Disclaimer: The following template was created by a lawyer (Dr. jur. Schwenke, LL.M. commercial (UoA), Certified Data Protection Auditor (DSA-TÜV), Certified Data Protection Officer (TÜV Süd)) in accordance with the typical requirements of an online shop. However, you should only use the template after careful review and adaptation to your specific business model. The following template therefore contains additional notes that you must observe and red passages that you must check particularly carefully and adapt if necessary. Please remove the notes after editing. If in doubt, seek legal advice. Copyright: You may use the template within the domain/website for as long as your Marketpress license applies to it. Passing it on to third parties, including customers (e.g., as a developer), is not permitted.

Privacy Policy

Introduction

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

The terms used are not gender-specific.

Status: XX.XX.20XX

Please indicate the status of the privacy policy.

Controller

First Name, Last Name / Company
Street, House No.
ZIP Code, City
Country

Email Address: Your email address

Phone: Your phone number (optional)

Legal Notice: URL of your legal notice (optional, but recommended)

Notes: For sole proprietors, please use the designation “Owner” and not “Managing Director”.

Contact Data Protection Officer

First Name, Last Name / Company
Street, House No.
ZIP Code, City
Country

Note: Only the email address is mandatory; other details are optional. Data protection officers only need to be specified if they have been appointed. According to § 38 BDSG-new, an appointment is necessary for 20 or more employees who process personal data (for which an email inbox is practically sufficient).

Overview of Processing

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

Note: The following information includes the typical data processed and categories of data subjects (these themselves as well as the explanations in brackets are for clarification only and can be adapted or deleted).

Types of Data Processed

Inventory data (e.g., names, addresses).
Content data (e.g., entries in online forms).
Contact data (e.g., email, phone numbers).
Meta/communication data (e.g., device information, IP addresses).
Usage data (e.g., visited websites, interest in content, access times).
Location data (information on the geographical position of a device or a person).
Contract data (e.g., subject matter of the contract, term, customer category).
Payment data (e.g., bank details, invoices, payment history).

Categories of Data Subjects

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

Purposes of Processing

Assessment of creditworthiness and credit standing.
Provision of our online offer and user-friendliness.
Evaluation of visit actions.
Office and organizational procedures.
Cross-device tracking (cross-device processing of user data for marketing purposes).
Direct marketing (e.g., by email or post).
Interest-based and behavioral marketing.
Contact requests and communication.
Conversion measurement (measuring the effectiveness of marketing measures).
Profiling (creation of user profiles).
Remarketing.
Reach measurement (e.g., access statistics, recognition of returning visitors).
Security measures.
Tracking (e.g., interest/behavioral profiling, use of cookies).
Provision of contractual services and customer service.
Management and answering of inquiries.
Target group formation (determination of target groups relevant for marketing purposes or other output of content).

Automated decisions in individual cases

Credit report (decision based on a credit assessment).

Relevant Legal Bases

In the following, we communicate the legal bases of the General Data Protection Regulation (GDPR) on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection requirements in your or our country of residence and seat may apply. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.

Consent (Art. 6 (1) (a) GDPR) – The data subject has given consent to the processing of their personal data for one or more specific purposes.
Performance of a contract and pre-contractual inquiries (Art. 6 (1) (b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Legal obligation (Art. 6 (1) (c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
Legitimate interests (Art. 6 (1) (f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by 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.

Security Measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, to ensure a level of security 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, entry, disclosure, ensuring availability, and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and reactions to data threats. 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 design and by default.

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 bar of your browser.

Note: Remove the reference to encryption if your offer is not encrypted. However, delivering the website via https is to be regarded as a duty.

Transfer and Disclosure of Personal Data

In the context of our processing of personal data, it happens that the data is transferred to other bodies, companies, legally independent organizational units, or persons or disclosed to them. 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 integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements that serve to protect your data with the recipients of 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 using third-party services or the disclosure or transfer of data to other persons, bodies, or companies, this only takes place in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we process or have the data processed only in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding corporate rules (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_en).

In the context of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the level of data protection for certain companies from the USA as secure within the framework of the adequacy decision of July 10, 2023. The list of certified companies as well as further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/. We inform you within the framework of the data protection notices which service providers used by us are certified under the Data Privacy Framework.

Use of Cookies

Cookies are small text files or other storage notices that store information on end devices and read information from end devices. For example, to store the login status in a user account, shopping cart content in an e-shop, the content accessed, or functions used in an online offer. Cookies can also be used for various purposes, e.g., for the functionality, security, and convenience of online offers as well as for creating analyses of visitor flows.

Notes on consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, unless this is not legally required. Consent is particularly not necessary if the storage and reading of information, including cookies, is strictly necessary to provide the users with a telemedia service expressly requested by them (i.e., our online offer). The revocable consent is clearly communicated to the users and contains information on the respective cookie use.

Notes on legal bases under data protection law: The legal basis under data protection law on which we process the personal data of users with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing your data is the declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g., in the commercial operation of our online offer and improvement of its usability) or, if this takes place in the context of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We clarify the purposes for which the cookies are processed by us in the course of this privacy policy or within the framework of our consent and processing processes.

