Introduction

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

This website is operated as part of the online offering of Dr. Werner & Partners.

Status: 28 January 2020

Responsible

E-mail address: [email protected]

Imprint: https://www.drwerner.com/en/imprint/

Overview of processing

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

Types of data processed

• Inventory data (e.g. names, addresses).
• Content data (e.g. text entries, photographs, videos).
• Contact data (e.g. email, telephone numbers).
• Meta/communication data (e.g. device information, IP addresses).
• Usage data (e.g. websites visited, interest in content, access times).
• Location data (data indicating the location of an end user’s device).
• Contract data (e.g. subject matter of contract, term, customer category).
• Payment data (e.g. bank details, invoices, payment history).

Categories of data subjects

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

Purposes of processing

• Affiliate tracking.
• Provision of our online services and user experience.
• Visitor action evaluation.
• Office and organisational procedures.
• Cross-device tracking (processing user data across devices for marketing purposes).
• Direct marketing (e.g. by email or post).
• Feedback (e.g. collecting feedback via online form).
• Interest-based and behavioural marketing.
• Contact enquiries and communication.
• Conversion measurement (measuring the effectiveness of marketing activities).
• Profiling (creating user profiles).
• Remarketing.
• Reach measurement (e.g. access statistics, recognition of returning visitors).
• Security measures.
• Tracking (e.g. interest/behavioural profiling, use of cookies).
• Contractual performance and service.
• Managing and responding to enquiries.
• Target group formation (determination of target groups relevant for marketing purposes or other output of content).

Relevant legal basis

In the following, we share the legal bases of the General Data Protection Regulation (DSGVO) on the basis of which we process personal data. Please note that in addition to the regulations of the DSGVO, the national data protection regulations in your or our country of residence and domicile may apply.

• Consent (Art. 6 para. 1 p. 1 lit. a DSGVO) – The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
• Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO) – Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures carried out at the data subject’s request.
• Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
• Protection of vital interests (Art. 6 para. 1 p. 1 lit. d. DSGVO) – Processing is necessary to protect vital interests of the data subject or another natural person.
• Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO) – Processing is necessary to protect the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

Security measures

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

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. We also have procedures in place to ensure the exercise of data subjects’ rights, the deletion of data and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

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

Transmission and disclosure of personal data

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

Data transfer within the organisation: We may transfer personal data to other bodies within our organisation or grant them access to this data. Where this transfer is for administrative purposes, the transfer of data is based on our legitimate business and operational interests or is made where it is necessary for the performance of our contract-related obligations or where we have obtained the consent of the data subjects or legal permission.

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 takes place in the context of using third-party services or disclosing or transferring data to other persons, entities or companies, this will only be done in accordance with legal requirements.

Subject to explicit consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognised level of data protection, which includes US processors certified under the “Privacy Shield”, or on the basis of special guarantees, such as contractual obligation through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

Use of cookies

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

The following cookie types and functions are distinguished:

• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
• Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users used for range measurement or marketing purposes can be stored in such a cookie.
• First-party cookies: First-party cookies are set by ourselves.
  Third-party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
• Necessary (also: essential or absolutely necessary) cookies: Cookies may, on the one hand, be absolutely necessary for the operation of a website (e.g. to store logins or other user input or for security reasons).
• Statistical, marketing and personalisation cookies: Furthermore, cookies are usually also used in the context of range measurement and when a user’s interests or behaviour (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that matches their potential interests. This procedure is also referred to as “tracking”, i.e. following the potential interests of users. . Insofar as we use cookies or “tracking” technologies, we will inform you separately in our data protection declaration or in the context of obtaining consent.

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

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

Processing of cookie data on the basis of consent: Before we process or have data processed in the context of the use of cookies, we ask users for consent that can be revoked at any time. Before consent has been given, cookies are only used if they are necessary for the operation of our online offer. Their use is based on our interest and the interest of the users in the expected functionality of our online offer.

Cookie settings/options for objection:

Data protection settings

• Types of data processed: Usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Data subjects: Users (e.g. website visitors, users of online services).
• Legal grounds: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Commercial and business services

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

We process this data to fulfil our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as the entrepreneurial organisation. We only pass on the data of the contractual partners to third parties within the framework of the applicable law to the extent that this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or with the consent of the contractual partners (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.

