Privacy Policy

 

Introduction

With the following data privacy policy we would like to inform you about the types of personal data (hereinafter also referred to as “data”) we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter also referred to collectively as “online offer”).

The terms used are not gender-specific.

Last update: 10.08.2020

Table of contents

 

Person responsible

Alexander Kroeger
Uliana Kroeger und Alexander Kroeger GbR
Gerichtstraße 38
39624 Kalbe (Milde)

Persons authorized to represent the company: Managing Director

E-mail address: info@kochketo.com

Legal notice: https://kochketo.com/legal-notice

     

    Overview of the processing operations

    The following table summarises the types of data processed and the purposes of their processing, and refers to the data subjects.

    Types of data processed

    • stock data (e.g. names, addresses).

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

    • contact details (e.g. e-mail, telephone numbers).

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

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

    • Location data (data indicating the location of an end user’s terminal device).

    • contract data (e.g. subject of contract, duration, customer category).

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

     

    Categories of data subjects

    • Employees (e.g. employees, applicants, former employees).

    • Business and contractual partners.

    • Interested parties.

    • Communication partners.

    • Customers.

    • Users (e.g. website visitors, users of online services).

     

    Purpose of the processing

    • Affiliate Tracking.

    • Provision of our online offer and user-friendliness.

    • Visit action evaluation.

    • Office and organisational procedures.

    • Cross-device tracking (cross-device processing of user data for marketing purposes).

    • Direct marketing (e.g. by e-mail or post).

    • Feedback (e.g. collecting feedback via online form).

    • Interest based and behavioral marketing.

    • Contact requests and communication.

    • Conversion measurement (measuring the effectiveness of marketing measures).

    • Profiling (creation of user profiles).

    • Remarketing.

    • Range measurement (e.g. access statistics, recognition of returning visitors).

    • Safety measures.

    • Tracking (e.g. interest/behavioural profiling, use of cookies).

    • Contractual performance and service.

    • Management and response to requests.

    • Target group formation (determination of target groups relevant for marketing purposes or other output of content).

     

    Relevant legal bases

    In the following, we provide the legal basis of the basic data protection regulation (GDPR), on the basis of which we process personal data. Please note that in addition to the regulations of the GDPR, national data protection regulations may apply in your or our country of residence and domicile.

    • Consent (Art. 6 para. 1 sentence 1 lit. a GDPR) – the data subject has given his or her consent to the processing of personal data relating to him or her for one or more specific purposes.

    • Contract performance and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR) – processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

    • Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR) – The processing is necessary for compliance with a legal obligation to which the controller is subject.

    • Protection of vital interests (Art. 6 para. 1 sentence 1 lit. d. GDPR) – Processing is necessary to protect the vital interests of the data subject or of another natural person.

    • Legitimate interests (Art. 6 para. 1 sentence 1 letter f. GDPR) – processing is necessary in order to protect the legitimate interests of the controller or of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

     

    National data protection regulations in Germany: In addition to the data protection provisions of the basic data protection regulation, national regulations on data protection apply in Germany. These include in particular the law on protection against misuse of personal data in data processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to deletion, the right of objection, 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 (Section 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 be applicable.

       

      Safety measures

      We take appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, implementation costs and the nature, scope, circumstances and purposes of the processing as well as the varying degrees of probability of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

      These measures shall include in particular the safeguarding of confidentiality, integrity and availability of data by controlling physical and electronic access to data as well as access, input, disclosure, safeguarding of availability and segregation of data relating thereto. Furthermore, we have established procedures to ensure that data subjects’ rights are exercised, data is deleted, and responses are made to any threats to the data. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes in accordance with the principle of data protection, by designing technology and by using data protection-friendly default settings.

      SSL-Encryption (https): 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 and disclosure of personal data

        In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. The recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and in particular conclude appropriate contracts or agreements with the recipients of your data which 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 if the processing takes place within the scope of using the services of third parties or the disclosure or transfer of data to other persons, bodies or companies, this is only done in accordance with the legal requirements.