Storage duration: With regard to the storage duration, 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 offer and closed their end device (e.g., browser or mobile application).
Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be stored or preferred content can be displayed directly when the user visits a website again. Likewise, the user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information on the type and storage duration of cookies (e.g., in the context of obtaining consent), users should assume that cookies are permanent and the storage duration can be up to two years.

General notes on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke consent given or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can first declare your objection using the settings of your browser, e.g., by deactivating the use of cookies (although this may also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared using a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further objection notices within the framework of the information on the service providers and cookies used.

Processing of cookie data on the basis of consent: We use a cookie consent management procedure, within the framework of which the users’ consent to the use of cookies, or the processing and providers mentioned within the framework of the cookie consent management procedure, can be obtained and managed and revoked by the users. In this process, the declaration of consent is stored so as not to have to repeat the query and to be able to prove the consent in accordance with the legal obligation. The 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 the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following notes apply: The duration of the storage of consent can be up to two years. In this process, a pseudonymous user identifier is formed and stored with the time of consent, information on the scope of the consent (e.g., which categories of cookies and/or service providers) as well as the browser, system, and end device used.

Cookie Settings / Objection Option:

If you use a cookie consent banner (which is recommended), you can enter the option to call it up here (e.g., link or a so-called [shortcode] that is automatically converted into a button/link by your software).

Notes on the processing of cookie data on the basis of consent: You should only leave this option (and otherwise delete it) if you obtain a “real” opt-in, i.e., consent from users for the use of cookies (e.g., with so-called “cookie consent/opt-in banners” or in the context of a registration process).

Since a cookie opt-in is generally necessary according to the ECJ when using marketing tools frequently used in e-commerce (e.g., Google Analytics or Facebook Pixel), this option is preselected.

This means that until users have given their consent, you do not use any cookies (and do not use any third-party services within your websites that themselves use cookies). At most, the use of necessary cookies expected by users is permissible, such as a shopping cart function in the online shop or local reach measurement with the Matomo tool.

Commercial and Business Services

We process data of our contractual and business partners, e.g., customers and interested parties (collectively referred to as “contractual partners”) within the framework of contractual and comparable legal relationships 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 to fulfill our contractual obligations, to secure our rights, and for the purposes of the administrative tasks associated with this information as well as the entrepreneurial organization. We only pass on the data of the contractual partners to third parties within the framework of applicable law to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations or takes place with the consent of the data subjects (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). Contractual partners will be informed about further forms of processing, e.g., for marketing purposes, within the framework of this privacy policy.

We inform the 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., colors) or symbols (e.g., asterisks or similar), or personally.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e., generally after 4 years, unless the data is stored in a customer account, e.g., as long as it must be kept for legal reasons of archiving (e.g., for tax purposes usually 10 years). If a period does not explicitly start on a specific date and is at least one year, it starts automatically at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships within the framework of which data is stored, the event triggering the period is the time the termination or other end of the legal relationship becomes effective. Data disclosed to us by the contractual partner within the framework of an order will be deleted in accordance with the specifications of the order, generally after the end of the order.

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

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

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

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

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

Shop and E-Commerce: We process our customers’ data to enable them to select, purchase, or order the chosen products, goods, and related services, as well as their payment and delivery or execution. Insofar as necessary for the execution of an order, we use service providers, in particular postal, forwarding, and shipping companies, to carry out the delivery or execution for our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is marked as such in the context of the ordering or comparable acquisition process and includes the information required for delivery or provision and billing as well as contact information to be able to consult if necessary.

Processed data types: Inventory data (e.g., names, addresses), payment data (e.g., bank details, invoices, payment history), contact data (e.g., email, phone numbers), contract data (e.g., subject matter of the contract, term, customer category), usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
Data subjects: Interested parties, business and contractual partners, customers.
Purposes of processing: Provision of contractual services and customer service, contact requests and communication, office and organizational procedures, management and answering of inquiries, security measures, evaluation of visit actions, interest-based and behavioral marketing, profiling (creation of user profiles).
Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

Note: Please remove the passage on the customer account or analysis of customer data if you do not offer a customer account or do not analyze your customers’ data as described.

Payment Service Providers

Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other payment service providers in addition to banks and credit institutions for this purpose (collectively “payment service providers”).

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

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

Processed data types: 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., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
Data subjects: Customers, interested parties.
Purposes of processing: Provision of contractual services and customer service.
Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

Services and service providers used:

PayPal: Payment services and solutions (e.g., PayPal, PayPal Plus, Braintree); service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; website: https://www.paypal.com/en; privacy policy: https://www.paypal.com/en/legalhub/paypal/privacy-full.

Otherwise, adapt the list of services and providers as needed.

Credit Assessment

Insofar as we make advance payments or enter into comparable economic risks (e.g., when ordering on account), we reserve the right to obtain identity and credit information for the purpose of assessing the credit risk on the basis of mathematical-statistical procedures from specialized service companies (credit agencies) in order to safeguard legitimate interests.

