Privacy policy

Introduction

With the following privacy policy, 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 privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of our services and, in particular, on our websites, mobile devices, as well as within external online presences, such as our social media profiles (hereinafter collectively referred to as the “online offer”).

The terms used are not gender-specific.

Last updated: 08.01.2022

Outline

  • Introduction
  • Person in charge
  • Overview of processing operations
  • Contact Data Protection Officer
  • Relevant legal bases
  • Security Measures
  • Transfer and disclosure of personal data
  • Data processing in third countries
  • Use of cookies
  • Commercial and business services
  • Payment
  • Credit check
  • Provision of the online offer and web hosting
  • Contact
  • Newsletters and electronic notifications
  • Web Analysis, Monitoring and Optimization
  • Online Marketing
  • Presence in social networks (social media)
  • Plugins and embedded functions as well as content
  • Deletion of data
  • Changes and updates to the Privacy Policy
  • Rights of data subjects
  • Definitions

Person in charge

David Hudl
Hackhofergasse 9-11A/1/61190, ViennaAustria

Authorized representatives: David Hudl

E-mail address: [email protected]

Imprint: myzoneproducts.com/impressum/

Overview of processing operations

The following table summarises the types of data processed and the purposes for which they are processed, and refers to the data subjects.

Types of data processed

  • Inventory data (e.g. names, addresses).
  • Content data (e.g. entries in online forms).
  • Contact details (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).
  • Location data (information about the geographic location of a device or person).
  • Contract data (e.g. subject matter of the contract, duration, customer category).
  • Payment data (e.g. bank details, invoices, payment history).

Categories of data subjects

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

Purposes of processing

  • Provision of our online offer and user-friendliness.
  • Visit Action Evaluation.
  • Office and organizational procedures.
  • Cross-device tracking (cross-device processing of user data for marketing purposes).
  • Direct marketing (e.g. by e-mail or post).
  • Interest-based and behavioral marketing.
  • Contact requests and communication.
  • Conversion measurement (measuring the effectiveness of marketing efforts).
  • 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).
  • Provision of contractual services and customer service.
  • Manage and respond to requests.
  • Target grouping (identification of relevant target groups for marketing purposes or other output of content).

Relevant legal bases

In the following, we provide you with the legal basis of the General Data Protection Regulation (GDPR), on the basis of which we process the personal data. Please note that in addition to the provisions of the GDPR, the national data protection requirements may apply in your or our country of residence and domicile. Furthermore, if more specific legal bases are relevant in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR)  – The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or for several specific purposes.
  • Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR) – The processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR) – The processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR) – The processing is necessary for the purposes of the legitimate interests pursued by 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

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, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

The measures shall include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, availability and segregation of data. Furthermore, we have put in place procedures to ensure the exercise of data subject rights, the deletion of data and reactions to the risk of data being compromised. 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, through technical design and through privacy-friendly default settings.

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

Transfer and disclosure of personal data

In the course of our processing of personal data, it happens 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 comply with the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

Data processing in third countries

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

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

Use of cookies

Cookies are text files that contain data from websites or domains visited and are stored on the user’s computer by a browser. 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 place where a video was watched. 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”)

A distinction is made between the following types of cookies and functions:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
  • Persistent cookies: Persistent 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 reach measurement or marketing purposes may 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 strictly necessary) cookies: Cookies can 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 reach 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 corresponds to their potential interests. This method is also known as “tracking”, i.e. tracking the potential interests of users. . If we use cookies or “tracking” technologies, we will inform you separately in our privacy policy or in the context of obtaining consent.

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

Storage period: Unless we provide you with explicit information on the storage period of permanent cookies (e.g. as part of a so-called cookie opt-in), please assume that the storage period can be up to two years.

General information on revocation and objection  (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to withdraw your consent or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can first declare your objection using the settings of your browser, e.g. by deactivating the use of cookies (whereby this may also limit 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 websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further objection notices as part of the information on the service providers and cookies used.

