Data protection declaration

 

Premise

With the following data protection declaration, we would like to clarify which types of your personal data (hereinafter also briefly referred to as “data”) we process for which purposes and to what extent. The data protection declaration applies to all the processing of personal data we have carried out, both as part of the provision of our services as well as in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter referred to as “online offer”).
The terms used are not gender-specific.

Stand: 14. April 2023

Table of Contents

  • Preamble
  • Controller
  • Overview of Processing
  • Relevant Legal Bases
  • Security Measures
  • Transfer of Personal Data
  • Data Processing in Third Countries
  • Deletion of Data
  • Use of cookies
  • Business services
  • Provision of the online service and web hosting
  • Contact and inquiry management
  • Communication via messenger
  • Newsletter and electronic notifications
  • Advertising communication via email, mail, fax, or telephone
  • Web analysis, monitoring, and optimization
  • Online Marketing
  • Customer Reviews and Rating Processes
  • Presences in Social Networks (Social Media)
  • Plugins and Embedded Functions and Content
  • Changes and Updates to the Privacy Policy

Responsible Party

Distribution service Klevanskyy
Artem Klevanskyy
Philipsbornstraße 21
30165 Hanover
Germany

Email address:

info@verteilservice-klevanskyy.de

Phone:

0511 105 49 401 ● 0176. 239 92 734

Imprint:

https://www.verteilservice-klevanskyy.de/impressum/

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 data.
  • Location data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication, and procedural data.
  • Event data (Facebook).

Categories of data subjects

  • Customers.
  • Interested parties.
  • Communication partners.
  • Users.
  • Business and contractual partners.

Purposes of processing

  • Provision of contractual services and customer service.
  • Contact requests and communication.
  • Security measures.
  • Direct marketing.
  • Audience measurement.
  • Tracking.
  • Office and organizational procedures.
  • Conversion measurement.
  • Management and response to inquiries.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offering and user-friendliness.
  • Information technology infrastructure.

Relevant legal bases

Below you will find an overview of the GDPR legal bases on which we process personal data. Please note that in addition to the GDPR regulations, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 (1) (a) GDPR) – The data subject has given their consent to the processing of personal data concerning them for a specific purpose or several specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6 (1) (b) GDPR) – The processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.
  • Legal obligation (Art. 6 (1) (a) GDPR) 1 lit. c) GDPR) – Processing is necessary to fulfill a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 (1) (f) GDPR) – Processing is necessary to protect the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject which require protection of personal data prevail.

In addition to the data protection provisions of the GDPR, national data protection regulations apply in Germany. This includes, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The Federal Data Protection Act (BDSG) contains, in particular, special provisions on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and transmission and automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for the purposes of employment relationships (Section 26 BDSG), particularly with regard to the establishment, implementation, or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

Security Measures

We take appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, implementation costs, and the nature, scope, circumstances, and purposes of processing, as well as the varying likelihood 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.

These measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access, input, and transmission, ensuring availability, and segregation. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data, and responses to data threats. Furthermore, we consider the protection of personal data during the development and 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): To protect the data you transmit via our online service, we use TLS encryption. You can recognize such encrypted connections by the prefix https:// in your browser’s address bar.

Transmission of personal data

As part of our processing of personal data, it may happen that the data is transmitted to or disclosed to other bodies, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

Data transfer within the organization: We may transmit personal data to other bodies within our organization or grant them access to this data. If this transfer is for administrative purposes, the data is based on our legitimate business and operational interests or occurs if it is necessary to fulfill our contractual obligations or if the data subject’s consent or legal permission is available.

Data processing in third countries

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

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

Deletion of data

The data we process will be deleted in accordance with legal requirements as soon as the consents permitted for processing are revoked or other permissions expire (e.g., if the purpose of processing this data no longer applies or it is no longer required for the purpose). If the data is not deleted because it is required for other legally permissible purposes, its processing will be 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 retained for commercial or tax law reasons, or whose storage is necessary to assert, exercise, or defend legal claims or to protect the rights of another natural or legal person.

Our privacy policy may also contain further information on the storage and deletion of data that takes priority for the respective processing operations.

Newsletter

If you subscribe to our newsletter, we will regularly inform you by email about current offers, promotions, and news about our services. We need your email address to send it. Registration is done using the so-called double opt-in process, whereby you will receive a confirmation email after registration. The newsletter will only be sent after your active confirmation.

