privacy policy
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. This 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, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offering").
The terms used are not gender-specific.
As of November 24, 2022
table of contents
- Introduction
- responsible person
- Overview of processing
- Relevant legal bases
- security measures
- transmission of personal data
- data processing in third countries
- deletion of data
- use of cookies
- Business Services
- payment methods
- provision of the online offer and web hosting
- contact and inquiry management
- newsletters and electronic notifications
- web analysis, monitoring and optimization
- online marketing
- Plugins and embedded functions and content
- Change and update of the privacy policy
- rights of the data subjects
- definitions of terms
responsible person
Tolga Kutlu
Truckpoint Autoservice Inh. Tolga Kutlu
Maybachstraße 15-17
51381 Leverkusen
Email address: hallo@ gearshop24.de
Imprint: https:// gearshop24.de/imprint
Overview of processing
The following overview summarises the types of data processed and the purposes of their processing and refers to the persons concerned.
types of data processed
- inventory data.
- payment details.
- contact details.
- content data.
- contract data.
- usage data.
- Meta/communication data.
categories of data subjects
- Customers.
- interested parties.
- communication partner.
- users.
- business and contractual partners.
purposes of processing
- Provision of contractual services and customer service.
- contact requests and communication.
- security measures.
- direct marketing.
- reach measurement.
- tracking.
- office and organizational procedures.
- conversion measurement.
- Managing and responding to inquiries.
- feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online offering and user-friendliness.
- Information technology infrastructure.
Relevant legal bases
Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.
- Consent (Article 6, Paragraph 1, Sentence 1, Letter a) of GDPR) – The data subject has given consent to the processing of personal data concerning him or her for a specific purpose or for several specific purposes.
- Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Legal obligation (Article 6 (1) sentence 1 lit. c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR) – Processing is necessary to protect the legitimate interests of the controller or of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. This includes in particular the law on protection against misuse of personal data in data processing (Federal Data Protection Act - BDSG). The BDSG contains in particular special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission and automated decision-making in individual cases, including profiling. It also regulates data processing for the purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. In addition, state data protection laws of the individual federal states may apply.
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 different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, to ensure a level of protection appropriate to the risk.
The measures 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, transfer, securing availability and separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to threats to data. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
TLS encryption (https): We use TLS encryption to protect the data you transmit via our online service. You can recognize encrypted connections of this type by the prefix https:// in the address bar of your browser.
transmission of personal data
As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons or that it is disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and in particular conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.
data processing in third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or 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 be done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transmission, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, 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 ).
deletion of data
The data we process is deleted in accordance with legal requirements as soon as the consents to processing are revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or it is no longer required for the purpose). If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted 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 retained for commercial or tax law reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.
Our data protection notices may also contain further information on the storage and deletion of data, which apply primarily to the respective processing operations.
use of cookies
Cookies are small text files or other storage notes that store information on end devices and read information from the end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed or the functions used in an online service. Cookies can also be used for different purposes, e.g. to ensure the functionality, security and convenience of online services and to create analyses of visitor flows.
Notes on consent: We use cookies in accordance with legal regulations. We therefore obtain prior consent from users, unless this is not required by law. Consent is not necessary in particular if the storage and reading of information, including cookies, is absolutely necessary in order to provide users with a telemedia service that they have expressly requested (i.e. our online offering). The revocable consent is clearly communicated to users and contains information on the respective cookie usage.
Notes on data protection legal bases: The legal basis under data protection law on which we process users' personal data using cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and improving its usability) or, if this is done as part of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We will explain the purposes for which we process cookies in the course of this data protection declaration or as part of our consent and processing processes.
Storage period: With regard to the storage period, the following types of cookies are distinguished:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed his or her device (e.g. browser or mobile application).
- Persistent cookies: Permanent cookies remain stored even after the device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The user data collected using cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.
General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also object to the processing in accordance with the legal requirements in Art. 21 GDPR. Users can also declare their objection via the settings of their browser, e.g. by deactivating the use of cookies (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be made via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ be explained.
