Introduction

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 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 the provision of our services and in particular on our websites, mobile, as well as within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).

The terms used are not gender-specific.

Status: 01.07.2022

 

Outline

Controller

Efe Köse / 2K Digital e.K.
Alexander-Wiegand-Str. 19
63911, Klingenberg
Deutschland

Authorised representative: Efe Köse

E-Mail address: support@pushtube.shop

 

Overview of the processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

  • Inventory data (e.g. names, addresses).
  • Content data (e.g. entries in online forms).
  • 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 (information about the geographical location of a device or person).
  • Contract data (e.g. subject matter of the contract, term, customer category).
  • Payment data (e.g. bank details, invoices, payment history).

Categories of data subjects

  • Business and contractual partners.
  • Interested parties.
  • Communication partners.
  • Customers.
  • Users (e.g. website visitors, users of online services).

Purposes of processing

  • Assessment of creditworthiness and creditworthiness.
  • Provision of our online offer and user-friendliness.
  • Visit action evaluation.
  • Office and organizational procedures.
  • Cross-device tracking (cross-device processing of user data for marketing purposes).
  • Direct marketing (e.g. by e-mail or post).
  • Interest-based and behavioral marketing.
  • Contact requests and communication.
  • Conversion measurement (measuring the effectiveness of marketing measures).
  • Profiling (creating user profiles).
  • Remarketing.
  • Range measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures.
  • Tracking (e.g. interest/behavioural profiling, use of cookies).
  • Provision of contractual services and customer service.
  • Managing and responding to requests.
  • Target group formation (determination of target groups relevant for marketing purposes or other output of content).

Automated decision-making in individual cases

  • Credit report (decision based on a credit check).

Relevant legal bases

In the following, we inform you of the legal bases of the General Data Protection Regulation (GDPR), on the basis of which we process the personal data. Please note that in addition to the provisions of the GDPR, the national data protection requirements may apply in your or our country of residence and domicile. If, in addition, more specific legal bases are decisive in individual cases, we will inform you of these in the data protection declaration.

  • 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 concerning him or her for a specific purpose or for several specific purposes.
  • Performance of the contract and pre-contractual requests (Art. 6 para. 1 sentence 1 lit. b. GDPR) – The processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR) – The processing is necessary to fulfill a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR) – The processing is necessary to safeguard the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject requiring the protection of personal data prevail.

 

Security measures

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

Measures shall include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, ensuring 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 the threat to the data. Furthermore, we take into account the protection of personal data already during the development or selection of hardware, software and procedures 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 bar of your browser.

 

Transmission and disclosure of personal data

As part of our processing of personal data, it happens 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 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 a case, we observe the legal requirements and, in particular, conclude corresponding 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 if the processing takes place in the context of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements. Subject to express consent or contractually or legally required transfer, we process or have the data processed only in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence 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 websites or domains visited and are stored by a browser on the user’s computer. A cookie is primarily used to store the information about a user during or after his visit 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 place where a video was watched. The term cookies also includes other technologies that perform the same functions as cookies (e.g. when user information is stored on the basis of 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 range measurement or marketing purposes may be stored in such a cookie.
  • First-party cookies: First-party cookies are set by ourselves.
  • Third-party cookies (also: 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 can be strictly necessary for the operation of a website (e.g. to store logins or other user input or for security reasons).
  • Statistical, marketing and personalization cookies: Furthermore, cookies are usually also used in the context of range measurement and when the interests of a user or his behavior (e.g. viewing certain content, use of functions, etc.) are stored on individual websites in a user profile. Such profiles are used to show users, for example, content that corresponds to their potential interests. This procedure is also referred to as “tracking”, i.e. tracking the potential interests of users. If we use cookies or “tracking” technologies, we will inform you separately in our privacy policy or as part of obtaining consent.

Information on legal bases: The legal basis on which we process your personal data with the help of cookies depends on whether we ask for your consent. If this is the case and you consent to the use of cookies, the legal basis for the processing of your data is the 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.

Storage period: If we do not provide you with explicit information on the storage period of permanent cookies (e.g. as part of a so-called cookie opt-in), please assume that the storage period can be up to two years.