The legal basis for the processing of your data is your consent in accordance with Art. 6 (1) (a) GDPR. You can revoke your consent at any time – for example, via the unsubscribe link in the newsletter or by emailing us.

We use an external service provider for delivery. Your data will be used exclusively to send our newsletter and will not be shared with third parties.

Use of Cookies

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

Notes on Consent:We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, unless this is not required by law. In particular, consent is not required if the storage and retrieval of information, including cookies, is absolutely necessary to provide users with a telemedia service expressly requested by them (i.e., our online offering). Strictly necessary cookies generally include cookies with functions that serve to display and operate the online offering, load balancing, security, storing user preferences and options, or similar purposes related to providing the main and secondary functions of the online offering requested by users. Revocable consent will be clearly communicated to users and will contain information about the respective cookie usage.

Notes on data protection legal bases:The legal basis under data protection law for processing users’ personal data with the help of cookies depends on whether we request users’ consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g., in the commercial operation of our online offering and improving its usability) or, if this occurs as part of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We will explain the purposes for which we process cookies in the course of this privacy policy or as part of our consent and processing procedures.

Storage period: With regard to the storage period, a distinction is made between the following types of cookies:

  • Temporary cookies (also: session cookies):Temporary cookies are deleted at the latest after a user has left an online offering and closed their device (e.g., browser or mobile application).
  • Permanent cookies:Permanent cookies remain stored even after the device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g., when obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.

General information on revocation and objection (opt-out):Users can revoke their consent at any time and also object to processing in accordance with the legal requirements of Art. 21 GDPR. Users can also declare their objection via their browser settings, e.g., by deactivating the use of cookies (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites
https://optout.aboutads.info and https://www.youronlinechoices.com/.

  • Legal basis:Consent (Art. 6 (1) (a) GDPR).

Further information on processing procedures, methods, and services:

  • Processing of cookie data based on consent: We use a cookie consent management process within which users’ consent to the use of cookies, or the processing operations and providers specified in the cookie consent management process, can be obtained, managed, and revoked by users. The declaration of consent is saved so that it does not have to be requested again and so that consent can be proven in accordance with legal requirements. Storage can be done on the server side and/or in a cookie (so-called opt-in cookie or using comparable technologies) in order to assign consent to a user or their device. Subject to individual information about the providers of cookie management services, the following information applies: Consent can be stored for up to two years. A pseudonymous user identifier is created and stored along with the time of consent, information on the scope of the consent (e.g., which categories of cookies and/or service providers), as well as the browser, system, and device used. Legal basis: Consent (Art. 6 (1) (a) GDPR).

Business Services

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

We process this data to fulfill our contractual obligations. This includes, in particular, the obligations to provide the agreed services, any update obligations, and remedy in the event of warranty and other service disruptions. In addition, we process the data to protect our rights and for the purposes of the administrative tasks associated with these obligations, as well as for the company organization. Furthermore, we process the data based on our legitimate interests in proper and efficient business management as well as in security measures to protect our contractual partners and our business operations from misuse and compromise of their data, secrets, information, and rights (e.g., involving telecommunications, transport, and other auxiliary services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Within the framework of applicable law, we only disclose contractual partner data to third parties to the extent necessary for the aforementioned purposes or to fulfill legal obligations. The contractual partners will be informed about further forms of processing, e.g., for marketing purposes, within the framework of this privacy policy.

We will inform the contractual partners which data is required for the aforementioned purposes before or during data collection, e.g., in online forms, by special marking (e.g., colors) or symbols (e.g., asterisks, etc.), or in person.

We delete the data after the expiration of statutory warranty and similar obligations, i.e., generally after 4 years, unless the data is stored in a customer account, e.g., for as long as it must be retained for legal archiving reasons. The statutory retention period is ten years for documents relevant to tax law, as well as for commercial ledgers, inventories, opening balance sheets, annual financial statements, the work instructions necessary to understand these documents, and other organizational documents and accounting documents. Six years for received commercial and business letters and reproductions of sent commercial and business letters are required. This period begins at the end of the calendar year in which the last entry was made in the ledger, the inventory, opening balance sheet, annual financial statements, or management report was prepared, the commercial or business letter was received or sent, or the accounting document was created, the recording was made, or the other documents were created.

To the extent we use third-party providers or platforms to provide our services, the terms and conditions and privacy policy of the respective third-party providers or platforms apply to the relationship between users and the providers.
 