Processing of cookie data on the basis of consent: Before we process or have data processed in the context of the use of cookies, we ask users for their consent, which can be revoked at any time. Until consent has been given, cookies may be used that are absolutely necessary for the operation of our online offering.

Cookie settings/opt-out:

Please note that if you do not accept cookies, the functionality of our website may be limited. You can change the cookie preferences you set when you first visited our site at any time here.

  • 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).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit.  a. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

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 the contractual partners (or pre-contractual), e.g. to answer enquiries.

We process this data in order 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 business organisation. Within the scope of applicable law, we only pass on the data of the contractual partners to third parties insofar as this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or is carried out with the consent of the data subjects (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 are 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 as part of the data collection, e.g. in online forms, by means of special markings (e.g. colours) or symbols (e.g. asterisks or similar), or in person.

We delete the data after expiry of statutory warranty and comparable obligations, i.e., generally after the expiry of 7 years, unless the data is stored in a customer account, e.g. as long as it must be kept for legal reasons of archiving (e.g. for tax purposes usually 10 years). We delete data that has been disclosed to us by the contractual partner in the context 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, or “customer account” for short). If the registration of a customer account is required, contractual partners will be informed of this as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. As part of the registration process as well as subsequent logins and use of the customer account, we store the IP addresses of the customers along with the access times in order to be able to prove the registration and prevent any misuse of the customer account.

If customers have terminated their customer account, the data relating to the customer account will be deleted, subject to the retention of which is required by law. It is the customer’s responsibility to back up their data in the event of termination of the customer account.

Economic analyses and market research: For business reasons and in order to be able to identify market trends, wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., whereby the group of data subjects may include contractual partners, interested parties, customers, visitors and users of our online offer.

The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). If available, we may take into account the profiles of registered users and their information, e.g. on services used. The analyses are for our sole use and will not be disclosed externally, unless they are anonymous analyses with aggregated, i.e. anonymised values. Furthermore, we take the privacy of the users into account and process the data for analysis purposes as pseudonymously as possible and, if possible, anonymously (e.g. as aggregated data).

Shop and e-commerce: We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and related services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution to our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such as in the context of the order or comparable purchase process and includes the information required for delivery, provision and billing as well as contact information in order to be able to hold any consultation.

  • Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g.  subject matter of the contract, duration, 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: Provision of contractual services and customer service, contact requests and communication, office and organizational procedures, management and response to requests, security measures, evaluation of visit actions, interest-based and behavioral marketing, profiling (creation of user profiles).
  • Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR  ), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Payment

In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer efficient and secure payment options to the data subjects 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 name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient-related information. The details are required to carry out the transactions. However, the data entered will only be processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, 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 transfer is to verify identity and creditworthiness. For this purpose, we refer to the terms and conditions and the data protection notices of the payment service providers.

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

  • 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 the contract, duration, 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, prospects.
  • Purposes of processing: Provision of contractual services and customer service.
  • Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services and service providers used:

Provision of the online offer and web hosting

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

The data processed in the context of the provision of the hosting offer may include all information concerning the users of our online offer that arises in the context of use and communication. This usually includes the IP address, which is necessary to be able to deliver the content of online offers to browsers, and all entries made within our online offer or from websites.

E-mail sending and hosting: The web hosting services we use also include the sending, receiving and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the sending of e-mails (e.g. the providers involved) as well as the content of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of detecting 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 method is used) not on the servers from which they are sent and received. Therefore, we cannot assume any responsibility for the transmission path of the e-mails between the sender and the receipt on our server.

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

On the one hand, 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, on the other hand, to ensure the utilization of the servers and their stability.

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

Contact

When contacting us (e.g. via contact form, e-mail, telephone or social media), the details of the enquiring persons will be processed insofar as this is necessary to answer the contact requests and any measures requested.