          Subject to express consent or transfer required by contract or law, we will only process or transfer the data to third countries with a recognised level of data protection, including the US processors certified under the Privacy Shield, or on the basis of specific guarantees, such as contractual obligation through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

             

            Use of cookies

            Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after his visit within an online offer. The stored information may include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was viewed. The term “cookies” also includes other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also referred to as “user IDs”)

            The following cookie types and functions 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 browser.
            • Permanent cookies: Permanent cookies remain stored even after closing the browser. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users used for reach measurement or marketing purposes can be stored in such a cookie.
            • First-party-cookies: First-party-cookies are set by ourselves.
            • Third-party-cookies: Third party cookies are mainly used by advertisers (so-called third parties) to process user information.
            • Necessary (also: essential or absolutely necessary) cookies: Cookies may be absolutely necessary for the operation of a website (e.g. to store logins or other user entries or for security reasons).
            • Statistical, marketing and personalization cookies: In addition, cookies are generally also used in the context of range measurement and when the interests of a user or his behaviour (e.g. viewing certain content, using functions etc.) on individual web pages are stored in a user profile. Such profiles are used to show users e.g. content that corresponds to their potential interests. This procedure is also known as “tracking”, i.e. following the potential interests of users. . If we use cookies or tracking technologies, we will inform you separately in our privacy policy or when you give your consent.

             

            Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing 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 business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfil our contractual obligations.

            General information on revocation and opposition (Opt-Out): Depending on whether the processing is based on consent or legal permission, you may at any time revoke any consent you have given or object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection by means of the settings of your browser, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online service). An objection to the use of cookies for online marketing purposes can also be made by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ be explained. You can change your selected settings here: cookie settings

            Processing of cookie data based on consent: Before we process or allow data to be processed in the context of the use of cookies, we ask users for their consent, which can be revoked at any time. Before the consent has not been given, cookies will be used if necessary, which are necessary for the operation of our online offer. Their use is based on our interest and the interest of the users in the expected functionality of our online offer.

            • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

            • Persons concerned: Users (e.g. website visitors, users of online services).

            • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

             

            Commercial and business services

            We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) within the framework of contractual and comparable legal relationships and associated measures and within the framework of communication with the contractual partners (or pre-contractual), e.g. in order to answer inquiries.

            We process these data in order to fulfil our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with these data and for the purposes of the business organisation. Within the framework of the applicable law, we only pass on the data of the contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations or with the consent of the contractual partners (e.g. to participating telecommunication, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.

            Which data is required for the above-mentioned purposes is communicated to the contractual partners before or during data collection, e.g. in online forms, by special marking (e.g. colours) or symbols (e.g. asterisks or similar), or personally.

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

            If we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.

            Shop and e-commerce: We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and related services, as well as their payment and delivery or execution.

            The required information is marked as such within the scope of the ordering or comparable acquisition process and includes the information required for delivery, provision and invoicing as well as contact information in order to be able to make any necessary arrangements.

            Publication activity: We process the data of our contact partners, interview partners and other persons who are the subject of our journalistic, editorial, journalistic and related activities. In this context, we refer to the validity of protective regulations of the freedom of opinion and freedom of the press according to Art. 85 GDPR in connection with the respective national laws. The processing serves the fulfilment of our commissioned activities and is otherwise carried out in particular on the basis of the general public’s interest in information and media services.

            • Data types processed: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

            • Persons concerned: interested parties, business and contractual partners, customers.

            • Purpose of the processing: Contractual performance and service, contact requests and communication, office and organisational procedures, administration and response to requests, security measures.

            • Legal bases: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

             

            Blogs and publication media

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

            Comments and contributions: If users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone leaves illegal content in comments and contributions (insults, prohibited political propaganda etc.). In this case we can be prosecuted ourselves for the comment or contribution and are therefore interested in the identity of the author.

            Furthermore, we reserve the right, based on our legitimate interests, to process the information provided by users for the purpose of spam detection.

            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 contributions, any contact and website information as well as the content will be permanently stored by us until the user objects.

            Profile pictures of Gravatar: We use the service Gravatar within our online offer and especially in our blog.

            Gravatar is a service where users can register and store profile pictures and their email addresses. If users leave contributions or comments on other online presences (especially blogs) using their e-mail address, their profile pictures can be displayed next to the contributions or comments. For this purpose, the e-mail address provided by the user is transmitted in encrypted form to Gravatar for the purpose of checking whether a profile is stored for it. This is the only purpose of transmitting the e-mail address. It will not be used for other purposes, but will be deleted afterwards.

            The use of Gravatar is based on our legitimate interests, as Gravatar enables authors of articles and comments to personalize their contributions with a profile picture.