We process the information received from the credit agencies about the statistical probability of a payment default within the framework of an appropriate discretionary decision on the establishment, implementation, and termination of the contractual relationship. We reserve the right to refuse payment on account or another advance payment in the event of a negative result of the credit assessment.

The decision as to whether we make an advance payment is made in accordance with Art. 22 GDPR solely on the basis of an automated decision in an individual case, which our software makes on the basis of the information from the credit agency.

Insofar as we obtain express consent from contractual partners, the legal basis for the credit report and the transmission of the customer’s data to the credit agencies is the consent. If no consent is obtained, the credit report is based on our legitimate interests in the security of our payment claims.

Processed data types: Inventory data (e.g., names, addresses), payment data (e.g., bank details, invoices, payment history), contact data (e.g., email, phone numbers), contract data (e.g., subject matter of the contract, term, customer category).
Data subjects: Customers, interested parties.
Purposes of processing: Assessment of creditworthiness and credit standing.
Legal bases: Consent (Art. 6 (1) (a) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
Automated decisions in individual cases: Credit report (decision based on a credit assessment).

Services and service providers used:

Verband der Vereine Creditreform e.V.: Credit agency; service provider: Verband der Vereine Creditreform e.V., Hammfelddamm 13, D-41460 Neuss, Germany; website: https://www.creditreform.de/en; privacy policy: https://www.creditreform.de/datenschutz.

Note: Remove the passage on credit assessment if you do not carry out a credit assessment. Check and change the list of service providers if necessary. Checking a customer’s creditworthiness is permissible if there is otherwise a risk of payment default, i.e., if the goods are delivered without payment having been received (i.e., if the customer chooses purchase on account). On the other hand, there is no risk of payment default if the customer chooses the prepayment option, for example, or carries out the payment via third-party providers such as PayPal.

It should also be noted that obtaining an automatic credit report constitutes an “automated decision in an individual case” according to Art. 22 GDPR, i.e., a legal decision without human intervention. This is permissible if the customer has consented or if this decision is necessary for the conclusion of the contract. Whether the decision is necessary has not yet been conclusively clarified, but is often represented as given, also by the author of this template.

However, if you want to exclude any risk, you should obtain consent. Consent also becomes necessary if the credit report is already used to decide whether the “on account” option should be displayed at all. For it could have been that the customer would have opted for prepayment or PayPal anyway and the credit assessment would not have been necessary. Such consent could, for example, read as follows:

 I agree that a credit check will be carried out in order to decide in an automated procedure (Art. 22 GDPR) whether the option of purchase on account is offered. Further information on the credit check, the credit agencies used, and the procedure as well as the objection options can be found in our [Link]privacy policy[/Link].

Provision of the Online Offer and Web Hosting

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

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

Email sending and hosting: The web hosting services used by us also include the sending, receiving, and storage of emails. For these purposes, the addresses of the recipients and senders as well as further information regarding the email sending (e.g., the providers involved) and the contents of the respective emails are processed. The aforementioned data can also be processed for the purpose of detecting SPAM. We ask you to note that emails on the internet are generally not sent encrypted. As a rule, emails are encrypted during transport, but (unless a so-called end-to-end encryption procedure is used) not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of the emails between the sender and the receipt on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files can include the address and name of the accessed websites and files, 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) and, as a rule, IP addresses and the requesting provider.

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

Processed data types: Content data (e.g., entries in online forms), usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
Data subjects: Users (e.g., website visitors, users of online services).
Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).

Note: If not already done: Please ask the respective web hosters for a so-called “Data Processing Agreement”. This is legally required because the hoster collects personal data of website visitors for you.

Contacting Us

When contacting us (e.g., via contact form, email, telephone, or via social media), the information of the inquiring persons is processed insofar as this is necessary to answer the contact inquiries and any requested measures.

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

Types of data processed: Inventory data (e.g., names, addresses), 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).
Data subjects: Communication partners, prospects.
Purposes of processing: Contact requests and communication, administration and response to inquiries.
Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6(1)(1)(b) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).

Services and service providers used:

Contact form: When users contact us via our contact form, email, or other communication channels, we process the data provided to us in this context to handle the communicated request. For this purpose, we process personal data in the context of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfillment, and otherwise on the basis of our legitimate interests as well as the interests of communication partners in responding to requests and our legal retention obligations.
Help Scout: Management of contact requests and communication; Service provider: Help Scout PBC, 100 City Hall Square Suite 510 USA; Website: https://www.helpscout.com; Privacy policy: https://www.helpscout.com/company/legal/privacy/; Basis for third-country transfer: Standard Contractual Clauses (https://www.helpscout.com/company/legal/dpa/); Data processing agreement: https://www.helpscout.com/company/legal/dpa/.

Note: If third-party CRM systems are used, their providers should be named. Adjust this information or remove the specified service provider. Furthermore, data processing agreements (or “Data Processing Agreements”) must be concluded with the providers. If the providers process user data in third countries, special guarantees must be in place (e.g., Standard Contractual Clauses).

