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Data privacy

This privacy policy informs you about the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) in the context of the provision of our services as well as within our online offering and the associated websites, functions and content, and external online presences, such as our social media profiles (hereinafter collectively referred to as the “online offering”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).


Controller
Zwilling – Double Blessing GmbH
Arno-Nitzsche-Str. 45A
04277 Leipzig

Phone: +49 (0)341 99 19 000
E-mail: [email protected]

Represented by: Oliver Weber, Tobias Böttger


Types of data processed

  • Inventory data (e.g. master data of persons, names or addresses)

  • Contact data (e.g. e-mail, telephone numbers)

  • Content data (e.g. text entries, photographs, videos)

  • Usage data (e.g. websites visited, interest in content, access times)

  • Meta/communication data (e.g. device information, IP addresses)


Categories of data subjects
Visitors and users of the online offering (hereinafter we also refer to the data subjects collectively as “users”).


Purposes of processing

  • Provision of the online offering, its functions and content

  • Responding to contact requests and communicating with users

  • Security measures

  • Reach measurement/marketing


Terminology used

“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.

“Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically any handling of data.

“Pseudonymisation” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures which ensure that the personal data are not attributed to an identified or identifiable natural person.

“Profiling” means any form of automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

“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.

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.


Relevant legal bases

In accordance with Article 13 GDPR, we inform you of the legal bases of our data processing. For users from the scope of the General Data Protection Regulation (GDPR), i.e. the EU and the EEA, the following applies insofar as the legal basis is not specified in the privacy policy:

  • The legal basis for obtaining consent is Article 6(1)(a) and Article 7 GDPR;

  • The legal basis for processing for the performance of our services and the execution of contractual measures as well as responding to enquiries is Article 6(1)(b) GDPR;

  • The legal basis for processing for compliance with our legal obligations is Article 6(1)(c) GDPR;

  • In the event that vital interests of the data subject or of another natural person require the processing of personal data, Article 6(1)(d) GDPR serves as the legal basis;

  • The legal basis for the processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Article 6(1)(e) GDPR;

  • The legal basis for processing for the purposes of our legitimate interests is Article 6(1)(f) GDPR.

The processing of data for purposes other than those for which they were collected is determined in accordance with the requirements of Article 6(4) GDPR.

The processing of special categories of data (in accordance with Article 9(1) GDPR) is based on the requirements of Article 9(2) GDPR.


Security measures

We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, context and purposes of the processing as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.

These measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data as well as the access, input, transfer, safeguarding of availability and separation of the data. Furthermore, we have implemented procedures that ensure the exercise of data subjects’ rights, the deletion of data and a response to threats to data. In addition, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design and by default.


Cooperation with processors, joint controllers and third parties

If, in the course of our processing, we disclose data to other persons and companies (processors, joint controllers or third parties), transmit data to them or otherwise grant them access to the data, this is only done on the basis of a legal permission (e.g. if a transfer of data to third parties, such as payment service providers, is required for the performance of a contract), if users have given their consent, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosting providers, etc.).

If we disclose, transmit or otherwise grant access to data to other companies in our group of companies, this is done in particular for administrative purposes as a legitimate interest and, moreover, on a basis that complies with legal requirements.


Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this is done in the context of the use of third-party services or disclosure or transfer of data to other persons or companies, this will only occur if it is necessary for the fulfilment of our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or have the data processed in a third country if the special conditions of Article 44 et seq. GDPR are met. That is, the processing is carried out, for example, on the basis of special guarantees, such as the officially recognised determination of a level of data protection corresponding to the EU or compliance with officially recognised special contractual obligations.


Rights of data subjects

You have the right to request confirmation as to whether data concerning you is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with the legal requirements.

In accordance with the legal provisions, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.

In accordance with the legal provisions, you have the right to request that data concerning you be deleted without delay or, alternatively, in accordance with the legal provisions, to request a restriction of the processing of the data.

You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with the legal provisions and to request its transmission to another controller.

Furthermore, in accordance with the legal provisions, you have the right to lodge a complaint with the competent supervisory authority.


Right to withdraw consent

You have the right to withdraw consent you have given with effect for the future.