  • Types of data processed: Inventory data (e.g., names, addresses); payment data (e.g., bank details, invoices, payment history); contact data (e.g., email, telephone numbers); contract data (e.g., subject matter of the contract, term, customer category).
  • Data subjects: Interested parties; business and contractual partners.
  • Purposes of processing: Provision of contractual services and customer service; contact inquiries and communication; office and organizational procedures; Managing and responding to inquiries.
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Legal obligation (Art. 6 (1) (c) GDPR); Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing procedures, methods, and services:

  • Agency services:We process our customers’ data within the scope of our contractual services, which may include, for example, conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consulting services, and training services; Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).

Provision of the online service and web hosting

We process user data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or device.

  • Types of data processed: Usage data (e.g., websites visited, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
  • Data subjects:Users (e.g., website visitors, users of online services).
  • Purposes of processing:Provision of our online offering and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); Security measures.
  • Legal basis:Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing procedures, methods, and services:

  • Collection of access data and log files:Access to our online offering is logged in the form of so-called “server log files.” The server log files may include the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user’s operating system, the referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g., to avoid overloading the servers (particularly in the case of abusive attacks, so-called DDoS attacks), and to ensure server utilization and stability; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Deletion
    of data:
    Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is necessary for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified.
  • netcup: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacity); Service provider:netcup GmbH, Daimlerstraße 25, D-76185 Karlsruhe, Germany; Legal basis:Legitimate interests (Art. 6 (1) (f) GDPR); Website:
    https://www.netcup.de/; Privacy Policy:
    https://www.netcup.de/kontakt/datenschutzerklaerung.php; Contract Processing Agreement: https://www.netcup-wiki.de/wiki/Zusatzvereinbarung_zur_Auftragsverarbeitung.

Contact and Inquiry Management

When you contact us (e.g., by mail, contact form, email, telephone, or via social media), as well as within the framework of existing user and business relationships, the information provided by the person making the inquiry will be processed to the extent necessary to answer the contact inquiries and any requested measures.

  • Types of data processed: Contact details (e.g., email, telephone numbers); content data (e.g., entries in online forms); usage data (e.g., websites visited, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
  • Data subjects:Communication partners.
  • Purposes of processing:Contact inquiries and communication; administration and response to inquiries; feedback (e.g., collecting feedback via online form); provision of our online offering and user-friendliness.
  • Legal bases:Legitimate interests (Art. 6 (1) (f) GDPR); Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).

Further information on processing procedures, methods, and services:

  • Contact form:If users contact us via our contact form, email, or other communication channels, we process the data communicated to us in this context to process the communicated request; Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

Communication via Messenger

We use messengers for communication purposes and therefore ask you to note the following information regarding the functionality of the messengers, encryption, the use of communication metadata, and your options for objection.

You can also contact us via alternative means, e.g., by phone or email. Please use the contact options provided to you or the contact options provided within our online offering.

In the case of end-to-end encryption of content (i.e., the content of your message and attachments), we would like to point out that the communication content (i.e., the content of the message and attached images) is encrypted end-to-end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messenger with encryption enabled to ensure the encryption of the message content.

However, we would also like to point out to our communication partners that while the messenger providers cannot view the content, they can learn that and when communication partners communicate with us, as well as technical information about the device used by the communication partners and, depending on their device settings, location information (so-called metadata) is processed.
Notes on legal bases: If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and they contact us on their own initiative, for example, we use Messenger in our relationship with our contractual partners and in the context of contract initiation as a contractual measure, and in the case of other interested parties and communication partners, we use Messenger based on our legitimate interests in fast and efficient communication and in meeting the needs of our communication partners in communicating via Messenger. We would also like to point out that we will not transmit the contact details provided to us to Messenger for the first time without your consent.

  • Types of data processed: Contact details (e.g., email, telephone numbers); Usage data (e.g., websites visited, interest in content, – This text area must be activated with a premium license. – premiumtext premiumtext premiumtext ); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, – This text area must be activated with a premium license. – premiumtext premiumtext premiumtext ).
  • Data subjects:Communication partners.
  • Purposes of processing:Contact requests and communication; Direct marketing (e.g., by email or post).
  • Legal bases: Consent (Art. 6 (1) (a) GDPR); Legitimate interests (Art. 6 (1) (f) GDPR).

