Privacy Policy
This privacy policy informs you about the nature, scope and purpose of the processing of personal data (hereinafter “data”) within our online offering and the associated websites, functions and content, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as “online offering”). With regard to the terminology used, such as “processing” or “controller”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
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Controller
OM Network GmbH
Alexanderstraße 9b
70184 Stuttgart
Types of data processed:
– Inventory data (e.g. names, addresses).
– Contact data (e.g. email, telephone numbers).
– Content data (e.g. text inputs, photographs, videos).
– Usage data (e.g. websites visited, interest in content, access times).
– Meta/communication data (e.g. device information, IP addresses).
Categories of data subjects
Visitors and users of the online offering (hereinafter collectively referred to as “users”, which also includes the data subjects).
Purpose of processing
– Providing the online offering, its functions and content.
– Responding to contact requests and communicating with users.
– Security measures.
– Reach measurement/marketing
Terminology used
“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.
“Processing” means any operation or set of operations which is performed on personal data, with or without the aid of automated procedures. The term is broad and covers virtually any handling of data.
“Pseudonymisation” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
“Profiling” means any form of automated processing of personal data which consists of using that personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
“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.
“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Relevant Legal Bases
In accordance with Art. 13 GDPR, we inform you of the legal bases for our data processing. Where the legal basis is not stated in the privacy policy, the following applies: the legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 GDPR; the legal basis for processing in order to provide our services, carry out contractual measures and answer enquiries is Art. 6(1)(b) GDPR; the legal basis for processing to comply with our legal obligations is Art. 6(1)(c) GDPR; and the legal basis for processing to safeguard our legitimate interests is Art. 6(1)(f) GDPR. In the event that vital interests of the data subject or of another natural person make the processing of personal data necessary, Art. 6(1)(d) GDPR serves as the legal basis.
Security Measures
In accordance with Art. 32 GDPR, and taking into account the state of the art, the implementation costs, the nature, scope, context and purposes of processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data as well as access to, input of, disclosure of, the safeguarding of its availability and its separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and the response to threats to data. In addition, we take the protection of personal data into account already during the development or selection of hardware, software and procedures, in accordance with the principles of data protection by design and by default (Art. 25 GDPR).
Working with Processors and Third Parties
Where, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transfer it to them or otherwise grant them access to the data, this takes place only on the basis of a statutory permission (for example, where transferring the data to third parties, such as payment service providers, is necessary for the performance of a contract pursuant to Art. 6(1)(b) GDPR), where you have consented, where a legal obligation provides for it, or on the basis of our legitimate interests (for example, when using agents, web hosts, etc.).
Where we engage third parties to process data on the basis of a so-called “data processing agreement”, this is done on the basis of Art. 28 GDPR.
Transfers to Third Countries
Where we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or this occurs in the context of using third-party services or disclosing or transferring data to third parties, this takes place only where it is necessary to fulfil our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to statutory or contractual permissions, we process or allow the data to be processed in a third country only where the special conditions of Art. 44 et seq. GDPR are met. That is, processing takes place, for example, on the basis of special safeguards, such as the officially recognised determination of a level of data protection equivalent to that of the EU (for example, for the USA, through the “Privacy Shield”) or the observance of officially recognised special contractual obligations (so-called “standard contractual clauses”).
Rights of Data Subjects
You have the right to request confirmation as to whether data concerning you is being processed, and to request access to that data, further information and a copy of the data in accordance with Art. 15 GDPR.
Accordingly, under Art. 16 GDPR, you have the right to request the completion of data concerning you or the correction of inaccurate data concerning you.
In accordance with Art. 17 GDPR, you have the right to request that data concerning you be deleted without delay or, alternatively, in accordance with Art. 18 GDPR, to request a restriction of the processing of the data.
You have the right to request that the data concerning you, which you have provided to us, be received in accordance with Art. 20 GDPR and to request its transfer to other controllers.
You also have the right, pursuant to Art. 77 GDPR, to lodge a complaint with the competent supervisory authority.
Right of Withdrawal
You have the right to withdraw consent you have given, pursuant to Art. 7(3) GDPR, with effect for the future.
Right to Object
You may object at any time to the future processing of your data in accordance with Art. 21 DSGVO. The objection may in particular be made to processing for direct marketing purposes.
Cookies and right to object to direct marketing
“Cookies” are small files stored on users’ computers. Various information can be stored within cookies. A cookie primarily serves to store information about a user (or the device on which the cookie is stored) during or after their visit to an online service. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes their browser. Such a cookie can, for example, store the contents of a shopping basket in an online shop or a login status. Cookies that remain stored even after the browser is closed are referred to as “permanent” or “persistent”. For example, the login status can be saved if users return to the site after several days. Likewise, such a cookie can store users’ interests, which are used for reach measurement or marketing purposes. Cookies offered by providers other than the controller operating the online service are referred to as “third-party cookies” (if they are only the controller’s own cookies, they are called “first-party cookies”).
