedures and services:
– Processing of cookie data based on consent: We use a cookie consent management procedure, in the context of which the consent of users to the use of cookies, or the processing and providers mentioned in the cookie consent management procedure can be obtained and managed and revoked by users. Here, the declaration of consent is stored in order not to have to repeat its query and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies), in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. Here, a pseudonymous user identifier is formed and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used; legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
– Compliance: Cookie consent management; Service provider: Hosted locally on our server, no data transfer to third parties; Website: https://complianz.io/ ; Privacy policy: https://complianz.io/legal/ . Additional Information: An individual user ID, language, as well as types of consents and the time of their submission are stored on the server side and in the cookie on the users’ device.
Business services
We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer inquiries.
We process this data in order to fulfill our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. In addition, we process the data to safeguard our rights and for the purpose of administrative tasks associated with these obligations and company organization. Furthermore, we process the data on the basis of our legitimate interests in proper and business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.
We inform the contractual partners which data is required for the aforementioned purposes before or in the course of data collection, e.g. in online forms, by means of special marking (e.g. colors) 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. The statutory retention period for documents relevant under tax law and for commercial books, inventories, opening balances, annual financial statements, the work instructions required to understand these documents and other organizational documents and accounting records is ten years and for received commercial and business letters and reproductions of sent commercial and business letters six years. The period shall commence at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was prepared, the commercial or business letter was received or dispatched or the accounting document was created, furthermore the recording was made or the other documents were created.
Insofar as 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 shall apply in the relationship between the users and the providers.
– Types of data processed: inventory data (e.g., names, addresses); payment data (e.g., bank details, invoices, payment history); contact data (e.g., e-mail, telephone numbers); contract data (e.g., subject matter of contract, term, customer category); usage data (e.g., websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
– Special categories of personal data: Health data; Sex life or sexual orientation data; Religious or ideological beliefs. Data revealing racial or ethnic origin.
– Data subjects: Customers; prospective customers; business and contractual partners. Pupils/ students/ participants.
– Purposes of processing: provision of contractual services and fulfillment of contractual obligations; security measures; contact requests and communication; office and organizational procedures. Administration and response to requests.
– Legal grounds: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); legal obligation (Art. 6 para. 1 p. 1 lit. c) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further notes on processing processes, procedures and services:
– Customer account: Customers can create an account within our online offer (e.g. customer or user account, “customer account” for short). If registration of a customer account is required, customers will be informed of this as well as the information required for registration. Customer accounts are not public and cannot be indexed by search engines. In the course of registration and subsequent logins and use of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove registration and prevent any misuse of the customer account. If the customer account has been terminated, the data of the customer account will be deleted after the termination date, unless they are kept for other purposes than the provision in the customer account or must be kept for legal reasons (e.g. internal storage of customer data, order transactions or invoices). It is the responsibility of the customers to secure their data when terminating the customer account; legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
– Store and e-commerce: We process the data of our customers to enable them to select, purchase or order the selected products, goods and associated services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery, or execution to our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is identified as such in the context of the order or comparable acquisition process and includes the information needed for delivery, or provision and billing, as well as contact information in order to be able to make any consultations; Legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
– Education and training services: We process the data of participants in our education and training services (uniformly referred to as “trainees”) in order to be able to provide our training services to them. The data processed in this context, the nature, scope, purpose and necessity of their processing are determined by the underlying contractual and training relationship. The forms of processing also include the performance assessment and evaluation of our services and those of the teachers. In the course of our activities, we may also process special categories of data, in particular data relating to the health of trainees and students, as well as data revealing ethnic origin, political opinions, religious or philosophical beliefs. For this purpose, we obtain the explicit consent of the trainees, if required, and otherwise process the special categories of data only if it is necessary for the provision of the training services, for the purposes of preventive health care, social protection or the protection of vital interests of the trainees; legal grounds: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
– Coaching: We process the data of our clients as well as 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.