Newsletters and electronic notifications

We only send newsletters, emails, and other electronic notifications (hereinafter “newsletters”) with the recipient’s consent or legal permission. If the newsletter content is specifically described when registering for the newsletter, it is decisive for the user’s consent. Our newsletters also contain information about our services and us.

To subscribe to our newsletter, it is generally sufficient to provide your email address. However, we may ask you to provide a name for the purpose of addressing you personally in the newsletter, or other information if this is necessary for the purposes of the newsletter.

Double opt-in process:Subscription to our newsletter is generally carried out using a so-called double opt-in process. This means that after registration, you will receive an email asking you to confirm your registration. This confirmation is necessary to ensure that no one can register using someone else’s email address. Newsletter subscriptions are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation, as well as the IP address. Changes to your data stored by the shipping service provider are also logged.

Deletion and restriction of processing:We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove 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 objections, we reserve the right to store the email address in a block list (so-called “block list”) for this purpose alone.

The registration process is logged based on our legitimate interests for the purpose of proving its proper execution. If we commission a service provider to send emails, this is done on the basis of our legitimate interest in an efficient and secure delivery system.

Content:

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

  • Types of data processed: Inventory data (e.g., names, addresses); contact data (e.g., email, telephone numbers); Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
  • Data subjects:Communication partners.
  • Purposes of processing:Direct marketing (e.g., by email or post).
  • Legal basis:Consent (Art. 6 (1) (a) GDPR).
  • Opt-out option: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email.

Advertising Communication via Email, Mail, Fax, or Telephone

We process personal data for the purposes of advertising communication, which can be carried out via various channels, such as email, telephone, mail, or fax, in accordance with legal requirements.

Recipients have the right to revoke consent given at any time or to object to advertising communication at any time.

After revocation or objection, we will store the data required to prove previous authorization for contacting or sending for up to three years after the end of the year of 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. Based on our legitimate interest in permanently respecting the user’s revocation or objection, we also store the data necessary to avoid further contact (e.g., depending on the communication channel, email address, telephone number, name).

  • Types of data processed: Inventory data (e.g., names, addresses); contact data (e.g., email, telephone numbers).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g., by email or post).
  • Legal basis: Consent (Art. 6 (1) (a) GDPR); Legitimate interests (Art. 6 (1) (f) GDPR).

Web analysis, monitoring, and optimization

Web analysis (also known as “reach measurement”) is used to evaluate visitor flows to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, determine when our online offering or its functions or content are most frequently used or encourage reuse. We can also understand which areas require optimization.

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

Unless otherwise stated below, profiles, i.e., data summarized for a usage process, may be created for these purposes, and information may be stored in a browser or device and read from it. The information collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used, and information on usage times. If users have consented to the collection of their location data with us or with the providers of the services we use, location data may also be processed.

Users’ IP addresses are also stored. However, we use an IP masking process (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no real user data (such as email addresses or names) is stored for web analysis, A/B testing, and optimization; instead, pseudonyms are used. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.

  • Types of data processed: Usage data (e.g., websites visited, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, consent status).
  • Data subjects:Users (e.g., website visitors, users of online services).
  • Purposes of processing:Reach measurement (e.g., access statistics, recognition of recurring visitors); profiles with user-related information (creation of user profiles); tracking (e.g., interest-/behavior-based profiling, use of cookies); Provision of our online offering and user-friendliness.
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 (1) (a) GDPR).
  • Types of data processed: Inventory data (e.g., names, addresses); contact data (e.g., email, telephone numbers).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g., by email or post).
  • Legal basis: Consent (Art. 6 (1) (a) GDPR); Legitimate interests (Art. 6 (1) (f) GDPR).

Web analysis, monitoring, and optimization

Web analysis (also known as “reach measurement”) is used to evaluate visitor flows to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, determine when our online offering or its functions or content are most frequently used or encourage reuse. We can also understand which areas require optimization.

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

Unless otherwise stated below, profiles, i.e., data summarized for a usage process, may be created for these purposes, and information may be stored in a browser or device and read from it. The information collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used, and information on usage times. If users have consented to the collection of their location data with us or with the providers of the services we use, location data may also be processed.

Users’ IP addresses are also stored. However, we use an IP masking process (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no real user data (such as email addresses or names) is stored for web analysis, A/B testing, and optimization; instead, pseudonyms are used. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.