            By displaying the images, Gravatar obtains the IP address of users, as this is necessary for communication between a browser and an online service.

            If users do not want a user image linked to their email address at Gravatar to appear in their comments, they should use an email address that is not stored at Gravatar. We would also like to point out that it is also possible to use an anonymous email address or no email address at all if users do not want their own email address to be sent to Gravatar. Users can completely prevent the transmission of data by not using our comment system.

            • Data types processed: inventory data (e.g. names, 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).

            • Persons concerned: Users (e.g. website visitors, users of online services).

            • Purpose of the processing: Contractual performance and service, feedback (e.g. collecting feedback via online form), security measures, administration and answering of inquiries, provision of our online offer and user-friendliness.

            • Legal basis: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR), consent (Art. 6 para. 1 sentence 1 lit. a GDPR), protection of vital interests (Art. 6 para. 1 sentence 1 lit. d. GDPR).

             

            Used services and service providers:

             

            Surveys and questionnaires

            The surveys and questionnaires we conduct (hereinafter referred to as “surveys”) are evaluated anonymously. Personal data will only be processed to the extent necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address to display the survey in the user’s browser or to enable a resumption of the survey by means of a temporary cookie (session cookie)) or if users have consented to this.

            Notes on legal bases: If we ask the participants for their consent to the processing of their data, this is the legal basis for the processing, otherwise the processing of the participants’ data is based on our legitimate interest in conducting an objective survey.

            • Data types processed: 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).

            • Persons concerned: Communication partners.

            • Purposes of processing: contact requests and communication, direct marketing (e.g. by e-mail or by post).

            • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

             

            Provision of the online offer and web hosting

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

            The data processed within the framework of the provision of the hosting offer may include all data relating to the users of our online offer, which are generated within the framework of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

            E-mail delivery and hosting: The web hosting services we use also include the sending, receiving and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as other information concerning the sending of e-mails (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of SPAM detection. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but (unless an end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.

            Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). Server log files may include the address and name of the web pages and files accessed, date and time of access, data volume transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

            The server log files can be used on the one hand for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and on the other hand to ensure the utilization of the servers and their stability.

            • Data types processed: 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).

            • Persons concerned: users (e.g. website visitors, users of online services).

            • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

             

            Cloudservices

            We use software services accessible via the Internet and running on the servers of their providers (so-called “cloud services”, also referred to as “software as a service”) for the following purposes: document storage and management, calendar management, e-mailing, spreadsheets and presentations, exchanging documents, content and information with specific recipients or publishing web pages, forms or other content and information, as well as chatting and participating in audio and video conferences.

            In this context, personal data may be processed and stored on the servers of the providers, as far as they are part of communication processes with us or otherwise processed by us as described in this privacy policy. This data may include, in particular, master data and contact details of users, data on procedures, contracts, other processes and their contents. The providers of cloud services also process usage data and metadata that they use for security purposes and service optimization.

            If we use cloud services to provide other users or publicly accessible websites with forms or other documents and content, the providers may store cookies on the users’ devices for web analysis purposes or to remember user settings (e.g. in the case of media control).

            Notes on legal bases: If we ask for consent to use the cloud services, the legal basis for processing is consent. Furthermore, their use can be a component of our (pre-)contractual services, provided that the use of the cloud services has been agreed in this context. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient and secure administration and collaboration processes).

            • Data types processed: Inventory data (e.g. names, 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).

            • Persons concerned: Customers, employees (e.g. employees, applicants, former employees), interested parties, communication partners.

            • Purposes of the processing: Office and organisational procedures.

            • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Performance of the contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR)

             

            Used services and service providers:

             

            Newsletter and mass communication

            We send newsletters, e-mails and other electronic notifications (hereinafter referred to as “newsletters”) only with the consent of the recipients or a legal permission. If, in the course of registering for the newsletter, its contents are specifically described, they are decisive for the consent of the users. Furthermore, our newsletters contain information about our services and us.

            To subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name for the purpose of personal contact in the newsletter, or other information if this is necessary for the purposes of the newsletter.

            Double-Opt-In-Procedure: The registration for our newsletter is always done in a so-called Double-Opt-In-Procedure. This means that you will receive an e-mail after registration in which you are asked to confirm your registration. This confirmation is necessary so that nobody can register with foreign e-mail addresses. The newsletter registrations are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored by the shipping service provider are also logged.

