Data protection

initiation

With the following data protection declaration, we would like to inform you about which types of your personal data (hereinafter also referred to as "data") we process for which purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both within the framework 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.

As of September 5, 2020

Responsible

Spiritual life coaching

Julia Restle

Cron 77

47809 Krefeld

Authorized persons:

Julia Restle

E-mail address:

info@juliarestle.net

Imprint: https://www.juliarestle.net/impressum

 

 

Relevant legal bases

Below you will find an overview of the legal bases of 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. If more specific legal bases are relevant in individual cases, we will inform you of them in the data protection declaration.

  • Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR) - The person concerned has given their consent to the processing of their personal data for a specific purpose or several specific purposes.

  • Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. DSGVO) - The processing is necessary for the fulfillment of a contract to which the data subject is a party, or for the implementation of pre-contractual measures, which are required at the request of the data subject respectively.

  • Legal obligation (Art. 6 Para. 1 S. 1 lit. c. GDPR) - The processing is necessary to fulfill a legal obligation to which the person responsible is subject.

  • Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR) - Processing is necessary to safeguard the legitimate interests of the person responsible or a third party, unless the interests or fundamental rights and freedoms of the data subject, which protect personal Data require prevail.

 

In addition to the data protection regulations of the General Data Protection Regulation, national data protection regulations apply in Germany. This includes in particular the law on the 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, it regulates data processing for the purposes of the employment relationship (§ 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

 

Safety measures

We meet the legal requirements, taking into account the state of the art, the implementation costs and the type, scope, circumstances and

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the purposes of the processing and the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

The measures include, in particular, securing the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, disclosure, securing availability and their separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to data threats. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

SSL encryption (https): In order to protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.

Transmission of personal data

As part 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. The recipients of this data can include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such a case, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

 

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 within the framework of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies takes place, this is only done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transmission, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, if there are certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, Information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

 

deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as your consent to processing is revoked or other permissions are no longer applicable (e.g. if the purpose of processing this data no longer applies or it is not required for the purpose).

If the data is not deleted because it is required for other, legally permissible purposes, its processing will be limited to these purposes. This means that 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 reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.

Our data protection information can also contain further information on the storage and deletion of data, which apply primarily to the respective processing.

 

Use of cookies

Cookies are small text files or other memory notes that store information on end devices and read information from the end devices. For example, to save the login status in a user account, the content of a shopping cart in an e-shop, the content accessed or the functions used in an online offer. Cookies can also be used for various purposes, e.g. for purposes of functionality, security and comfort of online offers as well as the creation of analyzes of visitor flows.

 

Notes on consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, except where not required by law. In particular, consent is not necessary if the storage and reading of the information, including cookies, is absolutely necessary in order to provide the users with a telemedia service (i.e. our online offer) that they have expressly requested. The revocable consent is clearly communicated to the users and contains the information on the respective cookie use.

 

Notes on data protection legal bases: 

The data protection legal basis on which we process the personal data of users with the help of cookies depends on whether we ask users for their consent. If the users consent, the legal basis for the processing of your data is the declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offer and improving its usability) or, if this is done in the context of fulfilling our contractual obligations, if the use of cookies is necessary to enable our to fulfill contractual obligations. We will explain the purposes for which we process cookies in the course of this data protection declaration or as part of our consent and processing processes.

 

Storage period: With regard to the storage period, the following types of cookies are distinguished:

  • Temporary cookies (also: session or 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, the user data collected with the help of cookies can be used to measure reach. Unless we provide users with explicit information on the type and storage period of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and the storage period can be up to two years.

General information on revocation and objection (opt-out):

Users can revoke the consent they have given at any time and also object to the processing in accordance with the legal requirements in Art. 21 DSGVO (further information on the objection is provided in this data protection declaration). Users can also declare their objection using the settings in their browser.

 

Further information on processing processes, procedures and services:

  • Processing of cookie data on the basis of consent: We use a cookie consent management procedure, in the context of which the user consents to the use of cookies or the processing mentioned in the context of the cookie consent management procedure and providers can be obtained and managed and revoked by the users. The declaration of consent is stored here so that the query does not have to be repeated 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 his device. Subject to individual information about the providers of cookie management services, the following information applies: The duration of the storage of the consent can be up to two years. A pseudonymous user identifier is created and stored with the time of the consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) and the browser, system and end device used.