The answers to contact requests in the context of contractual or pre-contractual relationships are carried out in order to fulfil our contractual obligations or to answer (pre-)contractual inquiries and otherwise on the basis of the legitimate interests in answering the enquiries.

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

Newsletters and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter referred to as “newsletters”) only with the consent of the recipients or a legal permission. Insofar as the contents of the newsletter are specifically described as part of a subscription, they are decisive for the consent of the user. In addition, our newsletters contain information about our services and us.

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

Double opt-in procedure:  Registration for our newsletter is generally carried out in a so-called double opt-in procedure, i.e. you will receive an e-mail after registration in which you will be asked to confirm your registration. This confirmation is necessary so that no one can log in with someone else’s email addresses. Subscriptions to 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 time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider will also be logged.

Deletion and restriction of processing: We may store the 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 a previously given consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion 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 (so-called “blacklist”) solely for this purpose.

The registration process is logged on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system.

Notes on legal bases: The newsletter is sent on the basis of the consent of the  recipients 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 existing customer advertising. To the extent that we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration procedure is recorded on the basis of our legitimate interests to prove that it has been carried out in accordance with the law.

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

Analysis and 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 mailing service provider, from its server when the newsletter is opened. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of access, is first 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 behavior 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 shipping service provider to monitor individual users. Rather, the evaluations serve us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

Subject to the express consent of the users, the evaluation of the newsletter and the measurement of success are carried out 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 the expectations of the users.

Unfortunately, it is not possible to revoke the performance measurement separately, in which case the entire newsletter subscription must be cancelled or objected to.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g. by e-mail or post).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit.  a. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
  • Opt-out: You can cancel your subscription to our newsletter at any time, i.e. revoke your consent, or .dem object to further receipt. You will either find a link to unsubscribe from the newsletter at the end of each newsletter or you can use one of the contact options listed above, preferably e-mail.

Web Analysis, Monitoring and Optimization

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, identify at what time our online offer or its functions or content are most frequently used or invite them to reuse. We can also understand which areas need to be optimized.

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

For these purposes, so-called user profiles can be created and stored in a file (so-called “cookie”) or similar processes with the same purpose can be used. 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 process (i.e., pseudonymization by shortening the IP address) to protect users. In general, in the context of web analysis, A/B testing and optimization, no clear user data (such as e-mail addresses or names) is stored, 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 purposes of the respective procedures.

Notes on legal bases: 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, the user’s data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economical and user-friendly services). In this context, we would also like to draw your attention 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/behavioural profiling, use of cookies), visitor action evaluation, profiling (creation of user profiles).
  • Security measures: IP  masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit.  a. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Online Marketing

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

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar processes are used, by means of which the information about the user relevant to the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical data 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 data can also be processed.

The IP addresses of the users are also stored. However, we use available IP masking methods (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored as part 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 cookies or by means of similar processes. These cookies can later generally be read on other websites that use the same online marketing method and analysed for the purpose of displaying content, as well as supplemented with further data and stored on the server of the online marketing process 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 process we use and the network connects the profiles of the users with the aforementioned information. Please note that users can make additional arrangements with the providers, e.g. by giving their consent as part of the registration process.

As a matter of principle, we only have access to aggregated information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e. e.g. to the conclusion of a contract with us. Conversion measurement is used solely to analyze the success of our marketing efforts.

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

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, the user’s data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economical and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

 Facebook pixel: With the help of the Facebook pixel, Facebook is able to determine 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 the partners cooperating with Facebook (so-called “Audience Network” https://www.facebook.com/audiencenetwork/ ) who have  also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products that are apparent 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. With the help of the Facebook pixel, we can also understand the effectiveness of Facebook advertisements for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook advertisement (so-called “conversion measurement”).

