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Data protection

 

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

 

Responsibility

 

bits&birds GmbH

Bergstraße 11

20095 Hamburg

Commercial register: HRB 163582

Register court: Hamburg

Represented by: Thomas Bockholdt & Daniel Stojanovic

Types of processed data

– Inventory data (e.g., personal master data, names or addresses).

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

– Content data (e.g., text input, photographs, videos).

– Usage data (e.g., web pages visited, interest in content, access times).

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

 

 

Categories of data subjects

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

 

 

Purpose of data processing

– Providing the online offer, its functions and content.

– Responding to contact requests and communicating with users.

– Security measures.

– Reach measurement/marketing.

Terms used

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

 

“Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data.

 

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

 

“Profiling” means any automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular, to analyze or predict aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or change of location.

 

“Controller” means the natural or legal person, public authority, agency or other body that alone or jointly with others determines the purposes and means of the processing of personal data.

 

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

Relevant legal basis

 

According to Art. 13 DSGVO, we inform you about the legal bases of our data processing activities. For users from the area of application of the General Data Protection Regulation (DSGVO), i.e. the EU and the EEC, the following applies, unless the legal basis is stated in the privacy policy:

 

The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 DSGVO;

 

The legal basis for processing the fulfilment of our services and implementation of contractual measures as well as answering inquiries is Art. 6 (1) lit. b DSGVO;

 

The legal basis for processing to fulfil our legal obligations is Art. 6 (1) lit. c DSGVO;

 

In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) lit. d DSGVO serves as the legal basis.

 

The legal basis for the processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Art. 6 (1) lit. e DSGVO.

 

The legal basis for processing to protect our legitimate interests is Art. 6 (1) lit. f DSGVO.

 

The processing of data for purposes other than those for which it was collected is determined by the requirements of Art. 6 (4) DSGVO.

 

The processing of special categories of data (according to Art. 9 (1) DSGVO) is determined according to the requirements of Art. 9 (2) DSGVO.

Security measures

 

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

 

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, entry into, disclosure of, assurance of availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, deletion of data, and response to data compromise. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.

Cooperations with processors, joint controllers and third parties

 

If in the course of our processing, we disclose data to other persons and companies (order processors, jointly responsible persons or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if transmission of the data to third parties, such as to payment service providers, is necessary for the performance of the contract), users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

 

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

Transfers to third countries

 

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this occurs in the context of the use of third-party services or disclosure, or transfer of data to other persons or companies, this will only occur if it is done for the fulfilment of our (pre)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to explicit consent or contractually required transfer, we only process or allow data to be processed in third countries with a recognized level of data protection, which includes US processors certified under the “Privacy Shield” or on the basis of special guarantees, such as contractual obligation through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection rules (Art. 44 to 49 DSGVO, information page of the EU Commission).

Rights of data subjects

 

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

 

You have the right, in accordance with. the legal requirements, to request that the data concerning you be completed or that incorrect data concerning you be corrected.

 

In accordance with the legal requirements, you have the right to demand that data concerning you be deleted immediately, or alternatively, in accordance with the legal requirements, to demand restriction of the processing of the data.

 

You have the right to demand that the data concerning you that you have provided to us be received in accordance with the legal requirements and to demand that it be transferred to other responsible parties.

 

You also have the right to lodge a complaint with the competent supervisory authority in accordance with the law.

 

 

Right of withdrawal

 

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

 

 

Right of objection

 

You may object to the future processing of data relating to you at any time in accordance with the legal requirements. An objection can be made in particular against processing for direct advertising purposes.

Cookies and right to object in the case of direct advertising

 

“Cookies” are small files that are stored on users’ computers. Various data can be stored within the cookies. The primary purpose of a cookie is to store information about a user (or the device on which the cookie is stored) during or after his or her visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. Such a cookie may store, for example, the contents of a shopping cart in an online store or a login status. Cookies that remain stored even after the browser is closed are referred to as “permanent” or “persistent”. For example, the login status can be stored if users visit them after several days. Likewise, the interests of users can be stored in such a cookie, which is used for range measurement or marketing purposes. Third-party cookies” are cookies that are offered by providers other than the responsible party that operates the online offer (otherwise, if they are only its cookies, they are referred to as “first-party cookies”).