 

Business Achievements

We process the data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners") within the framework of contractual and comparable legal relationships and related measures and within the framework of communication with the contractual partners (or pre-contractual), e.g respond.

We process this data to fulfill our contractual obligations. This includes in particular the obligations to provide the agreed services, any updating obligations and remedy in the case of warranty and other service disruptions. In addition, we process the data to protect our rights and for the purpose of the administrative tasks associated with these obligations and the corporate organization. In addition, we process the data on the basis of our legitimate interests in proper and economical business management and security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. to involve 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 the applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. The contractual partners will be informed about other 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 during data collection, e.g. in online forms, by means of special markings (e.g. colours) or symbols (e.g. asterisks or similar), or personally.

We delete the data after statutory warranty and comparable obligations have expired, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. for as long as it has to be kept for legal archiving reasons (e.g. for tax purposes usually 10 years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications of the order, generally after the end of the order.

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 apply in the relationship between the users and the providers.

 

meetings and events

We process the data of the participants of the events, events and similar activities offered or organized by us (hereinafter referred to as "participants" and "events") in order to allow them to participate in the events and use the services or promotions associated with participation enable.

If we process health-related data, religious, political or other special categories of data in this context, then this is done within the scope of obviousness (e.g. in the case of thematically oriented events or is used for health care, security or with the consent of those affected).

The information required is marked as such within the framework of the conclusion of the contract, order or comparable contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations. Insofar as we have access to information from end customers, employees or other persons, we process this in accordance with the legal and contractual requirements.

  • Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); Contact information (e.g. email, phone numbers); Contract data (e.g. subject of the contract, term, customer category).

  • Affected persons: interested parties; business and contractual partners; Customers.

  • Purposes of processing: provision of contractual services and customer service; contact requests and communication; office and organizational procedures; Management and response to inquiries.

  • Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legal obligation (Art. 6 Para. 1 S. 1 lit. c. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

 

Use of online platforms for offer and sales purposes

We offer our services on online platforms operated by other service providers. In this context, the data protection notices of the respective platforms apply in addition to our data protection notices. This applies in particular with regard to the execution of the payment process and the methods used on the platforms for measuring reach and for interest-based marketing.

  • Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); Contact information (e.g. email, phone numbers); Contract data (e.g. subject matter, term, 

  • customer category); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).

  • Data Subjects: Customers.

  • Purposes of processing: Provision of contractual services and customer service.

  • Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Further information on processing processes, procedures and services:

 

payment procedure

As part of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the data subjects efficient and secure payment options and use other service providers in addition to banks and credit institutions (collectively "payment service providers").

The data processed by the payment service provider includes inventory data such as name and address, bank details such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered will only be processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, only information with confirmation or negative information about the payment. Under certain circumstances, the payment service provider may transmit the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. For this we refer to the terms and conditions and the data protection information of the payment service provider.

The terms and conditions and 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 this for the purpose of further information and the 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 of the contract, term, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).

  • Affected persons: customers; Interested persons.

  • Purposes of processing: Provision of contractual services and customer service.

  • Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Further information on processing processes, procedures and services:

Provision of the online offer and web hosting

In order to be able to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services.

The data processed as part of the provision of the hosting offer may include all information relating to the users of our online offer that arises in the context of use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or on websites.

  • Types of data processed: content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).

  • Affected persons: users (e.g. website visitors, users of online services).

  • Purposes of processing: Provision of our online offer and user-friendliness; Provision of contractual services and customer service.

  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Further information on processing processes, procedures and services:

  • Collection of access data and log files: We ourselves (or our web hosting provider) collect data for every access to the server (so-called server log files). The address and name of the retrieved websites and files, date and time of retrieval, amounts of data transferred, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP Addresses and the requesting provider belong. The server log files can be used on the one hand for security purposes, e.g. to avoid overloading the server (especially in the case of abusive attacks, so-called DDoS attacks) and on the other hand to ensure server utilization and stability; Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or made anonymous. Data whose further storage is required for evidence purposes are excluded from deletion until the respective incident has been finally clarified.