We inform the contractual partners which data is required for the aforementioned purposes before or in the course of data collection, e.g. in online forms, by means of special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.

We delete the data after the expiry of legal warranty and comparable obligations, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. as long as it must be kept for legal archiving reasons (e.g. for tax purposes generally 10 years). We delete data disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, generally after the end of the order.

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

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

If customers have terminated their customer account, the data relating to the customer account will be deleted, unless their retention is required for legal reasons. It is the responsibility of customers to back up their data when their customer account is terminated.

Shop and e-commerce: We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and associated services, as well as their payment and delivery or execution.

The information required is identified as such in the order or similar purchase process and includes the information required for delivery or provision and billing, as well as contact information for consultation.

Education and training services: We process the data of the participants of our education and training offers (uniformly referred to as “trainees”) in order to be able to provide our training services to them. The data processed in this context, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and training relationship. The forms of processing also include the performance assessment and evaluation of our services and those of the teachers.

In the course of our activities, we may also process special categories of data, in particular information on the health of students and trainees as well as data revealing ethnic origin, political opinions, religious or philosophical beliefs. For this purpose, we obtain the explicit consent of the trainees, if required, and otherwise process the special categories of data only if it is necessary for the provision of the training services, for the purposes of health care, social protection or the protection of vital interests of the trainees.

If it is necessary for the fulfilment of our contract, for the protection of vital interests or required by law, or if the trainees have given their consent, we disclose or transfer the trainees’ data to third parties or agents, such as authorities or in the field of IT, office or comparable services, in compliance with the requirements of professional law.

Offer of software and platform services: We process the data of our users, registered users and any test users (hereinafter uniformly referred to as “users”) in order to be able to provide our contractual services to them and on the basis of legitimate interests in order to ensure the security of our offer and to be able to develop it further. The required information is identified as such in the context of the order, purchase order or comparable contract conclusion 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.

Events: We process the data of the participants of the events offered or organised by us, events and similar activities (hereinafter uniformly referred to as “participants” and “events”) in order to enable them to participate in the events and to take advantage of the services or promotions associated with participation.

Insofar as we process health-related data, religious, political or other special categories of data in this context, this is done within the scope of disclosure (e.g. in the case of thematically oriented events or serves health care, safety or is done with the consent of the persons concerned).

The required information is identified as such in the context of the order, purchase order or comparable contract conclusion 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. Insofar as we obtain access to information of the end customers, employees or other persons, we process this in accordance with the legal and contractual requirements.

Further information on commercial services: We process the data of our customers and clients (hereinafter uniformly referred to as “customers”) in order to enable them to select, purchase or commission the chosen services or works and related activities as well as their payment and delivery or execution or performance.

The information required is identified as such in the context of the conclusion of the order, purchase order or comparable contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations.

Types of data processed: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

• Data subjects: Interested parties, business and contractual partners, customers.
• Purposes of processing: Contractual performance and service, contact requests and communication, office and organisational procedures, administration and response to requests, security measures.
• Legal basis: Contractual performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Use of online marketplaces for e-commerce

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 procedures used on the platforms for range measurement and interest-based marketing.

• Types of data processed: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Data subjects: Customers.
• Purposes of processing: Contractual performance and service.
• Legal basis: Contractual performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

• Digistore24: Online marketplace for e-commerce; Service provider: Digistore24 GmbH, St.-Godehard-Straße 32, 31139 Hildesheim, Germany; website: https://www.digistore24.com/; privacy policy: https://www.digistore24.com/de/home/extern/cms/page/frontend/legal/privacy.
• elopage: Online marketplace for e-commerce; Service provider: elopay GmbH, Skalitzer Straße 138, 10999 Berlin, Germany, Germany; Website: https://elopage.com/; Privacy policy: https://elopage.com/privacy.

