Status: 21 February 2020
Table of contents
- Overview of the processing operations
- Relevant legal bases
- Security measures
- Transmission and disclosure of personal data
- Data processing in third countries
- Commercial and business services
- Registration and login
- Single Sign-On registration
- Provision of the online offer and web hosting
- Web analysis and optimization
- Presence in social networks
- Plugins and embedded functions and content
- Deletion of data
- Rights of data subjects
- Definitions of terms
Overview of the processing operations
The following overview summarises the types of data processed and the purposes of their processing, and refers to the data subjects.
Types of data processed
- Inventory data (e.g. names, addresses).
- Content data (e.g. text entries, photographs, videos).
- Contact data (e.g. e-mail, telephone numbers).
- Meta/communication data (e.g. device information, IP addresses).
- Usage data (e.g. websites visited, interest in content, access times).
- Contract data (e.g. subject matter of the contract, duration, customer category).
- Payment data (e.g. bank details, invoices, payment history).
Categories of affected persons
- Business and contractual partners.
- Interested parties.
- Users (e.g. website visitors, users of online services).
Purposes of processing
- Provision of our online offer and user-friendliness.
- Visitor action evaluation.
- Office and organisational procedures.
- Contact requests and communication.
- Profiling (creation of user profiles).
- Reach measurement (e.g. access statistics, recognition of returning visitors).
- Security measures.
- Contractual performance and service.
- Management and response to inquiries.
Relevant legal bases
In the following, we provide the legal basis of the basic data protection regulation (DSGVO), on the basis of which we process personal data. Please note that in addition to the regulations of the DSGVO, national data protection regulations may apply in your or our country of residence and domicile. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data protection declaration.
- Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO) - The data subject has given his or her consent to the processing of personal data relating to him or her for one or more specific purposes.
- Fulfilment of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. FADP) - Processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the request of the data subject.
- Legal obligation (Art. 6 para. 1 sentence 1 lit. c. DPA) - The processing is necessary for the performance of a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. FADP) - The processing is necessary to safeguard the legitimate interests of the controller or of a third party, unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data outweigh the data subject's legitimate interests or fundamental rights and freedoms.
National data protection regulations in Germany: In addition to the data protection regulations of the Basic Data Protection Regulation, national regulations on data protection apply in Germany. These include in particular the law on protection against misuse of personal data in data processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to deletion, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision making in individual cases including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.
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, in order to ensure a level of protection commensurate with the risk.
Those measures shall include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, safeguarding of availability and segregation of data relating to them. Furthermore, we have established procedures to ensure that data subjects' rights are exercised, data is deleted and responses to data threats are made. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures in accordance with the principle of data protection, by designing technology and by using data protection-friendly default settings.
Abbreviation of the IP address: If it is possible for us or if it is not necessary to save the IP address, we will shorten or have your IP address shortened. In the case of shortening the IP address, also known as "IP masking", the last octet, i.e. the last two numbers of an IP address, are deleted (in this context, the IP address is an identifier individually assigned to an Internet connection by the online access provider). The purpose of shortening the IP address is to prevent or make it considerably more difficult to identify a person on the basis of their IP address.
SSL encryption (https): To protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.
Transmission and disclosure of personal data
Within the scope of our processing of personal data, it happens that the data is transferred to other bodies, companies, legally independent organisational units or persons or that it is disclosed to them. The recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data which serve to protect your data.
Data processing in third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of services provided by third parties or the disclosure or transfer of data to other persons, bodies or companies, this is only done in accordance with the legal requirements.
Subject to express consent or to contractual or legally required transfers, we process or allow the data to be processed only in third countries with a recognised level of data protection, including the US processors certified under the Privacy Shield, or on the basis of special guarantees, such as contractual obligations under so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).
Commercial and business services
We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as "contractual partners") within the scope of contractual and comparable legal relationships as well as associated measures and within the scope of communication with contractual partners (or pre-contractual), e.g. to answer inquiries.
We process this data for the purpose of fulfilling our contractual obligations, for securing our rights and for the purposes of the administrative tasks associated with this information as well as for business organisation. Within the framework of the applicable law, we only pass on the data of the contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations or with the consent of the contractual partners (e.g. to involved telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.
We will inform the contractual partners which data is required for the above-mentioned purposes before or during the data collection, e.g. in online forms, by special marking (e.g. colours) or symbols (e.g. asterisks or similar), or personally.
We delete the data after expiry of legal warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g., as long as it must be kept for legal archiving reasons (e.g., for tax purposes usually 10 years). We will delete data that has been disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, generally after the end of the order.
If we use third-party providers or platforms to provide our services, the terms and conditions and data protection information of the respective third-party providers or platforms apply in the relationship between the users and the providers.
customer account: Contracting parties can create an account within our online offer (e.g. customer or user account, in short "customer account"). If the registration of a customer account is required, contractual partners are informed of this as well as of the information required for registration. The customer accounts are not public and cannot be indexed by search engines. Within the scope of registration and subsequent logins and use of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove registration and prevent possible misuse of the customer account.