Right to object

You may object at any time, in accordance with the legal requirements, to the future processing of data concerning you. The objection may, in particular, be made against processing for direct marketing purposes.


Cookies and right to object to direct marketing

“Cookies” are small files that are stored on users’ computers. Various information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit within an online offering. “Session cookies” or “transient cookies” are cookies that are deleted after a user leaves an online offering and closes their browser. For example, the content of a shopping cart in an online shop or a login status can be stored in such a cookie. “Permanent” or “persistent” cookies are cookies that remain stored even after the browser has been closed. For example, a login status can be saved when users visit again after several days. Likewise, users’ interests can be stored in such a cookie and used for reach measurement or marketing purposes. “Third-party cookies” are cookies that are offered by providers other than the controller that operates the online offering (otherwise, if they are only the controller’s cookies, they are called “first-party cookies”).

We may use temporary and permanent cookies and provide information about this in our privacy policy.

If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in their browser’s system settings. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies may lead to functional restrictions of this online offering.

A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, particularly in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be prevented by switching them off in the browser settings. Please note that, in that case, not all functions of this online offering may be available.


Deletion of data

The data processed by us will be deleted or its processing restricted in accordance with the legal provisions. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and no statutory retention obligations prevent deletion.

If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. That is, the data will be blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax law reasons.


Changes and updates to the privacy policy

We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as the changes in the data processing carried out by us make this necessary. We will inform you if the changes require your cooperation (e.g. consent) or another individual notification.

Business-related processing

In addition, we process

  • Contract data (e.g. subject matter of the contract, term, customer category)

  • Payment data (e.g. bank details, payment history)

of our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.

Order processing in the online shop and customer account

We process the data of our customers in the context of order processes in our online shop, to enable them to select and order the chosen products and services and their payment and delivery or execution.

The data processed includes inventory data, communication data, contract data, payment data and, as regards data subjects, our customers, prospects and other business partners. The processing is carried out for the purpose of providing contractual services in the context of the operation of an online shop, billing, delivery and customer service. In this context, we use session cookies to store the contents of the shopping cart and permanent cookies to store the login status.

The processing is carried out for the performance of our services and execution of contractual measures (e.g. execution of order processes) and insofar as it is legally required (e.g. legally required archiving of business transactions for commercial and tax purposes). The information marked as required is necessary for the justification and fulfilment of the contract. We disclose the data to third parties only in the context of delivery, payment or in the context of legal permissions and obligations, as well as when this is based on our legitimate interests, which we inform you about in this privacy policy (e.g. to legal and tax advisors, financial institutions, freight companies, as well as authorities).

Users can optionally create a user account, in which they can, in particular, view their orders. As part of the registration process, the required mandatory information is communicated to users. The user accounts are not public and cannot be indexed by search engines. If users cancel their user account, their data relating to the user account will be deleted, subject to its retention being necessary for commercial or tax reasons. Information in the customer account remains until its deletion with subsequent archiving in the event of a legal obligation or our legitimate interests (e.g. in the event of legal disputes). It is the responsibility of users to back up their data before the end of the contract if the account is terminated.

In the context of registration and renewed logins as well as the use of our online services, 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 to protect against misuse and other unauthorised use. This data is generally not passed on to third parties unless it is required to pursue our claims as a legitimate interest or there is a legal obligation to do so.

Data is deleted after the expiry of statutory warranty and comparable obligations (e.g. payment claims or performance obligations from contracts with customers), whereby the necessity of retaining the data is reviewed every three years; in the case of statutory archiving obligations, deletion takes place after their expiry.

Agency services

We process our customers’ data in the context of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes/handling, server administration, data analysis/consulting services and training services.