Payment service provider

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

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

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

• Types of data processed: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), contact data (e.g. e-mail, telephone numbers).
• Data subjects: Customers, prospective customers.
• Purposes of processing: Contractual performance and service.
• Legal grounds: Contractual performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services and service providers used:

• American Express: payment services; service providers: American Express Europe S.A., Theodor-Heuss-Allee 112, 60486 Frankfurt am Main, Germany; Website: https://www.americanexpress.com/de; Privacy Policy: https://www.americanexpress.com/de/legal/online-datenschutzerklarung.html.
• Apple Pay: Payment services; Service provider: Apple Inc, Infinite Loop, Cupertino, CA 95014, USA; Website: https://www.apple.com/de/apple-pay/; Privacy policy: https://www.apple.com/legal/privacy/de-ww/.
• Klarna / Sofortüberweisung: Payment services; Service provider: Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden; Website: https://www.klarna.com/de; Privacy policy: https://www.klarna.com/de/datenschutz.
• Mastercard: payment services; service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; website: https://www.mastercard.de/de-de.html; privacy policy: https://www.mastercard.de/de-de/datenschutz.html.
• PayPal: Payment services and solutions (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; website: https://www.paypal.com/de; privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
• Visa: payment services; service provider: Visa Europe Services Inc, London Branch, 1 Sheldon Square, London W2 6TT, UK; website: https://www.visa.de; privacy policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html.

Registration and login

Users can create a user account. As part of the registration process, users are provided with the required mandatory information and this information is processed for the purposes of providing the user account on the basis of contractual obligation. The processed data includes in particular the login information (name, password and an e-mail address). The data entered during registration is used for the purposes of using the user account and its purpose.

Users may be informed by e-mail about processes relevant to their user account, such as technical changes. If users have terminated their user account, their data relating to the user account will be deleted, subject to any legal obligation to retain it. It is the responsibility of the users to save their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract.

Within the scope of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorised use. As a matter of principle, this data is not passed on to third parties unless it is necessary for the prosecution of our claims or there is a legal obligation to do so.

Online forum: Participation in the forum requires registration, in which, subject to other details in the registration form, a or your name, a password and the e-mail address to which the access data will be sent must be provided. For security reasons, the password should be state of the art, i.e. complicated (users will be advised of this during registration if necessary) and should not be used elsewhere. The contributions in the forum are visible to the public, unless their visibility is restricted to certain members or groups of members. The contributions of the authors are stored with their name, if registered or indicated, the time and the content of the entry. In the case of registrations and when writing entries, the IP addresses of the users are also stored in the event that the entries should have inadmissible content and the IP addresses could be used for legal prosecution. The responsible person reserves the right to delete the registrations and entries on the basis of an appropriate consideration.

• Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Contractual performance and service, security measures, administration and response to enquiries.
• Legal grounds: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Contractual performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data are processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.

Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.

Furthermore, we reserve the right, on the basis of our legitimate interests, to process users’ details for the purpose of spam detection.

On the same legal basis, we reserve the right to store the IP addresses of users for the duration of surveys and to use cookies in order to avoid multiple voting.

The personal information provided in the context of comments and contributions, any contact and website information as well as the content-related information will be permanently stored by us until the user objects.

Comment subscriptions: Follow-up comments can be subscribed to by users with their consent. Users will receive a confirmation email to verify that they are the owner of the email address entered. Users can unsubscribe from ongoing comment subscriptions at any time. The confirmation email will include instructions on how to unsubscribe. For the purposes of proving users’ consent, we store the time of subscription along with users’ IP address and delete this information when users unsubscribe.

You can unsubscribe at any time, i.e. withdraw your consent. We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to prove consent was previously given. The processing of this data is limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.

Retrieval of WordPress emojis and smilies: Within our WordPress blog, graphical emojis (or smilies), i.e. small graphic files expressing emotions, are used for the purpose of efficient integration of content elements, obtained from external servers. The providers of the servers collect the IP addresses of the users. This is necessary so that the emoji files can be transmitted to the users’ browsers.

Akismet anti-spam check: We use the “Akismet” service based on our legitimate interests. With the help of Akismet, comments from real people are distinguished from spam comments. For this purpose, all comment details are sent to a server in the USA, where they are analysed and stored for four days for comparison purposes. If a comment has been classified as spam, the data is stored beyond this time. This information includes the name entered, the e-mail address, the IP address, the comment content, the referrer, information on the browser used as well as the computer system and the time of the entry.

Users are welcome to use pseudonyms or to refrain from entering their name or email address. They can completely prevent the transmission of data by not using our comment system. That would be a shame, but unfortunately we don’t see any alternatives that work just as effectively.

