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Data protection

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 in the context 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 the “Online Offer”).

The terms used are not gender-specific.

Status: 8 March 2021

Responsible

Eller + Eller Architekten GmbH
Augustastraße 30
40477 Düsseldorf

Person authorised to represent the company: Erasmus Eller, Managing Director

E-mail-adress: ed.relle-relle@nimdabew

Telefon: +49 211 4352-0

Imprint: https://www.eller-eller.de/impressum

Contact Data Protection Officer

Wolfgang Branz
Birnbaumweg 57
88326 Aulendorf
Telefon 07525 94 69 859
E-Mail ed.relle-relle@ztuhcsnetad

Overview of the 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).
  • Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, curriculum vitae, certificates as well as other information provided with regard to a specific position or voluntarily by applicants regarding their person or qualifications).
  • Content data (e.g. text input, photographs, videos).
  • 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 (data indicating the location of an end user’s terminal device).
  • Contract data (e.g. subject matter of the contract, term, customer category).
  • Payment data (e.g. bank details, invoices, payment history).
Categories of persons concerned
  • Employees (e.g. employees, applicants, former employees).
  • Applicants.
  • Business and contractual partners.
  • Interested parties.
  • Communication partner.
  • Customers.
  • Users (e.g. website visitors, users of online services).
Purposes of the processing
  • Provision of our online offer and user-friendliness.
  • Visit action evaluation.
  • Application procedure (establishment and possible subsequent implementation as well as possible subsequent termination of the employment relationship.).
  • Office and organisational procedures.
  • Direct marketing (e.g. by e-mail or post).
  • Feedback (e.g. collecting feedback via online form).
  • Interest-based and behavioural marketing.
  • Contact requests and communication.
  • Conversion measurement (measuring the effectiveness of marketing measures).
  • Profiling (creation of user profiles).
  • Remarketing.
  • Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Safety measures.
  • Tracking (e.g. interest/behavioural profiling, use of cookies).
  • Contractual benefits and service.
  • Managing and responding to enquiries.

Relevant legal bases

In the following, we share the legal basis of the General Data Protection Regulation (GDPR) on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, the national data protection regulations in your or our country of residence and domicile may apply. Should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 para. 1 sent. 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.
  • Contract performance 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 taken 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.
  • 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.
  • Art. 9 para. 1 p. 1 lit. b DSGVO (application procedure as pre-contractual or contractual relationship) (Insofar as special categories of personal data within the meaning of Article 9 (1) of the GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants in the context of the application procedure so that the controller or the data subject can exercise the rights accruing to him or her under labour law and social security and social protection law and fulfil his or her obligations in this regard, their processing shall be carried out in accordance with Article 9 (2) (b) of the GDPR. DSGVO, in the case of the protection of vital interests of the applicants or other persons pursuant to Art. 9 para. 2 lit. c. DSGVO or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s fitness for work, for medical diagnostics, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 para. 2 lit. h. DSGVO. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 (2) lit. a. DSGVO. DSGVO).

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

Security measures

We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk 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.

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, entry into, disclosure of, assurance of availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data and responses to data compromise. Furthermore, we already take the protection of personal data into account during 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): 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.

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 the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this is only done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we only process or have the data processed in third countries with a recognised level of data protection, 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 bis 49 DSGVO, Informationsseite der EU-Kommission: 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 their visit within an online offering. 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 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 absolutely necessary) cookies: Cookies may be absolutely necessary for the operation of a website (e.g. to save logins or other user entries or for security reasons).
  • Statistics, 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 process is also known 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 the processing of 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.

Storage period: If we do not provide you with explicit information on the storage period of permanent cookies (e.g. in the context 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 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 receive further instructions on how to object within the scope 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.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Betroffene Personen: Nutzer (z.B. Webseitenbesucher, Nutzer von Onlinediensten).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Specific information on the cookies used on our website and the possibility to view and change your personal settings can be found in our separate cookie instructions.

Your personal cookie ID:

The consent history of your personal cookie selection:

DateVersionConsents

Change your personal cookie settings:

Cookie Opt-Out:

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 safeguard our rights and for the purposes of the administrative tasks associated with this information as well as for business organisation. Within the framework of the applicable law, we only disclose the data of the contractual partners to third parties 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 of the data required for the above-mentioned 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., in principle 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 usually 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, in principle 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.

Architectural and planning services: We process the data of our clients and customers (hereinafter uniformly referred to as “clients”) 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.

In the course of our activities, we may also process special categories of data, in particular information on the health of clients. For this purpose, we obtain the express consent of the customers if necessary and otherwise only process the special categories of data if this corresponds to our contractual obligations.

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 invoicing 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).
  • Affected persons: Interested parties, business and contractual partners.
  • Purposes of processing: Contractual performance and service, contact requests and communication, office and organisational procedures, administration and response to requests.
  • Legal basis: Contract 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).

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 services and technical maintenance services.

The data processed as part of the provision of the hosting service may include all information relating to the users of our online service that arises 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 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 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 SPAM detection purposes. 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. 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 can be used on the one hand 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 utilisation of the servers and their stability.