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke a given consent or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can first declare your objection by means of the settings of your browser, e.g. by deactivating the use of cookies (whereby this may also limit the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared 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. In addition, you can receive further objection notices in the context of the information on the service providers and cookies used.

Processing of cookie data on the basis of consent: Before we process or have processed data in the context of the use of cookies, we ask users for consent that can be revoked at any time. Until consent has been given, cookies are used that are absolutely necessary for the operation of our online offer.

Cookie settings/ objection option:
 
  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: 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).
  • Please address the objection to the processing of your personal data to the following e-mail address: support@pushtube.shop

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 in the context of communication with the contractual partners (or pre-contractual), e.g. to answer inquiries.

We process this data to fulfil our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information and the corporate organisation. Within the scope of 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 for the fulfilment of legal obligations or with the consent of the persons concerned (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners are informed about further forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.

We inform the contractual partners before or within the scope of data collection, e.g. in online forms, by means of special markings (e.g. colours) or symbols (e.g. asterisks or similar), or in person, which data is required for the aforementioned purposes.

We delete the data after expiry of statutory warranty and comparable obligations, i.e., in principle after expiry of 4 years, unless the data is stored in a customer account, e.g. as long as it must be stored for legal reasons of archiving (e.g. for tax purposes usually 10 years). Data that has been disclosed to us as part of an order by the contractual partner will be deleted in accordance with the specifications of the order, in principle 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 information of the respective third-party providers or platforms apply in the relationship between the users and the providers.

Customer account: Contractual partners can create an account within our online offer (e.g. customer or user account, in short “customer account”). If the registration of a customer account is required, contractual partners will be informed of this as well as of the information required for registration. The customer accounts are not public and cannot be indexed by search engines. As part of the registration as well as subsequent registrations and uses of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove the registration and to prevent any misuse of the customer account.

If customers have terminated their customer account, the data relating to the customer account will be deleted, subject to the retention of which is required for legal reasons. It is the customer’s responsibility to secure their data upon termination of the customer account.

Economic analyses and market research: For business reasons and in order to be able to identify market trends, wishes of the contractual partners and users, we analyse the data available to us on business transactions, contracts, inquiries, etc., whereby contractual partners, interested parties, customers, visitors and users of our online offer may fall into the group of data subjects.

The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we can, if available, take into account the profiles of registered users including their information, e.g. on services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with aggregated, i.e. anonymised values. Furthermore, we take into account the privacy of the users and process the data for the analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as aggregated data).

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. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is marked as such in the context of the order or comparable purchase process and includes the information required for delivery, provision and billing as well as contact information in order to be able to hold any consultation.

  • Types of data processed: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of 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).
  • Data subjects: 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 requests, security measures, visit action evaluation, interest-based and behavioral marketing, profiling (creation of user profiles).
  • Legal basis: Performance of the 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).

 

Payment Provider

In the context 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 payment service providers in addition to banks and credit institutions (collectively “payment service providers”).

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

The terms and conditions and the data protection information of the respective payment service providers apply to the payment transactions, which can be called up within the respective websites or transaction applications. We also refer to these for the purpose of further information and assertion of rights of revocation, information and other data subject rights.

  • Types of data processed: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of 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).
  • Data subjects: customers, interested parties.
  • Purposes of processing: Provision of contractual services and customer service.
  • Legal basis: 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).

Services and service providers used:

 

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 retrieved. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security and technical maintenance services.

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

E-mail sending and hosting: The web hosting services used by us also include the sending, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as other information regarding the e-mail dispatch (e.g. the providers involved) as well as the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purposes of detecting SPAM. Please note that e-mails on the Internet are generally not sent encrypted. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore assume no responsibility for the transmission path of the e-mails between the sender and the receipt on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on each access to the server (so-called server log files). The server log files may include the address and name of the accessed websites and files, date and time of retrieval, 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.

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.

  • 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).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

 

Contact

When contacting us (e.g. via contact form, e-mail, telephone or via social media), the details of the requesting persons will be processed insofar as this is necessary to answer the contact inquiries and any requested measures.