Further information on processing procedures, methods and services:
- Processing of cookie data based on consent: We use a cookie consent management process within which users' consent to the use of cookies or the processing and providers named in the cookie consent management process can be obtained and managed and revoked by users. The declaration of consent is saved so that it does not have to be requested again and consent can be proven in accordance with the legal obligation. Storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies) in order to be able to assign consent to a user or their device. Subject to individual information about the providers of cookie management services, the following information applies: The consent can be stored for up to two years. A pseudonymous user identifier is created and saved with the time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) and the browser, system and device used.
- BorlabsCookie: Cookie consent management; Service provider: Hosted locally on our server, no data transfer to third parties; Website: https://de.borlabs.io/borlabs-cookie/ ; Further information: An individual user ID, language, types of consent and the time of their submission are stored on the server side and in the cookie on the user's device.
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 as well as related measures and within the framework of communication with the contractual partners (or pre-contractually), e.g. to answer inquiries.
We process this data in order to fulfil our contractual obligations. This includes in particular the obligations to provide the agreed services, any updating obligations and remedy in the event of warranty and other service disruptions. In addition, we process the data to protect our rights and for the purposes of the administrative tasks associated with these obligations and the company organization. In addition, we process the data on the basis of our legitimate interests in proper and economical business management and in security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. The contractual partners are informed about other forms of processing, e.g. for marketing purposes, in the context of this data protection declaration.
We inform our contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by special marking (e.g. colours) or symbols (e.g. asterisks or similar), or in person.
We delete the data after statutory warranty and similar obligations have expired, i.e., generally after 4 years, unless the data is saved in a customer account, e.g. as long as it must be kept for legal archiving reasons. The statutory retention period is ten years for documents relevant for tax purposes as well as for commercial books, inventories, opening balance sheets, annual financial statements, the work instructions required to understand these documents and other organizational documents and accounting documents, and six years for received commercial and business letters and reproductions of sent commercial and business letters. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, opening balance sheet, annual financial statements or management report was drawn up, the commercial or business letter was received or sent, or the accounting document was created, the recording was made or the other documents were created.
To the extent that we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply to the relationship between the users and the providers.
- Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. email, telephone numbers); contract data (e.g. subject of the contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
- Affected persons: Customers; prospective customers; business and contractual partners.
- Purposes of processing: Provision of contractual services and customer service; security measures; contact requests and communications; office and organizational procedures; administration and response to inquiries.
- Legal basis: Contract performance and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR); Legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
- customer account: Contractual partners can create an account within our online offering (e.g. customer or user account, in short "customer account"). If the registration of a customer account is necessary, contractual partners will be informed of this as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. As part of the registration and subsequent logins and use of the customer account, we save the customers' IP addresses along with the access times in order to be able to prove registration and prevent any misuse of the customer account.If customers have canceled their customer account, the data relating to the customer account will be deleted, unless their retention is required for legal reasons. It is the responsibility of the customer to back up their data when the customer account is canceled; Legal basis: Contract performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR).
- Shop and e-commerce: We process our customers' data to enable them to select, purchase or order the selected products, goods and associated services, as well as to pay for and deliver or execute them. If necessary to execute an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution for our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such in 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 consultations; Legal basis: Contract performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR).
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Craftsmanship: We process the data of our customers and clients (hereinafter referred to as “customers”) in order to enable them to select, purchase or commission the selected services or works and related activities as well as to pay for and deliver or execute or provide them.
The required information is marked as such in the context of the order, purchase order or similar contract conclusion and includes the information required for delivery and invoicing as well as contact information in order to be able to hold any further consultations; Legal basis: Contract performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR).
payment methods
Within the framework 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, in addition to banks and credit institutions, use other service providers for this purpose (collectively "payment service providers").
The data processed by the payment service providers includes inventory data such as name and address, bank details such as account numbers or credit card numbers, passwords, TANs and checksums as well as contract, sum and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, only information confirming or rejecting the payment. The payment service providers may transmit the data to credit agencies. This transmission is for the purpose of checking 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 data protection notices of the respective payment service providers apply to payment transactions and can be accessed on the respective websites or transaction applications. We also refer to these for further information and to assert revocation, information and other rights of those affected.