Within the scope of our activities, we may also process special categories of data, in this case in particular information on the health of clients, possibly with reference to their sex life or sexual orientation, as well as data revealing racial and ethnic origin, political opinions, religious or ideological beliefs or trade union membership. For this purpose, we obtain explicit consent from clients, if required, and otherwise process the special categories of data if this serves the health of the clients, the data is public or other legal permissions exist.
If it is necessary for the fulfillment of our contract, for the protection of vital interests or required by law, or if we have the consent of the client, we disclose or transfer the client’s data to third parties or agents, such as public authorities, billing offices and in the area of IT, office or comparable services, in compliance with the requirements of professional law;
Legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
– Online courses and online training: We process the data of the participants of our online courses and online trainings (uniformly referred to as “Participants”) in order to be able to provide our course and training services to them. The data processed in this context, the type, scope, purpose and necessity of its processing are determined by the underlying contractual relationship. The data basically include details of the courses taken and services provided and, insofar as part of our range of services, personal specifications and results of the participants. The forms of processing also include the performance evaluation and the evaluation of our services as well as those of the course and training instructors; legal basis: fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Payment procedure
In the context 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 service providers for this purpose in addition to banks and credit institutions (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 in order 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 payment service providers transmit the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the terms and conditions and the privacy policy of the payment service providers.
The terms and conditions and the data protection notices of the respective payment service providers apply to the payment transactions, which can be accessed within the respective websites or transaction applications. We also refer to these for further information and assertion of revocation, information and other data subject rights.
– Types of data processed: inventory data (e.g., names, addresses); payment data (e.g., bank details, invoices, payment history); contract data (e.g., subject matter of contract, term, customer category); usage data (e.g., websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
– Data subjects: Customers. Interested parties.
– Purposes of processing: provision of contractual services and fulfillment of contractual obligations.
– Legal grounds: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Further notes on processing processes, procedures and services:
– Giropay: Payment services (technical connection of online payment methods); Service provider: giropay GmbH, An der Welle 4, 60322 Frankfurt, Germany; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://www.giropay.de . Privacy policy: https://www.giropay.de/rechtliches/datenschutzerklaerung/ .
– PayPal: payment services (technical connection of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; legal basis: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); website: https://www.paypal.com/de . Privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full .
– Stripe: payment services (technical connection of online payment methods); service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://stripe.com ; Privacy policy: https://stripe.com/de/privacy . Basis of third country transfer: EU-US Data Privacy Framework (DPF).
Provision of the online offer and web hosting
We process users’ data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or terminal device.
– Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status). Content data (e.g., entries in online forms).
– Data subjects: Users (e.g. website visitors, users of online services).
– Purposes of processing: provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.).). Security measures.
– Legal grounds: legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further notes on processing processes, procedures and services:
– Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called “web hoster”); legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
– Collection of access data and log files: Access to our online offer is logged in the form of 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 access, data volumes 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. The server log files may be used, on the one hand, for security purposes, e.g., to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO). Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.
– 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 SPAM detection purposes. Please note that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method 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; legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
– Mittwald: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: Mittwald CM Service GmbH & Co. KG, Königsberger Straße 4-6, 32339 Espelkamp, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.mittwald.de ; Privacy policy: https://www.mittwald.de/datenschutz . Order processing contract: https://www.mittwald.de/faq/service-informationen/faq/datenschutz-alles-wichtige-zur-dsgvo .
– WordPress.com: hosting and software for the creation, provision and operation of websites, blogs and other online offerings; service provider: Aut O’Mattic A8C Ireland Ltd, Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://wordpress.com ; Privacy policy: https://automattic.com/de/privacy/ ; Order processing contract: https://wordpress.com/support/data-processing-agreements/ . Basis third country transfer: EU-US Data Privacy Framework (DPF).
Registration, login and user account
Users can create a user account. As part of the registration process, users are provided with the required mandatory data and processed for purposes of providing the user account based on contractual obligation fulfillment. The processed data includes in particular the login information (username, password and an e-mail address).
Within the scope of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorized use. As a matter of principle, this data is not passed on to third parties unless it is necessary for the prosecution of our claims or there is a legal obligation to do so.