In this context, we process inventory data (e.g. customer master data such as names or addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), contract data (e.g. subject matter of contract, term), payment data (e.g. bank details, payment history), usage and meta data (e.g. as part of the evaluation and measurement of the success of marketing measures). As a rule, we do not process special categories of personal data unless these are part of commissioned processing. Data subjects include our customers, prospects and their customers, users, website visitors or employees as well as third parties. The purpose of processing is the provision of contractual services, billing and our customer service. The legal bases of processing are derived from Article 6(1)(b) GDPR (contractual services) and Article 6(1)(f) GDPR (analysis, statistics, optimisation, security measures). We process data that is necessary for the justification and fulfilment of contractual services and point out the necessity of its disclosure, unless this is evident to the contract partners. Disclosure to external parties only takes place if it is necessary in the context of an assignment. When processing data handed over to us within the scope of an assignment, we act in accordance with the instructions of the client and the legal requirements for commissioned processing pursuant to Article 28 GDPR and do not process the data for any purposes other than those of the assignment.

We delete the data after expiry of statutory warranty and comparable obligations. The necessity of storing the data is reviewed every three years; in the case of statutory archiving obligations, deletion takes place after their expiry (6 years according to Section 257(1) HGB, 10 years according to Section 147(1) AO). In the case of data disclosed to us by the client as part of an assignment, we delete the data in accordance with the specifications of the assignment, generally after the end of the assignment.

Therapeutic services and coaching

We process the data of our clients and prospects and other clients or contractual partners (uniformly referred to as “clients”) in accordance with Article 6(1)(b) GDPR in order to provide them with our contractual or pre-contractual services. The data processed, the type, scope and purpose and the necessity of their processing are determined by the underlying contractual relationship. The data processed generally includes inventory and master data of the clients (e.g. name, address, etc.) as well as contact data (e.g. e-mail address, telephone, etc.), contract data (e.g. services used, fees, names of contact persons, etc.) and payment data (e.g. bank details, payment history, etc.).

In the context of our services, we may also process special categories of data pursuant to Article 9(1) GDPR, in particular information on the health of clients, possibly with reference to their sex life or sexual orientation, ethnic origin or religious or ideological beliefs. Where necessary, we obtain explicit consent from clients in accordance with Article 6(1)(a), Article 7 and Article 9(2)(a) GDPR and otherwise process special categories of data for purposes of health care on the basis of Article 9(2)(h) GDPR, Section 22(1) No. 1(b) BDSG.

Where required for the fulfilment of the contract or by law, we disclose or transmit clients’ data to other professionals, third parties necessarily or typically involved in the fulfilment of the contract, such as billing offices or comparable service providers, insofar as this serves the provision of our services in accordance with Article 6(1)(b) GDPR, is legally prescribed in accordance with Article 6(1)(c) GDPR, serves our interests or those of clients in an efficient and cost-effective healthcare provision as a legitimate interest in accordance with Article 6(1)(f) GDPR, or is necessary in accordance with Article 6(1)(d) GDPR to protect vital interests of clients or another natural person, or on the basis of consent in accordance with Article 6(1)(a), Article 7 GDPR.

Data is deleted when it is no longer required for the fulfilment of contractual or legal duties of care as well as dealing with any warranty and comparable obligations, whereby the necessity of data retention is reviewed every three years; otherwise, the statutory retention obligations apply.

Contractual services

We process the data of our contractual partners and prospects as well as other clients, customers, principals or contractual partners (uniformly referred to as “contractual partners”) in accordance with Article 6(1)(b) GDPR in order to provide them with our contractual or pre-contractual services. The data processed, the type, scope and purpose and the necessity of their processing are determined by the underlying contractual relationship.

The data processed includes the master data of our contractual partners (e.g. names and addresses), contact data (e.g. e-mail addresses and telephone numbers) as well as contract data (e.g. services used, contractual content, contractual communication, names of contact persons) and payment data (e.g. bank details, payment history).

As a rule, we do not process special categories of personal data unless these are part of a commissioned or contractually agreed processing.

We process data that is required for the justification and fulfilment of contractual services and point out the necessity of its disclosure, insofar as this is not obvious to the contractual partners. Disclosure to external persons or companies only takes place if this is necessary in the context of a contract. When processing data provided to us within the scope of an order, we act in accordance with the instructions of the client and legal requirements.

In the context of the use of our online services, we may store the IP address and the time of the respective user action. Storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorised use. This data is generally not passed on to third parties unless it is required to pursue our claims pursuant to Article 6(1)(f) GDPR or there is a legal obligation to do so pursuant to Article 6(1)(c) GDPR.