- 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); contact data (e.g. e-mail, telephone numbers).
- Affected persons: customers; interested parties.
- Purposes of processing: Provision of contractual services and customer service.
- Legal basis: Contract performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR).
Further information on processing procedures, methods and services:
- Apple Pay: Payment services (technical connection of online payment methods); Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal basis: Contract performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR); Website: https://www.apple.com/de/apple-pay/ ; Privacy Policy: https://www.apple.com/legal/privacy/de-ww/ .
- Google Pay: Payment services (technical connection of online payment methods); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Contract performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR); Website: https://pay.google.com/intl/de_de/about/ ; Privacy Policy: https://policies.google.com/privacy .
- Klarna / Sofortüberweisung: Payment services (technical connection of online payment methods); Service provider: Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden; Legal basis: Contract performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR); Website: https://www.klarna.com/de ; Privacy Policy: https://www.klarna.com/de/datenschutz .
- Mastercard: Payment services (technical connection of online payment methods); Service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; Legal basis: Contract performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR); Website: https://www.mastercard.de/de-de.html ; Privacy Policy: https://www.mastercard.de/de-de/datenschutz.html .
- PayPal: Payment services (technical connection of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à rl et Cie, SCA, 22-24 Boulevard Royal, L-2449 Luxembourg; Legal basis: Contract performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR); Website: https://www.paypal.com/de ; Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full .
- Stripe: Payment services (technical connection of online payment methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal basis: Contract performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR); Website: https://stripe.com ; Privacy Policy: https://stripe.com/de/privacy .
- Visa: Payment services (technical connection of online payment methods); Service provider: Visa Europe Services Inc., London Branch, 1 Sheldon Square, London W2 6TT, GB; Legal basis: Contract performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR); Website: https://www.visa.de ; Privacy Policy: https://www.visa.de/USE Conditions/ visa-privacy-center.html .
provision of the online offer and web hosting
We process user data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or device.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses); content data (e.g. entries in online forms).
- Affected persons: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); security measures; provision of contractual services and customer service.
- Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
- Provision of online offering on rented storage space: To provide our online service, we use storage space, computing capacity and software that we rent from a corresponding server provider (also called “web host”) or obtain from another source; Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
- Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files". The server log files can include the address and name of the web pages and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (particularly 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; Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR); Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that needs to be retained for evidentiary purposes is exempt from deletion until the respective incident has been finally resolved.
- Email sending and hosting: The web hosting services we use also include the sending, receiving and storing of emails. For these purposes, the addresses of the recipients and senders as well as other information regarding the email sending (e.g. the providers involved) and the contents of the respective emails are processed. The aforementioned data may also be processed for the purposes of detecting SPAM. Please note that emails are generally not sent encrypted on the Internet. Emails are usually encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We cannot therefore accept any responsibility for the transmission path of emails between the sender and the recipient on our server; Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
- 1&1 IONOS: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany; Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR); Website: https://www.ionos.de ; Privacy Policy: https://www.ionos.de/terms-gtc/terms-privacy ; Data processing agreement: https://www.ionos.de/hilfe/datenschutz/generale-information-zur-datenschutz-grundverfassung-dsgvo/vertragsprocessing/?utm_source=search&utm_medium=global&utm_term=Auft&utm_campaign=HELP_CENTER&utm_content=/hilfe/ .
contact and inquiry management
When you contact us (e.g. via contact form, e-mail, telephone or via social media) and within the framework of existing user and business relationships, the information provided by the inquiring persons is processed to the extent necessary to answer the contact inquiries and any requested measures.
- Types of data processed: Contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
- Affected persons: communication partner.
- Purposes of processing: Contact requests and communication; administration and response to inquiries; feedback (e.g. collecting feedback via online form); provision of our online offering and user-friendliness.
- Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR); Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).