  • Wix: hosting platform for websites; Service Provider: Wix.com Ltd., 40 Nemal St., 6350671 Tel Aviv, Israel; Website: https://de.wix.com/ ; Privacy Policy: https://de.wix.com/about/privacy ; Order processing agreement: https://www.wix.com/about/privacy-dpa-users .

 

Registration, login and user account

Users can create a user account. As part of the registration, the users are informed of the required mandatory information and processed for the purpose of providing the user account on the basis of contractual fulfillment of obligations. The processed data includes in particular the login information (user name, password and an e-mail address).

When using our registration and login functions and when using the user account, we store the IP address and the time of the respective user action. The storage takes place on the basis of our legitimate 

Interests as well as those of the users in protection against misuse and other unauthorized use. In principle, this data will not be passed on to third parties, unless it is necessary to pursue our claims or there is a legal obligation to do so.

Users can be informed by email about processes that are relevant to their user account, such as technical changes.

 

  • Types of data processed: Inventory data (e.g. names, addresses); Contact information (e.g. email, phone numbers); Content data (e.g. entries in online forms); Meta/communication data (e.g. device information, IP addresses).

  • Affected persons: users (e.g. website visitors, users of online services).

  • Purposes of processing: provision of contractual services and customer service; Safety measures; Management and response to inquiries.

  • Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Further information on processing processes, procedures and services:

  • Registration with real names: Due to the nature of our community, we ask users to only use our offer using real names. Ie the use of pseudonyms is not permitted.

  • 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 a legal permission, obligation or consent of the user.

  • No storage obligation for data: It is the user's responsibility to back up their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the contract period.

 

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). The data of the readers are processed for the purposes of the publication medium only insofar as it is necessary for its presentation and the communication between authors and readers or for reasons of security. In addition, we refer to the information on the processing of visitors to our publication medium in the context of this data protection notice.

 

  • Types of data processed: Inventory data (e.g. names, addresses); Contact information (e.g. email, phone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).

  • Affected persons: users (e.g. website visitors, users of online services).

  • Purposes of processing: provision of contractual services and customer service; Feedback (e.g. collecting feedback via online form); Safety measures; Management and response to inquiries.

  • Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Further information on processing processes, procedures and services:

  • Comments and Posts: When users leave comments or other posts, their IP addresses may be stored based on our legitimate interests. This is for our security if someone leaves illegal content in comments and posts (insults, forbidden political propaganda, etc.). In this case, we can be prosecuted for the comment or contribution and are therefore interested in the identity of the author. Furthermore, we reserve the right to process user information for the purpose of spam detection on the basis of our legitimate interests. On the same legal basis, in the case of surveys, we reserve the right to store the IP addresses of users for the duration of the survey and to use cookies to avoid multiple votes. The personal information provided in the comments and posts, any contact and website information as well as the content will be stored by us permanently until the user objects.

Contact and request management

When contacting us (e.g. via contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the details of the requesting person are processed to the extent necessary to answer the contact request and any requested measures.

The answering of contact inquiries as well as the administration of contact and inquiry data within the framework of contractual or pre-contractual relationships takes place to fulfill our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of the legitimate interests in answering the inquiries and maintenance of User or Business Relationships.

  • Types of data processed: Inventory data (e.g. names, addresses); Contact information (e.g. email, phone numbers); Content data (e.g. entries in online forms).

  • Affected persons: communication partners.

  • Purposes of processing: contact requests and communication; Provision of contractual services and customer service.

  • Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR); Legal obligation (Art. 6 Para. 1 S. 1 lit. c. GDPR).

 

Further information on processing processes, procedures and services:

  • Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context to process the communicated request. For this purpose, we process personal data within the framework of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfillment and otherwise on the basis of our legitimate interests and the interests of the communication partners in answering the concerns and our legal storage obligations.

