Data Privacy Agreement
Introduction
With the following data protection declaration, we would like to inform you about
which types of your personal data (hereinafter also referred to as "data") we
process for which purposes and to what extent. The data protection declaration
applies to all processing of personal data carried out by us, both within the
framework the provision of our services and, in particular, on our websites, in
mobile applications and within external online presences, such as our social media
profiles (hereinafter collectively referred to as "online offer").
The terms used are not gender specific.
As of December 20, 2022
Table of Contents
Responsible
XPACE GmbH
Blucherstrasse 32
75117, Pforzheim
Authorized persons:
Holger Friedrich, Prof. Dr. Thomas Schuster
E-mail address:
info@negami.de
Phone:
+49 7231 462 68 95
Imprint:
www.negami.de/en/imprint/
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.
- payment details.
- location data.
- Contact details.
- content data.
- contract data.
- usage data.
- Meta/Communication Data.
Categories of data subjects
- Customers.
- Interested persons.
- communication partner.
- user.
- business and contractual partners.
Purposes of processing
- Provision of contractual services and customer service.
- Contact Requests and Communication.
- Safety measures.
- direct marketing.
- range measurement.
- tracking.
- office and organizational procedures.
- Management and response to inquiries.
- feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online offer and user-friendliness.
- information technology infrastructure.
We partner with Microsoft Clarity and Microsoft Advertising to capture how you use
and interact with our website through behavioral metrics, heatmaps, and session
replay to improve and market our products/services. Website usage data is captured
using first and third-party cookies and other tracking technologies to determine the
popularity of products/services and online activity. Additionally, we use this
information for site optimization, fraud/security purposes, and advertising. For
more information about how Microsoft collects and uses your data, visit the Microsoft
Privacy Statement.
Relevant legal bases
Below you will find an overview of the legal bases of the GDPR, on the basis of which
we process personal data. Please note that, in addition to the provisions of the
GDPR, national data protection regulations may apply in your or our country of
residence or domicile. If more specific legal bases are relevant in individual
cases, we will inform you of 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 party, or for the implementation of
pre-contractual measures which are required at the request of the data subject
take place.
- 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.
In addition to the data protection regulations of the General Data Protection
Regulation, national data protection regulations apply in Germany. This includes in
particular the law on the protection against misuse of personal data in data
processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains
special regulations on the right to information, the right to erasure, the right to
object, the processing of special categories of personal data, processing for other
purposes and transmission as well as automated decision-making in individual cases
including profiling. Furthermore, it regulates data processing for the purposes of
the employment relationship (§ 26 BDSG), in particular with regard to the
establishment, implementation or termination of employment relationships and the
consent of employees.
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.
TLS encryption (https): In order to protect your data transmitted via our online
offer, we use TLS encryption. You can recognize such encrypted connections by the
prefix https:// in the address line of your browser.
Transmission of personal data
As part of our processing of personal data, it may happen that the data is
transmitted to other bodies, companies, legally independent organizational units or
persons or that it is disclosed to them. The recipients of this data can include,
for example, 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 DSGVO, Information page of the EU Commission:
https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en
).
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.
Our data protection information can also contain further information on the storage
and deletion of data, which apply primarily to the respective processing.
Use of cookies
Cookies are small text files or other memory notes that store information on end
devices and read information from the end devices. For example, to save the login
status in a user account, the content of a shopping cart in an e-shop, the content
accessed or the functions used in an online offer. Cookies can also be used for
various purposes, e.g. for purposes of functionality, security and comfort of online
offers as well as the creation of analyzes of visitor flows.
Notes on consent: We use cookies in accordance with legal
regulations. Therefore, we obtain prior consent from users, except where not
required by law. In particular, consent is not necessary if the storage and reading
of the information, including cookies, is absolutely necessary in order to provide
the users with a telemedia service (i.e. our online offer) that they have expressly
requested. The revocable consent is clearly communicated to the users and contains
the information on the respective cookie use.
Notes on data protection legal bases:The data protection legal basis
on which we process the personal data of users with the help of cookies depends on
whether we ask users for their consent. If the users consent, 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 improving its usability)
or, if this is done in the context of fulfilling our contractual obligations, if the
use of cookies is necessary to enable our to fulfill contractual obligations. For
what purposes the cookies are processed by us,
Storage period: With regard to the storage period, the
following types of cookies 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 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 saved 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 to
measure reach. Unless we provide users with explicit information on the type and
storage period of cookies (e.g. when obtaining consent), users should assume
that cookies are permanent and the storage period can be up to two years.