Further information on processing procedures, methods and services:
- Contact form: If users contact us via our contact form, email or other communication channels, we process the data communicated to us in this context to process the communicated request; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
newsletters and electronic notifications
We only send newsletters, emails and other electronic notifications (hereinafter "newsletters") with the consent of the recipient or with legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user's consent. Otherwise, our newsletters contain information about our services and us.
To subscribe to our newsletter, it is generally sufficient to provide your email address. However, we may ask you to provide a name for the purpose of addressing you personally in the newsletter or other information if this is necessary for the purposes of the newsletter.
Double opt-in procedure: Registration for our newsletter is always carried out using a so-called double opt-in process. This means that after registration you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register using someone else's email address. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider are also logged.
Deletion and restriction of processing: We can store the unsubscribed email addresses for up to three years based on our legitimate interests before we delete them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address in a block list (so-called "block list") for this purpose alone.
The registration process is logged on the basis of our legitimate interests for the purpose of proving that it was carried out correctly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure shipping system.
Contents:
Information about us, our services, promotions and offers.
- Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers); meta/communication data (e.g. device information, IP addresses); usage data (e.g. websites visited, interest in content, access times).
- Affected persons: communication partner.
- Purposes of processing: Direct marketing (e.g. by email or post).
- Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR).
- Opt-out option: You can cancel your subscription to our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email.
Further information on processing procedures, methods and services:
- Measuring open and click rates: 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 shipping 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, is initially collected. This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and ; Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR).
web analysis, monitoring and optimization
Web analysis (also known as "reach measurement") is used to evaluate the flow of visitors to our online offering and can include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at what time our online offering or its functions or content are most frequently used or invite reuse. We can also understand which areas require optimization.
In addition to web analysis, we can also use testing procedures to test and optimize, for example, different versions of our online offering or its components.
Unless otherwise stated below, profiles, i.e. data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in a device and read from it. The information collected includes in particular websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to us or the providers of the services we use collecting their location data, location data can also be processed.
The IP addresses of the users are also stored. However, we use an IP masking process (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored as part of web analysis, A/B testing and optimization, but rather pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
- Affected persons: Users (e.g. website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles).
- Safety measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR).
Further information on processing procedures, methods and services:
- Google Analytics 4: We use Google Analytics to perform user analysis based on a pseudonymous user identification number. This identification number does not contain any unique data such as names or email addresses. It is used to assign analysis information to a device in order to recognize which content users have accessed within one or more usage processes, which search terms they have used, accessed them again or interacted with our online offering. The time of use and its duration are also stored, as well as the sources of users who refer to our online offering and technical aspects of their devices and browsers. Pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used. Analytics provides higher-level geographic location data by collecting the following metadata based on the IP search: "City" (and the derived latitude and longitude of the city), "Continent", "Country", "Region", "Subcontinent" (and the ID-based equivalents). To ensure the protection of user data in the EU, Google receives and processes all user data via domains and servers within the EU. The IP address of users is not logged and is shortened by default by the last two digits. The shortening of the IP address takes place on EU servers for EU users. In addition, all sensitive data collected from users in the EU is deleted before it is collected via EU domains and servers; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/ ; Privacy Policy: https://policies.google.com/privacy ; Data processing agreement: https://business.safety.google/adsprocessorterms/ ; Standard contractual clauses (ensuring data protection level when processing in third countries): https://business.safety.google/adsprocessorterms ; Opt-out option: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de , Settings for the display of advertisements: https://adssettings.google.com/authenticated ; Further information: https://privacy.google.com/businesses/adsservices (Types of processing and data processed).
online marketing
We process personal data for the purposes of online marketing, 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 the potential interests of users and the measurement of their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar procedures are used by means of which the information about the user relevant to 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 as well as information on usage times and functions used. If users have consented to the collection of their location data, this can also be processed.
The IP addresses of the users are also stored. However, we use available IP masking procedures (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored as part of the online marketing process, but rather pseudonyms. This means that neither we nor the providers of the online marketing process know the actual identity of the users, only the information stored in their profiles.
