Data protection

initiation

With the following data protection declaration, we would like to explain to you which types of your personal data (hereinafter also referred to as “data”) we process for which purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part of the provision of our services and in particular on our websites, mobile, as well as within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer” ).

The terms used are not gender specific.

Status: 20.10.2021

 

Table of Contents

Responsible

Dreiklang GmbH
Norderstrasse 6
24568 Kaltenkirchen
Germany

Authorized representatives: Uwe Heymann

Email address: info@hotel-dreiklang.de

Telephone: +49 (0)4191 921-0

Imprint: hotel-dreiklang.de/impressum

 

Contact Data Protection Officer

Uwe Heyman
Norderstrasse 6
24568 Kaltenkirchen

Overview of processing

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

Types of data processed

  • Inventory data (e.g. names, addresses).
  • Content data (e.g. entries in online forms).
  • Contact information (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).
  • Location data (information about the geographical position of a device or a person).
  • Payment data (e.g. bank details, invoices, payment history).

Categories of data subjects

  • Interested persons.
  • communication partner.
  • Customers.
  • Users (e.g. website visitors, users of online services).

purposes of processing

  • Provision of our online offer and user-friendliness.
  • visit action evaluation.
  • Cross-device tracking (cross-device processing of user data for marketing purposes).
  • Direct marketing (e.g. by e-mail or post).
  • Interest-Based and Behavioral Marketing.
  • Contact Requests and Communication.
  • Conversion measurement (measurement of the effectiveness of marketing measures).
  • Profiling (creating user profiles).
  • remarketing.
  • Range measurement (e.g. access statistics, recognition of returning visitors).
  • Safety measures.
  • Tracking (e.g. interest/behavioural profiling, use of cookies).
  • Provision of contractual services and customer service.
  • Management and response to inquiries.
  • Target group formation (determination of target groups relevant for marketing purposes or other output of content).

Relevant legal bases

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

  • Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR) – The person concerned has given their consent to the processing of their personal data for a specific purpose or several specific purposes.
  • Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR) – The processing is necessary for the fulfillment of a contract to which the data subject is a party, or for the implementation of pre-contractual measures which are required at the request of the data subject respectively.
  • Legal obligation (Art. 6 Para. 1 S. 1 lit. c. GDPR) – The processing is necessary to fulfill a legal obligation to which the person responsible is subject.
  • Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR) – Processing is necessary to safeguard the legitimate interests of the person responsible or a third party, unless the interests or fundamental rights and freedoms of the data subject, which protect personal Data require prevail.

Safety measures

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

The measures include, in particular, securing the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, disclosure, securing availability and their separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to data threats. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

SSL encryption (https) : In order to protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.

 

Transfer and Disclosure of Personal Data

As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons or that it is disclosed to them. The recipients of this data can include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such a case, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

Data processing in third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing within the framework of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies takes place, this is only done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transmission, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, if there are certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

Use of cookies

Cookies are text files containing data from websites or domains visited and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after their visit to an online offer. The stored information can include, for example, the language settings on a website, the login status, a shopping cart or the place where a video was viewed. The term cookies also includes other technologies that fulfill the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also referred to as “user IDs”).

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
  • Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users, which are used to measure reach or for marketing purposes, can be stored in such a cookie.
  • First-party cookies: First-party cookies are set by us.
  • Third-party cookies (also: third-party cookies) : Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or absolutely necessary) cookies: Cookies can be absolutely necessary for the operation of a website (e.g. to save logins or other user entries or for security reasons).
  • Statistics, marketing and personalization cookies : Cookies are also usually used to measure range and when the interests of a user or his behavior (e.g. viewing certain content, using functions, etc.) on individual websites in a user profile get saved. Such profiles are used to show users, for example, content that corresponds to their potential interests. This procedure is also referred to as “tracking”, ie tracking the potential interests of users. . If we use cookies or “tracking” technologies, we will inform you separately in our data protection declaration or when obtaining consent.

Notes on legal bases: The legal basis on which we process your personal data with the help of cookies depends on whether we ask for your consent. If this is the case and you consent to the use of cookies, the legal basis for the processing of your data is the declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offer and its improvement) or if the use of cookies is necessary to fulfill our contractual obligations.