Newsletters and electronic notifications

We send newsletters, emails, and other electronic notifications (hereinafter “newsletters”) only with the consent of recipients or with legal permission. If the content of a newsletter is specifically described during registration, it is decisive for the users’ consent. Otherwise, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to provide your email address. However, we may ask you to provide a name for personal address in the newsletter, or other information if required for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter generally takes place using a so-called double opt-in procedure. This means you will receive an email after registration asking you to confirm your registration. This confirmation is necessary to prevent anyone from registering with someone else’s email address. Newsletter registrations are logged to demonstrate the registration process in accordance with legal requirements. This includes storing the registration and confirmation times as well as the IP address. Changes to your data stored with the dispatch service provider are also logged.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them, in order to demonstrate previously given consent. The processing of this data is limited to the purpose of possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed. In the case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a blocklist (so-called “blacklist”).

The logging of the registration procedure is based on our legitimate interests for the purpose of demonstrating its proper execution. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system.

Notes on legal bases: Newsletters are sent on the basis of recipients’ consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent this is legally permitted, e.g., in the case of existing customer advertising. If we commission a service provider to send emails, this is done on the basis of our legitimate interests. The registration procedure is recorded on the basis of our legitimate interests to demonstrate that it was carried out in accordance with the law.

Content: 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).
Data subjects: Communication partners.
Purposes of processing: Direct marketing (e.g., by email or post).
Legal bases: Consent (Art. 6(1)(1)(a) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).
Opt-out option: You can cancel receipt of our newsletter at any time, i.e., revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options provided above, preferably email.

Services and service providers used:

Measurement of open and click rates: The newsletters contain a so-called “web beacon,” i.e., a pixel-sized file that is retrieved from our server, or from the server of a dispatch service provider if we use one, when the newsletter is opened. As part of this retrieval, technical information such as browser information and your system, as well as your IP address and the time of retrieval, are initially collected. This information is used to technically improve our newsletter based on technical data or target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or access times. This analysis also includes determining whether and when newsletters are opened and which links are clicked. The information is assigned to individual newsletter recipients and stored in their profiles until deletion. The evaluations serve to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of open and click rates as well as the storage of measurement results in user profiles and their further processing are based on user consent. A separate revocation of success measurement is unfortunately not possible; in this case, the entire newsletter subscription must be canceled or objected to. In that case, the stored profile information will be deleted; Legal bases: Consent (Art. 6(1)(1)(a) GDPR);
CleverReach: Email marketing platform; Service provider: CleverReach GmbH & Co. KG, //CRASH Building, Schafjückenweg 2, 26180 Rastede, Germany; Website: https://www.cleverreach.com/de; Privacy policy: https://www.cleverreach.com/de/datenschutz/; Data processing agreement: Concluded with provider.
Mailchimp: Email dispatch and email marketing platform; Service provider: Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Website: https://mailchimp.com; Privacy policy: https://mailchimp.com/legal/; Data processing agreement: https://mailchimp.com/legal/; Basis for third-country transfer: Data Privacy Framework, Standard Contractual Clauses (incorporated in data processing agreement); Further information: Special security measures: https://mailchimp.com/help/Mailchimp-european-data-transfers/.

Please delete the newsletter section if you do not send newsletters. Otherwise, adjust the list of services and providers as well as the information on newsletter content and success measurement as needed.

Web analytics, monitoring, and optimization

Web analytics (also referred to as “reach measurement”) serves to evaluate visitor flows 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 reach analysis, we can, for example, recognize at what time our online offering or its functions or content are most frequently used or invite reuse. We can also track which areas require optimization.

In addition to web analytics, we may also use testing procedures to test and optimize different versions of our online offering or its components.

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

Users’ IP addresses are also collected. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored in the context of web analytics, A/B testing, and optimization, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of users, but only the information stored in their profiles for the purposes of the respective procedures.

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

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

Services and service providers used:

etracker: Web analytics/reach measurement; Service provider: etracker GmbH, Erste Brunnenstraße 1 20459 Hamburg, Germany; Website: https://www.etracker.com; Privacy policy: https://www.etracker.com/datenschutz/; Data processing agreement: https://www.etracker.com/av-vertrag/.
Google Analytics: We use Google Analytics to measure and analyze the use of our online offering based on a pseudonymous user identification number. This identification number does not contain unique data such as names or email addresses. It serves to assign analysis information to an end 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 that refer to our online offering and technical aspects of their end devices and browsers.
Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides coarse geographic location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based counterparts). For EU traffic, IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. It is not logged, is not accessible, and is not used for further purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(1)(a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymization of IP address); Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfer: Data Privacy Framework (DPF); Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for ad display: https://myadcenter.google.com/personalizationoff; Further information: https://business.safety.google/adsservices/ (types of processing and data processed).
Google as recipient of consent: The consent given by users in a consent dialog (also known as “cookie opt-in/consent,” “cookie banner,” etc.) serves multiple purposes. On the one hand, it serves us to fulfill our obligation to obtain consent for storing and reading information on and from users’ end devices (in accordance with ePrivacy directives). On the other hand, it covers the processing of users’ personal data in accordance with data protection requirements. In addition, this consent also applies to Google, as the company is required under the Digital Markets Act to obtain consent for personalized services. Therefore, we share the status of consents given by users with Google. Our consent management software informs Google whether consents have been granted or not. The aim is to ensure that the consents granted or not granted by users are taken into account when using Google Analytics and when integrating functions and external services. In this way, users’ consents and their revocation can be dynamically adjusted within Google Analytics and other Google services in our online offering depending on user selection; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(1)(a) GDPR); Website: https://support.google.com/analytics/answer/9976101?hl=de; Privacy policy: https://policies.google.com/privacy.
Google Tag Manager: Google Tag Manager is a solution that allows us to manage so-called website tags via an interface and thus integrate other services into our online offering (reference is made to further information in this privacy policy). With the Tag Manager itself (which implements the tags), for example, no user profiles are created or cookies are stored. Google only learns the user’s IP address, which is necessary to run Google Tag Manager; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Data processing agreement:
https://business.safety.google/adsprocessorterms; Basis for third-country transfer: Data Privacy Framework, Standard Contractual Clauses (https://business.safety.google/adsprocessorterms); Further information: https://privacy.google.com/businesses/adsservices (types of processing and data processed).
Matomo (without cookies): Matomo is a privacy-friendly web analytics software that is used without cookies and in which the recognition of returning users is carried out using a so-called “digital fingerprint” that is stored anonymously and changed every 24 hours; With the “digital fingerprint,” user movements within our online offering are recorded using pseudonymized IP addresses in combination with user-side browser settings in such a way that conclusions about the identity of individual users are not possible. The user data collected as part of using Matomo is processed only by us and not shared with third parties; Website: https://matomo.org/.
Matomo: Matomo is software used for web analytics and reach measurement purposes. As part of using Matomo, cookies are generated and stored on users’ end devices. The user data collected as part of using Matomo is processed only by us and not shared with third parties. The cookies are stored for a maximum period of 13 months: https://matomo.org/faq/general/faq_146/; Data deletion: The cookies have a storage duration of a maximum of 13 months.

Please delete the web analytics, monitoring, and optimization section if you do not use web analytics, monitoring, and optimization tools on your website. Adjust the list of services and providers as needed.

Online marketing

We process personal data for online marketing purposes, which may include in particular the marketing of advertising space or the display of advertising and other content (collectively referred to as “content”) based on potential interests of users as well as measuring 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 relevant to the display of the aforementioned content is stored about the user. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used, and information on usage times. If users have consented to the collection of their location data, this may also be processed.

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

The information in the profiles is generally stored in cookies or by means of similar procedures. These cookies can later also be read on other websites that use the same online marketing procedure, analyzed for the purpose of displaying content, supplemented with additional data, and stored on the server of the online marketing procedure provider.

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

We generally only receive access to aggregated information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing procedures led to a so-called conversion, i.e., for example, to a contract conclusion with us. Conversion measurement is used solely to analyze the success of our marketing measures.

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

Types of data processed: Usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses), location data (information on the geographic position of a device or person).
Data subjects: Users (e.g., website visitors, users of online services), prospects.
Purposes of processing: Tracking (e.g., interest/behavior-based profiling, use of cookies), remarketing, visit action evaluation, interest-based and behavioral marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g., access statistics, recognition of returning visitors), audience building (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes).
Security measures: IP masking (pseudonymization of IP address).
Legal bases: Consent (Art. 6(1)(1)(a) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).
Opt-out option: We refer to the privacy notices of the respective providers and the opt-out options provided for the providers (so-called “opt-out”). If no explicit opt-out option has been provided, you have the option of disabling cookies in your browser settings. However, this may restrict functions of our online offering. We therefore additionally recommend the following opt-out options, which are offered collectively for 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.

Services and service providers used:

Meta Pixel and audience building (Custom Audiences): With the help of the Meta Pixel (or comparable functions for transmitting event data or contact information via interfaces in apps), the company Meta is able to determine the visitors of our online offering as a target group for the display of advertisements (so-called “Meta Ads”). Accordingly, we use the Meta Pixel to display the Meta Ads placed by us only to those users on Meta platforms and within the services of partners cooperating with Meta (so-called “Audience Network” https://www.facebook.com/audiencenetwork/) who have also shown an interest in our online offering or who have certain characteristics (e.g., interest in certain topics or products that are evident from the websites visited) that we transmit to Meta (so-called “Custom Audiences”). With the help of the Meta Pixel, we also want to ensure that our Meta Ads correspond to the potential interest of users and do not have a harassing effect. With the help of the Meta Pixel, we can also track the effectiveness of Meta Ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Meta Ad (so-called “conversion measurement”); Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Consent (Art. 6(1)(1)(a) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/; Data processing agreement: https://www.facebook.com/legal/terms/dataprocessing; Basis for third-country transfer: Data Privacy Framework (DPF); Further information: Users’ event data, i.e., behavioral and interest information, is processed for the purposes of targeted advertising and audience building on the basis of the joint controllership agreement (“Controller Addendum,” https://www.facebook.com/legal/controller_addendum). Joint controllership is limited to the collection by and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transmission of data to the parent company Meta Platforms, Inc. in the USA (on the basis of the Standard Contractual Clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
Google Ad Manager: We use the “Google Ad Manager” service to place ads on the Google advertising network (e.g., in search results, in videos, on websites, etc.). Google Ad Manager is characterized by the fact that ads are displayed in real time based on presumed interests of users. This allows us to display ads for our online offering to users who may have a potential interest in our offering or who had previously shown interest in it, as well as to measure the success of the ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfer: Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/; Data processing terms for Google advertising products: Information on services data processing terms between controllers and Standard Contractual Clauses for third-country data transfers: https://business.safety.google/adscontrollerterms; if Google acts as a processor, data processing terms for Google advertising products and Standard Contractual Clauses for third-country data transfers: https://business.safety.google/adsprocessorterms.
Google Ads and conversion measurement: Online marketing procedure for the purpose of placing content and ads within the service provider’s advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads. In addition, we measure the conversion of the ads, i.e., whether users have taken them as an occasion to interact with the ads and use the advertised offers (so-called conversions). However, we only receive anonymous information and no personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(1)(a) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfer: Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/; Data processing terms between controllers and Standard Contractual Clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.

Please delete the online marketing section if you do not use online marketing tools on your website. Adjust the list of services and providers as needed. Please note that the use of marketing services on the website generally requires cookie opt-in.

Presence on social networks (social media)

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

We point out that user data may be processed outside the European Union. This may result in risks for users because, for example, the enforcement of users’ rights could be made more difficult.

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

For a detailed description of the respective forms of processing and opt-out options, we refer to the privacy policies and information provided by the operators of the respective networks.

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

Types of data processed: Inventory data (e.g., names, addresses), contact data (e.g., 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).
Data subjects: Users (e.g., website visitors, users of online services).
Purposes of processing: Contact requests and communication, tracking (e.g., interest/behavior-based profiling, use of cookies), remarketing, reach measurement (e.g., access statistics, recognition of returning visitors).
Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).

Services and service providers used:

Instagram: Social network, enables the sharing of photos and videos, commenting on and liking posts, messaging, following profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/; Basis for third-country transfers: Data Privacy Framework (DPF).
Facebook Pages: Profiles within the social network Facebook – We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content that users view or interact with, or actions they take (see “Things You and Others Do and Provide” in the Facebook Privacy Policy: https://www.facebook.com/privacy/policy/), as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see “Device Information” in the Facebook Privacy Policy: https://www.facebook.com/privacy/policy/). As explained in the Facebook Privacy Policy under “How Do We Use This Information?”, Facebook also collects and uses information to provide analytics services, known as “Page Insights,” for page operators so that they can gain insights into how people interact with their pages and the content associated with them. We have entered into a specific agreement with Facebook (“Information about Page Insights”, https://www.facebook.com/legal/terms/page_controller_addendum), which in particular regulates which security measures Facebook must observe and in which Facebook has agreed to fulfill data subject rights (i.e., users can, for example, direct information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information about Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data). The joint responsibility is limited to the collection by and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transmission of data to the parent company Meta Platforms, Inc. in the USA; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/; Basis for third-country transfers: Data Privacy Framework (DPF).
LinkedIn: Social network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of data from visitors that is created for the purpose of generating “Page Insights” (statistics) for our LinkedIn profiles.
This data includes information about the types of content that users view or interact with, or actions they take, as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data) and information from users’ profiles, such as job function, country, industry, seniority level, company size, and employment status. Privacy information regarding the processing of user data by LinkedIn can be found in LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy. We have entered into a specific agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum (the ‘Addendum’)”, https://legal.linkedin.com/pages-joint-controller-addendum), which in particular regulates which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill data subject rights (i.e., users can, for example, direct information or deletion requests directly to LinkedIn). The rights of users (in particular to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection of data by and transmission to Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of Ireland Unlimited Company, which in particular concerns the transmission of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: Data Privacy Framework (DPF); Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Pinterest: Social network; Service provider: Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA; Website: https://www.pinterest.com; Privacy Policy: https://about.pinterest.com/de/privacy-policy; Further information: Pinterest Data Sharing Addendum (ANNEX A): https://business.pinterest.com/de/pinterest-advertising-services-agreement/.
TikTok: Social network / video platform; Service provider: musical.ly Inc., 10351 Santa Monica Blvd #310, Los Angeles, CA 90025 USA; Website: https://www.tiktok.com; Privacy Policy: https://www.tiktok.com/de/privacy-policy.
X: Social network; Service provider: X Internet Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland; Privacy Policy: https://x.com/de/privacy, (Settings: https://x.com/settings/account/personalization).
YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Privacy Policy: https://policies.google.com/privacy; Opt-out option: https://adssettings.google.com/authenticated; Basis for third-country transfers: Data Privacy Framework.
Xing: Social network; Service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Website: https://www.xing.de; Privacy Policy: https://privacy.xing.com/de/datenschutzerklaerung.