The information in the profiles is usually stored in cookies or using similar processes. These cookies can generally also be read later on other websites that use the same online marketing process and analyzed for the purposes of displaying content, as well as supplemented with further data and stored on the server of the online marketing process provider.
In exceptional cases, clear data can be assigned to profiles. This is the case if, for example, the users are members of a social network whose online marketing processes we use and the network links the users' profiles with the aforementioned information. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.
In principle, we only receive access to summarized information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, ie, for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyze the success of our marketing measures.
Unless otherwise stated, please assume that cookies used will be stored for a period of two years.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
- Affected persons: Users (e.g. website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest/behavior-related profiling, use of cookies); marketing; profiles with user-related information (creation of user profiles); conversion measurement (measurement of the effectiveness of marketing measures).
- Safety measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR).
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Opt-out option: 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, you can deactivate cookies in your browser settings. However, this may restrict functions of our online offer. We therefore also recommend the following opt-out options, which are offered in summary for the respective regions: a) Europe: https://www.youronlinechoices.eu .
b) Canada: https://www.youradchoices.ca/choices .
c) USA: https://www.aboutads.info/choices .
d) Cross-regional: https://optout.aboutads.info .
Further information on processing procedures, methods and services:
- Google Ads and conversion measurement: We use the online marketing process "Google Ads" to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are shown to users who are likely to be interested in the ads (so-called "conversion"). We also measure the conversion of the ads. However, we only learn 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 that can be used to identify users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com ; Privacy Policy: https://policies.google.com/privacy ; Further information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices ; Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms .
Plugins and embedded functions and content
We incorporate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may include, for example, graphics, videos or city maps (hereinafter referred to uniformly as "content").
The integration always requires that the third-party providers of this content process the IP address of the user, since without the IP address they would not be able to send the content to their browser. The IP address is therefore required to display this content or functions. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers can also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user's device and can contain, among other things, technical information about the browser and operating system, referring websites, the time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses); inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms).
- Affected persons: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offering and user-friendliness.
- Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
- YouTube videos: video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR); Website: https://www.youtube.com ; Privacy Policy: https://policies.google.com/privacy ; Opt-out option: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de , Settings for the display of advertisements: https://adssettings.google.com/authenticated .
Change and update of the privacy policy
We ask you to regularly inform yourself about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting us.
rights of the data subjects
As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:
- Right to object: You have the right to object at any time to the processing of personal data concerning you which is carried out on the basis of Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you are processed in order to conduct direct advertising, you have the right to object at any time to the processing of personal data concerning you for the purposes 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 to information: You have the right to request confirmation as to whether or not data concerning you is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with legal requirements.
- Right to rectification: In accordance with the statutory provisions, you have the right to request that the data concerning you be completed or that inaccurate data concerning you be corrected.
- Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to request that data concerning you be deleted immediately or, alternatively, to request that the processing of the data be restricted in accordance with the statutory provisions.
- Right to data portability: You have the right to receive the data concerning you that you have made available to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transmitted to another controller.
- Complaint to the supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the provisions of the GDPR.
definitions of terms
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 are defined primarily in Art. 4 GDPR. The legal definitions are binding. The following explanations, however, are primarily intended to help you understand. The terms are sorted alphabetically.
- Conversion measurement: Conversion measurement (also known as "visit action evaluation") is a process that can be used to determine the effectiveness of marketing measures. This usually involves storing a cookie on the user's device within the websites on which the marketing measures take place and then retrieving it on the target website. For example, this allows us to see whether the ads we have placed on other websites were 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. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any type of automated processing of personal data consisting of the use of this personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information relating to demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
- reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, such as the 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 enables 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 precise analyses of the use of an online offering.
- Tracking: “Tracking” is when the behavior of users can be tracked across multiple online offerings. As a rule, behavior and interest information relating to the online offerings used is stored in cookies or on servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to show users advertisements that are likely to correspond to their interests.
- Responsible: The “controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of the processing of personal data.
- Processing: "Processing" is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically any handling of data, be it collection, evaluation, storage, transmission or deletion.
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