 

We may use temporary and permanent cookies and explain this in our privacy policy.

 

If we ask users to consent to the use of cookies (e.g. in the context of a cookie consent), the legal basis of this processing is Art. 6 para. 1 lit. a. DSGVO. Otherwise, the personal cookies of users are processed in accordance with the following explanations within the scope of this privacy policy on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) or insofar as the use of cookies is necessary for the provision of our contract-related services, pursuant to Art. 6 para. 1 lit. b. DSGVO, or insofar as the use of cookies is necessary for the performance of a task which is in the public interest or is carried out in the exercise of official authority, pursuant to Art. 6 para. 1 lit. e. DSGVO, processed.

 

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

 

EA general objection to the use of cookies used for online marketing purposes can be declared for a large number of the services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by disabling them in the browser settings. Please note that in this case not all functions of this online offer can be used.

Deletion of data

 

The data processed by us will be deleted or restricted in its processing in accordance with the legal requirements. Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory retention obligations.

 

If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e. 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.

Change and updates to the privacy policy

 

We kindly ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

Agency services

 

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

 

In doing so, we process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter of contract, term), payment data (e.g., bank details, payment history), usage data and metadata (e.g., in the context of evaluating and measuring the success of marketing measures). As a matter of principle, we do not process special categories of personal data, unless these are components of commissioned processing. Data subjects include our customers, prospective customers as well as their customers, users, website visitors or employees as well as third parties. The purpose of the processing is the provision of contractual services, billing and customer service. The legal basis for the processing results from Art. 6 para. 1 lit. b DSGVO (contractual services), Art. 6 para. 1 lit. f DSGVO (analysis, statistics, optimization, security measures). We process data that are necessary for the justification and fulfilment of the contractual services and point out the necessity of their indication. Disclosure to external parties only takes place if it is necessary in the context of an order. When processing the data provided to us as part of an order, we act in accordance with the instructions of the client as well as the legal requirements of a contract processing pursuant to Art. 28 DSGVO and do not process the data for any other purposes than those specified in the order.

 

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

Administration, financial accounting, office organization, contact management

 

We process data in the context of administrative tasks as well as the organization of our business, financial accounting and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c. DSGVO, Art. 6 para. 1 lit. f. DSGVO. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lie in the administration, financial accounting, office organization, and archiving of data, i.e. tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information mentioned in these processing activities.

 

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

 

Furthermore, based on our business interests, we store information on suppliers, event organizers and other business partners, e.g. for the purpose of contacting them at a later date. This data, most of which is company-related, is generally stored permanently.

Data protection information in the application process

 

We process applicant data only for the purpose of and within the scope of the application process in accordance with legal requirements. Applicant data is processed for the fulfilment of our (pre)contractual obligations within the scope of the application procedure in accordance with Art. 6 para. 1 lit. b. DSGVO Art. 6 para. 1 lit. f. DSGVO insofar as the data processing becomes necessary for us, e.g. within the scope of legal procedures (in Germany, § 26 BDSG also applies).

 

The application procedure requires applicants to provide us with applicant data. The necessary applicant data are marked if we offer an online form, otherwise results from the job descriptions and basically includes the personal details, postal and contact addresses and the information required for the application documents belonging to the application, such as cover letter, curriculum vitae and certificates. In addition, applicants may voluntarily provide us with additional information.

 

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

 

To the extent that special categories of personal data within the meaning of Art. 9 (1) DSGVO are voluntarily disclosed within the scope of the application procedure, their processing shall additionally be carried out in accordance with Art. 9 (2) lit. b DSGVO (e.g. health data, such as severely disabled status or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 (1) DSGVO are requested from applicants as part of the application process, their processing is additionally carried out in accordance with Art. 9 (2) a DSGVO (e.g. health data, if this is necessary for the exercise of the profession).

 

If provided, applicants can submit their applications to us using an online form on our website. The data is transmitted to us in encrypted form in accordance with the state of the art.

 

Applicants can also send us their applications by e-mail. Please note, however, that e-mails are generally not sent in encrypted form and applicants must ensure that they have encrypted themselves. We cannot, therefore, accept any responsibility for the transmission path of the application between the sender and receipt on our server and therefore recommend rather using an online form or sending by post. This is because instead of applying via the online form and e-mail, applicants still have the option of sending us their applications by post.