 

Newsletters and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter "newsletters") only with the consent of the recipient or legal permission. If the content of the newsletter is specifically described when registering for it, it is decisive for the consent of the user. In addition, our newsletters contain information about our services and us. To register for our newsletters, it is generally sufficient if you provide your e-mail address. However, we may ask you to enter a name so that we can address you personally in the newsletter, or to provide further information if this is necessary for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registration you will receive an e-mail in which you will be asked to confirm your registration. This confirmation is necessary so that nobody can register with someone else's e-mail address. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider are also logged.

Deletion and restriction of processing: We can store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before we delete 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 defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time. In the case of obligations to permanently observe contradictions, we reserve the right to store the e-mail address in a blacklist (so-called "blocklist") solely for this purpose.

The registration process is logged on the basis of our legitimate interests for the purpose of proving that it was carried out properly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure shipping system.

Notes on the legal basis: The newsletter is sent on the basis of the consent of the recipient or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of advertising for existing customers. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in efficient and secure delivery. The registration process is recorded on the basis of our legitimate interests to demonstrate that it has been carried out in accordance with the law.

Content:

Information about us, our services, promotions and offers.

  • Types of data processed: Inventory data (e.g. names, addresses); Contact information (e.g. email, phone numbers); Meta/communication data (e.g. device information, IP addresses); Usage data (e.g. websites visited, interest in content, access times).

  • Affected persons: communication partners.

  • Purposes of processing: direct marketing (e.g. by e-mail or post).

  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

  • Possibility of objection (opt-out): You can cancel the receipt of our newsletter at any time, ie revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options given above, preferably e-mail. ​

Further information on processing processes, procedures and services:

  • Measurement of opening and click rates: The newsletters contain a so-called "web beacon", ie a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from their server of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, is initially collected.This information is used to technically improve our newsletter on the basis of the technical data or the target groups and their reading behavior on the basis of their Retrieval locations (which can be determined using the IP address) or access times are used. This analysis also includes determining whether the newsletters are opened and when they are opened. We use two providers:

  • CleverReach: email marketing platform; Service provider: CleverReach GmbH & Co. KG, //CRASH Building, Schafjückenweg 2, 26180 Rastede, Germany; Website: https://www.cleverreach.com/de ; Data protection declaration: https://www.cleverreach.com/de/datenschutz/ ; Order processing contract: concluded with the provider.

  • Goolux GmbH, Döberitzer Str. 35, 14727 Premnitz OT: Mögelin (hereinafter Dooplix). The e-mail addresses of our newsletter recipients, as well as their other data described in this notice, are stored on the Dooplix servers in Germany. Dooplix uses this information to send and evaluate the newsletter on our behalf. Furthermore, Dooplix can, according to its own information, use this data to optimize or improve its own services, e.g. to technically optimize the dispatch and presentation of the newsletter or for economic purposes, in order to determine from which countries the recipients come. However, Dooplix does not use the data of our newsletter recipients to write to them or pass them on to third parties. We trust in the reliability and the IT and data security of Dooplix. Dooplix is located in Germany and is therefore obliged to comply with EU data protection regulations. Furthermore, we have concluded an order processing contract with Dooplix. This is a contract in which Dooplix undertakes to protect the data of our users, to process it on our behalf in accordance with their data protection regulations and, in particular, not to pass it on to third parties. You can view Dooplix's privacy policy here https://www.goolux24.com/datenschutz-von-goolux.

Web analysis, monitoring and optimization

The web analysis (also referred to as "reach measurement") serves to evaluate the flow of visitors to our online offer and can include behavior, interests or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of the range analysis, we can, for example, identify at what time our online offer or its functions or content are used most frequently or invite people to use them again. We can also understand which areas need optimization.

In addition to web analysis, we can also use test procedures, for example to test and optimize different versions of our online offering or its components.

Unless otherwise stated below, profiles, ie data summarized for a usage process, can be created for these purposes and information can 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 given their consent to us or the providers of the services we use to collect their location data, location data can also be processed.

The IP addresses of the users are also saved. However, we use an IP masking process (ie pseudonymization by shortening the IP address) to protect users. In general, no clear user data (e.g. e-mail addresses or names) are stored in the context of web analysis, A/B testing and optimization, but pseudonyms. This means that we and 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 process.

 

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed on the basis of our legitimate interests (ie interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.

  • Types of data processed: usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).