Profile pictures from Gravatar: We use the service Gravatar within our online offer and especially in the blog.Gravatar is a service where users can register and leave profile pictures and their email addresses. If users leave posts or comments on other online presences (especially blogs) with the respective email address, their profile pictures can be displayed next to the posts or comments. For this purpose, the email address provided by users is transmitted to Gravatar in encrypted form for the purpose of checking whether a profile is stored for it. This is the sole purpose of the transmission of the email address. It is not used for other purposes, but is deleted afterwards.

The use of Gravatar is based on our legitimate interests, as we use Gravatar to offer post and comment authors the opportunity to personalise their posts with a profile picture.

By displaying the images, Gravatar obtains the IP address of users, as this is necessary for a communication between a browser and an online service.

If users do not want a user image linked to their Gravatar email address to appear in the comments, they should use an email address that is not on file with Gravatar to comment. We also point out that it is also possible to use an anonymous email address or no email address at all if users do not want their email address to be sent to Gravatar. Users can completely prevent the transmission of data by not using our commenting system.

• Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. email, phone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), contract data (e.g. subject matter of contract, duration, customer category).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Contractual performance and service, feedback (e.g. collecting feedback via online form), security measures, managing and responding to enquiries, contact requests and communication, providing our online service and user friendliness.
• Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO), Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Protection of vital interests (Art. 6 para. 1 p. 1 lit. d. DSGVO).

Services used and service providers:

• Retrieval of WordPress emojis and smilies: Retrieval of WordPress emojis and smilies; service provider: Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA; Website: https://automattic.com; Privacy Policy: https://automattic.com/privacy.
• Akismet Anti-Spam Check: Akismet Anti-Spam Check; Service provider: Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA; Website: https://automattic.com; Privacy Policy: https://automattic.com/privacy.
• Profile pictures from Gravatar: Profile pictures; Service provider: Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA; Website: https://automattic.com; Privacy policy: https://automattic.com/privacy.
• Wordfence: Firewall and security and error detection functions; Service provider: Defiant, Inc, 800 5th Ave Ste 4100, Seattle, WA 98104, USA; website: https://www.wordfence.com; privacy policy: https://www.wordfence.com/privacy-policy/; standard contractual clauses (ensuring level of data protection for third country processing): https://www.wordfence.com/gdpr/dpa.pdf.

Contacting

When contacting us (e.g. via contact form, email, telephone or via social media), the information provided by the inquiring person is processed to the extent necessary to respond to the contact requests and any requested action.

The response to contact enquiries in the context of contractual or pre-contractual relationships is carried out to fulfil our contractual obligations or to respond to (pre)contractual enquiries and otherwise on the basis of the legitimate interests in responding to the enquiries.

• Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Data subjects: Communication partners.
• Purposes of processing: contact requests and communication.
• Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Surveys and interviews

The surveys and polls we conduct (hereinafter “surveys”) are evaluated anonymously. Personal data is only processed insofar as this is necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address in order to display the survey in the user’s browser or to enable the survey to be resumed with the aid of a temporary cookie (session cookie)) or users have consented to this.

Notes on legal basis: If we ask participants to consent to the processing of their data, this is the legal basis for the processing; otherwise, the processing of participants’ data is based on our legitimate interests in conducting an objective survey.

• Types of data processed: contact data (e.g. email, phone numbers), content data (e.g. text input, photographs, videos), usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Data subjects: Communication partners, users (e.g. website visitors, users of online services).
• Purposes of processing: contact requests and communication, direct marketing (e.g. by email or post), tracking (e.g. interest/behavioural profiling, use of cookies), feedback (e.g. collecting feedback via online form).
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Provision of the online offer and web hosting

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

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

E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of recognising SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption procedure is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

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

• Types of data processed: Content data (e.g. text entries, photographs, videos), usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Data subjects: Users (e.g. website visitors, users of online services).
• Legal grounds: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Cloud services

We use software services accessible via the Internet and running on the servers of their providers (so-called “cloud services”, also referred to as “software as a service”) for the following purposes: document storage and management, calendar management, sending e-mails, spreadsheets and presentations, exchanging documents, content and information with specific recipients or publishing web pages, forms or other content and information, as well as chats and participation in audio and video conferences.