If customers have cancelled their customer account, the data relating to the customer account will be deleted, subject to the retention of such data being required for legal reasons. It is the responsibility of the customers to secure their data upon termination of the customer account.
Project and development services: We process the data of our customers as well as clients (hereinafter uniformly referred to as "customers") in order to enable them to select, acquire or commission the selected services or works as well as related activities, as well as to pay for them and make them available or execute or provide them.
The required information is identified as such in the context of the conclusion of the order, purchase order or comparable contract and includes the information required for the provision of services and invoicing as well as contact information in order to be able to make any necessary arrangements. Insofar as we gain access to information from end customers, employees or other persons, we process this information in accordance with legal and contractual requirements.
Events and functions: We process the data of the participants of the events, functions and similar activities offered or organized by us (hereinafter referred to uniformly as "participants" and "functions") in order to enable them to participate in the functions and use the services or activities associated with participation.
If we process health-related data, religious, political or other special categories of data in this context, then this is done in the context of publicity (e.g. in the case of thematically oriented events or serves the purpose of health care, safety or is done with the consent of the persons concerned).
The required information is marked as such in the context of the conclusion of the order, purchase order or comparable contract and includes the information required for the provision of services and invoicing as well as contact information in order to be able to make any necessary arrangements. Insofar as we gain access to information from end customers, employees or other persons, we process this information in accordance with legal and contractual requirements.
- Types of data processed: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Affected persons: Interested parties, business and contractual partners, customers.
- Purposes of processing: contractual services and performance, contact requests and communication, office and organisational procedures, administration and answering of requests, security measures.
- Legal basis: Fulfilment of contract and pre-contractual enquiries (Art. 6 Paragraph 1 S. 1 lit. b. DSGVO), Legal obligation (Art. 6 Paragraph 1 S. 1 lit. c. DSGVO), Legitimate interests (Art. 6 Paragraph 1 S. 1 lit. f. DSGVO).
Registration and login
Users can create a user account. Within the scope of registration, users are provided with the necessary mandatory data and processed for the purpose of providing the user account on the basis of contractual obligation fulfilment. The processed data includes in particular the login information (name, password and an e-mail address). The data entered during registration is used for the purpose of using the user account and its purpose.
Users can be informed by e-mail about processes relevant to their user account, such as technical changes. If users have cancelled their user account, their data relating to the user account will be deleted, subject to a legal obligation to retain data. It is the users' responsibility to save their data in case of 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 the users in protection against misuse and other unauthorised use. As a matter of principle, this data is not passed on to third parties, unless it is necessary to pursue our claims or there is a legal obligation to do so.
- Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, phone numbers), content data (e.g. text entries, photographs, videos), meta/communication data (e.g. device information, IP addresses).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Contractual services and performance, security measures, administration and answering inquiries.
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Single sign-on registration
Single sign-on" or "single sign-on registration or authentication" refers to procedures that allow users to log on to a provider of single sign-on procedures (e.g. a social network), including our online offering, using a user account. The prerequisite for single sign-on authentication is that users are registered with the respective single sign-on provider and enter the required access data in the online form provided for this purpose, or are already registered with the single sign-on provider and confirm the single sign-on registration via button.
Authentication takes place directly with the respective single sign-on provider. Within the scope of such authentication, we receive a user ID with the information that the user is logged in under this user ID with the respective single sign-on provider and an ID that cannot be used for other purposes (so-called "user handle"). Whether additional data is transmitted to us depends solely on the Single Sign-On procedure used, on the data releases selected during authentication and also on the data that users have released in the privacy or other settings of the user account with the Single Sign-On provider. Depending on the single sign-on provider and the user's choice, different data can be used, usually the e-mail address and the user name. The password entered with the single sign-on provider as part of the single sign-on procedure is neither visible to us nor is it stored by us.
Users are asked to note that the information stored with us can be automatically compared with their user account with the single sign-on provider, but that this is not always possible or actually takes place. If, for example, the users' e-mail addresses change, they must change them manually in their user account with us.
We can use the Single-Sign-On registration, if agreed with the users, within the scope of or prior to the fulfilment of the contract, if the users have been asked to do so, within the scope of a consent and otherwise we use it on the basis of the legitimate interests on our part and the interests of the users in an effective and secure registration system.
Should users ever decide that they no longer wish to use the link of their user account with the Single Sign-On provider for the Single Sign-On procedure, they must cancel this link within their user account with the Single Sign-On provider. If users wish to delete their data from our system, they must cancel their registration with us.
Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
Affected persons: Users (e.g. website visitors, users of online services).
Purposes of processing: contractual services and service, registration procedure.
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Services used and service providers:
Provision of the online offer and web hosting
In order to provide our online services securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online services can be accessed. For these purposes we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security and technical maintenance services.