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographical location of a device or a person).
  • Data subjects: Users (e.g. website visitors, users of online services), interested parties.
  • Purposes of processing: Tracking (e.g. interest/behavioural profiling,  use of cookies), remarketing, evaluation of visit actions, interest-based and behavioural marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors), target group formation (determination of target groups relevant for marketing purposes or other content output), cross-device tracking (cross-device processing of user data for marketing purposes).
  • Security measures: IP  masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit.  a. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
  • Possibility of objection (opt-out):  We refer to the data protection notices of the respective providers and the objection options specified for the providers (so-called “opt-out”). If no explicit opt-out option has been specified, you have the option of disabling cookies in your browser settings. However, this may limit the functions of our online offering. We therefore also recommend the following opt-out options, which are offered in summary for the respective territories:a) Europe: https://www.youronlinechoices.eu.b) Canada: https://www.youradchoices.ca/choices.c) USA: https://www.aboutads.info/choices.d) Cross-territorial: https://optout.aboutads.info.

Services and service providers used:

  • Google Tag Manager: Google Tag Manager is a solution that allows us to manage so-called website tags via an interface and thus integrate other services into our online offering. 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.
  • Google Analytics: online marketing and web analytics; 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; Possibility of objection (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • Google Ads and conversion measurement: We use the online marketing process “Google Ads” to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest 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 with a so-called “conversion tracking tag”. However, we do not receive any information that can be used to identify users. 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.
  • Google Ad Manager: We use the “Google  Marketing Platform” (and services such as “Google Ad Manager”) to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.). Google Marketing Platform excels at displaying ads in real-time based on users’ presumed interests. This allows us to display ads for and within our online offering in a more targeted manner in order to only present users with ads that potentially correspond to their interests. If, for example, a user is shown ads for products that he or she has been interested in on other online offers, this is referred to as “remarketing”. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy.
  • Facebook Pixel:  Service provider: https://www.facebook.com, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Possibility of objection (opt-out): https://www.facebook.com/settings?tab=ads.

Presence in social networks (social media)

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

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

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

For a detailed description of the respective forms of processing and the options for objection (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.

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

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g.  websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • 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 sentence 1 lit. f. GDPR).

Services and service providers used:

Plugins and embedded functions as well as content

We integrate functional and content elements into our online offering, which are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). This may include, for example, graphics, videos or social media buttons, as well as posts (hereinafter referred to collectively as “Content”).

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

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, the user’s data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economical and user-friendly services). In this context, we would also like to draw your attention 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), location data (information on the geographical location of a device or person), content data (e.g. entries in online forms), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
  • Data subjects: Users (e.g. website visitors, users of online services), communication partners.
  • Purposes of processing: Provision of our online offer and user-friendliness, provision of contractual services and customer service, contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), interest-based and behavioural marketing, profiling (creation of user profiles), security measures, management and response to enquiries.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR), consent (Art. 6 para. 1 sentence 1 lit. a. GDPR  ), performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR).

Services and service providers used:

  • 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 from this online offering 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; 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 data of the users 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 presentation 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.
  • ReCaptcha: We integrate the “ReCaptcha” function to detect bots, e.g. when entering online forms. The user’s behavioral information (e.g. mouse movements or queries) is evaluated in order to be able 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; Possibility of objection (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • Twitter plugins and content: Twitter plugins and buttons  – 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 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.
  • 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; Possibility of objection (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.

Deletion of data

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

Unless the data is erased because it is necessary for other purposes permitted by law, its processing will be limited to these purposes. This means that the data will be blocked and will not be processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary 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 provided within the framework of the individual data protection notices of this data protection declaration.

Changes and updates to the Privacy Policy

We ask you to regularly inform yourself about the content of our privacy policy. We will amend the Privacy Policy as soon as the changes to the data processing we carry out make it necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or another individual notification.