  • Types of data processed: Usage data (e.g., websites visited, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, consent status).
  • Data subjects:Users (e.g., website visitors, users of online services).
  • Purposes of processing:Reach measurement (e.g., access statistics, recognition of recurring visitors); profiles with user-related information (creation of user profiles); tracking (e.g., interest-/behavior-based profiling, use of cookies); Provision of our online offering and user-friendliness.
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 (1) (a) 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 users’ potential interests, as well as 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 to store user information relevant to the presentation of the aforementioned content. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information, such as the browser used, the computer system used, as well as information on usage times and functions used. If users have consented to the collection of their location data, this can also be processed.

Users’ IP addresses are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no user data (such as email addresses or names) is stored as part of the online marketing process, but rather pseudonyms. This means that neither we nor the providers of the online marketing processes know the actual identity of the users, only the information stored in their profiles.

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

In exceptional cases, clear data can be assigned to profiles. This is the case, for example, if the users are members of a social network whose online marketing method we use, and the network links the users’ profiles with the aforementioned information. Please note that users can enter into additional agreements with the providers, e.g., by giving their consent during registration.

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

Unless otherwise stated, we ask you to 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, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest-based/behavioral profiling, use of cookies); marketing; Profiles with user-related information (creation of user profiles); conversion measurement (measurement of the effectiveness of marketing measures).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 (1) (a) GDPR); Legitimate interests (Art. 6 (1) (f) GDPR).
  • Opt-out option:We refer to the privacy policy of the respective providers and the opt-out options specified for the providers (so-called “opt-out”). If no explicit opt-out option has been provided, you have the option of deactivating cookies in your browser settings. However, this may limit the functions of our online offering. We therefore also recommend the following opt-out options, which are summarized for the respective regions: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-regional: https://optout.aboutads.info.

Further information on processing procedures, methods, and services:

  • Google Ads and Conversion Measurement:Online marketing methods for the purpose of placing content and advertisements within the service provider’s advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who are likely to be interested in the advertisements. We also measure the conversion of the advertisements, i.e., whether users have used them as an opportunity to interact with the advertisements and use the advertised offers (so-called conversion). However, we only receive anonymous information and no personal information about individual users; Service provider:Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 (1) (a) GDPR), Legitimate interests (Art. 6 (1) (f) GDPR); Website:
    https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Further information:Types of processing and data processed: https://privacy.google.com/businesses/adsservices; Data processing conditions between controllers and standard contractual clauses for third-country transfers of data: https://business.safety.google/adscontrollerterms.

Customer reviews and rating processes

We participate in review and rating processes to evaluate, optimize, and promote our services. If users rate us via the participating rating platforms or processes or otherwise provide feedback, the providers’ general terms and conditions of use and privacy policies also apply. As a rule, rating also requires registration with the respective providers.

To ensure that the reviewers have actually used our services, we transmit, with the customer’s consent, the necessary data regarding the customer and the service used to the respective rating platform (including name, email address, and order number or item number). This data is used solely to verify the user’s authenticity.

  • Types of data processed: Contract data (e.g., subject matter of the contract, term, customer category); usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
  • Data subjects: Customers; users (e.g., website visitors, users of online services).
  • Purposes of processing: Feedback (e.g., collecting feedback via online form); Marketing.
  • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing procedures, methods, and services:

  • Rating widget:We integrate so-called “rating widgets” into our online offering. A widget is a functional and content element integrated into our online offering that displays variable information. It can be displayed, for example, in the form of a seal or similar element, sometimes also called a “badge.” The corresponding content of the widget is displayed within our online offering, but is retrieved at that moment from the servers of the respective widget provider. This is the only way to always show the most current content, especially the most recent rating. For this to happen, a data connection must be established from the website accessed within our online offering to the server of the widget provider, and the widget provider receives certain technical data (access data, including IP address) that is necessary so that the content of the widget can be delivered to the user’s browser. Furthermore, the widget provider receives information that users have visited our online offering. This information can be stored in a cookie and used by the widget provider to identify which online offerings that participate in the rating process have been visited by the user. The information can be stored in a user profile and used for advertising or market research purposes; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

Presences in social networks (social media)

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

We would like to point out that user data may be processed outside the European Union. This may result in risks for users, for example, because it could make it more difficult to enforce their rights.