  • Affected persons: users (e.g. website visitors, users of online services).

  • Purposes of processing: range measurement (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (creating user profiles).

  • Security measures: IP masking (pseudonymization of the IP address).

  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

 

Further information on processing processes, procedures and services:

Google Analytics: web analysis, range measurement and measurement of user flows; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Further information: Types of processing and the data processed: https://privacy.google.com/businesses/adsservices; Data processing terms for Google advertising products and standard contractual clauses for third-country transfers of data: https://business.safety.google/adsprocessorterms.  

Online marketing

We process personal data for online marketing purposes, which may include the marketing of advertising space or the presentation of advertising and other content (collectively referred to as "content") based on the potential interests of users and the measurement of their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar processes are used, by means of which the information about the user relevant to the presentation of the aforementioned content is stored. This information can include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times and functions used. If users have consented to the collection of their location data, this can also be processed.

The IP addresses of the users are also saved. However, we use available IP masking procedures (ie pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) are stored as part of the online marketing process, but pseudonyms. This means that we and the providers of the online marketing process do not know the actual identity of the users, only the information stored in their profiles.

The information in the profiles is usually stored in the cookies or by means of similar processes. These cookies can later generally also be read on other websites that use the same online marketing process and analyzed for the purpose of displaying content, as well as supplemented with further data and stored on the server of the online marketing process provider.

As an exception, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing process we use and the network connects the user's profile with the aforementioned information. We kindly ask you to note that users can make additional agreements with the providers, e.g. by giving their consent during registration. In principle, we only receive access to summarized information about the success of our advertisements. However, we can use so-called conversion measurements to check which of our online marketing processes have led to a so-called conversion, ie, to a contract with us, for example. The conversion measurement is only used to analyze the success of our marketing measures.

 

Unless otherwise stated, please assume that cookies used will be stored for a period of two years.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed on the basis of our legitimate interests (ie interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.

  • Types of data processed: usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).

  • Affected persons: users (e.g. website visitors, users of online services).

  • Purposes of processing: marketing; Profiles with user-related information (creating user profiles).

  • Security measures: IP masking (pseudonymization of the IP address).

  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

  • Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the possibilities of objection specified for the providers (so-called "opt-out"). If no explicit opt-out option has been specified, you can turn off cookies in your browser settings. However, this can limit the functions of our online offer. We therefore also recommend the following opt-out options, which are offered in summary for the respective areas: a) Europe: https://www.youronlinechoices.eu . b) Canada: https://www.youradchoices.ca/choices . c) USA: https://www.aboutads.info/choices . d) Cross-Territory: https://optout.aboutads.info .    

 

Services and service providers used:

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 the users active there or to offer information about us.

We would like to point out that user data can be processed outside of the European Union. This can result in risks for the user, because it could make it more difficult to enforce the user's rights, for example.

Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created on the basis of usage behavior and the resulting interests of users. The usage profiles can in turn be used, for example, to place advertisements inside and outside the networks that presumably correspond to the interests of the user. For these purposes, cookies are usually stored on the users' computers, in which the usage behavior and the interests of the users are stored. Furthermore, data can also be stored in the usage profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).

For a detailed description of the respective forms of processing and the possibility of objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.

Also in the case of requests for information and the assertion of data subject rights, we would like to point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can take appropriate measures and provide information directly. If you still need help, you can contact us.

  • Types of data processed: contact details (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 data (e.g. device information, IP addresses).

  • Affected persons: 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 S. 1 lit. f. GDPR).

 

Further information on processing processes, procedures and services:

  • Instagram: social network; Service Provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; 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 the collection (but not further processing) of data from visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see “Things Done and Provided by You and Others” in the Facebook Data Policy: https:// www.facebook.com/policy ), as well as information about the devices used by the users (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 site operators so that they can gain insights into how people are using their Pages and interact with the content associated with them. We have concluded a special agreement with Facebook ("Information on Page Insights", https://www.facebook.com/legal/terms/page_controller_addendum ), which regulates in particular which security measures Facebook must observe and in which Facebook itself has declared its willingness to fulfill the rights of the data subject (ie users can, for example, send information or requests for deletion directly to Facebook). The rights of users (in particular to information, deletion, objection and complaints 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, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com ; Privacy Policy: https://www.facebook.com/about/privacy ; Standard contractual clauses (ensuring the level of data protection when processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum ; More information: Joint Controllership Agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data .