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

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke your consent or to object to the processing of your data by cookie technologies ( collectively referred to as “opt-out”). You can initially declare your objection using the settings in your browser, e.g. by deactivating the use of cookies (which can also limit 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/ will. In addition, you can receive further objection notices as part of the information on the service providers and cookies used.

Processing of cookie data on the basis of consent : Before we process or have data processed as part of the use of cookies, we ask users to give their consent, which can be revoked at any time. Before consent has not been given, cookies may be used that are absolutely necessary for the operation of our online offer.

Cookie settings / opt-out option:

  • Types of data processed: usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: users (e.g. website visitors, users of online services).
  • Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Commercial and Business Services

We process the data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) within the framework of contractual and comparable legal relationships and related measures and within the framework of communication with the contractual partners (or pre-contractual), e.g respond.

We process this data to fulfill our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with this information and the corporate organization. We only pass on the data of the contractual partners to third parties within the framework of the applicable law to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations or with the consent of the persons concerned (e.g. to telecommunications, transport and other auxiliary services involved 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 inform the contracting parties which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special markings (e.g. colours) or symbols (e.g. asterisks or similar), or personally.

We delete the data after statutory warranty and comparable obligations have expired, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. for as long as it has to be kept for legal archiving reasons (e.g. for tax purposes usually 10 years). We delete data disclosed to us by the contractual partner as part of an order 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, “customer account” for short). If it is necessary to register a customer account, contractual partners will be informed of this as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. As part of the registration and subsequent registrations and uses of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove the registration and to prevent any misuse of the customer account.

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

Economic analyzes and market research : For business reasons and in order to be able to identify market trends and the wishes of contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc., whereby the group of persons concerned includes contractual partners, interested parties, customers, Visitors and users of our online offer can fall.

The analyzes 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 together with their information, e.g. on services used. The analyzes serve us alone and are not disclosed externally, unless they are anonymous analyzes with summarized, i.e. anonymous values. Furthermore, we take the privacy of the 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 the data of our customers in order to enable them to select, purchase or order the selected products, goods and associated services, as well as their payment and delivery or execution. If 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. We use the services of banks and payment service providers to process payment transactions. 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 in order to be able to hold any consultation.

  • Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content , access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: interested parties, business and contractual partners, customers.
  • Purposes of processing: Provision of contractual services and customer service, contact inquiries and communication, office and organizational procedures, administration and answering of inquiries, security measures, evaluation of visits, interest-based and behavioral marketing, profiling (creating user profiles).
  • Legal basis: fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. GDPR), legal obligation (Art. 6 para. 1 p. 1 lit. c. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

 

payment service provider

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

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

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

  • Types of data processed: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g device information, IP addresses).
  • Affected persons: customers, interested parties.
  • Purposes of processing: Provision of contractual services and customer service.
  • Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Services and service providers used:

  • PayPal: payment services and solutions (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à rl et Cie, SCA, 22-24 Boulevard Royal, L-2449 Luxembourg; Website: https://www.paypal.com/de ; Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full .
  • Stripe: Payment service provider for credit card payments. Your credit card details are not stored on our server. You can find out more about our payment provider Stripe at www.stripe.com.

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 may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services.

The data processed as part of the provision of the hosting offer may 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 in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or on websites.

E-mail sending and hosting : The web hosting services we use also include sending, receiving and storing e-mails. For these purposes, the addresses of the recipients and senders as well as other information regarding the e-mail dispatch (e.g. the providers involved) and the content of the respective e-mails are processed. The aforementioned data can also be processed for SPAM detection purposes. We ask you to note that e-mails are generally not sent in encrypted form on the Internet. As a rule, e-mails are encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. Therefore, we cannot accept any responsibility for the transmission path of the e-mails between the sender and receipt on our server.

Collection of access data and log files : We ourselves (or our web hosting provider) collect data for each access to the server (so-called server log files). The address and name of the retrieved websites and files, date and time of retrieval, amounts of data transferred, notification of successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP Addresses and the requesting provider belong.