General information on revocation and objection (opt-out): Users can
revoke the consent they have given at any time and also object to the processing in
accordance with the legal requirements in Art. 21 DSGVO. Users can also declare
their objection via their browser settings, e.g. by deactivating the use of cookies
(which can also limit the functionality of our online services). An objection to the
use of cookies for online marketing purposes can also be declared via the websites
https://optout.aboutads.info and https://www.youronlinechoices.com/ .
Cookie
settings / opt-out option:
The provider of this technology is: CookieYes Limited, 3 Warren Yard Warren Park,
Wolverton Mill, Milton Keynes, MK12 5NW, United Kingdom. Email: support@cookieyes.com .
Further information on processing processes, procedures and
services:
- Processing of cookie data based on consent:We use a procedure
for cookie consent management, as part of which the consent of the user to the
use of cookies or the processing and providers mentioned in the context of the
cookie consent management procedure is obtained and managed and revoked by the
user can become. The declaration of consent is stored here so that the query
does not have to be repeated 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 his device.
Subject to individual information on the providers of cookie management
services, the following notices apply: The duration of the storage of the
consent can be up to two years. A pseudonymous user identifier is created and
stored with the time of the consent, information on the scope of the consent
(e.g. which categories of cookies and/or service providers) and the browser,
system and end device used.
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. This includes in
particular the obligations to provide the agreed services, any updating obligations
and remedy in the case of warranty and other service disruptions. In addition, we
process the data to protect our rights and for the purpose of the administrative
tasks associated with these obligations and the corporate organization. In addition,
we process the data on the basis of our legitimate interests in proper and
economical business management and in security measures to protect our contractual
partners and our business operations from misuse, endangerment of their data,
secrets, information and rights (e.g. to involve telecommunications, transport and
other auxiliary services as well as subcontractors, banks, tax and legal advisors,
payment service providers or tax authorities). Within the framework of the
applicable law, we only pass on the data of contractual partners to third parties to
the extent that this is necessary for the aforementioned purposes or to fulfill
legal obligations. 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 contractual partners 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,
ie, in principle after 4 years, unless the data is stored in a customer account,
e.g. for as long as it must be kept for legal archiving reasons. The statutory
retention period is ten years for documents relevant to tax law and for trading
books, inventories, opening balance sheets, annual financial statements, the work
instructions and other organizational documents and accounting documents required to
understand these documents, and six years for received commercial and business
letters and reproductions of the commercial and business letters sent. The period
begins at the end of the calendar year in which the last entry was made in the book,
the inventory, the opening balance sheet,
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.
- Types of data processed: Inventory data (e.g. names,
addresses); payment data (e.g. bank details, invoices, payment history); Contact
information (e.g. email, phone numbers); Contract data (e.g. subject of the
contract, term, customer category).
- Affected persons: interested parties; business and contractual
partners.
- Purposes of processing: provision of contractual services and
customer service; contact requests and communication; office and organizational
procedures; Management and response to inquiries.
- Legal basis: Fulfillment of contract and pre-contractual
inquiries (Art. 6 Para. 1 S. 1 lit. b) DSGVO); Legal obligation (Art. 6 Para. 1
S. 1 lit. c) GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
Further information on processing processes, procedures and
services:
- Offer of software and platform services: We process the data of
our users, registered users and any test users (hereinafter referred to as
"users") in order to be able to provide them with our contractual services and
on the basis of legitimate interests to ensure the security of our offer and to
be able to develop it further. The required information is marked as such within
the framework of the contract, order or comparable contract and includes the
information required for the provision of services and billing as well as
contact information in order to be able to hold any consultations; Legal
basis: Fulfillment of contract and pre-contractual inquiries (Art.
6 Para. 1 S. 1 lit. b) DSGVO).
Use of online platforms for offer and sales purposes
We offer our services on online platforms operated by other service providers. In
this context, the data protection notices of the respective platforms apply in
addition to our data protection notices. This applies in particular with regard to
the execution of the payment process and the methods used on the platforms for
measuring reach and for interest-based marketing.
- Types of data processed: Inventory data (e.g. names,
addresses); payment data (e.g. bank details, invoices, payment history); Contact
information (e.g. email, phone numbers); Contract data (e.g. subject of the
contract, term, customer category); Usage data (e.g. websites visited, interest
in content, access times); Meta/communication data (e.g. device information, IP
addresses).
- Data Subjects: Customers.