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

Rights of data subjects

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

  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data based on Art. 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions. If your personal data is processed for the purpose of direct marketing, you have the right to object at any time to the processing of your personal data 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 withdraw your consent at any time.
  • Right of access: You have the right to request confirmation as to whether the data in question is being processed and to request access to this data, as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the law, you have the right to request the completion of the data concerning you or the correction of the inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that  data concerning you be erased without undue delay or, alternatively, to demand that the processing of the data be restricted in accordance with the legal requirements.
  • Right to data portability: You have the  right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with the legal requirements, or to request that it be transmitted to another controller.
  • Complaint to a supervisory authority: You also have the right, in accordance with the law, 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 your personal data infringes the GDPR.

Definitions

This section provides an overview of the terminology used in this Privacy Policy. Many of the terms are taken from the law and are defined primarily in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to serve the purpose of understanding. The terms are sorted alphabetically.

  • Conversion Tracking refers to a method used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user’s devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, it allows us to understand whether the ads we serve on other websites have been successful).
  • Credit report: Automated decisions are based on automatic data processing without human intervention (e.g. in the case of an automatic rejection of an invoice purchase, an online loan application or an online application process without any human intervention). According to Art. 22 GDPR, such automated decisions are only permissible if data subjects give their consent, if they are necessary for the performance of a contract or if national laws allow these decisions.
  • Cross-device tracking: Cross-device tracking is a form of tracking in which users’ behavioral and interest information is collected across devices in so-called profiles by assigning users an online identifier. As a result, user information can usually be analysed for marketing purposes, regardless of the browser or device used (e.g. mobile phones or desktop computers). With most providers, the online identifier is not linked to clear data, such as names, postal addresses or e-mail addresses.
  • IP masking: “IP  masking” is a method in which the last octet, i.e. the last two digits of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymising processing methods, especially in online marketing
  • Interest-based and behavioral marketing:  Interest-based and/or behavioral marketing is when users’ potential interests in ads and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behaviour (e.g. visiting and staying on certain websites, purchasing behaviour or interaction with other users), which is stored in a so-called profile. Cookies are usually used for these purposes.
  • Conversion measurement: Conversion measurement is a process that can be used to determine the effectiveness of marketing efforts. For this purpose, a cookie is usually stored on the user’s devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, it allows us to understand whether the ads we serve on other websites have been successful.
  • Personal data: “Personal data”  means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is defined as one who identifies directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to it which are an expression of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiling: “Profiling” refers to any type of automated processing of personal data consisting in the use of such personal data to identify certain personal aspects relating to a natural person (depending on the type of profiling, this includes information relating to age, gender, location and movement data, interaction with websites and their content, shopping behaviour, social interactions with others Analyze, evaluate, or predict people (e.g., interest in certain content or products, click behavior on a website, or location). Cookies and web beacons are often used for profiling purposes.
  • Reach measurement: Reach measurement (also referred to as web analytics) is used to evaluate the flow of visitors to an online offer and can include the behavior or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, see at what time visitors visit their website and what content they are interested in. This allows them to better adapt the content of the website to the needs of their visitors, for example. For the purpose of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Remarketing: “Remarketing” or “retargeting” is used when, for example, for advertising purposes, it is noted which products a user has been interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Location data: Location data is generated when a mobile device (or any other device with the technical requirements of location determination) connects to a radio cell, a Wi-Fi network or similar technical means and functions of location determination. Location data is used to indicate the geographically determinable position on earth at which the respective device is located. Location data can be used, for example, to display map functions or other location-related information.
  • Tracking: “Tracking” is when the behavior of users can be tracked across several online offers. As a rule, behavioural and interest information is stored in cookies or on servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can then be used, for example, to show users advertisements that are likely to match their interests.
  • Controller: “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and encompasses practically any handling of data, be it collection, evaluation, storage, transmission or deletion.
  • Target group formation: Target group formation (or “custom audiences”) is when target groups are determined for advertising purposes, e.g. the display of advertisements. For example, based on a user’s interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which he or she viewed the products. In turn, “lookalike audiences” (or similar target groups) are when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were formed. Cookies and web beacons are usually used for the purpose of creating Custom Audiences and Lookalike Audiences.