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

  • Types of data processed: content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: users (e.g. website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

contact

When contacting us (e.g. via contact form, e-mail, telephone or via social media), the details of the requesting person will be processed to the extent that this is necessary to answer the contact request 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 the legitimate interests in answering the inquiries.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: communication partners, interested parties.
  • Purposes of processing: contact requests and communication, management and response to requests.
  • Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Newsletters and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter “newsletters”) only with the consent of the recipient or legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the consent of the user. Our newsletter also contains information about our services and us.

In order to register for our newsletters, it is generally sufficient if you enter your e-mail address. However, we may ask you to provide a name so that we can address you personally in the newsletter, or other information if this is necessary for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registration you will receive an e-mail in which you will be asked to confirm your registration. This confirmation is necessary so that nobody can register with someone else’s e-mail address. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider are also logged.

Deletion and restriction of processing: We can store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time. In the case of obligations to permanently observe contradictions, we reserve the right to store the e-mail address in a blocking list (so-called “blacklist”) solely for this purpose.

The registration process is logged on the basis of our legitimate interests for the purpose of proving that it was carried out properly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure shipping system.

Notes on the legal basis: The newsletter is sent on the basis of the consent of the recipient or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of advertising for existing customers. If we commission a service provider to send emails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to demonstrate that it has been carried out in accordance with the law.

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

Analysis and measurement of success: The newsletters contain a so-called “web beacon”, ie a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from their server. Technical information is initially collected as part of this retrieval , such as information about the browser and your system, as well as your IP address and the time of retrieval.

This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our aim nor, if used, that of the shipping service provider to monitor individual users. Rather, the evaluations serve us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the user, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system, which serves both our business interests and meets the expectations of the users.

Unfortunately, a separate revocation of the performance measurement is not possible. In this case, the entire newsletter subscription must be canceled or objected to.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
  • Affected persons: communication partners.
  • Purposes of processing: direct marketing (e.g. by email or post).
  • Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
  • Possibility of objection (opt-out): You can cancel the receipt of our newsletter at any time, ie revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options given above, preferably e-mail.

Services and service providers used:

 

Web analysis, monitoring and optimization

The web analysis (also referred to as “reach measurement”) serves to evaluate the flow of visitors to our online offer and can include behavior, interests or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of the range analysis, we can, for example, identify the time at which our online offer or its functions or content are used most frequently or invite users to reuse them. We can also understand which areas need optimization.

In addition to web analysis, we can also use test procedures, for example to test and optimize different versions of our online offering or its components.

For these purposes, so-called user profiles can be created and stored in a file (so-called “cookie”) or similar processes can be used for the same purpose. This information can 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 can also be processed depending on the provider.

The IP addresses of the users are also saved. However, we use an IP masking process (ie pseudonymization by shortening the IP address) to protect users. In general, no clear user data (e.g. e-mail addresses or names) are stored in the context of web analysis, A/B testing and optimization, but pseudonyms. This means that we and 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 process.

Notes on legal bases: 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 (ie interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.

  • Types of data processed: usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: users (e.g. website visitors, users of online services).
  • Purposes of processing: range measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behaviour-related profiling, use of cookies), evaluation of visits, profiling (creation of user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

 

Online marketing

We process personal data for online marketing purposes, which may include in particular the marketing of advertising space or the presentation of advertising and other content (collectively referred to as “content”) based on the potential interests of users and the measurement of their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar processes are used, by means of which the information about the user relevant to the presentation of the aforementioned content is stored. This information can 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 can also be processed.

The IP addresses of the users are also saved. However, we use available IP masking procedures (ie pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) are stored as part of the online marketing process, but pseudonyms. This means that we and the providers of the online marketing process do not know the actual identity of the users, only the information stored in their profiles.

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

As an exception, plain data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing process we use and the network connects the user’s profile with the aforementioned information. We ask you to note that users can make additional agreements with the providers, e.g. by giving their consent during registration.

In principle, we only receive access to summarized information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, ie to a contract with us, for example. The conversion measurement is only used to analyze the success of our marketing measures.

Unless otherwise stated, please assume that cookies used will be stored for a period of two years.

Notes on legal bases: 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 (ie interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.