The data is deleted when it is no longer required for the fulfilment of contractual or legal duties of care as well as dealing with any warranty and comparable obligations, whereby the necessity of retention of the data is reviewed every three years; otherwise, the statutory retention obligations apply.

External payment service providers

We use external payment service providers, through whose platforms users and we can carry out payment transactions (e.g., each with a link to their privacy policy: PayPal (https://www.paypal.com/de/webapps/mpp/ua/privacy-full), Klarna (https://www.klarna.com/de/datenschutz/), Skrill (https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/), Giropay (https://www.giropay.de/rechtliches/datenschutz-agb/), Visa (https://www.visa.de/datenschutz), Mastercard (https://www.mastercard.de/de-de/datenschutz.html), American Express (https://www.americanexpress.com/de/content/privacy-policy-statement.html)).

In the context of fulfilling contracts, we use payment service providers on the basis of Article 6(1)(b) GDPR. Otherwise, we use external payment service providers on the basis of our legitimate interests in accordance with Article 6(1)(f) GDPR in order to offer our users effective and secure payment options.

The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums as well as contract, sums and recipient-related information. The information is required to carry out the transactions. However, the data entered is processed and stored solely by the payment service providers. That is, we do not receive any account or credit card-related information, only information with confirmation or negative information of the payment. Under certain circumstances, the payment service providers may transmit the data to credit agencies. This transmission is for identity and credit checks. In this respect, we refer to the general terms and conditions and privacy notices of the payment service providers.

For payment transactions, the terms and conditions and privacy notices of the respective payment service providers apply, which are accessible within the respective websites or transaction applications. We also refer to these for further information and for asserting rights of revocation, access and other data subject rights.

Administration, financial accounting, office organisation, contact management

We process data in the context of administrative tasks as well as organisation of our operations, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of providing our contractual services. The legal bases for processing are Article 6(1)(c) GDPR and Article 6(1)(f) GDPR. Data subjects include customers, prospects, business partners and website visitors. The purpose and our interest in processing lies in administration, financial accounting, office organisation and data archiving, i.e. tasks that serve the maintenance of our business activities, the performance of our duties and the provision of our services. Data deletion with regard to contractual services and contractual communication corresponds to the information provided for these processing activities.

In this context, we disclose or transmit data to the tax authorities, consultants such as tax advisors or auditors, as well as other fee offices and payment service providers.

Furthermore, on the basis of our business interests, we store information on suppliers, organisers and other business partners, e.g. for the purpose of later contact. This data, which is predominantly company-related, is generally stored permanently.

Business analyses and market research

In order to operate our business economically, to identify market trends and wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc. In doing so, we process inventory data, communication data, contract data, payment data, usage data and meta data on the basis of Article 6(1)(f) GDPR, whereby data subjects include contractual partners, prospects, customers, visitors and users of our online offering.

The analyses are carried out for the purpose of business evaluations, marketing and market research. We can take into account the profiles of registered users with information, for example, on the services they have used. The analyses help us to increase user-friendliness, optimise our offering and improve business efficiency. The analyses are for our use only and are not disclosed externally, unless they are anonymous analyses with aggregated values.

If these analyses or profiles are personal, they are deleted or anonymised upon termination of the users’ accounts, otherwise after two years from conclusion of the contract. In all other cases, business analyses and general trend determinations are prepared anonymously where possible.

Participation in affiliate partner programmes

Within our online offering, we use industry-standard tracking measures on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offering) pursuant to Article 6(1)(f) GDPR, insofar as these are necessary for the operation of the affiliate system. Below we explain the technical background to users.

The services offered by our contractual partners can also be advertised and linked on other websites (so-called affiliate links or after-buy systems, if e.g. links or services of third parties are offered after a contract has been concluded). The operators of the respective websites receive a commission if users follow the affiliate links and subsequently take up the offers.

In summary, it is necessary for our online offering that we can track whether users who are interested in affiliate links and/or the offers available with us subsequently take up the offers at the instigation of the affiliate links or our online platform. For this purpose, the affiliate links and our offers are supplemented with certain values that can be part of the link or otherwise, e.g. stored in a cookie. The values include, in particular, the referrer website (referrer), time, an online identifier of the website operator on which the affiliate link was placed, an online identifier of the respective offer, an online identifier of the user as well as tracking-specific values such as advertising material ID, partner ID and categorizations.