 

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

 

Subject to a justified withdrawal by the applicants, the deletion will take place after the expiry of a period of six months so that we can answer any follow-up questions about the application and satisfy our obligations to provide evidence under the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with tax law requirements.

Talent pool

 

As part of the application process, we offer applicants the opportunity to be included in our “talent pool” for a period of two years on the basis of consent within the meaning of Art. 6 Para. 1 lit. a. and Art. 7 DSGVO.

 

The application documents in the talent pool will be processed solely in the context of future job advertisements and employee searches and will be destroyed at the latest after the expiry of the deadline. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the current application process and that they can revoke this consent at any time in the future and declare their objection within the meaning of Art. 21 DSGVO.

Registration function

 

Users can create a user account. As part of the registration process, the required mandatory information is provided to users and processed on the basis of Art. 6 (1) lit. b DSGVO for purposes of providing the user account. The processed data includes in particular the login information (name, password as well as an email address). The data entered during registration is used for the purposes of using the user account and its purpose.

 

Users may be informed about information relevant to their user account, such as technical changes, by e-mail. If users have terminated their user account, their data relating to the user account will be deleted, subject to any legal obligation to retain it. It is the responsibility of users to back up their data upon termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract.

 

Within the scope of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as those of users, in protection against abuse and other unauthorized use. In principle, this data is not passed on to third parties, unless it is necessary for the pursuit of our claims or there is a legal obligation to do so pursuant to Art. 6 para. 1 lit. c. DSGVO. The IP addresses are anonymized or deleted after 7 days at the latest.

Akismet anti-spam check

 

Our online offer uses the service “Akismet”, which is offered by Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA. The use is based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f) DSGVO. With the help of this service, comments from real people are distinguished from spam comments. For this purpose, all comment details are sent to a server in the USA, where they are analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data is stored beyond this time. This information includes the name entered, the email address, the IP address, the comment content, the referrer, information about the browser used as well as the computer system and the time of the entry.

 

For further information on the collection and use of data by Akismet, please refer to Automattic’s privacy policy: https://automattic.com/privacy/.

 

Users are welcome to use pseudonyms or to refrain from entering their name or email address. You can completely prevent the transmission of data by not using our commenting system. That would be a shame, but unfortunately, we don’t see any other alternatives that work just as effectively.

Contacting

 

When contacting us (e.g. via contact form, email, telephone or social media), the user’s details are used to process the contact request and handle it in accordance with Art. 6 para. 1 lit. b. (in the context of contractual/pre-contractual relations), Art. 6 para. 1 lit. f. (other requests) DSGVO processed. The user’s details may be stored in a customer relationship management system (“CRM system”) or comparable inquiry organization.

 

We delete the requests if they are no longer necessary. We review the necessity every two years; Furthermore, the legal archiving obligations apply.

Newsletter

 

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

 

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

 

Double-Opt-In and logging: The registration for our newsletter takes place in a so-called double-opt-in process. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address. Likewise, changes to your data stored with the dispatch service provider are logged.

 

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

 

The dispatch of the newsletter and the associated performance measurement are based on the consent of the recipients pursuant to Art. 6 para. 1 lit. a, Art. 7 DSGVO in conjunction with § 7 para. 2 no. 3 UWG or, if consent is not required, on the basis of our legitimate interests in direct marketing pursuant to Art. 6 para. 1 lt. f. DSGVO in conjunction with. § Section 7 (3) UWG.

 

The logging of the registration process takes place on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f DSGVO. Our interest is directed towards the use of a user-friendly as well as secure newsletter system that serves our business interests as well as meets the expectations of the users and furthermore allows us to prove consent.

 

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

Newsletter – Newsletter2Go

 

The newsletter is sent by means of the dispatch service provider Newsletter2Go GmbH, Köpenicker Str. 126, 10179 Berlin, Germany. You can view the privacy policy of the dispatch service provider here: https://www.newsletter2go.de/datenschutz/. The shipping service provider is used on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. DSGVO and an order processing contract pursuant to Art. 28 para. 3 p. 1 DSGVO.