 

 

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 presupposes 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 therefore required for the display of this content or functions. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers can also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user's device and contain, among other things, technical information about the browser and the operating system, websites to be referred to, the time of the visit and other information on the use of our online offer and can also be linked to such information from other sources.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed on the basis of our legitimate interests (ie interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.

  • Types of data processed: usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses); Inventory data (e.g. names, addresses); Contact information (e.g. email, phone numbers); Content data (e.g. entries in online forms); Event data (Facebook) ("Event data" is data that can be transmitted by us to Facebook, e.g. via Facebook pixels (via apps or other means) and relates to people or their actions; Data includes, for example, information about visits to websites, interactions with content, functions, installation of apps, purchases of products, etc. The event data is processed in order to form target groups for content and advertising information (custom audiences); event data do not contain the actual content (such as comments written), no login information and no contact information (i.e. no names, e-mail addresses and telephone numbers).Event data will be deleted by Facebook after a maximum of two years formed target groups with the deletion of our Facebook account).

  • Affected persons: users (e.g. website visitors, users of online services).

  • Purposes of processing: Provision of our online offer and user-friendliness; Marketing; Profiles with user-related information (creating user profiles).

  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

 

Further information on processing processes, procedures and services:

  • Facebook plugins and content: Facebook social plugins and content - This can include content such as images, videos or text and buttons with which users can share content from this online offer within Facebook. The list and appearance of the Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/ - We are jointly responsible with Meta Platforms Ireland Limited for collection or receipt as part of a transmission (but not the further processing) of "event data" that Facebook collects using the Facebook social plugins (and embedding functions for content) that are executed on our online offer or receives as part of a transmission for the following purposes: a) Display of content and advertising information that match the presumed interests of users; b) Delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) Improving the delivery of ads and personalizing functions and content (e.g. improving the recognition of which content or advertising information presumably corresponds to the interests of users). We have concluded a special agreement with Facebook ("Addendum for those responsible", https://www.facebook.com/legal/controller_addendum ), which regulates in particular which security measures Facebook must observe ( https://www.facebook. com/legal/terms/data_security_terms ) and in which Facebook has agreed to fulfill the rights of the data subject (ie users can, for example, send information or requests for deletion directly to Facebook). Note: If Facebook provides us with measurements, analyzes and reports (which are aggregated, i.e. do not contain any information on individual users and are anonymous to us), then this processing does not take place within the framework of joint responsibility, but on the basis of an order processing contract ("Data Processing Terms"). , https://www.facebook.com/legal/terms/dataprocessing) , the "Data Security Conditions" (https://www.facebook.com/legal/terms/data_security_terms) and with regard to processing in the USA of standard contractual clauses ("Facebook-EU data transfer addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaints to the competent supervisory authority) are guaranteed by the agreements with Facebook not restricted; Service Provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https:// www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy.

  • Instagram plugins and content: Instagram plugins and content: This can include content such as images, videos or text and buttons with which users can share content from this online offer within Instagram. - We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt as part of a transmission (but not further processing) of "Event Data" provided by Facebook using features of Instagram (e.g. content embedding features) running on Our online offer is executed, collected or received as part of a transmission for the following purposes, jointly responsible: a) Display of content and advertising information that correspond to the presumed interests of the user; b) Delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) Improving the delivery of ads and personalizing functions and content (e.g. improving the recognition of which content or advertising information presumably corresponds to the interests of users). We have concluded a special agreement with Facebook ("Addendum for those responsible", https://www.facebook.com/legal/controller_addendum ), which regulates in particular which security measures Facebook must observe ( https://www.facebook. com/legal/terms/data_security_terms ) and in which Facebook has agreed to fulfill the rights of the data subject (ie users can, for example, send information or requests for deletion directly to Facebook). Note: If Facebook provides us with measurements, analyzes and reports (which are aggregated, i.e. do not contain any information on individual users and are anonymous to us), then this processing does not take place within the framework of joint responsibility, but on the basis of an order processing contract ("Data Processing Terms"). , https://www.facebook.com/legal/terms/dataprocessing ), the "Data Security Terms" ( https://www.facebook.com/legal/terms/data_security_terms ) and with regard to processing in the USA of standard contractual clauses ("Facebook-EU data transfer addendum, https://www.facebook.com/legal/EU_data_transfer_addendum ). The rights of users (in particular to information, deletion, objection and complaints to the competent supervisory authority) are guaranteed by the agreements with Facebook unrestricted; Service Provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com ; Data sc privacy statement: https://instagram.com/about/legal/privacy .