In this context, personal data may be processed and stored on the servers of the providers to the extent that these are part of communication processes with us or are otherwise processed by us as set out in the context of this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents. The cloud service providers also process usage data and metadata used by them for security purposes and service optimisation.

If we use the cloud services to provide forms or other documents and content to other users or publicly accessible websites, the providers may store cookies on the users’ devices for the purpose of web analysis or to remember the users’ settings (e.g. in the case of media control).

Notes on legal bases: Where we ask for consent to use cloud services, the legal basis for processing is consent. Furthermore, their use may be a component of our (pre)contractual services, provided that the use of the cloud services has been agreed within this framework. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient and secure management and collaboration processes).

• Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. email, phone numbers), content data (e.g. text input, photographs, videos), usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Data subjects: Customers, employees (e.g. employees, applicants, former employees), prospective customers, communication partners.
• Purposes of processing: Office and organisational procedures.
• Legal grounds: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

• Microsoft Cloud Services: cloud storage services; service providers: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Website: http://microsoft.com/de-de; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, Security notices: https://www.microsoft.com/de-de/trustcenter; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active.

Newsletter and broad communication

We send newsletters, e-mails and other electronic notifications (hereinafter “newsletters”) only with the consent of the recipients or with legal permission. If the contents of a newsletter are specifically described in the course of registration, they are decisive for the consent of the users. In addition, our newsletters contain information about our services and us.

In order to subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name, for the purpose of personal address in the newsletter, or further details, if these are necessary for the purposes of the newsletter.

Double opt-in procedure: The registration for our newsletter is always carried out in a so-called double opt-in procedure. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other people’s e-mail addresses. 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 the storage of the registration and confirmation time as well as the IP address. Changes to your data stored with the dispatch service provider are also logged.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove consent formerly given. The processing of this data will be limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a blacklist for this purpose alone.

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

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

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

Performance measurement: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server or, if we use a shipping service provider, from their server when the newsletter is opened. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and the time of the retrieval, are initially collected.

This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our intention nor, if used, that of the dispatch service provider to observe individual users. The evaluations serve us rather to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

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

Unfortunately, a separate revocation of the performance measurement is not possible; in this case, the entire newsletter subscription must be cancelled or revoked.

Prerequisite for the use of free services: Consent to the sending of mailings can be made dependent as a prerequisite for the use of free services (e.g. access to certain content or participation in certain promotions). If users wish to take advantage of the free service without subscribing to the newsletter, please contact us.

• Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
• Data subjects: Communication partners, users (e.g. website visitors, users of online services).
• Purposes of processing: direct marketing (e.g. by e-mail or post), contractual performance and service.
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
• Opt-out: 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 cancel the newsletter either at the end of each newsletter or you can use one of the contact options given above, preferably e-mail, for this purpose.

Services used and service providers:

• Mailchimp: Email marketing platform; Service provider: “Mailchimp” – Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Website: https://mailchimp.com; Privacy policy: https://mailchimp.com/legal/privacy/; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active.

Promotional communication via e-mail, post, fax or telephone

We process personal data for the purposes of promotional communication, which may be carried out via various channels, such as e-mail, telephone, post or fax, in accordance with the legal requirements.

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

After revocation or objection, we may store the data required to prove consent for up to three years based on our legitimate interests before deleting it. The processing of this data is limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.

• Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
• Data subjects: Communication partners.
• Purposes of processing: direct marketing (e.g. by e-mail or post).
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Web analysis and optimisation

Web analysis (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the reach analysis, we can, for example, recognise at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimisation.

In addition to web analysis, we may also use test procedures, e.g. to test and optimise different versions of our online offer or its components.

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

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

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

• Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behaviour-based profiling, use of cookies), visit action evaluation, profiling (creation of user profiles), interest-based and behavioural marketing.
• Security measures: IP masking (pseudonymisation of the IP address).
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

• Google Optimize: Use of Google Analytics data for the purposes of improving areas of our online offering and better aligning our marketing efforts with potential user interests; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://optimize.google.com; Privacy policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; Opt-out: Opt-out plugin: http://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertising: https://adssettings.google.com/authenticated.
• Jetpack (WordPress Stats): Jetpack offers analysis – functions for WordPress software. Service provider: Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA; website: https://automattic.com; security measures: IP masking (pseudonymisation of IP address); Privacy policy: https://automattic.com/privacy, Cookies policy: https://jetpack.com/support/cookies.