            Deletion and limitation of processing: We may 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 defence against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time. In case of obligations to permanently observe contradictions, we reserve the right to store the e-mail address in a blacklist for this purpose alone.

            The logging of the registration procedure is based on our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

            Notes on legal bases: The sending of newsletters is based on the consent of the recipients or, if consent is not required, on our legitimate interests in direct marketing, if and to the extent permitted by law, e.g. in the case of existing customer advertising. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests in order to prove that it was carried out in accordance with the law.

            Content: Information about us, our services, actions and offers.

            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, if we use a mailing service provider, from their server. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and the time of the retrieval, is initially collected.

            This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined by means of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor, if used, that of the mailing service provider to observe individual users. Rather, the evaluations serve us to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

            The evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system, which both serves our business interests and meets the expectations of the users.

            A separate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled or must be contradicted.

            • Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).

            • Persons concerned: Communication partners.

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

            • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

            • Opt-Out: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the above mentioned contact options, preferably e-mail.

             

            Used services and service providers:

             

            Web analysis and optimization

            Web analysis (also known as “reach measurement”) is used to evaluate the streams of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the range analysis we can, for example, identify at what time our online offer or its functions or contents are most frequently used or invite reuse. We can also understand which areas require optimization.

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

            For these purposes, so-called user profiles can be created and stored in a file (so-called “cookie”) or similar procedures with the same purpose can be used. This information may include, for example, content viewed, web pages visited and elements used there, and technical details such as the browser used, the computer system used and information on times of use. If users have consented to the collection of their location data, this data may also be processed, depending on the provider.

            The IP addresses of users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect the users. In general, the data stored in the context of web analysis, A/B testing and optimization are not clear user data (such as e-mail addresses or names), but pseudonyms. This means that we as well as the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

            Notes on legal bases: If we ask the users for their consent to the use of the third party providers, the legal basis for the processing of data is the consent. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

            • Data types processed: usage data (e.g. websites visited, interest in content, access times).

            • Persons concerned: Users (e.g. website visitors, users of online services).

            • Purpose of the processing: Reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behavioural profiling, use of cookies), visitor action evaluation, profiling (creation of user profiles), interest-based and behaviour-based marketing.

            • Security measures: IP-Masking (pseudonymisation of the IP address).

            • Legal basis: Consent (Art. 6 para. 1 sentence 1 letter a GDPR), legitimate interests (Art. 6 para. 1 sentence 1 letter f. GDPR).

             

            online marketing

            We process personal data for online marketing purposes, which may include in particular the marketing of advertising space or the display of advertising and other content (collectively referred to as “Content”) based on the potential interests of users and the measurement of its effectiveness.

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

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

            The information in the profiles is usually stored in the cookies or by similar methods. These cookies can later generally also be read out on other websites that use the same online marketing procedure, analysed for the purpose of presenting content and supplemented with additional data and stored on the server of the online marketing procedure 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 methods we use and the network links the profiles of the users in the aforementioned data. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.

            As a matter of principle, we only have access to summarized information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyse the success of our marketing measures.

            Unless otherwise stated, we ask you to assume that cookies used are stored for a period of two years.

            Notes on legal bases: If we ask the users for their consent to the use of the third party providers, the legal basis for the processing of data is the consent. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

            • Data types processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (data indicating the location of an end user’s terminal equipment).

            • Persons concerned: Users (e.g. website visitors, users of online services), interested parties.

            • Purpose of the processing: Tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, visitor action evaluation, interest-based and behaviour-based marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors), target group formation (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes).

            • Security measures: IP-Masking (Pseudonymisation of the IP address).

            • Legal basis: Consent (Art. 6 para. 1 sentence 1 letter a GDPR), legitimate interests (Art. 6 para. 1 sentence 1 letter f. GDPR).

            • Opt-Out: We refer to the data protection notices of the respective providers and the possibilities of objection (so-called “opt-out”) indicated for the providers. If no explicit opt-out option has been specified, it is possible to switch off cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary form 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) Transnational: https://optout.aboutads.info.

             

            Used services and service providers:

             

            Affiliate programs and affiliate links

            In our online offer we include so-called affiliate links or other references (which may include discount codes, for example) to the offers and services of third parties (collectively referred to as “affiliate links”). If users follow the affiliate links, or subsequently take advantage of the offers, we may receive commission or other benefits from these third parties (collectively referred to as “commission”).