The online identifiers of the users we use are pseudonymous values. That is, the online identifiers themselves contain no personal data such as names or e-mail addresses. They only help us to determine whether the same user who clicked on an affiliate link or was interested in an offer via our online offering has taken up the offer, i.e. e.g. concluded a contract with the provider. However, the online ID is personal insofar as the partner company and also we have the online ID available together with other user data. Only in this way can the partner company inform us whether the user has taken up the offer and we can, for example, pay out the bonus.

Amazon partner programme

We participate in the partner programme of Amazon EU on the basis of our legitimate interests (i.e. interest in the economic operation of our online offering within the meaning of Article 6(1)(f) GDPR), which is designed to provide a medium for websites by means of which advertising fees can be earned through the placement of advertisements and links to Amazon.de (so-called affiliate system). That is, as an Amazon partner we earn from qualified purchases.

Amazon uses cookies to trace the origin of orders. Among other things, Amazon can recognise that you clicked on the partner link on this website and subsequently purchased a product from Amazon.

Further information on data use by Amazon and objection options can be found in the company’s privacy policy: https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010.

Note: Amazon and the Amazon logo are trademarks of Amazon.com, Inc. or one of its affiliated companies.

Digistore24 partner programme

We participate in the partner programme of Digistore24 GmbH, St.-Godehard-Straße 32, 31139 Hildesheim, Germany on the basis of our legitimate interests (i.e. interest in the economic operation of our online offering within the meaning of Article 6(1)(f) GDPR), which is designed to provide a medium for websites by means of which advertising fees can be earned through the placement of advertisements and links to Digistore24 (so-called affiliate system). Digistore24 uses cookies to be able to trace the origin of the contract conclusion. Among other things, Digistore24 can recognise that you clicked on the partner link on this website and subsequently concluded a contract with or via Digistore24.

Further information on data use by Digistore24 and objection options can be found in the company’s privacy policy: https://www.digistore24.com/page/privacyl.

Data protection information in the application process

We only process applicant data for the purpose and within the scope of the application process in accordance with legal requirements. The processing of applicant data takes place for the fulfilment of our (pre-)contractual obligations within the framework of the application procedure within the meaning of Article 6(1)(b) GDPR and Article 6(1)(f) GDPR, insofar as data processing becomes necessary for us, for example in the context of legal proceedings (in Germany, Section 26 BDSG additionally applies).

The application process requires that applicants provide us with the applicant data. The necessary applicant data are, if we offer an online form, marked as such, otherwise they result from the job descriptions and generally include information about the person, postal and contact addresses and the documents belonging to the application, such as cover letter, CV and references. In addition, applicants may voluntarily provide us with additional information.

By submitting their application to us, applicants consent to the processing of their data for the purposes of the application process in accordance with the nature and scope set out in this privacy policy.

If, within the scope of the application process, special categories of personal data within the meaning of Article 9(1) GDPR are voluntarily provided, their processing is additionally carried out in accordance with Article 9(2)(b) GDPR (e.g. health data, such as information on a severe disability or ethnic origin). If special categories of personal data within the meaning of Article 9(1) GDPR are requested from applicants within the scope of the application process, their processing is additionally carried out in accordance with Article 9(2)(a) GDPR (e.g. health data if this is necessary for the exercise of the profession).

If provided, applicants can submit their applications to us via an online form on our website. The data is transmitted to us in encrypted form in accordance with the state of the art. Furthermore, applicants can send us their applications via e-mail. However, please note that e-mails are generally not sent in encrypted form and applicants must ensure encryption themselves. We therefore cannot accept responsibility for the transmission path of the application between the sender and receipt on our server and therefore recommend using an online form or postal dispatch instead. Instead of applying via the online form and e-mail, applicants still have the option of sending us their application by post.

The data provided by applicants may be further processed by us for the purposes of the employment relationship if the application is successful. Otherwise, if the application for a job offer is not successful, the applicant’s data will be deleted. The applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time.