Adjust the list of social networks as needed.

Plugins and Embedded Features and Content

We integrate 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 social media buttons and posts (hereinafter uniformly referred to as “content”).

Integration always requires that the third-party providers of this content process the IP address of users, as they could not send the content to their browser without the IP address. The IP address is therefore necessary for the display of this content or functions. We strive to use only content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to 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, visit time, and other information about the use of our online offering, as well as be linked to such information from other sources.

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

Types of data processed: Usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses), location data (information about the geographical position of a device or person), content data (e.g., entries in online forms), inventory data (e.g., names, addresses), contact data (e.g., email, telephone numbers).
Data subjects: Users (e.g., website visitors, users of online services), communication partners.
Purposes of processing: Provision of our online offering and user-friendliness, provision of contractual services and customer service, contact requests and communication, tracking (e.g., interest/behavioral profiling, use of cookies), interest-based and behavioral marketing, profiling (creating user profiles), security measures, administration and response to inquiries.
Legal basis: Legitimate interests (Art. 6(1)(1)(f) GDPR), consent (Art. 6(1)(1)(a) GDPR), contract performance and pre-contractual inquiries (Art. 6(1)(1)(b) GDPR).

Services and Service Providers Used:

Facebook Plugins and Content: Facebook Social Plugins and content – This may include, for example, content such as images, videos, or texts and buttons with which users can share content from this online offering within Facebook. The list and appearance of Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/ – We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt in the context of a transmission (but not the further processing) of “event data” that Facebook collects by means of the Facebook Social Plugins (and embedding functions for content) that are executed on our online offering, or receives in the context of a transmission for the following purposes: a) display of content and advertising information that corresponds to the presumed interests of users; b) delivery of commercial and transactional messages (e.g., addressing users via Facebook Messenger); c) improvement of ad delivery and personalization of features and content (e.g., improving the recognition of which content or advertising information presumably corresponds to the interests of users). We have entered into a specific agreement with Facebook (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum), which in particular regulates which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill data subject rights (i.e., users can, for example, direct information or deletion requests directly to Facebook). Note: If Facebook provides us with metrics, analyses, and reports (which are aggregated, i.e., do not contain information about individual users and are anonymous to us), this processing does not take place within the framework of joint responsibility, but on the basis of a data processing agreement (“Data Processing Terms”, https://www.facebook.com/legal/terms/dataprocessing), the “Data Security Terms” (https://www.facebook.com/legal/terms/data_security_terms), and with regard to processing in the USA on the basis of standard contractual clauses (“Facebook EU Data Transfer Addendum”, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6(1)(1)(a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/; Basis for third-country transfers: Data Privacy Framework (DPF).
Google Fonts (obtained from Google server): Obtaining fonts (and symbols) for the purpose of technically secure, maintenance-free, and efficient use of fonts and symbols with regard to currency and loading times, their uniform display, and consideration of possible licensing restrictions. The provider of the fonts is informed of the user’s IP address so that the fonts can be made available in the user’s browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) is transmitted, which is necessary for the provision of the fonts depending on the devices used and the technical environment. This data may be processed on a server of the font provider in the USA – When visiting our online offering, users’ browsers send their browser HTTP requests to the Google Fonts Web API (i.e., a software interface for retrieving the fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) of Google Fonts and then the fonts specified in the CSS. These HTTP requests include (1) the IP address used by the respective user to access the Internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user agent, which describes the browser and operating system versions of website visitors, as well as the referrer URL (i.e., the website on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and are not analyzed. The Google Fonts Web API logs details of HTTP requests (requested URL, user agent, and referrer URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must adjust the font that is generated for the respective browser type. The user agent is primarily logged for debugging and used to generate aggregated usage statistics that measure the popularity of font families. These aggregated usage statistics are published on Google Fonts’ “Analytics” page. Finally, the referrer URL is logged so that the data can be used for production maintenance and an aggregated report on top integrations can be generated based on the number of font requests. According to its own information, Google does not use any of the information collected by Google Fonts to create profiles of end users or to display targeted ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: https://developers.google.com/fonts/faq/privacy?hl=de.
Google Maps: We integrate the maps of the “Google Maps” service provided by Google. The data processed may include, in particular, IP addresses and location data of users; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Consent (Art. 6(1)(1)(a) GDPR); Website: https://mapsplatform.google.com/; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF).
YouTube Videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6(1)(1)(a) GDPR); Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF); Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff.
Vimeo Video Player: Integration of a video player; Service provider: Vimeo Inc., Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA; Legal basis: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://vimeo.com; Privacy Policy: https://vimeo.com/privacy; Data Processing Agreement: https://vimeo.com/enterpriseterms/dpa; Basis for third-country transfers: Standard Contractual Clauses (https://vimeo.com/enterpriseterms/dpa).

Please delete the section on plugins and embedded features and content if you do not use any plugins or embedded features and content within your website. Otherwise, adjust the list of services and providers as needed.