Users may be informed by e-mail about events relevant to their user account, such as technical changes.
– Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms). Meta, communication and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
– Data subjects: Users (e.g., website visitors, users of online services).
– Purposes of processing: providing contractual services and fulfilling contractual obligations; security measures; managing and responding to requests. Provision of our online offer and user-friendliness.
– Legal grounds: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further notes on processing processes, procedures and services:
– Registration with clear name: Due to the nature of our community, we ask users to use our services only by using clear names. I.e. the use of pseudonyms is not permitted; legal basis: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
– User profiles are not public: User profiles are not publicly visible or accessible.
– Deletion of data after termination: If users have terminated their user account, their data with regard to the user account will be deleted, subject to any legal permission, obligation or consent of the users; legal grounds: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
– No obligation to retain data: It is incumbent on users to save their data in the event of termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract; legal basis: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Blogs and publication media
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.
– Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. web pages visited, interest in content, access times). Meta, communication and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
– Data subjects: Users (e.g., website visitors, users of online services).
– Purposes of processing: provision of contractual services and fulfillment of contractual obligations; feedback (e.g., collecting feedback via online form); provision of our online offer and user experience. Security measures.
– Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further information on processing processes, procedures and services:
– Akismet Anti-Spam Check: Akismet Anti-Spam Check – We use the service “Akismet” based on our legitimate interests. With the help of Akismet, comments from real people are distinguished from spam comments. For this purpose, all comment details are sent to a server in the USA, where they are analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data is stored beyond this time. This information includes the name entered, the e-mail address, the IP address, the comment content, the referrer, information about the browser used as well as the computer system and the time of the entry.
Users are welcome to use pseudonyms or to refrain from entering their name or email address. You can completely prevent the transfer of data by not using our commenting system. That would be a shame, but unfortunately we don’t see any alternatives that work as effectively;
Service provider: Aut O’Mattic A8C Ireland Ltd, Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://automattic.com ; Privacy policy: https://automattic.com/privacy . Basis third country transfer: EU-US Data Privacy Framework (DPF).
– UpdraftPlus: backup software and backup storage; service provider: Simba Hosting Ltd, 11, Barringer Way, St. Neots, Cambs., PE19 1LW, GB; Legal basis: Legitimate Interests (Art. 6 para. 1 sentence 1 lit. f) DSGVO); Website: https://updraftplus.com/ . Privacy Policy: https://updraftplus.com/data-protection-and-privacy-centre/ .
Video conferencing, online meetings, webinars and screen sharing.
We use platforms and applications of other providers (hereinafter referred to as “conference platforms”) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as “conference”). When selecting the Conference Platforms and their services, we comply with the legal requirements.
Data Processed by Conference Platforms: In the course of participating in a conference, the conference platforms process the personal data of the participants mentioned below. The scope of the processing depends, on the one hand, on which data is requested in the context of a specific conference (e.g., provision of access data or clear names) and which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants’ data may also be processed by the conference platforms for security purposes or service optimization. The processed data includes personal data (first name, last name), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the Internet access, information on the participants’ terminal devices, their operating system, the browser and its technical and language settings, information on the content of communications, i.e. entries in chats and audio and video data, as well as the use of other available functions (e.g. surveys). Content of communications is encrypted to the extent technically provided by the conference providers. If participants are registered as users with the conference platforms, then further data may be processed according to the agreement with the respective conference provider.
Logging and recordings: If text entries, participation results (e.g., from surveys), and video or audio recordings are logged, this will be transparently communicated to participants in advance and they will be asked for consent – if necessary.
Data protection measures of the participants: Please note the details of the processing of your data by the conference platforms in their data protection notices and select the security and data protection settings that are optimal for you within the framework of the settings of the conference platforms. Furthermore, please ensure data and privacy protection in the background of your recording for the duration of a videoconference (e.g., by notifying roommates, locking doors, and using the background masking function, if technically possible). Links to the conference rooms as well as access data, must not be passed on to unauthorized third parties.