            In order to be able to track whether the users have taken advantage of the offers of an affiliate link used by us, it is necessary that the respective third party providers learn that the users have followed an affiliate link used within our online offer. The assignment of the affiliate links to the respective business transactions or other actions (e.g. purchases) serves the sole purpose of the commission settlement and is cancelled as soon as it is no longer necessary for the purpose.

            For the purposes of the aforementioned affiliate link assignment, the affiliate links may be supplemented by certain values that are a component of the link or may be stored in some other way, e.g. in a cookie. These values can include in particular the initial website (referrer), the time, an online identification of the operator of the website on which the affiliate link was located, an online identification of the respective offer, the type of link used, the type of offer and an online identification of the user.

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

            • Data types processed: Contract data (e.g. subject matter of contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

            • Persons concerned: Users (e.g. website visitors, users of online services).

            • Purpose of the processing: Affiliate Tracking.

            • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Performance of the contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

             

            Used services and service providers:

             

            Presence in social networks

            We maintain online presences within social networks in order to communicate with the users active there or to offer information about us there.

            We point out that user data may be processed outside the European Union. This may result in risks for the users, because the enforcement of the users’ rights could be made more difficult. With regard to US providers that are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we would like to point out that they thereby undertake to comply with the data protection standards of the EU.

            Furthermore, user data within social networks is usually processed for market research and advertising purposes. Thus, for example, user profiles can be created based on the user behaviour and the resulting interests of the users. The user profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behaviour and interests of the users are stored. Furthermore, data may also be stored in the user 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 presentation of the respective forms of processing and the possibilities 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 most effectively be asserted with the providers. Only the providers have access to the data of the users and can take appropriate measures and provide information directly. Should you nevertheless require assistance, you can contact us.

            • Data types processed: Inventory data (e.g. names, 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).

            • Persons concerned: Users (e.g. website visitors, users of online services).

            • Purposes of processing: Contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors), affiliate tracking.

            • Legal basis: Justified interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

             

            Used services and service providers:

             

            Plugins and embedded functions and content

            We include in our online offer functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as “third party providers”). These can be, for example, graphics, videos or social media buttons and contributions (hereinafter referred to uniformly as “content”).

            The integration always assumes that the third party providers of this content process the IP address of the users, as without the IP address they would not be able to send the content to their browsers. The IP address is therefore required to display these contents or functions. We make every effort to use only such content whose respective providers use the IP address only to deliver the content. Third party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain technical information about the browser and operating system, the websites to be linked, the time of visit and other details about the use of our online offer, as well as being linked to such information from other sources.

            Notes on legal bases: If we ask the users for their consent to the use of the third party providers, the legal basis for the processing of data is the consent. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

            Integration of third-party software, scripts or frameworks (e.g. jQuery): We include software in our online offer which we call up from servers of other providers (e.g. function libraries which we use for the purpose of displaying or making our online offer user-friendly). The respective providers collect the IP addresses of the users and can process them for the purpose of transmitting the software to the users’ browser and for security purposes, as well as for the evaluation and optimisation of their offer.

            • Data types 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 data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos).

            • Persons concerned: Users (e.g. website visitors, users of online services).

            • Purpose of the processing: Provision of our online offer and user-friendliness, contractual benefits and service, security measures, administration and response to inquiries.

            • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR), consent (Art. 6 para. 1 sentence 1 lit. a GDPR), contract performance and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR)

             

            Used services and service providers:

             

            deletion of data

            The data processed by us will be deleted in accordance with the statutory provisions as soon as their consent permitted for processing is revoked or other permissions cease to apply (e.g. if the purpose for which the data were processed ceases to apply or they are not necessary for the purpose).

            Unless the data are deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or that must be stored for the assertion, exercise or defence of legal claims or to protect the rights of another natural or legal person.

            Further information on the deletion of personal data can also be found in the individual data protection notes of this privacy policy.

               

              Amendment 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 changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes make it necessary for you to take action to cooperate (e.g. to give your consent) or to receive other individual notification.

              If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.