- Purposes of processing: provision of contractual services and
customer service; Marketing.
- Legal basis: Fulfillment of contract and pre-contractual
inquiries (Art. 6 Para. 1 S. 1 lit. b) DSGVO).
Provision of the online offer and web hosting
We process user data in order to be able to provide our online services to them. For
this purpose we process the IP address of the user, which is necessary to transmit
the content and functions of our online services to the browser or the end device of
the user.
- 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: Provision of our online offer and
user-friendliness; Information technology infrastructure (operation and
provision of information systems and technical devices (computers, servers,
etc.)); Safety measures.
- Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f)
GDPR).
Further information on processing processes, procedures and
services:
- Provision of online offer on rented storage space: For the
provision of our online offer, we use storage space, computing capacity and
software that we rent from a corresponding server provider (also called "web
hoster") or obtain from another source; Legal basis: Legitimate
interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- Collection of access data and log files: Access to our online
offer is logged in the form of 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;
Legal bases:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f)
GDPR); Deletion of data: Log file information is stored for a
maximum of 30 days and then deleted or made anonymous. Data whose further
storage is required for evidence purposes are excluded from deletion until the
respective incident has been finally clarified.
- Content Delivery Network: We use a "Content Delivery Network"
(CDN). A CDN is a service with the help of which the content of an online offer,
in particular large media files such as graphics or program scripts, can be
delivered faster and more securely with the help of regionally distributed
servers connected via the Internet; Legal basis: Legitimate
interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter
"publication medium"). The data of the readers are processed for the purposes of the
publication medium only insofar as it is necessary for its presentation and the
communication between authors and readers or for reasons of security. In addition,
we refer to the information on the processing of visitors to our publication medium
in the context of this data protection notice.
- Types of data processed: Inventory data (e.g. names,
addresses); Contact information (e.g. email, phone 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: provision of contractual services and
customer service; Feedback (e.g. collecting feedback via online form); Provision
of our online offer and user-friendliness; Safety measures; Management and
response to inquiries.
- Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f)
GDPR).
Further information on processing processes, procedures and
services:
- Comments and Posts:When users leave comments or other posts,
their IP addresses may be stored based on our legitimate interests. This is for
our security if someone leaves illegal content in comments and posts (insults,
forbidden political propaganda, etc.). In this case, we can be prosecuted for
the comment or contribution and are therefore interested in the identity of the
author. Furthermore, we reserve the right to process user information for the
purpose of spam detection on the basis of our legitimate interests. On the same
legal basis, in the case of surveys, we reserve the right to store the IP
addresses of users for the duration of the survey and to use cookies to avoid
multiple votes.Legal basis: Legitimate interests (Art. 6 Para.
1 S. 1 lit. f) GDPR).
- Akismet Anti-Spam Check:by not using our comment system. That
would be a shame, but unfortunately we don't see any alternatives that work just
as effectively;Service Provider: Aut O'Mattic A8C Ireland Ltd.,
Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal
basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR);
Website: https://automattic.com ; Privacy Policy:
https://automattic.com/privacy .
- DISQUS comment function:Based on our legitimate interests in
efficient, secure and user-friendly comment management, we use the DISQUS
comment service. To use the DISQUS comment function, users can register via
their own DISQUS user account or an existing social media account (e.g. OpenID,
Facebook, Twitter or Google). The login data of the users are obtained from the
platforms by DISQUS. It is also possible to use the DISQUS comment function as a
guest without creating or using a user account with DISQUS or one of the
specified social media providers. We only embed DISQUS with its functions in our
website, whereby we can influence the comments of the users. However, the users
enter into a direct contractual relationship with DISQUS, In the context of
which DISQUS processes the comments of the users and is a contact person for any
deletion of the data of the users. We refer to the data protection declaration
of DISQUS and also point out to users that they can assume that DISQUS will also
save their IP address and the time of the comment in addition to the content of
the comment. Cookies can also be stored on users' computers and used to display
advertising;Service Provider: DISQUS, Inc., 301 Howard St,
Floor 3 San Francisco, California- 94105, USA; Legal basis:
Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website:
https://disqus.com/
; Privacy Policy: https://help.disqus.com/terms-and-policies/disqus-privacy-policy
; Possibility of objection (opt-out): https://disqus.com/data-sharing-settings .
Contact and request management
When contacting us (e.g. via contact form, e-mail, telephone or via social media) as
well as in the context of existing user and business relationships, the details of
the requesting person are processed to the extent necessary to answer the contact
request and any requested measures.