Notes on legal grounds: If, in addition to the conference platforms, we also process users’ data and ask users for their consent to use the conference platforms or certain functions (e.g., consent to a recording of conferences), the legal basis for the processing is this consent. Furthermore, our processing may be necessary for the fulfillment of our contractual obligations (e.g., in lists of participants, in the case of reprocessing of call results, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.
– Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
– Data subjects: Communication partners; users (e.g., website visitors, users of online services). Persons depicted.
– Purposes of processing: provision of contractual services and fulfillment of contractual obligations; contact requests and communication. Office and organizational procedures.
– Legal grounds: legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further notes on processing operations, procedures and services:
– Zoom: conferencing and communications software; service provider: Zoom Video Communications, Inc, 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://zoom.us ; Privacy policy: https://zoom.us/docs/de-de/privacy-and-legal.html ; Order processing agreement: https://zoom.us/docs/de-de/privacy-and-legal.html (referred to as Global DPA). Basis for third country transfers: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://zoom.us/docs/de-de/privacy-and-legal.html (referred to as Global DPA)).
Newsletter and electronic notifications
We send newsletters, e-mails and other electronic notifications (hereinafter referred to as “newsletters”) only with the consent of the recipients or a legal permission. If the contents of the Newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. Otherwise, our newsletters contain information about our services and us.
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 the purpose of personal address in the newsletter, or further information, if this is 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 e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise, changes to your data stored with the dispatch service provider are logged.
Deletion and restriction of processing: We may store unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove consent previously given. The processing of this data will be limited to the purpose of a possible defense 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 case of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list (so-called “block list”) for this purpose alone.
The logging of the registration process takes place on the basis of our legitimate interests for the purposes of proving its proper course. Insofar as 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.
Contents:
Information about us, our services, promotions and offers.
– Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status). Usage data (e.g., web pages visited, interest in content, access times).
– Data subjects: Communication partners.
– Purposes of processing: direct marketing (e.g., by e-mail or postal mail).
– Legal grounds: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
– 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 otherwise use one of the contact options given above, preferably e-mail, for this purpose.
Further information on processing, procedures and services:
– Measurement of opening and click-through rates: The newsletters contain a so-called “web beacon”, i.e., a pixel-sized file that is retrieved from our server or, if we use a shipping service provider, from its server when the newsletter is opened. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the retrieval, are initially collected. This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. We use the analyses to identify 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 measurement of the opening rates and the click rates as well as the storage of the measurement results in the profiles of the users and their further processing are based on the consent of the users.
A separate revocation of the performance measurement is unfortunately not possible; in this case, the entire newsletter subscription must be cancelled or must be contradicted. In this case, the stored profile information will be deleted;
Legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
– Mailchimp: email delivery and automation services; service provider: Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://mailchimp.com ; Privacy policy: https://mailchimp.com/legal/ ; Order processing agreement: https://mailchimp.com/legal/ ; Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (Will be provided by the service provider). Additional information: Special security measures: https://mailchimp.com/help/Mailchimp-european-data-transfers/ .
Promotional communications via email, post, fax or telephone.
We process personal data for the purposes of promotional communications, which may take place via various channels, such as e-mail, telephone, mail or fax, in accordance with legal requirements.
Recipients have the right to revoke consent given at any time or to object to promotional communication at any time.
After revocation or objection, we store the data required to prove the previous authorization to contact or send for up to three years after the end of the year of revocation or objection based on our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. Based on the legitimate interest of permanently observing the user’s revocation or objection, we also store the data required to avoid contacting the user again (e.g., depending on the communication channel, the e-mail address, telephone number, name).
– Types of data processed: inventory data (e.g. names, addresses). Contact data (e.g. e-mail, telephone numbers).
– Data subjects: Communication partners.
– Purposes of processing: direct marketing (e.g. by e-mail or post).
– Legal grounds: consent (Art. 6 (1) p. 1 lit. a) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Web analysis, monitoring and optimization
Web analysis (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can recognize, for example, 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 optimization.