Deletion of Data

The data we process will be deleted in accordance with legal requirements as soon as consent for processing is revoked or other permissions cease to apply (e.g., if the purpose of processing this data has ceased to apply or it is not 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. That is, 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 for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person.

Further information on the deletion of personal data may also be provided within the individual privacy notices of this privacy policy.

Changes and Updates to the Privacy Policy

We ask you to regularly inform yourself about the content of our privacy policy. We will update the privacy policy 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 addresses may change over time and please verify the information before contacting us.

Rights of Data Subjects

As a data subject under the GDPR, you have various rights, which arise in particular from Articles 15 to 21 of the GDPR:

Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling insofar as it is related to such direct marketing.
Right to withdraw consent: You have the right to withdraw consent at any time.
Right of access: You have the right to request confirmation as to whether data concerning you is being processed and to 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 legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be deleted immediately, or alternatively, in accordance with legal requirements, to request restriction of the processing of the data.
Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used, and machine-readable format in accordance with legal requirements, or to request its transmission to another controller.
Complaint to supervisory authority: In accordance with legal requirements, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you believe that the processing of personal data concerning you violates the GDPR.

Definitions of Terms

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

Conversion tracking: “Conversion tracking” refers to a procedure that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the devices of users within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the advertisements we placed on other websites were successful.
Credit information: Automated decisions are based on automatic data processing without human intervention (e.g., in the case of automatic rejection of a purchase on account, an online credit application, or an online application process without any human intervention). Such automated decisions are only permissible under Article 22 GDPR if data subjects consent, if they are necessary for the performance of a contract, or if national laws permit these decisions.
Cross-device tracking: Cross-device tracking is a form of tracking in which behavioral and interest information of users is recorded across devices in so-called profiles by assigning an online identifier to users. This allows user information to be analyzed for marketing purposes, regardless of the browsers or devices used (e.g., mobile phones or desktop computers). For most providers, the online identifier is not linked to clear data such as names, postal addresses, or email addresses.
IP masking: “IP masking” refers to a method in which the last octet, i.e., the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing procedures, particularly in online marketing.
Interest-based and behavioral marketing: Interest-based and/or behavioral marketing refers to when potential interests of users in advertisements and other content are determined as precisely as possible. This is done on the basis of information about their previous behavior (e.g., visiting certain websites and staying on them, purchasing behavior, or interaction with other users), which is stored in a so-called profile. Cookies are usually used for these purposes.
Conversion measurement: Conversion measurement is a procedure that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the devices of users within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the advertisements we placed on other websites were successful.
Personal data: “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.
Profiling: “Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person (depending on the type of profiling, this includes information concerning age, gender, location data and movement data, interaction with websites and their content, purchasing behavior, social interactions with other people), to analyze or predict them (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 referred to as web analytics) is used to evaluate visitor flows to an online offering and may include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, website owners can, for example, recognize at what time visitors visit their website and what content they are interested in. This allows them, for example, to better adapt the content of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis purposes to recognize returning visitors and thus obtain more accurate analyses of the use of an online offering.
Remarketing: “Remarketing” or “retargeting” refers to when, for example, it is noted for advertising purposes which products a user was interested in on a website in order to remind the user of these products on other websites, e.g., in advertisements.
Location data: Location data is generated when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, WLAN, or similar technical means and functions of location determination. Location data is used to indicate at which geographically determinable position on earth the respective device is located. Location data can be used, for example, to display map functions or other information dependent on a location.
Tracking: “Tracking” refers to when the behavior of users can be tracked across multiple online offerings. As a rule, behavioral and interest information is stored in cookies or on servers of the providers of tracking technologies with regard to the online offerings used (so-called profiling). This information can then be used, for example, to show users advertisements that presumably correspond to their interests.
Controller: “Controller” means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Processing: “Processing” means any operation or set of operations 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 every handling of data, whether it is collection, evaluation, storage, transmission, or deletion.
Audience building: Audience building (or “custom audiences”) refers to when target groups are determined for advertising purposes, e.g., display of advertisements. For example, it can be concluded from a user’s interest in certain products or topics on the Internet that this user is interested in advertisements for similar products or the online shop in which they viewed the products. “Lookalike audiences” (or similar audiences) refers to when content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are usually used for the purpose of creating custom audiences and lookalike audiences.

About NaturalAqua

Guide

Partnerships

Privacy Policy

Introduction

Table of Contents

Controller

Contact Data Protection Officer

Overview of Processing

Types of Data Processed

Categories of Data Subjects

Purposes of Processing

Automated decisions in individual cases

Relevant Legal Bases

Security Measures

Transfer and Disclosure of Personal Data

Data Processing in Third Countries

Use of Cookies

Commercial and Business Services

Payment Service Providers

Credit Assessment

Provision of the Online Offer and Web Hosting

Contacting Us

Newsletters and electronic notifications

Web analytics, monitoring, and optimization

Online marketing

Presence on social networks (social media)

Plugins and Embedded Features and Content

Deletion of Data

Changes and Updates to the Privacy Policy

Rights of Data Subjects

Definitions of Terms

Login

Register