Online marketing

We process personal data for online marketing purposes, which may include, in particular, marketing advertising space or displaying promotional and other content (collectively, “content”) based on users’ potential interests and measuring its effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which the information about the user relevant to the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed.

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

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

Exceptionally, 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 procedure we use and the network links the profiles of the users in the aforementioned data. We ask you to note that users can make additional agreements with the providers, e.g. by giving their consent as part of the registration process.

In principle, we only receive access to summarised information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to a conclusion of a contract with us. The conversion measurement is used solely to analyse the success of our marketing measures.

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

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

Facebook pixel: With the help of the Facebook pixel, it is possible for Facebook, on the one hand, to determine the visitors to our online offer as a target group for the display of advertisements (so-called “Facebook ads”).

Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those users on Facebook and within the services of partners cooperating with Facebook (so-called “Audience Network” https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products that are evident from the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of the users and do not have a harassing effect. The Facebook Pixel also allows us to track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook ad (so-called “conversion measurement”).

• Types of data processed: Usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (data indicating the location of an end user’s device).
• Data subjects: Users (e.g. website visitors, users of online services), prospective customers.
• Purposes of processing: tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, visit action evaluation, interest-based and behavioural marketing, profiling (creating user profiles), conversion measurement (measuring the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors), targeting (determining target groups relevant for marketing purposes or otherwise outputting content), cross-device tracking (processing user data across devices for marketing purposes).
• Security measures: IP masking (pseudonymisation of the IP address).
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
• Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the possibilities of objection given to the providers (so-called “opt-out”). If no explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary 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-territory: http://optout.aboutads.info.

Services used and service providers:

• Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface (and thus integrate Google Analytics and other Google marketing services into our online offering, for example). The tag manager itself (which implements the tags) does not process any personal data of the users. With regard to the processing of users’ personal data, please refer to the following information on Google services. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent Company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
• Google Analytics: Online marketing and web analysis; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com/intl/de/about/analytics/; privacy policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; opt-out: opt-out plugin: http://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.
• Google Ads and conversion measurement: We use the online marketing procedure “Google Ads” to place ads in the Google advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. We also measure the conversion of the ads. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page marked with a so-called “conversion tracking tag”. However, we ourselves do not receive any information with which users can be identified. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
• Facebook Pixel: Facebook Pixel; Service Provider: https://www.facebook.com, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, Parent Company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Opt-Out: https://www.facebook.com/settings?tab=ads.
• LinkedIn: Insights Tag / Conversion Measurement; Service Provider: LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA; website: https://www.linkedin.com; security measures: IP masking (pseudonymisation of the IP address); Privacy policy: https://www.linkedin.com/legal/privacy-policy, Cookie policy: https://www.linkedin.com/legal/cookie_policy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active; Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Affiliate programmes and affiliate links

We include so-called affiliate links or other references (which may include discount codes, for example) to the offers and services of third-party providers in our online offer (collectively referred to as “affiliate links”). If users follow the Affiliate Links or subsequently take advantage of the offers, we may receive a commission or other benefits from those third parties (collectively, “Commission”).

In order to be able to track whether users have taken advantage of the offers of an affiliate link used by us, it is necessary that the respective third-party providers learn that the users have followed an affiliate link used within our online offer. The assignment of the affiliate links to the respective business transactions or to other actions (e.g. purchases) serves the sole purpose of commission accounting and will be cancelled as soon as it is no longer necessary for the purpose.

For the purposes of the aforementioned allocation of the affiliate links, the affiliate links may be supplemented by certain values which are a component of the link or may be stored elsewhere, e.g. in a cookie. The values may include in particular the source website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer and an online identifier of the user.

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

Types of data processed: contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Affiliate tracking.
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services and service providers used:

• Digistore24 affiliate programme: Service provider: Digistore24 GmbH, St.-Godehard-Straße 32, 31139 Hildesheim, Germany; Website: https://www.digistore24.com; Privacy policy: https://www.digistore24.com/page/privacy.