In addition to web analytics, we may also use testing procedures, for example, to test and optimize different versions of our online offering or its components.
Unless otherwise stated below, profiles, i.e. data summarized for a usage process, may be created for these purposes and information may be stored in a browser, or in a terminal device, and read from it. The information collected includes, in particular, websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed.
The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, in the context of web analysis, A/B testing and optimization, no clear data of the users (such as e-mail addresses or names) are stored, but pseudonyms. 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.
– Types of data processed: Usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
– Data subjects: Users (e.g., website visitors, users of online services).
– Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online services and user experience.
– Security measures: IP masking (pseudonymization of the IP address).
– Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further notes on processing processes, procedures and services:
– Google Analytics 4: We use Google Analytics to measure and analyze the use of our online offer on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or e-mail addresses. It is used to assign analysis information to a terminal device in order to recognize which content users have accessed within one or various usage processes, which search terms they have used, have accessed again or have interacted with our online offering. Likewise, the time of use and its duration are stored, as well as the sources of users referring to our online offer and technical aspects of their end devices and browsers. In the process, pseudonymous profiles of users are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides coarse geographic location data by deriving the following metadata from IP addresses: City (and the derived latitude and longitude of the city), Continent, Country, Region, Subcontinent (and ID-based counterparts). For EU traffic, IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. They are not logged, are not accessible, and are not used for any other purpose. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before traffic is forwarded to Analytics servers for processing; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://marketingplatform.google.com/intl/de/about/analytics/ ; Privacy policy: https://policies.google.com/privacy ; Order processing agreement: https://business.safety.google/adsprocessorterms/ ; Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms ); Opt-out: Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de , Ad Display Settings: https://adssettings.google.com/authenticated . Further information: https://privacy.google.com/businesses/adsservices (types of processing as well as data processed).
Digital Badges
Digital Badges, also referred to as Open Badges (hereinafter “Badges” for short), are digital certificates confirming the skills, achievements and interests of individuals or organizations. They are issued by credible organizations. Badges are accompanied by metadata and information about the skills and achievements acquired. Typically, badges are represented by an image or a digital certificate that includes details about the recipient, issuer, metadata, and other relevant information.
When badges are issued individually to specific individuals, the metadata stored in the badges and used for attribution purposes regarding the skills, achievements and interests of the individuals concerned are processed.
If cookies and comparable technologies are used as part of the badges that are not required and therefore or otherwise require the consent of the users, we obtain the relevant consent of the users and inform them accordingly.
– Types of data processed: inventory data (e.g. names, addresses); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
– Data subjects: Business and contractual partners. Users (e.g., website visitors, users of online services).
– Purposes of processing: provision of contractual services and fulfillment of contractual obligations; public relations and information purposes. Provision of our online offer and user-friendliness.
– Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further information on processing, procedures and services:
– Embedding of digital badges: as part of our online offer, we integrate badges from other sources (so-called “embedding”). This means that both the representation of the badge and the associated metadata are output within our offer. In doing so, they are loaded in real time from the servers of the respective badge provider in order to always present the most current content of the badge. To realize this, a data connection is established between our online offer and the server of the badge provider. The technical data that the badge provider receives includes the IP address, details and metadata of the badge, information about the website visited, the time of the call and technical details about the browser and system as they are transmitted from the end device to the server. This data transmission also informs the badge provider that a user has accessed our online offer; legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Presence in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for the users because, for example, it could make it more difficult to enforce the rights of the users.
Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior 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 behavior and interests of the users are stored. Furthermore, data may also be stored in the usage 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 presentation of the respective forms of processing and the options to object (opt-out), we refer to the privacy statements and information provided by the operators of the respective networks.
In the case of information requests and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need assistance, you can contact us.
– Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
– Data subjects: Users (e.g., website visitors, users of online services).
– Purposes of processing: contact requests and communication; feedback (e.g., collecting feedback via online form). Marketing.
– Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further notes on processing operations, procedures and services:
– Instagram: social network; service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal Grounds: Legitimate Interests (Art. 6 (1) p. 1 lit. f) DSGVO); Website: https://www.instagram.com . Privacy policy: https://instagram.com/about/legal/privacy .
– Facebook pages: Profiles within the Facebook social network – We are jointly responsible with Meta Platforms Ireland Limited for collecting (but not further processing) data from visitors to our Facebook page (known as a “Fan Page”). This data includes information about the types of content users view or interact with, or the actions they take (see under “Things You and Others Do and Provide” in the Facebook Data Policy: https://www.facebook.com/policy ), as well as information about the devices users use (e.g., IP addresses, operating system, browser type, language settings, cookie data; see under “Device Information” in the Facebook Data Policy: https://www.facebook.com/policy ). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, called “Page Insights,” to Page operators to provide them with insights into how people interact with their Pages and with content associated with them. We have entered into a special agreement with Facebook (“Page Insights Information,” https://www.facebook.com/legal/terms/page_controller_addendum ), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the data subject rights (i.e., users can, for example, direct information or deletion requests to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority), are not restricted by the agreements with Facebook. Further information can be found in the “Information on Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data ); service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.facebook.com ; Privacy policy: https://www.facebook.com/about/privacy ; Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum ). Further information: Shared Responsibility Agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data . Joint accountability is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of the data to the parent company Meta Platforms, Inc. in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
– YouTube: Social network and video platform; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Privacy policy: https://policies.google.com/privacy ; Basis third country transfer: EU-US Data Privacy Framework (DPF). Option to object (opt-out): https://adssettings.google.com/authenticated .
Plugins and embedded functions and content
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 city maps (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, since without the IP address they could not send the content to their browser. The IP address is thus required for the presentation of these contents or functions. We strive to use only such content whose respective providers use the IP address only for the delivery of 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 evaluate information such as visitor traffic on the pages of this website.
The pseudonymous information may further 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 be combined with such information from other sources.
– Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status); inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms). Location data (information about the geographical position of a device or person).
– Data subjects: Users (e.g. website visitors, users of online services).
– Purposes of processing: provision of our online offer and user-friendliness.
– Legal grounds: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further notes on processing processes, procedures and services:
– Google Fonts (provision on own server): Provision of font files for the purpose of a user-friendly presentation of our online offer; service provider: Google Fonts are hosted on our server, no data is transmitted to Google; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
– Font Awesome (provided on our own server): Display of fonts and icons; Service provider: Font Awesome icons are hosted on our server, no data is transmitted to the Font Awesome provider; Legal Grounds: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
– Google Maps: We integrate the maps of the service “Google Maps” of the provider Google. The processed data may include, in particular, IP addresses and location data of the users; service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://mapsplatform.google.com/ ; Privacy policy: https://policies.google.com/privacy . Basis third country transfer: EU-US Data Privacy Framework (DPF).
– YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) DSGVO); Website: https://www.youtube.com ; Privacy policy: https://policies.google.com/privacy ; Basis third country transfer: EU-US Data Privacy Framework (DPF). Option to object (opt-out): Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de , Ad Display Settings: https://adssettings.google.com/authenticated.
Change and update of the privacy policy
We ask you to regularly inform yourself about the content of our privacy policy. We adapt the privacy policy as soon as the changes in the data processing carried out by us make it necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy statement, please note that the addresses may change over time and please check the information before contacting us.
Definitions
This section provides an overview of the terms used in this privacy statement. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to help you understand them.
– Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
– Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any type of automated processing of personal data that consists in using such personal data to analyze, evaluate or to predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g., interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
– Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and may include visitors’ behavior or interests in certain information, such as web page content. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
– Location data: Location data is generated when a mobile device (or another device with the technical requirements of location determination) connects to a radio cell, a WLAN or similar technical means and functions of location determination. Location data is used to indicate the geographically determinable position on earth at which the respective device is located. Location data can be used, for example, to display map functions or other information dependent on a location.
– Controller: “Controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
– Processing: “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data, be it collection, analysis, storage, transmission or deletion.
END OF DOKUMENT