 

 

Management, organization and support tools

We use services, platforms and software from other providers (hereinafter referred to as "third-party providers") for the purposes of organization, administration, planning and the provision of our services. When selecting third-party providers and their services, we observe the legal requirements.

In this context, personal data can be processed and stored on the servers of third-party providers. Various data may be affected by this, which we process in accordance with this data protection declaration. This data can include, in particular, master data and contact details of users, data on transactions, contracts, other processes and their content.

If users are referred to the third-party providers or their software or platforms as part of communication, business or other relationships with us, the third-party providers can process usage data and metadata for security purposes, for service optimization or for marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.

 

Notes on legal bases:

If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Furthermore, their use can be part of our (pre)contractual services, provided that the use of third-party providers has been agreed in this context. Otherwise, user data is processed on the basis of our legitimate interests (ie interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.

  • Types of data processed: content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses); Inventory data (e.g. names, addresses); Contact information (e.g. email, phone numbers).

  • Affected persons: communication partners; Users (e.g. website visitors, users of online services).

  • Purposes of processing: contact requests and communication.

  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Further information on processing processes, procedures and services:

 

Change and update of the privacy policy

We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as the changes in the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this data protection declaration, please note that the addresses can change over time and ask you to check the information before contacting us.

 

Rights of data subjects

As a data subject, you have various rights under the GDPR, which result in particular from Art. 15 to 21 GDPR:

  • Right of objection: You have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data, which is based on Article 6 Paragraph 1 lit. e or f GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed in order to operate direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct advertising.

  • Right of revocation in the case of consent: You have the right to revoke your consent at any time.

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

  • Right to rectification: In accordance with legal requirements, you have the right to request the completion of the data concerning you or the correction of incorrect data concerning you.

  • Right to erasure and restriction of processing: You have the right, in accordance with the legal requirements, to request that the data concerning you be deleted immediately, or alternatively to request a restriction of the processing of the data in accordance with the legal requirements.

  • Right to data portability: You have the right to receive the data that you have provided to us in accordance with the legal requirements in a structured, common and machine-readable format or to request that it be transmitted to another person responsible.

  • Complaint to supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to complain to a supervisory authority, in particular in the member state of your habitual residence, your place of work or the place of the alleged infringement, if you believe that the processing of data concerning you personal data violates the provisions of the GDPR.

 

definitions of terms

This section provides you with an overview of the terms used in this data protection declaration. Many of the terms are taken from the law and defined above all in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended primarily for understanding. The terms are sorted alphabetically.

  • 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 means of assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special features, are an expression of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.​

  • 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 of using this personal data to identify certain personal aspects relating to a natural person (depending on the type of profiling, different information regarding demographics, behavior and interests, such as interaction with websites and their content, etc.) can be analyzed, evaluated or predicted (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.

  • Range measurement: The range measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offer and can include the behavior or interests of visitors in certain information, such as website content. With the help of the range analysis, website owners can, for example, see 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. Pseudonymous cookies and web beacons are often used for range analysis purposes in order to recognize returning visitors and thus obtain more precise analyzes of the use of an online offer.

  • Responsible: The "responsible person" is the natural or legal person, authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data.

  • Processing: "Processing" is any process or series of processes carried out with or without the aid of automated processes in connection with personal data. The term goes far and covers practically every handling of data, be it collection, evaluation, storage, transmission or deletion.

This data protection declaration was created with the free data protection generator from Dr. Thomas Schwenke created (14.2.22)