Evaluation platforms

We participate in rating procedures in order to evaluate, optimise and promote our services. If users rate us or otherwise provide feedback via the participating rating platforms or procedures, the General Terms and Conditions of Business or Use and the data protection information of the providers also apply. As a rule, the rating also requires registration with the respective providers.

In order to ensure that the persons rating have actually used our services, we transmit, with the consent of the customers, the data required for this with regard to the customer and the service used to the respective rating platform (including name, e-mail address and order number or item number). This data is used solely to verify the authenticity of the user.

Rating widget: We integrate so-called “rating widgets” into our online offer. A widget is a functional and content element integrated into our online offer that displays variable information. It can be displayed, for example, in the form of a seal or comparable element, sometimes also called a “badge”. In this case, the corresponding content of the widget is displayed within our online offer, but it is retrieved at that moment from the servers of the respective widget provider. This is the only way to always show the current content, especially the current rating. For this purpose, a data connection must be established from the website called up within our online offer to the server of the widget provider and the widget provider receives certain technical data (access data, including IP address) which are 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 offer. This information may be stored in a cookie and used by the widget provider to identify which online services participating in the evaluation process have been visited by the user. The information may be stored in a user profile and used for advertising or market research purposes.

• Types of data processed: contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Data subjects: Customers, users (e.g. website visitors, users of online services).
• Purposes of processing: Feedback (e.g. collecting feedback via online form), reach measurement (e.g. access statistics, recognition of returning visitors), visit action evaluation, interest-based and behavioural marketing, profiling (creating user profiles).
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Presence in social networks

We maintain online presences within social networks in order to communicate with users active there or to offer information about us there.

We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users’ rights. With regard to US providers that are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we point out that they thereby undertake to comply with EU data protection standards.

Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behaviour and resulting interests of the users. The usage 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 the users’ computers, in which the usage behaviour and the interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).

For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the data protection declarations 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 also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

• Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

• Instagram : Social network; Service provider: Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Privacy policy: http://instagram.com/about/legal/privacy.
• Facebook: Social network; service provider: Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Data protection declaration: https://www.facebook.com/about/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Opt-out option: Settings for advertisements: https://www.facebook.com/settings?tab=ads; Additional information on data protection: Agreement on joint processing of personal data on Facebook pages: https://www.facebook.com/legal/terms/page_controller_addendum, Data protection information for Facebook pages: https://www.facebook.com/legal/terms/information_about_page_insights_data.
• LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; website: https://www.linkedin.com; privacy policy: https://www.linkedin.com/legal/privacy-policy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active; opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
• TikTok: Social network / video platform; Service provider: musical.ly Inc., 10351 Santa Monica Blvd #310, Los Angeles, CA 90025 USA; Website: https://www.tiktok.com; Privacy policy: https://www.tiktok.com/de/privacy-policy.
• Twitter: Social network; Service provider: Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; privacy policy: https://twitter.com/de/privacy, (settings) https://twitter.com/personalization; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.
• YouTube: Social network; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; privacy policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; opt-out option: https://adssettings.google.com/authenticated.

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 social media buttons as well as posts (hereinafter uniformly referred to as “content”).

The integration always requires that the third-party providers of this content process the IP address of the user, as without the IP address they could not send the content to their browser. The IP address is thus required for the presentation of these contents or functions. We endeavour to only use content whose respective providers only use the IP address 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. The “pixel tags” can be used to analyse 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, time of visit and other information about the use of our online offer as well as be linked to such information from other sources.

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

Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offer that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of presentation or user-friendliness of our online offer). In doing so, the respective providers collect the IP address of the user and may 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 optimisation of their offer.

• Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), inventory data (e.g. names, addresses).
• Data subjects: Users (e.g. website visitors, users of online services), communication partners.
• Purposes of processing: Provision of our online offer and user-friendliness, contractual performance and service, contact requests and communication, direct marketing (e.g. by e-mail or post), tracking (e.g. interest/behaviour-based profiling, use of cookies), interest-based and behaviour-based marketing, profiling (creation of user profiles), security measures, administration and response to requests.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO), consent (Art. 6 para. 1 p. 1 lit. a DSGVO), contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO).