  • Types of data processed: 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: Users (e.g. website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Blogs and publication media

We use the WordPressblog system as a 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 reasons of security. 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.

Services used and service providers:

Videokonferenzen, Online-Meetings, Webinare und Bildschirmfreigabe

We use platforms and applications of other providers (hereinafter referred to as “Third Party Providers”) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings. When selecting third-party providers and their services, we observe the legal requirements.

In this context, data of the communication participants are processed and stored on the servers of the third-party providers, insofar as these are part of communication processes with us. This data may include, in particular, registration and contact details, visual and vocal contributions as well as entries in chats and shared screen contents.

Where 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, service optimisation or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.

Notes on legal bases: If we ask users for their consent to use the third-party providers or certain functions (e.g. consent to a recording of conversations), the legal basis of the processing is consent. Furthermore, their use may be a component of our (pre-)contractual services, provided that the use of the third-party providers has been agreed within this framework. Otherwise, the users’ data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners. In this context, we would also like to refer you to the information on the use of cookies in this data protection declaration.

  • 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: Contractual performance and service, contact requests and communication, office and organisational procedures.
  • Legal basis: 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).

Services used and service providers:

Application procedure

The application process requires applicants to provide us with the data necessary for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the information provided there.

Basically, the required information includes personal information such as name, address, contact details and proof of the qualifications required for a position. Upon request, we will be happy to provide additional information on which details are required.

Where provided, applicants may submit their applications to us using an online form. The data is transmitted to us encrypted according to the state of the art. Applicants can also send us their applications by e-mail. Please note, however, that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of the application between the sender and the reception on our server.

For the purposes of searching for applicants, submitting applications and selecting applicants, we may use applicant management or recruitment software and platforms and services from third party providers in compliance with the legal requirements.

Applicants are welcome to contact us regarding the method of submission of the application or to send us the application by post.

Processing of special categories of data: Insofar as special categories of personal data within the meaning of Art. 9 Para. 1 GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from job applicants in order for the controller or the data subject to exercise his or her rights under labour law and social security and social protection law and to comply with his or her obligations in this regard, their processing is carried out in accordance with Art. 9 (1) GDPR. 2 lit. b. DSGVO, in the case of the protection of vital interests of applicants or other persons pursuant to Art. 9 para. 2 lit. c. DSGVO or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s fitness for work, for medical diagnostics, for care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 (2) lit. h. DSGVO. In the case of a notification of the special categories of data based on voluntary consent, their processing is based on Art. 9 (2) lit. a. DSGVO.

Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is unsuccessful, the applicants’ data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. The deletion takes place, subject to a justified revocation by the applicants, at the latest after the expiry of a period of six months so that we can answer any follow-up questions about the application and fulfil our obligations to provide evidence under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses are archived in accordance with tax law requirements.

Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the current application process and that they can revoke their consent at any time for the future.

Duration of data retention in the applicant pool in months: 6

  • Types of data processed: Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, CV, certificates and other information provided with regard to a specific position or voluntarily by applicants regarding their person or qualifications).
  • Persons concerned: Applicants.
  • Purposes of processing: Application procedure (establishment and possible subsequent implementation as well as possible subsequent termination of the employment relationship.).
  • Legal basis: Art. 9 para. 1 sentence 1 lit. b DSGVO (application procedure as a pre-contractual or contractual relationship) (Insofar as special categories of personal data within the meaning of Art. 9 para. 1 DSGVO (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants within the scope of the application procedure, the data controller or the data subject shall be obliged to provide such data. health data, such as severely disabled status or ethnic origin) are requested from applicants so that the controller or the data subject can exercise the rights accruing to him or her under labour law and social security and social protection law and fulfil his or her obligations in this regard, their processing is carried out in accordance with Art. 9 para. 2 lit. b. DSGVO, in the case of the protection of vital interests of the applicants or other persons pursuant to Art. 9 para. 2 lit. c. DSGVO or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s fitness for work, for medical diagnostics, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 para. 2 lit. h. DSGVO. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 (2) lit. a. DSGVO. DSGVO).

Services used and service providers:

Cloud Service

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 insofar as 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, which they use for security purposes and service optimisation.

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

Notes on legal bases: Where we ask for consent to use the cloud services, the legal basis for the 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, users’ 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. e-mail, telephone numbers), content data (e.g. text entries, photos, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Customers, employees (e.g. employees, applicants, former employees), interested parties, communication partners.
  • Purposes of processing: Office and organisational procedures.
  • Legal basis: 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).

Services used and service providers:

Newsletter and broad communication

We send newsletters, e-mails and other electronic notifications (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. Insofar as the contents of the newsletter are specifically described in the course of registration, 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 personal address in the newsletter, or other details if these are necessary for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter is always carried out in a so-called double opt-in process. I.e., you will receive an email after registration asking you to confirm your registration. This confirmation is necessary so that no one can register with other people’s e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the subscription process in accordance with legal requirements. This includes the storage of the login and confirmation time as well as the IP address. Likewise, changes to your data stored with the shipping service provider are 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 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. 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 purposes 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 insofar as this is permitted by law, e.g. in the case of existing customer advertising. 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.