              Rights of data subjects

              As a data subject, you are entitled to various rights under the GDPR, which result in particular from Art. 15 to 18 and 21 GDPR:

              • Right of objection: You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data relating to you which is carried out pursuant to Article 6 paragraph 1 letter e or f FADP; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing, including profiling, insofar as it is linked to such direct marketing.
              • Right of withdrawal for consents: You have the right to revoke any consent given at any time.
              • Right of access to information: You have the right to obtain confirmation as to whether or not data in question is being processed and to obtain information on such data, as well as further information and a copy of the data in accordance with legal requirements.
              • Right of rectification: In accordance with the law, you have the right to request the completion of the data concerning you or the correction of incorrect data concerning you.
              • Right of cancellation and limitation of processing: In accordance with the statutory provisions, you have the right to demand that data concerning you be deleted immediately, or alternatively, in accordance with the statutory provisions, to demand that the processing of the data be restricted.
              • Right to data transferability: You have the right, in accordance with the law, to receive data concerning you which you have provided us with in a structured, common and machine-readable format or to request its transfer to another responsible party.
              • Complaint to the supervisory authority: You also have the right, in accordance with the statutory provisions, to apply to a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of suspected infringement, if you believe that the processing of personal data relating to you is in breach of the GDPR.

               

              California Online Privacy Protection Act

              CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. – See more at:
              https://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

               

              Definitions of terms

              This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined above all in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.

              • Affiliate Tracking: As part of the affiliate tracking, links are logged with the help of which the linking websites refer users to websites with product or other offers. The operators of the respective linking websites can receive a commission if users follow these so-called affiliate links and then take advantage of the offers (e.g. buy goods or services). To this end, it is necessary for the providers to be able to track whether users who are interested in certain offers subsequently take notice of them at the instigation of the affiliate links. Therefore, for affiliate links to work, it is necessary for them to be supplemented with certain values that become part of the link or are otherwise stored, e.g. in a cookie. These values include in particular the initial website (referrer), the time, an online identification of the operator of the website on which the affiliate link was located, an online identification of the respective offer, an online identification of the user as well as tracking specific values, such as advertising material ID, partner ID and categorizations.
              • Visit action evaluation: “Conversion Tracking” refers to a procedure that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user’s devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, we can use this to track whether the ads we have placed on other websites have been successful).
              • Cross-Device Tracking: Cross-device tracking is a form of tracking in which the behavioral and interest information of users is recorded across devices in so-called profiles by assigning users an online identifier. This allows the user information to be analyzed for marketing purposes, regardless of the browser or device used (e.g. mobile phones or desktop computers). With most providers, the online identification is not linked to clear data, such as names, postal or e-mail addresses.
              • IP-Masking: IP masking is a method of deleting the last octet, i.e. the last two numbers of an IP address, so that the IP address can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymising processing methods, especially in online marketing
              • Interest based and behavioral marketing: One speaks of interest-based and/or behavioral marketing when the potential interests of users in advertisements and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behaviour (e.g. visiting and staying on certain websites, buying behaviour or interaction with other users), which is stored in a so-called profile. Cookies are generally used for these purposes.
              • Conversion measurement: Conversion measurement is a method to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users’ devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this enables us to track whether the ads we have placed on other websites have been successful.
              • Personal data: “personal data” shall mean any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable 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. a cookie) or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
              • Profiling: Profiling is any automated processing of personal data that consists of using personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information on age, gender, location and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
              • Range measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behaviour or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, identify at what time visitors visit their website and what content they are interested in. This enables them to better adapt the contents of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for the purpose of range analysis in order to recognise returning visitors and thus obtain more precise analyses of the use of an online offering.
              • Remarketing: One speaks of “remarketing” or “retargeting”, for example, when it is noted for advertising purposes which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
              • Tracking: One speaks of “tracking” when the behaviour of users can be traced across several online offers. As a rule, behavioral and interest information regarding the online offers used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
              • Responsible person: Controller’ shall mean the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data.
              • Processing: “processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually all handling of data, whether it be collection, analysis, storage, transmission or deletion.
              • Target group formation: One speaks of target group formation (or “custom audiences”) when target groups are determined for advertising purposes, e.g. insertion of advertisements. For example, based on a user’s interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online shop where he/she viewed the products. Lookalike Audiences” (or similar target groups) are, in turn, when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used to create custom audiences and lookalike audiences.

              Created with the help of datenschutz-generator.de by Dr. Thomas Schwenke