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

  • Types of data processed: usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographic position of a device or a person).
  • Affected persons: users (e.g. website visitors, users of online services), interested parties.
  • Purposes of processing: Tracking (e.g. interest/behaviour-related profiling, use of cookies), remarketing, visit action evaluation, interest-based and behavior-related marketing, profiling (creating user profiles), conversion measurement (measuring the effectiveness of marketing measures), range measurement (e.g. access statistics, recognition of returning visitors), target group formation (Determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
  • Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the possibilities of objection specified for the providers (so-called “opt-out”). If no explicit opt-out option has been specified, you can turn off cookies in your browser settings. However, this can limit the functions of our online offer. We therefore also recommend the following opt-out options, which are offered in summary for the respective areas: a) Europe: https://www.youronlinechoices.eu .
    b) Canada: https://www.youradchoices.ca/choices .
    c) USA: https://www.aboutads.info/choices .
    d) Cross-Territory: https://optout.aboutads.info .

Services and service providers used:

  • Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offer. The Tag Manager itself (which implements the tags) does not process any personal data of the users. With regard to the processing of users’ personal data, reference is made to the following information on Google services. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com ; Privacy Policy: https://policies.google.com/privacy .
  • Google Analytics: online marketing and web analysis; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; site: https://marketingplatform.google.com/intl/de/about/analytics/ ; Data protection: https://policies.google.com/privacy ; Possibility of objection (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de , settings for the display of advertisements: https://adssettings.google.com/authenticated .
  • Google Ads and conversion measurement: We use the online marketing process “Google Ads” to place ads on the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest have on the ads. We also measure the conversion of the ads. However, we only find out the anonymous total number of users who clicked on our ad and were forwarded to a page with a so-called “conversion tracking tag”. However, we do not receive any information that could be used to identify users. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com ; Privacy Policy: https://policies.google.com/privacy .
  • Google Ad Manager: We use the “Google Marketing Platform” (and services such as “Google Ad Manager”) to place ads on the Google advertising network (e.g., in search results, in videos, on websites, etc.). The Google Marketing Platform is characterized by the fact that ads are displayed in real time based on users’ presumed interests. This allows us to display ads for and within our online offering in a more targeted manner in order to only present users with ads that potentially match their interests. If, for example, a user is shown ads for products that he was interested in on other online offers, this is referred to as “remarketing”. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com ; Privacy Policy: https://policies.google.com/privacy .
  • Facebook Pixel: Service Provider: https://www.facebook.com , Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA ; Website: https://www.facebook.com ; Privacy Policy: https://www.facebook.com/about/privacy ; Possibility of objection (opt-out): https://www.facebook.com/settings?tab=ads .

 

Presence in social networks (social media)

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

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

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

For a detailed description of the respective forms of processing and the possibility of objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.

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

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: users (e.g. website visitors, users of online services).
  • Purposes of processing: contact requests and communication, tracking (e.g. interest/behavioral profiling, use of cookies), remarketing, range measurement (e.g. access statistics, recognition of returning visitors).
  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Services and service providers used:

Customize the list of social networks as needed.

Plugins and embedded functions and content

We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). This can be, for example, graphics, videos or social media buttons as well as posts (hereinafter uniformly referred to as “content”).

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

Notes on legal bases: 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 (ie interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.

  • Types of data processed: usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographical position of a device or a person), content data (e.g. entries in online forms). ), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
  • Affected persons: users (e.g. website visitors, users of online services), communication partners.
  • Purposes of processing: Provision of our online offer and user-friendliness, provision of contractual services and customer service, contact inquiries and communication, tracking (e.g. interest/behavioral profiling, use of cookies), interest-based and behavioral marketing, profiling (creating user profiles), security measures, administration and Responding to Inquiries.
  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR), consent (Art. 6 para. 1 p. 1 lit. a. GDPR), fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. GDPR).

Services and service providers used:

deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as your consent to processing is revoked or other permissions are no longer applicable (e.g. if the purpose of processing this data no longer applies 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 limited to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.

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

Change and update of the privacy policy

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 the changes in 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 data protection declaration, please note that the addresses can change over time and ask you to check the information before contacting us.