- Types of data processed: contact details (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.
- Purposes of processing: contact requests and communication;
managing and responding to inquiries; Feedback (e.g. collecting feedback via
online form); Provision of our online offer and user-friendliness.
- Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f)
GDPR); Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S.
1 lit. b) DSGVO).
Further information on processing processes, procedures and
services:
- Contact form: If users contact us via our contact form, e-mail
or other communication channels, we process the data communicated to us in this
context to process the communicated request; 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
content of the newsletter is specifically described when registering for it, it is
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 blacklist (so-called "blocklist") 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.
Content:
Information about us, our services, promotions and offers.
- Types of data processed: Inventory data (e.g. names,
addresses); Contact information (e.g. email, phone 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 e-mail or
post).
- Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) 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.
Further information on processing processes, procedures and
services:
- Measurement of open and click rates: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.;Legal
basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR).
Promotional communication via e-mail, post, fax or telephone
We process personal data for the purpose of advertising communication, which can take
place via various channels, such as e-mail, telephone, post or fax, in accordance
with legal requirements.
The recipients have the right to revoke their consent at any time or to object to
advertising communication at any time.
After revocation or objection, we store the data required to prove the previous
authorization for contacting or sending up to three years after the end of the year
of the revocation or objection on the basis of our legitimate interests. The
processing of this data is limited to the purpose of a possible defense against
claims. On the basis of the legitimate interest in permanently observing the
revocation or objection of the user, we also store the data required to avoid being
contacted again (e.g. e-mail address, telephone number, name depending on the
communication channel).
- Types of data processed: Inventory data (e.g. names,
addresses); Contact information (e.g. email, telephone numbers).
- Affected persons: communication partners.
- Purposes of processing: direct marketing (e.g. by e-mail or
post).
- Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR);
Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
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 at what
time our online offer or its functions or content are used most frequently or invite
people to use them again. 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.
Unless otherwise stated below, profiles, ie data summarized for a usage process, can
be created for these purposes and information can be stored in a browser or in a
terminal device and read from it. The information collected includes, in particular,
websites visited and elements used there, as well as technical information such as
the browser used, the computer system used and information on usage times. If users
have given their consent to us or the providers of the services we use to collect
their location data, location data can also be processed.
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.
Settings/possibility of objection:
UXCam is provided by UXCam Inc, 814 Mission St, San Francisco, California, USA
("UXCam"). We use UXCam to create heatmaps, session recording and how users browse
across multiple pages.
- 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); Profiles with user-related
information (creating user profiles).
- Security measures: IP masking (pseudonymization of the IP
address).
Online marketing
We process personal data for online marketing purposes, which may include 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 and functions used. If users have consented to the
collection of their location data, this can also be processed.
The IP addresses of the users are also 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, clear 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 kindly 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, we can use so-called conversion measurements to 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.
- 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/behavioural profiling, use of cookies); Marketing; Profiles with
user-related information (creating user profiles).
- Security measures: IP masking (pseudonymization of the IP
address).
- 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)
Inter-territorial:https://optout.aboutads.info .
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 it could make it more
difficult to enforce the user's rights, for example.
Furthermore, user data is usually processed within social networks for market
research and advertising purposes. For example, usage 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: contact details (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;
Feedback (e.g. collecting feedback via online form); Marketing.
- Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f)
GDPR).
Further information on processing processes, procedures and
services:
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"). These can be, for example, graphics, videos or city maps
(hereinafter uniformly referred to as "content" ).
The integration always presupposes 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.
- Types of data processed: usage data (e.g. websites visited,
interest in content, access times); Meta/communication data (e.g. device
information, IP addresses); Inventory data (e.g. names, addresses); Contact
information (e.g. email, phone numbers); Content data (e.g. entries in online
forms); Location data (information about the geographical position of a device
or a person).
- Affected persons: users (e.g. website visitors, users of online
services).
- Purposes of processing: Provision of our online offer and
user-friendliness.
- Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f)
GDPR).
