With the following data protection declaration we would like to inform you about the types of personal data (hereinafter also referred to as “data”) 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 in the context of providing our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter also referred to collectively as “online offer”). The terms used are not gender-specific. Status: March 10, 2020
Table of Contents
- Overview of the processing operations
- Relevant legal bases
- Security measures
- Transmission and disclosure of personal data
- Data processing in third countries
- Provision of the online offer and web hosting
- Deletion of data
- Rights of data subjects
- Definitions of terms
Overview of the processing operations
The following table 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. e-mail, telephone numbers).
- Meta/communication data (e.g. device information, IP addresses).
- Usage data (e.g. websites visited, interest in content, access times).
Categories of data subjects
- Communication partner.
- Users (e.g. website visitors, users of online services).
Purpose of the processing
- Contact requests and communication.
- Comments on blog posts.
Relevant legal bases
In the following, we provide the legal basis of the basic data protection regulation (DSGVO), on the basis of which we process personal data. Please note that in addition to the regulations of the DSGVO, national data protection regulations may apply in your or our country of residence and domicile. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data protection declaration.
- Consent (Art. 6 para. 1 sentence 1 letter a FADP) – The data subject has given his or her consent to the processing of personal data relating to him or her for one or more specific purposes.
- Fulfilment of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 letter b. FADP) – Processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the request of the data subject.
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. FADP) – The processing is necessary to safeguard the legitimate interests of the controller or of a third party, unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data outweigh those of the controller.
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection commensurate with the risk.
Such measures shall include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, safeguarding of availability and segregation of data relating to them. Furthermore, we have established procedures to ensure that data subjects’ rights are exercised, data is deleted, and responses are made to any threats to the data. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes in accordance with the principle of data protection, by designing technology and by using data protection-friendly default settings.
Transmission and disclosure of personal data
In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. 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 with the recipients of your data which serve to protect your data.
Data processing in third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of services of third parties or the disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements.
Subject to express consent or transfer required by contract or by law, we process or allow the data to be processed only in third countries with a recognised level of data protection, including the US processors certified under the Privacy Shield, or on the basis of special guarantees, such as contractual obligations under 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 ).
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 visit within an online offer. The stored information may include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was viewed. The term “cookies” also includes other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also referred to as “user IDs”)
The following cookie types and functions are distinguished:
- Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
- Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The interests of users used for reach measurement or marketing purposes can also be stored in such a cookie.
- First-party cookies: First-party cookies are set by us.
- Third party cookies (also: third party cookies): Third party cookies are mainly used by advertisers (so-called third parties) to process user information.
- Necessary (also: essential or absolutely necessary) cookies: Cookies can be absolutely necessary for the operation of a website (e.g. to store logins or other user entries or for security reasons).
Notes on legal bases:
General information on withdrawal and opposition (opt-out):
Processing of cookie data based on consent:
- Processed data types: 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).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 letter a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 letter f. DSGVO).
When contacting us (e.g. via contact form, e-mail, telephone or via social media), the data of the inquiring persons will be processed to the extent necessary to answer the contact inquiries and any requested measures.
The answering of contact inquiries within the scope of contractual or pre-contractual relations is carried out in order to fulfil our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of the legitimate interest in answering the inquiries.
- Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos).
- Persons concerned: communication partners.
- Purposes of processing: contact requests and communication.
- Legal basis: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Provision of the online offer and web hosting
In order to provide our online services securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online services can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, and security and technical maintenance services.
The data processed within the framework of the provision of the hosting offer may include all data relating to the users of our online offer, which are generated within the framework 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.
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). Server log files may include the address and name of the web pages and files accessed, date and time of access, data volume transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.
The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the capacity utilisation of the servers and their stability.
- Processed data types: 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).
- Affected persons: Users (e.g. website visitors, users of online services).
- Legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Deletion of data
The data processed by us will be deleted in accordance with the legal requirements as soon as their consent permitted for processing is revoked or other permissions cease to apply (e.g. if the purpose for which the data were processed ceases to apply or if they are not necessary for the purpose).
Unless the data are deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that 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 that must be stored for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person.
Further information on the deletion of personal data can also be provided in the individual data protection notes of this data protection declaration.
We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes make it necessary for you to take action to cooperate (e.g. to give your consent) or to receive other individual notification.
Rights of data subjects
As a data subject, you are entitled to various rights under the DSGVO, which result in particular from Articles 15 to 18 and 21 DSGVO:
- Right of objection: You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data relating to you which is carried out pursuant to Article 6 paragraph 1 letter e or f FADP; this also applies to profiling based on these provisions. If the personal data concerning you are 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, including profiling, insofar as it is linked to such direct marketing.
- Right to withdraw consent: You have the right to withdraw any consent given at any time.
- Right of access: You have the right to obtain confirmation as to whether or not data in question is being processed and to obtain information about such data and to receive further information and a copy of the data in accordance with the law.
- Right of rectification: You have the right to ask for the completion of the data concerning you or the rectification of incorrect data concerning you, in accordance with the law.
- Right to erasure and limitation of processing: You have the right to request that data concerning you be erased immediately in accordance with the law or, alternatively, that the processing of such data be limited in accordance with the law.
- Right to data transferability: You have the right to obtain, in accordance with the law, data concerning you that you have provided to us in a structured, common and machine-readable format or to request that it be transferred to another responsible party.
- Complaints to the supervisory authority: You also have the right, in accordance with the statutory provisions, to lodge a complaint with a supervisory authority, in particular in the Member State in which you have your habitual residence, your place of work or the place where the alleged infringement occurred, if you believe that the processing of personal data relating to you is in breach of the DPA.
Definitions of terms
- Personal data: ‘personal data’ shall mean any information relating to an identified or identifiable natural person (hereinafter referred to as ‘data subject’); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, a location data, an online identifier (e.g. a cookie) or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
- Controller: “Controller” shall mean the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data.
- Processing: “processing” shall mean any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually all processing of data, whether it be collection, analysis, storage, communication or deletion.