 

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

Newsletter – performance measurement

 

The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened, or if we use a dispatch service provider, from their server. In the course of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the retrieval are collected.

 

This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined with the help of the IP address) or the access times. The statistical surveys also include the determination of 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 dispatch service provider to observe individual users. The evaluations serve us much more 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.

 

Unfortunately, a separate revocation of the performance measurement is not possible, in which case the entire newsletter subscription must be cancelled.

Hosting and e-mail dispatch

 

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

 

In doing so, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, metadata and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer pursuant to Art. 6 (1) lit. f DSGVO in conjunction with Art. 28 DSGVO. Art. 28 DSGVO (conclusion of order processing contract).

Collection of access data and log flies

 

We, respectively our hosting provider, collect on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO, we collect data about each access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

 

Log file information is stored for security reasons (e.g. for the clarification of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.

Google Tag Manager

 

Google Tag Manager is a solution that allows us to manage so-called website tags via an interface (and thus, for example, integrate Google Analytics as well as other Google marketing services into our online offering). 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, please refer to the following information on Google services. Usage guidelines: https://www.google.com/intl/de/tagmanager/use-policy.html.

Google Analytics

 

We use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by the users is usually transmitted to a Google server in the USA and stored there.

 

Google will use this information on our behalf for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. In doing so, pseudonymous usage profiles of the users can be created from the processed data.

 

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

 

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

 

If we ask users for consent (e.g. in the context of a cookie consent), the legal basis of this processing is Art. 6 para. 1 lit. a. DSGVO. Otherwise, the users’ personal data is processed on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) are processed.

 

Insofar as data is processed in the USA, we would like to point out that Google is certified under the Privacy Shield agreement and thereby assures that it complies with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

 

For further information on data used by Google, settings and objection options, please refer to Google’s privacy policy (https://policies.google.com/privacy) as well as the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

 

The users’ personal data is deleted or anonymized after 14 months.

Google Universal Analytics

 

We use Google Analytics in the form of “Universal Analytics”. “Universal Analytics” refers to a method of Google Analytics in which the user analysis is based on a pseudonymous user ID and thus a pseudonymous profile of the user is created with information from the use of different devices (so-called “cross-device tracking”).

Target group building with Google Analytics

 

We use Google Analytics to display the ads placed by within advertising services of Google and its partners, only to those users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited), which we transmit to Google (so-called “Remarketing Audiences”, or “Google Analytics Audiences”). With the help of Remarketing Audiences, we also want to ensure that our ads correspond to the potential interest of users.

Google Adsense with personalized ads

 

We use the services of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

 

We use the service AdSense, with the help of which ads are displayed on our website and we receive payment for their display or other use. For these purposes, usage data such as the click on an ad and the IP address of the user are processed, whereby the IP address is shortened by the last two digits. Therefore, the processing of the users’ data is pseudonymized.

 

We use Adsense with personalized ads. In doing so, Google draws conclusions about users’ interests based on the websites they visit or apps they use and the user profiles thus created. Advertisers use this information to tailor their campaigns to these interests, which benefits users and advertisers alike. For Google, ads are personalized when captured or known data determines or influences ad selection. This includes past search queries, activities, website visits, app usage, demographic and location information, among others. Specifically, this includes: demographic targeting, targeting on interest categories, remarketing, and targeting on customer match lists and audience lists uploaded to DoubleClick Bid Manager or Campaign Manager.

 

If we ask users for consent (e.g., in the context of cookie consent), the legal basis of this processing is Art. 6 (1) lit. a. DSGVO. Otherwise, the users’ personal data is processed on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) are processed.

 

Insofar as data is processed in the USA, we point out that Google is certified under the Privacy Shield agreement and thereby assures that it complies with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

 

For more information on the use of data by Google, settings and opt-out options, please refer to Google’s privacy policy (https://policies.google.com/technologies/ads) and the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

Google Adsense with non-personalized ads

 

We use the services of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

 

We use the service AdSense, with the help of which ads are displayed on our website and we receive payment for their display or other use. For these purposes, usage data such as the click on an ad and the IP address of the user are processed, whereby the IP address is shortened by the last two digits. Therefore, the processing of the users’ data is pseudonymized.