Rights of data subjects

As a data subject, you have various rights under the GDPR, which result in particular from Art. 15 to 21 GDPR:

  • Right of objection: You have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data, which is based on Art. 6 para. 1 lit. e or f GDPR to file an objection; this also applies to profiling based on these provisions. If the personal data concerning you is processed in order to operate direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct advertising.
  • Right of revocation in the case of consent: You have the right to revoke your consent at any time.
  • Right to information: You have the right to request confirmation as to whether the data in question is being processed and to request 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 the data concerning you or the correction of incorrect data concerning you.
  • Right to erasure and restriction of processing: You have the right, in accordance with the legal requirements, to request that the data concerning you be deleted immediately, or alternatively to request a restriction of the processing of the data in accordance with the legal requirements.
  • Right to data portability: You have the right to receive the data that you have provided to us in accordance with the legal requirements in a structured, common and machine-readable format or to request that it be transmitted to another person responsible.
  • Complaint 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 data concerning you personal data violates the GDPR.

definitions of terms

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

  • Visit action evaluation: “Visit action evaluation” (English “Conversion Tracking”) refers to a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the user’s device within the website on which the marketing measures take place and then called up again on the target website. For example, we can use this to understand whether the ads we placed on other websites were successful).
  • Credit report: Automated decisions are based on automatic data processing without human intervention (e.g. in the case of an automatic rejection of a purchase on account, an online loan application or an online application process without any human intervention). According to Art. 22 GDPR, such automated decisions are only permissible if the data subjects consent, if they are necessary for the fulfillment of a contract or if national laws allow these decisions.
  • Cross-device tracking: Cross-device tracking is a form of tracking in which information on the behavior and interests of users is recorded across devices in so-called profiles by assigning an online ID to the user. This allows user information to be analyzed for marketing purposes, regardless of the browser or device used (e.g. mobile phones or desktop computers). With most providers, the online identifier is not linked to clear data such as names, postal addresses or e-mail addresses.
  • IP masking: “IP masking” is a method in which the last octet, ie the last two digits of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing methods, especially in online marketing
  • Interest-based and behavioral marketing: One speaks of interest- and/or behavioral marketing when potential user interests in ads and other content are predetermined as precisely as possible. This is done using 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 method that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user’s device within the website on which the marketing measures take place and then called up again on the target website. For example, this allows us to understand whether the ads 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 means of assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special features, are an expression of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiling: “Profiling” means any type of automated processing of personal data, which consists in using this personal data to identify certain personal aspects relating to a natural person (depending on the type of profiling, this includes information regarding age, gender, location data and movement data, interaction with websites and their content, shopping behavior, social interactions with other people) to analyze, evaluate 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.
  • Range measurement: The range measurement (also referred to as web analytics) serves to evaluate the flow of visitors to an online offer and can include the behavior or interests of visitors in certain information, such as website content. With the help of the range analysis, website owners can, for example, see at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for range analysis purposes in order to recognize returning visitors and thus obtain more precise analyzes of the use of an online offer.
  • Remarketing: One speaks of “remarketing” or “retargeting” when, for advertising purposes, for example, it is noted 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 created when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, a WLAN or similar technical media and location determination functions. Location data is used to indicate at which geographically determinable position on earth the respective device is located. Location data can e.g. B. be used to display map features or other information dependent on a location.
  • Tracking: One speaks of “tracking” when the behavior of users can be traced across several online offers. As a rule, behavioral and interest information is stored in cookies or on the servers of the tracking technology providers with regard to the online offers used (so-called profiling). This information can then be used, for example, to show users advertisements that are likely to match their interests.
  • Responsible: The “responsible person” is the natural or legal person, authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data.
  • Processing: “Processing” is any process or series of processes carried out with or without the aid of automated processes in connection with personal data. The term goes far and covers practically every handling of data, be it collection, evaluation, storage, transmission or deletion.
  • Target group formation: One speaks of target group formation (or “custom audiences”) when target groups are determined for advertising purposes, e.g. display of advertisements. For example, based on a user’s interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which he viewed the products. In turn, we speak of “lookalike audiences” (or similar target groups) when the content assessed as 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.