Subject to a justified revocation by the applicants, the deletion takes place after the expiry of a period of six months so that we can answer any follow-up questions regarding the application and satisfy our obligations of proof under the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with tax regulations.

Registration function

Users can create a user account. As part of the registration process, the required mandatory information is communicated to users and processed on the basis of Article 6(1)(b) GDPR for the purpose of providing the user account. The data processed includes, in particular, login information (name, password and an e-mail address). The data entered during registration is used for the purpose of using the user account and its purpose.

Users can be informed by e-mail about information relevant to their user account, such as technical changes. If users cancel their user account, their data relating to the user account will be deleted, subject to a legal retention obligation. It is the responsibility of users to back up their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all data stored during the term of the contract.

As part of the use of our registration and login functions and the use of the user account, we store the IP address and the time of the respective user action. Storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorised use. This data is generally not passed on to third parties unless it is required to pursue our claims or there is a legal obligation to do so pursuant to Article 6(1)(c) GDPR. IP addresses are anonymised or deleted at the latest after 7 days.

Contacting us

When contacting us (e.g. via contact form, e-mail, telephone or via social media), the user’s details are processed to handle the contact request and its processing in accordance with Article 6(1)(b) (in the context of contractual/pre-contractual relationships) and Article 6(1)(f) (other enquiries) GDPR. The user’s information may be stored in a customer relationship management system (“CRM system”) or comparable enquiry organisation.

We delete the enquiries if they are no longer required. We review the necessity every two years; statutory archiving obligations also apply.

Newsletter

The following information informs you about the contents of our newsletter as well as the registration, mailing and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.

Content of the newsletter: We send newsletters, e-mails and other electronic notifications with promotional information (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. If the contents of the newsletter are specifically described during registration, they are decisive for the consent of the users. Otherwise, our newsletters contain information about our services and us.

Double opt-in and logging: Registration for our newsletter takes place in a so-called double opt-in procedure. That is, after registration you 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 people’s e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored with the mailing service provider are also logged.

Registration data: To register for the newsletter, it is sufficient to enter your e-mail address. Optionally, we ask you to provide a name for the purpose of personal address in the newsletter.

The sending of the newsletter and the associated performance measurement are based on the consent of the recipients in accordance with Article 6(1)(a), Article 7 GDPR in conjunction with Section 7(2)(3) UWG or, if consent is not required, on the basis of our legitimate interests in direct marketing in accordance with Article 6(1)(f) GDPR in conjunction with Section 7(3) UWG.

The logging of the registration process is based on our legitimate interests in accordance with Article 6(1)(f) GDPR. Our interest is directed towards the use of a user-friendly and secure newsletter system that serves our business interests and meets the expectations of the users, as well as allows us to prove consent.

Cancellation/withdrawal: You can cancel the receipt of our newsletter at any time, i.e. withdraw your consent. You will find a link to cancel the newsletter at the end of each newsletter. We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that at the same time the former existence of consent is confirmed.

Newsletter – mailing service provider

The newsletter is sent using the mailing service provider [NAME, ADDRESS, COUNTRY]. You can view the privacy policy of the mailing service provider here: [LINK TO PRIVACY POLICY]. The mailing service provider is used on the basis of our legitimate interests in accordance with Article 6(1)(f) GDPR and an order processing contract in accordance with Article 28(3)(1) GDPR.

The mailing service provider may use the data of recipients in pseudonymous form, i.e. without assignment to a user, to optimise or improve its own services, e.g. for the technical optimisation of sending and the presentation of the newsletter or for statistical purposes. However, the mailing service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.

Newsletter – performance measurement

The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened, or from the server of the mailing service provider if one is used. As part of this retrieval, technical information is initially collected, such as information about the browser and your system as well as your IP address and time of retrieval.

This information is used to technically improve the services based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined with the help of the IP address) or the access times. The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor, if used, that of the mailing service provider to observe individual users. The evaluations serve us much more to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

A separate withdrawal of performance measurement is unfortunately not possible; in this case the entire newsletter subscription must be cancelled.

Hosting and e-mail dispatch

The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services, which we use for the purpose of operating this online offering.