 

We use Adsense with non-personalized ads. In this case, the ads are not displayed based on user profiles. Non-personalized ads are not based on past user behaviour. Targeting uses contextual information, including broad (e.g., location-level) geographic targeting based on current location, content on the current website or app, and current search terms. Google prevents any personalized targeting, including demographic targeting and targeting based on user lists.

 

If we ask users for consent (e.g. in the context of cookie consent), the legal basis for this processing is Art. 6 (1) lit. a. DSGVO. Otherwise, the users’ personal data is processed on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) are processed.

 

Insofar as data is processed in the USA, we would like to point out that Google is certified under the Privacy Shield agreement and thereby assures that it complies with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

 

For more information on the use of data by Google, settings and opt-out options, please refer to Google’s privacy policy (https://policies.google.com/technologies/ads) and the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

Google AdWords and conversion measurement

 

We use the services of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, (“Google”).

 

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

 

We use the online marketing method Google “AdWords” to place ads in the Google advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. This allows us to display ads for and within our Online Offerings in a more targeted manner to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products in which he or she has expressed interest in other online offers, this is referred to as “remarketing”. For these purposes, when our website and other websites on which the Google advertising network is active are called up, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also referred to as “web beacons”) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). This file records which web pages the user has visited, which content the user is interested in and which offers the user has clicked on, as well as technical information about the browser and operating system, referring web pages, time of the visit and other information about the use of the online offer.

 

Furthermore, we receive an individual “conversion cookie”. The information obtained with the help of the cookie is used by Google to create conversion statistics for us. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page tagged with a conversion tracking tag. However, we do not receive any information that personally identifies users.

 

The users’ data is processed pseudonymously within the Google advertising network. I.e. Google does not store and process e.g. the name or email address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. I.e. from Google’s perspective, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has explicitly allowed Google to process the data without this pseudonymization. The information collected about users is transmitted to Google and stored on Google’s servers in the USA.

 

If we ask users for consent (e.g. in the context of a cookie consent), the legal basis for this processing is Art. 6 para. 1 lit. a. DSGVO. Otherwise, the users’ personal data is processed on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) are processed.

 

Insofar as data is processed in the USA, we would like to point out that Google is certified under the Privacy Shield agreement and thereby assures that it complies with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

 

For more information on the use of data by Google, settings and opt-out options, please refer to Google’s privacy policy (https://policies.google.com/technologies/ads) and the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

Facebook Pixel, Custom Audiences and Facebook Conversion

 

Within our online offer, the so-called “Facebook pixel” of the social network Facebook, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), is used.

 

With the help of the Facebook pixel, it is possible for Facebook, on the one hand, to determine the visitors to our online offer as a target group for the display of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of users and do not have a harassing effect. With the help of the Facebook pixel, we can also track the effectiveness of the 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”).

 

The processing of the data by Facebook takes place within the framework of Facebook’s data usage policy. Accordingly, general information on the display of Facebook ads, in Facebook’s data usage policy: https://www.facebook.com/policy.

 

Specific information and details about the Facebook Pixel and how it works can be found in Facebook’s help section: https://www.facebook.com/business/help/651294705016616.

 

If we ask users for consent (e.g. in the context of cookie consent), the legal basis for this processing is Art. 6 para. 1 lit. a. DSGVO. Otherwise, the users’ personal data is processed on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) are processed.

 

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

 

You can object to the collection by the Facebook pixel and the use of your data to display Facebook ads. To set which types of advertisements are displayed to you within Facebook, you can visit the page set up by Facebook and follow the instructions there regarding the settings for usage-based advertising: https://www.facebook.com/settings?tab=ads. The settings are done in a platform-independent manner, which means that they are applied to all devices, such as desktop computers or mobile devices.

 

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

Online presence in social media

 

We maintain an online presence within social networks and platforms in order to be able to communicate with customers, interested parties and users active there and to inform them about our services there.

 

We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users’ rights. With regard to U.S. providers that are certified under the Privacy Shield, we point out that they thereby undertake to comply with the data protection standards of the EU.