The answer to contact requests in the context of contractual or pre-contractual relationships takes place to fulfil our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of the legitimate interests in answering the inquiries.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: communication partners, interested parties.
  • Purposes of processing: contact requests and communication, management and response to requests.
  • Legal basis: 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).

 

Newsletter and electronic notifications

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

In order to subscribe to our newsletters, it is generally sufficient if you provide your e-mail address. However, we may ask you to provide a name for the purpose of personal addressing 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 generally carried out in a so-called double opt-in procedure. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can register with foreign e-mail addresses. The subscriptions to the newsletter 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.

Deletion and restriction 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 the event of obligations to permanently observe contradictions, we reserve the right to store the e-mail address solely for this purpose in a blacklist.

The registration procedure is logged on the basis of our legitimate interests for the purpose of proving its proper operation. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure system.

Information on legal bases: The newsletter is sent on the basis of the consent of the recipients 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 existing customer advertising. Insofar as 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 to prove that it has been carried out in accordance with the law.

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

Analysis and 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 service provider, from its server. As part 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, are first collected.

This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior on the basis of their retrieval locations (which can be determined with the help 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 the individual newsletter recipients. However, it is neither our endeavor nor, if used, that of the service provider to observe individual users. Rather, the evaluations serve us to recognize 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 serves both our business interests and 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 terminated or contradicted.

Types of data processed: 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).

  • Types of data processed: 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).
  • Data subjects: communication partners.
  • Purposes of processing: Direct marketing (e.g. by e-mail or post).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
  • Possibility of objection (opt-out): You can cancel the receipt of our newsletter at any time, i.e. Revoke your consent or object to.dem further receipt. You will either find a link to cancel the newsletter at the end of each newsletter or you can otherwise use one of the above-mentioned contact options, preferably e-mail, for this purpose

 

Web analysis, monitoring and optimization

The web analysis (also referred to as “reach measurement”) serves to evaluate the visitor flows of 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 reach analysis, we can, for example, recognize at what time our online offer or its functions or content are most frequently used or invite reuse. We can also understand which areas need to be optimised.

In addition to web analysis, we can also use test procedures, e.g. to test and optimize 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, websites visited and elements used there and technical information, 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, these can also be processed depending on the provider.

The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, in the context of web analysis, A/B testing and optimization, no clear data of the users (such as e-mail addresses or names) are stored, but pseudonyms. 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.

Information on legal bases: If we ask the users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, the data of the users 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.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Range measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behavioural profiling, use of cookies), visit action evaluation, profiling (creation of user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR)

 

Online marketing

We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the presentation of advertising and other content (collectively referred to as “content”) based on 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 procedures are used by means of which the information about the user relevant for the presentation of the aforementioned content is stored. This information may 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 times of use. If users have consented to the collection of their location data, these can also be processed.

The IP addresses of the users are also stored. However, we use available IP masking procedures (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear data of the users (such as e-mail addresses or names) are stored as part of the online marketing process, but pseudonyms. This means that we, as well as the providers of 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 means of similar procedures. These cookies can later generally also be read on other websites that use the same online marketing procedure and analyzed for the purpose of presenting content as well as supplemented with further data and stored on the server of the online marketing method provider.

Exceptionally, clear data can be assigned to the profiles. This is the case if, for example, the users are members of a social network whose online marketing procedures we use and the network connects the profiles of the users with the aforementioned information. We ask you to note that users can make additional agreements with the providers, e.g. by giving their consent as part of the registration.

In principle, we only have access to aggregated 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. e.g., to the conclusion of a contract with us. Conversion measurement is used solely to analyze the success of our marketing efforts.

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

Information on legal bases: If we ask the users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, the data of the users 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.

Facebook pixel: With the help of the Facebook pixel, Facebook is able to determine the visitors of our online offer as a target group for the presentation of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those users on Facebook and within the services of the partners cooperating with Facebook (so-called “Audience Network” https://www.facebook.com/audiencenetwork/) who have also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products that become apparent on the basis of the websites visited), which we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of the users and do not appear annoying. With the help of the Facebook pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion measurement”).