In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, prospects and visitors to this online offering on the basis of our legitimate interests in an efficient and secure provision of this online offering in accordance with Article 6(1)(f) GDPR in conjunction with Article 28 GDPR (conclusion of an order processing contract).

Collection of access data and log files

We, or our hosting provider, collect data about every access to the server on which this service is located (so-called server log files) on the basis of our legitimate interests within the meaning of Article 6(1)(f) GDPR. Access data includes the name of the retrieved website, file, date and time of retrieval, amount of data transferred, notification of successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for security reasons (e.g. to investigate misuse or fraud) for a maximum of 7 days and then deleted. Data whose further retention is required for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified.

Google Analytics

On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offering within the meaning of Article 6(1)(f) GDPR), we use Google Analytics, a web analysis service of Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offering by users is generally transmitted to a Google server in the USA and stored there.

Google is certified under the Privacy Shield Agreement and thereby offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Google will use this information on our behalf to evaluate the use of our online offering by users, to compile reports on activities within this online offering and to provide us with further services associated with the use of this online offering and internet usage. In doing so, pseudonymous usage profiles of the users can be created from the processed data.

We use Google Analytics only with IP anonymisation activated. This means that the IP address of users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.

The IP address transmitted by the user’s browser is not merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offering to Google as well as the processing of this data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

Further information on data use by Google, setting and objection options can be found in Google’s privacy policy (https://policies.google.com/privacy) and in the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).

The personal data of users is deleted or anonymised after 14 months.

Google AdSense with personalised ads

We use the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”) on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offering within the meaning of Article 6(1)(f) GDPR).

Google is certified under the Privacy Shield Agreement and thereby offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

We use the AdSense service, which enables ads to be displayed on our website and we receive remuneration for their display or other use. For these purposes, usage data such as clicks on an ad and the IP address of users are processed, whereby the IP address is shortened by the last two digits. The processing of users’ data is therefore pseudonymised.

We use AdSense with personalised ads. In doing so, Google draws conclusions about users’ interests based on the websites visited or apps used and the user profiles thus created. Advertisers use this information to tailor their campaigns to these interests, which is beneficial for users and advertisers alike. Ads are personalised for Google when recorded or known data determines or influences ad selection. This includes, for example, past search queries, activities, website visits, app usage, demographic and location information. Specifically, this includes: demographic targeting, interest category targeting, remarketing as well as targeting on lists for customer matching and audience lists uploaded in DoubleClick Bid Manager or Campaign Manager.

Further information on data use by Google, setting and objection options can be found in Google’s privacy policy (https://policies.google.com/technologies/ads) and in the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).

Facebook Pixel, Custom Audiences and Facebook Conversion

Within our online offering, the “Facebook Pixel” of the social network Facebook, operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are resident in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), is used on the basis of our legitimate interests in analysis, optimisation and economic operation of our online offering and for these purposes.

Facebook is certified under the Privacy Shield Agreement and thereby offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

With the help of the Facebook Pixel, Facebook is able, on the one hand, to determine the visitors of our online offering as a target group for the display of advertisements (so-called “Facebook Ads”). Accordingly, we use the Facebook Pixel to display the Facebook Ads placed by us only to those Facebook users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook Pixel, we also want to ensure that our Facebook Ads correspond to the potential interests of users and are not annoying. With the help of the Facebook Pixel, we can also track the effectiveness of Facebook advertisements for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook advertisement (so-called “conversion”).

The processing of data by Facebook is carried out within the framework of Facebook’s data usage policy. Accordingly, general information on the display of Facebook Ads can be found in Facebook’s data usage policy: https://www.facebook.com/policy. Specific information and details about the Facebook Pixel and its functioning can be found in Facebook’s help section: https://www.facebook.com/business/help/651294705016616.

You can object to the collection by the Facebook Pixel and use of your data for the display of Facebook Ads. To set which types of advertisements are shown to you within Facebook, you can go to the page set up by Facebook and follow the instructions on the settings for usage-based advertising: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.

You can also object to the use of cookies used for reach measurement and advertising purposes via the deactivation page of the Network Advertising Initiative (http://optout.networkadvertising.org/) and additionally via the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).