 

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

 

The processing of the users’ personal data is based on our legitimate interests in effectively informing users and communicating with users pursuant to Art. 6 para. 1 lit. f. DSGVO. If the users are asked by the respective providers of the platforms for consent to the aforementioned data processing, the legal basis of the processing is Art. 6 para. 1 lit. a., Art. 7 DSGVO.

 

For a detailed description of the respective processing and the opt-out options, please refer to the information of the providers linked below.

 

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

 

– Facebook, -pages, -groups, (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) on the basis of an agreement on joint processing of personal data – Privacy Policy: https://www.facebook.com/about/privacy/, specifically for pages: https://www.facebook.com/legal/terms/ , Opt-Out: https://www.facebook.com/settings?tab=ads und http://www.youronlinechoices.com, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.

 

– Google/ YouTube (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) – Privacy Policy: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.

 

– Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – Privacy Policy/ Opt-Out: http://instagram.com/about/legal/privacy/.

 

– Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) – Privacy Policy: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.

 

– Pinterest (Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA) – Privacy Policy/ Opt-Out: https://about.pinterest.com/de/privacy-policy.

 

– LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland) – Privacy Policy https://www.linkedin.com/legal/privacy-policy, Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active.

 

– Xing (XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany) – Privacy Policy/ Opt-Out: https://privacy.xing.com/de/datenschutzerklaerung.

 

– Wakalet (Wakelet Limited, 76 Quay Street, Manchester, M3 4PR, United Kingdom) – Privacy Policy/ Opt-Out: https://wakelet.com/privacy.html.

 

– Soundcloud (SoundCloud Limited, Rheinsberger Str. 76/77, 10115 Berlin, Germany) – Privacy Policy/ Opt-Out: https://soundcloud.com/pages/privacy.

Integration of third-party services and content

 

Within our online offer, we use content or service providers on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. f. DSGVO) to integrate content or services offered by third-party providers, such as videos or fonts (hereinafter uniformly referred to as “Content”).

 

This always requires that the third-party providers of this content perceive the IP address of the user since without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content. We endeavour to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of the visit and other information about the use of our online offer, as well as be linked to such information from other sources.

Vimeo

 

We can embed the videos of the platform “Vimeo” of the provider Vimeo Inc, Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA. Privacy policy: https://vimeo.com/privacy. We point out that Vimeo may use Google Analytics and refer to the privacy policy (https://policies.google.com/privacy) as well as opt-out options for Google Analytics (http://tools.google.com/dlpage/gaoptout?hl=de) or Google’s settings for data used for marketing purposes (https://adssettings.google.com/).

Youtube

 

We integrate the videos of the platform “YouTube” of the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Google Fonts

 

We integrate the fonts (“Google Fonts”) of the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. According to Google, user data is used solely for the purpose of displaying the fonts in the user’s browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform display and consideration of possible licensing restrictions for their integration. Privacy policy: https://www.google.com/policies/privacy/.

Google Maps

 

We integrate the maps of the service “Google Maps” of the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The processed data may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually executed in the context of the settings of their mobile devices). The data may be processed in the USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Use of Facebook social plugins

 

We use on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) social plugins (“plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”).

 

This may include, for example, content such as images, videos or texts and buttons with which users can share the content of this online offer within Facebook. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.

 

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

 

In case a user calls up a function of this online offer that contains such a plugin, his or her device establishes a direct connection with Facebook’s servers. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated by the latter into the online offer. In the process, usage profiles of the users can be created from the processed data. We, therefore, have no influence on the scope of the data that Facebook collects with the help of this plugin and therefore inform users according to our level of knowledge.

 

By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user is logged into Facebook, Facebook can assign the visit to his Facebook account. If users interact with the plugins, for example by clicking the Like button or posting a comment, the corresponding information is transmitted from their device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will learn and store his or her IP address. According to Facebook, only an anonymized IP address is stored in Germany.

 

The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the related rights and settings options for protecting the privacy of users, can be found in Facebook’s privacy policy: https://www.facebook.com/about/privacy/.

 

If a user is a Facebook member and does not want Facebook to collect data about him or her via this online offer and link it to his or her membership data stored with Facebook, he or she must log out of Facebook and delete his or her cookies before using our online offer. Further settings and objections to the use of data for advertising purposes, are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.

Created with Datenschutz-Generator.de von RA Dr. Thomas Schwenke