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

Analysis and performance measurementThe newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a dispatch service provider, from their server. 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 based on the technical data or the target groups and their reading behaviour based on 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. The evaluations rather serve us 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 its 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 our business interests and meets the expectations of the users.

A separate revocation of the performance measurement is unfortunately not possible; in this case, the entire newsletter subscription must be cancelled or must be contradicted.

  • 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).
  • Affected persons: Communication partner.
  • 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).
  • 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:

  • CleverReach: email marketing platform; service provider: CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede, Germany; Website: https://www.cleverreach.com/de; Privacy policy: https://www.cleverreach.com/de/datenschutz/.

Web analysis and optimisation

Web analytics (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 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 testing 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, the data stored in the context of web analysis, A/B testing and optimisation are not clear user data (such as e-mail addresses or names), 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 bases: Where we ask users for their consent to use third-party providers, the legal basis for processing data is consent. 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: 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 behaviour-based 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:

Onlinemarketing

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 user data relevant for the presentation of the aforementioned contents are 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 can also be processed.

The IP addresses of the 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 as part of the online marketing process, but pseudonyms are. This means that we, as well as the providers of the online marketing methods, 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 later generally be read 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.

Ausnahmsweise können Klardaten den Profilen zugeordnet werden. This is the case if, for example, the users are members of a social network whose online marketing procedures we use and the network links the users’ profiles with the aforementioned information. 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, in the context of so-called conversion measurements, we can check which of our online marketing methods have led to a so-called conversion, i.e., for example, to a contract being concluded 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 bases: Where we ask users for their consent to use third-party providers, the legal basis for processing data is consent. 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: 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), interested parties.
  • Purposes of processing: tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, visit action evaluation, 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).
  • 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).
  • Opt-out: We refer to the data protection notices of the respective providers and the opt-out options given for the providers. 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 form for the respective areas:a) Europe: https://www.youronlinechoices.eu.
    b) Canada: https://www.youradchoices.ca/choices.
    c) USA: https://www.aboutads.info/choices.
    d) Cross-territorial: https://optout.aboutads.info.

Services used and service providers:

Rating platforms

We participate in evaluation processes 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 notices of the providers also apply. As a rule, the evaluation 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.

  • 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).
  • 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:

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”). This may include, 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 would not be able to send the content to their browser. The IP address is thus required for the display of this content or function. 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 evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, 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 bases: Where we ask users for their consent to use third-party providers, the legal basis for processing data is consent. 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: Usage data (e.g. websites 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 terminal device), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text input, photographs, videos).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness, contractual performance and service, security measures, administration and response to enquiries.
  • 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:

Data deletion

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are 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).

Unless the data are 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 update of the privacy policy

We ask you to regularly inform yourself about the content of our privacy policy. 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 the data subjects

As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 18 and 21 GDPR:

  • Right of objection: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data relating to 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 of revocation for consents: You have the right to revoke any consent you have given at any time.
  • Right of access: You have the right to request confirmation as to whether data in question is being processed and to be informed about this data and to receive 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 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 relating to you be erased immediately 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 relating to you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transferred to another controller.
  • Complaint to the 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, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Definitions of terms

This section provides you with an overview of the terms used in this privacy statement. Many of the terms are taken from the law and defined above all in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are sorted alphabetically.

  • Conversion tracking: “Conversion tracking” refers to a procedure that can be used to determine the effectiveness of marketing measures. This is usually done by storing a cookie on the users’ devices within the websites where the marketing takes place and then retrieving it again on the target website. For example, we can see whether the ads we have placed on other websites have been successful).
  • IP masking: IP masking is a method in which the last octet, i.e. the last two numbers 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 operations, especially in online marketing
  • Interest-based and behavioural marketing: Interest-based and/or behavioural 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 certain websites and staying on them, purchasing behaviour or interaction with other users), which is stored in a so-called profile. Cookies are generally used for these purposes.
  • Conversion measurement: Conversion measurement is a procedure that can be used to determine the effectiveness of marketing measures. This is usually done by storing a cookie on the users’ devices within the websites where the marketing takes place and then retrieving it again on the target website. For example, we can see whether the ads we have placed on other websites have been successful.
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiling: Profiling” is any form of automated processing of personal data which consists of using that personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information relating to age, gender, location data and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people) (e.g. interests in certain content or products, click behaviour 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 offering and may include visitors’ behaviour or interests in certain information, such as the content of web pages. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This allows them, for example, to better adapt the content of the website to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Remarketing: “Remarketing” or “retargeting” is when, for example, for advertising purposes, it is noted which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Tracking: We speak of “tracking” when the behaviour of users can be traced across several online offerings. As a rule, with regard to the online offers used, behavioural and interest information is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
  • Controller: The term “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 upon personal data, whether or not by automatic means. The term is wide-ranging and encompasses practically every handling of data, be it collection, evaluation, storage, transmission or deletion.

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