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographical position of a device or person).
  • Data subjects: Users (e.g. website visitors, users of online services), interested parties.
  • Purposes of processing: Tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, visitor action evaluation, interest-based and behavioural marketing, profiling (creation of user profiles), conversion measurement (measuring the effectiveness of marketing measures), range 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 (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
  • Possibility of objection (opt-out): We refer to the data protection information of the respective providers and the objection options specified for the providers (so-called “opt-out”). If no explicit opt-out option has been specified, there is the possibility that you deactivate cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore also recommend the following opt-out options, which are offered in summary to 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-territorial: https://optout.aboutads.info.
Services and service providers used:
  • Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offer. The Tag Manager itself (which implements the tags) does not process any personal data of the users. With regard to the processing of users’ personal data, reference is made to the following information on Google services. Service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy.
  • Google Analytics: online marketing and web analytics; Service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Possibility of objection (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • Google Ads and conversion measurement: We use the online marketing method “Google Ads” to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads. We also measure the conversion of the ads. However, we only know the anonymous total number of users who clicked on our ad and were redirected to a page with a so-called “conversion tracking tag”. However, we ourselves do not receive any information with which users can be identified. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy.
  • Google Ad Manager: We use the “Google Marketing Platform” (and services such as “Google Ad Manager”) to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.). The Google Marketing Platform is characterized by the fact that ads are displayed in real time based on the presumed interests of the users. This allows us to display ads for and within our online offer in a more targeted manner in order to present users only with ads that potentially correspond to their interests. If, for example, a user is shown ads for products that he has been interested in on other online offers, this is referred to as “remarketing”. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy.
  • Facebook Pixel: Service provider: https://www.facebook.com, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, Parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Possibility of objection (opt-out): https://www.facebook.com/settings?tab=ads.

 

Presence in social networks (Social Media)

We maintain online presences within social networks and, in this context, process user data in order to communicate with the users active there or to offer information about us.

We would like to point out that user data may be processed outside the territory of the European Union. This can result in risks for the users, because e.g. the enforcement of the rights of the users could be made more difficult.

Furthermore, the data of users within social networks are usually processed for market research and advertising purposes. For example, user profiles can be created based on the usage behavior and the resulting interests of the 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 users. For these purposes, cookies are usually stored on users’ computers, in which the usage behavior and interests of the users are stored. Furthermore, data may also be stored in the user profiles regardless of the devices used by the users (in particular 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 possibilities of objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.

Even 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 directly take appropriate measures and provide information. If you still need help, you can contact us.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: 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).
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
Services and service providers used:
 

 

Plugins and embedded functions as well as 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 may be, for example, graphics, videos or social media buttons as well as contributions (hereinafter uniformly referred to as “content”).

The integration always requires that the third-party providers of this content process the IP address of the users, since without the IP address they could not send the content to their browser. The IP address is therefore required for the presentation of this content or functions. We endeavor to use only such content whose respective providers use the IP address only to deliver the content. Third parties 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 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, to referring websites, the time of visit and other information on the use of our online offer as well as be combined with such information from other sources.

Information on legal bases: If we ask the users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, the data of the users 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.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographical position of a device or a person), content data (e.g. entries in online forms), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
  • Data subjects: Users (e.g. website visitors, users of online services), communication partners.
  • Purposes of processing: Provision of our online offer and user-friendliness, provision of contractual services and customer service, contact inquiries and communication, tracking (e.g. interest/behavioural profiling, use of cookies), interest-based and behavioural marketing, profiling (creation of user profiles), security measures, administration and response to requests.
  • 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 inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR).

Eingesetzte Dienste und Diensteanbieter:

  • Facebook plugins and content: Facebook Social plugins and content – This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within Facebook. The list and appearance of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/; Service providers: https://www.facebook.com, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Opt-out: Settings for advertisements: https://www.facebook.com/settings?tab=ads.
  • Google Fonts: We integrate the fonts (“Google Fonts”) of the provider Google, whereby the data of the users are used solely for the purpose of displaying the fonts in the browser of the users. The integration takes place on the basis of our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform presentation and taking into account possible licensing restrictions for their integration. Service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy
  • YouTube videos: video content; Service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Possibility of objection (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.

 

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions are omitted (e.g. if the purpose of the processing of this data has ceased to exist or they are not necessary for the purpose).