Services used and service providers:

• Facebook plugins and content: Facebook social plugins and content – This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within Facebook. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/; Service Provider: https://www.facebook.com, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, Parent Company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Opt-Out: Settings for advertisements: https://www.facebook.com/settings?tab=ads.
• Google Fonts: We integrate the fonts (“Google Fonts”) of the provider Google, whereby the user’s data is used solely for the purpose of displaying the fonts in the user’s browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform display and taking into account possible licensing restrictions for their integration. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://fonts.google.com/; privacy policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
• Google Maps: We integrate the maps of the “Google Maps” service of the provider Google. The data processed may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually executed in the context of the settings of their mobile devices). Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://maps.google.de; Privacy policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TRkEAAW&status=Active; Opt-out: Opt-out plugin: http://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertising: https://adssettings.google.com/authenticated.
• LinkedIn plugins and content: LinkedIn plugins and content- This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online offering within LinkedIn. Service Provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: https://www.instagram.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active; Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

• ReCaptcha: We integrate the “ReCaptcha” function for the recognition of bots, e.g. when entering data in online forms. The behavioural data of users (e.g. mouse movements or queries) are evaluated in order to distinguish humans from bots. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://www.google.com/recaptcha/; privacy policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TRkEAAW&status=Active; opt-out: opt-out plugin: http://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertising: https://adssettings.google.com/authenticated.

• TikTok plugins and content: TikTok plugins and content – This may include content such as images, videos or text and buttons. Service provider: musical.ly Inc, 10351 Santa Monica Blvd #310, Los Angeles, CA 90025 USA; website: https://www.tiktok.com; privacy policy: https://www.tiktok.com/de/privacy-policy.

• Twitter plugins and content: Twitter plugins and buttons – This may include content such as images, videos or text and buttons that allow users to share content from this online service within Twitter. Service provider: Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Website: https://twitter.com/de; Privacy policy: https://twitter.com/de/privacy.

• Typekit fonts from Adobe: We integrate the fonts (\”Typekit fonts\”) of the provider Adobe, whereby the users’ data is used solely for the purpose of displaying the fonts in the users’ browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform display as well as taking into account possible restrictions under licensing law for their integration. Service provider: Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Ireland; Website: https://www.adobe.com/de; Privacy Policy: https://www.adobe.com/de/privacy.html; Privacy Shield (ensuring level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TNo9AAG&status=Active.

• YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://www.youtube.com; privacy policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; opt-out: opt-out plugin: http://tools.google.com/dlpage/gaoptout?hl=de, settings for displaying advertisements: https://adssettings.google.com/authenticated.

Planning, organisation and support tools

We use services, platforms and software of other providers (hereinafter referred to as “third-party providers”) for the purposes of organisation, administration, planning as well as provision of our services. When selecting the third-party providers and their services, we observe the legal requirements.

In this context, personal data may be processed and stored on the servers of the third-party providers. This may involve various data that we process in accordance with this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents.

If users are referred to the third-party providers or their software or platforms in the course of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimisation or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.

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

• Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Data subjects: Communication partners, users (e.g. website visitors, users of online services).
• Purposes of processing: Office and organisational procedures.
• Legal grounds: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

• Doodle: Online appointment scheduling; Service provider: Doodle AG, Werdstrasse 21, P.O. Box, 8021 Zurich, Switzerland; Website: https://doodle.com/de; Privacy policy: https://doodle.com/de/datenschutzrichtlinie.

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consent to processing is revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose).

If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.

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

Amendment and updating of the data protection declaration

We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

Where we provide addresses and contact details of companies and organisations in this privacy statement, please note that the addresses may change over time and please check the details before contacting us.

Rights of data subjects

As a data subject, you have various rights under the GDPR, in particular under Articles 15 to 18 and 21 of the GDPR:

• Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
• Right to withdraw consent: You have the right to revoke any consent given at any time.
• Right to information: You have the right to request confirmation as to whether data in question is being processed and to information about this data as well as further information and a copy of the data in accordance with the legal requirements.
• Right to rectification: You have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be rectified.
• Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data concerning you be erased without delay or, alternatively, to request restriction of the processing of the data in accordance with the law.
• Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements, or to demand that it be transferred to another person responsible.
  Complaint to the supervisory authority: You also 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 personal data relating to you infringes the GDPR.