Further information on processing processes, procedures and
services:
- Integration of third-party software, scripts or frameworks (e.g.
jQuery):We integrate software into our online offer that we call up
from the servers of other providers (e.g. function libraries that we use for the
purpose of displaying or user-friendliness of our online offer). The respective
providers collect the IP address of the user and can process this for the
purpose of transmitting the software to the user's browser and for security
purposes, as well as for the evaluation and optimization of their offer. - We
integrate software into our online offer that we call up from servers of other
providers (e.g. function libraries that we use for the purpose of displaying or
user-friendliness of our online offer). The respective providers collect the IP
address of the user and can use this for the purposes of transmitting the
software to the user's browser and for security purposes,Legal
basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- Google Fonts (obtained from Google Server):Obtaining fonts (and
symbols) for the purpose of technically safe, maintenance-free and efficient use
of fonts and symbols with regard to topicality and loading times, their uniform
representation and consideration of possible license restrictions. The provider
of the fonts is informed of the IP address of the user 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) are transmitted
that are necessary for the provision of the fonts depending on the devices used
and the technical environment. This data can be processed on a server of the
font provider in the USA - When visiting our online offer, the user's browser
sends their browser HTTP requests to the Google Fonts Web API (ie a software
interface for retrieving the fonts). The Google Fonts Web API provides users
with the Google Fonts Cascading Style Sheets (CSS) and then the fonts specified
in the CCS. 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 the website visitors, as well as the
referrer URL (ie the web page where the Google font is to be displayed). IP
addresses are not logged or stored on Google servers and they 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 download fonts. This data is logged so that Google can determine how
often a particular font family is requested. The Google Fonts Web API requires
the user agent to customize the font that is generated for each browser type.
The user-agent is logged primarily for debugging and is used to generate
aggregate usage statistics that measure font family popularity. These aggregate
usage statistics are published on the Google Fonts Analytics page. Finally, the
referrer URL is logged so the data can be used for production maintenance and an
aggregated report can be generated on the top integrations 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
place targeted ads;Service provider: Google Ireland Limited,
Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis:
Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website:
https://fonts.google.com/ ; Privacy Policy:
https://policies.google.com/privacy ; Further
information: https://developers.google.com/fonts/faq/privacy?hl=de .
- Font Awesome (provided on own server): display of fonts and
symbols; Service provider: The Font Awesome icons are hosted on
our server, no data is transmitted to the provider of Font Awesome;
Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f)
GDPR).
- Google Maps: We integrate the maps of the service “Google Maps”
from the provider Google. The processed data may include, in particular, IP
addresses and location data of the users; Service Provider:
Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland;
Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f)
GDPR); Website: https://mapsplatform.google.com/ ; Privacy
Policy: https://policies.google.com/privacy .
- YouTube videos: video content; Service
provider: Google Ireland Limited, Gordon House, Barrow Street,
Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6
Para. 1 S. 1 lit. f) GDPR); Website: https://www.youtube.com ;
Privacy Policy: https://policies.google.com/privacy ; Objection
option (opt-out): opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de ,
settings for the display of advertisements: https://adssettings.google.com/authenticated .
Management, organization and support tools
We use services, platforms and software from other providers (hereinafter referred to
as “third-party providers”) for the purposes of organisation, management, planning
and the provision of our services. When selecting third-party providers and their
services, we observe the legal requirements.
In this context, personal data can be processed and stored on the servers of
third-party providers. Various data may be affected by this, which we process in
accordance with this data protection declaration. This data can include, in
particular, master data and contact details of users, data on transactions,
contracts, other processes and their content.
If users are referred to the third-party providers or their software or platforms as
part of communication, business or other relationships with us, the third-party
providers can process usage data and metadata for security purposes, for service
optimization or for marketing purposes. We therefore ask you to observe the data
protection notices of the respective third-party providers.
- 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: communication partners; Users (e.g. website
visitors, users of online services).
- Purposes of processing: provision of contractual services and
customer service; office and organizational procedures.
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 Article 6 Paragraph 1 lit. e or f GDPR;
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 withdrawal for consent: You have the right to withdraw
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 deletion and restriction of processing: You have the
right, in accordance with the legal requirements, to request that 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 supervisory authority: Without prejudice to any
other administrative or judicial remedy, you have the right to lodge a complaint
with a supervisory authority, in particular in the Member State of your habitual
residence, 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
provisions of 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.
- 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.
- Profiles with user-related information: The processing of
"profiles with user-related information", or "profiles" for short, includes any
type of automated processing of personal data, which consists of using this
personal data to determine certain personal aspects relating to a natural person
(depending on the type of profiling, different information regarding
demographics, behavior and interests, such as interaction with websites and
their content, etc.) can be analyzed, evaluated or predicted (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 known as web
analytics) is used 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.
- 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, behavior and interest
information with regard to the online offers used is stored in cookies or on
servers of the providers of the tracking technologies (so-called profiling).
This information can then be used, for example, to 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.