The data processed within the scope of providing the hosting offer may include all data concerning the users of our online offer, which are generated within the scope of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.
E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of SPAM detection. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.
Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). Server log files may include the address and name of the web pages and files accessed, date and time of access, data volume transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.
The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the capacity utilisation of the servers and their stability.
- Processed data types: Content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Web analysis and optimization
Web analysis (also known as "reach measurement") is used to evaluate the streams of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the range analysis we can, for example, identify at what time our online offer or its functions or contents are most frequently used or invite reuse. We can also understand which areas require optimization.
In addition to web analysis, we can also use test procedures, e.g. to test and optimise different versions of our online offer or its components.
For these purposes, so-called user profiles can be created and stored in a file (so-called "cookie") or similar procedures with the same purpose can be used. This information may include, for example, content viewed, web pages visited and elements used there, and technical information such as the browser used, the computer system used and information on times of use. If users have consented to the collection of their location data, this data may also be processed, depending on the provider.
The IP addresses of users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect the users. In general, the data stored in the context of web analysis, A/B testing and optimization are not clear user data (such as e-mail addresses or names), but pseudonyms. This means that we as well as the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.
- Persons concerned: Users (e.g. website visitors, users of online services).
- Security measures: IP-Masking (pseudonymization of the IP address).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Plugins and embedded functions and content
We include in our online offer functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as "third party providers"). These may be, for example, graphics, videos or social media buttons as well as contributions (hereinafter uniformly referred to as "content").
The integration always requires that the third party providers of such content process the IP address of the users, as without the IP address they would not be able to send the content to their browsers. The IP address is therefore required for the display of these contents or functions. We make every effort to use only such content whose respective providers use the IP address only to deliver the content. Third party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. Pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain technical information about the browser and operating system, websites to be referred to, the time of visit and other details about the use of our online offer, as well as being linked to such information from other sources.
- Processed types of data: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offer and user-friendliness, contractual services and service, security measures, administration and answering of inquiries.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO), consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO)
Services used and service providers:
Deletion of data
The data processed by us will be deleted in accordance with the legal requirements as soon as their consent permitted for processing is revoked or other permissions cease to apply (e.g. if the purpose for processing these data ceases to apply or if they are not necessary for the purpose).
Unless the data are deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose retention is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.
Further information on the deletion of personal data can also be provided in the individual data protection notes of this data protection declaration.
Amendment and updating of the data protection declaration
We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes make it necessary for you to cooperate (e.g. consent) or to receive other individual notification.
Rights of the persons concerned
As data subjects, they are entitled to various rights under the DSGVO, which result in particular from Art. 15 to 18 and 21 DSGVO:
- Right of objection: You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data relating to you which is carried out on the basis of Art. 6 paragraph 1 letter e or f FADP; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing, including profiling, insofar as it is linked to such direct marketing.
- Right to withdraw consent: You have the right to withdraw any consent given at any time.
- Right of access: You have the right to obtain confirmation as to whether data in question is being processed and to obtain information about such data and to obtain further information and copies of the data in accordance with the law.
- Right of rectification: You have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you in accordance with the law.
- Right to erasure and restriction of processing: You have the right to request that data concerning you be erased immediately or, alternatively, to request a restriction of processing of the data in accordance with the law.
- Right to data transferability: You have the right to receive data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transferred to another responsible party.
- Complaints to the supervisory authority: You also have the right, in accordance with the statutory provisions, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you believe that the processing of personal data relating to you is in breach of the DPA.
Definitions of terms
- Conversion tracking: Conversion tracking is a procedure that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user's devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, we can use this to track whether the ads we have placed on other websites have been successful).
- IP-Masking: "IP-Masking" is a method in which the last octet, i.e. the last two numbers of an IP address, are deleted so that the IP address can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymising processing procedures, especially in online marketing
- Personal data: 'personal data' shall mean 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 on-line identifier (e.g. a cookie) or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Profiling: "profiling" means any automated processing of personal data consisting of the use of personal data to analyse, evaluate or predict certain personal aspects relating to an individual (depending on the type of profiling, this may include information concerning age, gender, location and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people). 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 behaviour or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, identify at what time visitors visit their website and what content they are interested in. This enables them to better adapt the contents of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis purposes in order to recognise returning visitors and thus obtain more precise analyses of the use of an online offering.
- Remarketing: One speaks of "remarketing" or "retargeting", e.g. when it is noted for advertising purposes in which products a user was interested on a website in order to remind the user of these products on other websites, e.g. in advertisements.
- Tracking: One speaks of "tracking" if the behaviour of users can be traced across several online offers. As a rule, behavioral and interest information regarding the online offers used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
- Controller: The term "Controller" refers to the natural or legal person, authority, institution or other body which alone or jointly with others determines the purposes and means of processing personal data.
- Processing: "processing" shall mean any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually all processing of data, whether it be collection, analysis, storage, communication or deletion.