If the data is not deleted because it is necessary for other and legally permissible purposes, their 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 for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.

Further information on the deletion of personal data can also be provided in the context of the individual data protection information of this data protection declaration.

Changes and updates to the privacy policy

We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the privacy policy as soon as the changes to the data processing carried out by us 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 privacy policy, we ask you to note that the addresses may change over time and ask you to 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 Articles 15 to 21 GDPR:
 
  • Right to object: You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you on the basis of Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is related to such direct advertising.
  • Right of revocation for consents: You have the right to revoke your consent at any time.
  • Right of access: You have the right to request confirmation as to whether the data in question is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the legal requirements, you have the right to request the completion of the data concerning you or the correction of the incorrect data concerning you.
  • Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that data concerning you be deleted immediately or, alternatively, to demand a restriction of the processing of the data in accordance with the legal requirements.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request their transmission to another controller.
  • Complaint to the supervisory authority: In accordance with the legal requirements, you also have the right to lodge a complaint with 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 your personal data infringes the GDPR.

 

Definitions

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

  • Visit action evaluation: “Conversion Tracking” refers to a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users’ devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, we can track whether the ads we place on other websites were successful).
  • Credit information: Automated decisions are based on automatic data processing without human intervention (e.g. in the event of an automatic rejection of a purchase on account, an online loan application or an online application procedure without any human intervention. According to Art. 22 GDPR, such automated decisions are only permitted if data subjects give their consent, if they are necessary for the performance of a contract or if national laws allow these decisions.
  • Cross-device tracking: Cross-device tracking is a form of tracking in which behavioral and interest information of users is recorded across devices in so-called profiles by assigning users an online identifier. As a result, the user information can usually be analyzed for marketing purposes regardless of the browsers or devices used (e.g. mobile phones or desktop computers). For most providers, the online identifier is not linked to clear data such as names, postal addresses or e-mail addresses.
  • IP masking: “IP masking” is a method in which the last octet, i.e. the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing methods, especially in online marketing
  • Interest-based and behavioral marketing: Interest- and/or behavioral marketing is when potential interests of users in ads and other content are predetermined as precisely as possible. This is done on the basis of information on their previous behaviour (e.g. visiting certain websites and staying on them, purchasing behaviour or interaction with other users), which are stored in a so-called profile. Cookies are usually used for these purposes.
  • Conversion measurement: Conversion measurement is a method by which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users’ devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, we can track whether the ads we place on other websites have been successful.
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more special features that are an expression of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiling: “Profiling” refers to any type of automated processing of personal data consisting in the use of this personal data to address certain personal aspects relating to a natural person (depending on the type of profiling, this includes information relating to age, gender, location data and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people). analyze, evaluate or to predict them (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.
  • Reach measurement: The reach measurement (also referred to as web analytics) serves to evaluate the visitor flows of an online offer and can include the behavior or interests of visitors in certain information, such as content of websites. With the help of reach analysis, website owners can, for example, recognize at what time visitors visit their website and what content they are interested in. This allows them, for example, to better adapt the content of the website to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more detailed analyses of the use of an online offer.
  • Remarketing: “Remarketing” or “retargeting” is when, for example, for advertising purposes, it is noted which products a user has been interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Location data: Location data is generated when a mobile device (or other device with the technical requirements of a location determination) connects to a radio cell, a WLAN or similar technical intermediaries and functions of location determination. Location data is used to indicate at which geographically determinable position of the earth the respective device is located. Location data can be used, for example, to display map functions or other location-dependent information.
  • Tracking: “Tracking” is when the behavior of users can be tracked across several online offers. As a rule, behavioral and interest information is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling) with regard to the online offers used. This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
  • Controller: “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations performed on personal data, whether or not by automated means. The term goes far and covers practically every handling of data, be it the collection, evaluation, storage, transmission or deletion.
  • Target group formation: Target group formation (or “custom audiences”) is 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 in which he has viewed the products. “Lookalike audiences” (or similar target groups) are used when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were formed. For the purpose of creating Custom Audiences and Lookalike Audiences, cookies and web beacons are usually used.