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

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

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

  • Types of data processed: Contact data (e.g., email, telephone numbers); content data (e.g., entries in online forms); usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Contact inquiries and communication; Feedback (e.g., collecting feedback via online form); Marketing.
  • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing procedures, methods and services:

  • Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website:
    https://www.instagram.com; Privacy Policy:
    https://instagram.com/about/legal/privacy.
  • Facebook Pages: Profiles within the Facebook social network – We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not further processing) of data from visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content users view or interact with or the actions they take (see “Things you and others do and provide” in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see “Device information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, so-called “Page Insights”, to page operators to help them understand how people interact with their pages and associated content. We have entered into a special agreement with Facebook (“Information about Page Insights”, https://www.facebook.com/legal/terms/page_controller_addendum), which specifically regulates the security measures Facebook must observe and in which Facebook has agreed to fulfill data subject rights (i.e., users can, for example, direct information or deletion requests directly to Facebook). User rights (particularly to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information about Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website:
    https://www.facebook.com; Privacy Policy:
    https://www.facebook.com/about/privacy; Standard contractual clauses (ensuring data protection level in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Further information: Joint controllership agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data. The joint responsibility is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, particularly regarding the transfer of data to the parent company Meta Platforms, Inc. in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
  • LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website:
    https://www.linkedin.com; Privacy Policy:
    https://www.linkedin.com/legal/privacy-policy; Data Processing Agreement: https://legal.linkedin.com/dpa; Standard contractual clauses (ensuring data protection level in third countries): https://legal.linkedin.com/dpa; Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • Xing: Social network; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website:
    https://www.xing.de; Privacy Policy:
    https://privacy.xing.com/de/datenschutzerklaerung.

Plugins and embedded functions and content

We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These can include, for example, graphics, videos, or city maps (hereinafter collectively referred to as “content”).

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

  • Types of data processed: Usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status); location data (information about the geographical position of a device or person); Event Data (Facebook) (“Event Data” is data that can be transmitted by us to Facebook, e.g., via Facebook Pixel (via apps or other means) and relates to individuals or their actions. This data includes, for example, information about visits to websites, interactions with content, functions, app installations, product purchases, etc.; the event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); event data does not contain the actual content (such as comments written), login information, or contact information (i.e., no names, email addresses, or phone numbers). Event data is deleted by Facebook after a maximum of two years; the target groups created from it are deleted when our Facebook account is deleted).
  • Data subjects: Users (e.g., website visitors, users of Online services).
  • Purposes of processing: Provision of our online services and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Consent (Art. 6 (1) (a) GDPR).

Further information on processing methods, procedures, and services:

  • Facebook plugins and content:Facebook social plugins and content – This may include, for example, content such as images, videos, or texts and buttons that users can use to share content from this online offering within Facebook. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/ – We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt during transmission (but not the further processing) of “event data” that Facebook collects or receives during transmission using the Facebook social plugins (and content embedding functions) running on our online offering for the following purposes: a) Displaying content and advertising information that corresponds to the presumed interests of users; b) Delivering commercial and transaction-related messages (e.g., addressing users via Facebook Messenger); c) Improving ad delivery and personalizing features and content (e.g., improving the recognition of which content or advertising information presumably corresponds to users’ interests). We have concluded a special agreement with Facebook (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum), which specifically regulates the security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the rights of those affected (i.e., users can, for example, submit information or deletion requests directly to Facebook). Note: If Facebook provides us with metrics, analyses, and reports (which are aggregated, i.e., do not contain any information about individual users and are anonymous to us), this processing is not carried out under joint controllership, but on the basis of a data processing agreement (“Data Processing Terms”, https://www.facebook.com/legal/terms/dataprocessing), the “Data Security Terms” (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of standard contractual clauses (“Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). Users’ rights (in particular the right to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider:Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis:Consent (Art. 6 (1) (a) GDPR); Website: https://www.facebook.com Privacy Policy:
    https://www.facebook.com/about/privacy.
  • Google Maps:We integrate the maps of the “Google Maps” service provided by Google. The data processed may include, in particular, users’ IP addresses and location data; Service provider:Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis:Legitimate interests (Art. 6 (1) (f) GDPR); Website:
    https://mapsplatform.google.com/; Privacy Policy:
    https://policies.google.com/privacy.

Changes and Updates to the Privacy Policy

We ask you to regularly inform yourself about the content of our Privacy Policy. We will adapt the Privacy Policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g., consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this Privacy Policy, please note that the addresses may change over time and ask you to check the information before contacting us.