We may use temporary and permanent cookies and inform users about this within our privacy policy.
If users do not want cookies to be stored on their computer, they are asked to disable the relevant option in the system settings of their browser. Stored cookies can be deleted in the browser’s system settings. Excluding cookies may lead to functional restrictions of this online service.
A general objection to the use of cookies used for online marketing purposes can be made for a large number of services, particularly in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be prevented by switching them off in your browser settings. Please note that in that case, not all functions of this online offer may be available to you.
Deletion of data
Data we process will be deleted or its processing restricted in accordance with Art. 17 and 18 DSGVO. Unless expressly stated in this privacy policy, data stored by us will be deleted as soon as it is no longer required for its purpose and no statutory retention obligations prevent its deletion. Where data is not deleted because it is required for other legally permissible purposes, its processing will be restricted. That is, the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
Under statutory requirements in Germany, records are retained in particular for 10 years pursuant to §§ 147 para. 1 AO, 257 para. 1 nos. 1 and 4, para. 4 HGB (books, records, management reports, accounting vouchers, commercial books, documents relevant for taxation, etc.), and for 6 years pursuant to § 257 para. 1 nos. 2 and 3, para. 4 HGB (commercial letters).
Under statutory requirements in Austria, records are retained in particular for 7 years pursuant to § 132 para. 1 BAO (accounting records, vouchers and invoices, accounts, receipts, business papers, statements of income and expenses, etc.), for 22 years in connection with property, and for 10 years for documents relating to electronically supplied services, telecommunications, broadcasting and television services provided to non-entrepreneurs in EU member states for which the Mini One-Stop Shop (MOSS) is used.
Business-related processing
In addition, we process
– Contract data (e.g. subject matter of the contract, term, customer category).
– Payment data (e.g. bank details, payment history)
of our customers, prospects and business partners for the purposes of providing contractual services, service and customer care, marketing, advertising and market research.
Contractual services
We process the data of our contractual partners and prospects, as well as other clients, customers, principals, patients or contractual partners (collectively referred to as “contractual partners”) in accordance with Art. 6 para. 1 lit. b. GDPR, in order to provide our contractual or pre-contractual services to them. The data processed here, its type, scope, purpose and necessity, are determined by the underlying contractual relationship.
The processed data includes the master data of our contractual partners (e.g. names and addresses), contact details (e.g. email addresses and telephone numbers), contract data (e.g. services used, contract contents, contractual communication, names of contact persons) and payment data (e.g. bank details, payment history).
We generally do not process special categories of personal data, unless these form part of a commissioned or contractual processing.
We process data that is necessary for entering into and performing contractual services, and we point out the necessity of providing it where this is not evident to contractual partners. Data is only disclosed to external persons or companies where this is necessary within the framework of a contract. When processing data entrusted to us within the framework of an order, we act in accordance with the instructions of the clients and statutory requirements.
In connection with the use of our online services, we may store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as the interests of users in protection against misuse and other unauthorised use. Such data is generally not passed on to third parties, unless this is necessary to pursue our claims pursuant to Art. 6 para. 1 lit. f. DSGVO or there is a statutory obligation to do so pursuant to Art. 6 para. 1 lit. c. DSGVO.
Data is deleted when it is no longer required to fulfil contractual or statutory duties of care and to handle any warranty and comparable obligations, whereby the necessity of retaining the data is reviewed every three years; otherwise, statutory retention obligations apply.
Administration, financial accounting, office organisation, contact management
We process data as part of administrative tasks and the organisation of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in providing our contractual services. The legal bases for processing are Art. 6 para. 1 lit. c. GDPR and Art. 6 para. 1 lit. f. GDPR. Customers, prospects, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lie in administration, financial accounting, office organisation and archiving of data, i.e. tasks that serve to maintain our business activities, perform our duties and provide our services. The deletion of data relating to contractual services and contractual communication corresponds to the details stated for these processing activities.
In doing so, we disclose or transmit data to the tax authorities, advisers such as tax advisers or auditors, as well as other fee-collecting bodies and payment service providers.
Furthermore, on the basis of our business interests, we store information about suppliers, event organisers and other business partners, for example for later contact. This largely company-related data is generally stored permanently.
Participation in affiliate partner programmes
Within our online offer, on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer) and pursuant to Art. 6 para. 1 lit. f GDPR, we use tracking measures common in the industry, where these are necessary for the operation of the affiliate system. Below, we explain the technical background to users.
The services offered by our contractual partners may also be advertised and linked on other websites (so-called affiliate links or after-buy systems, for example where third-party links or services are offered after a contract has been concluded). The operators of the respective websites receive a commission if users follow the affiliate links and subsequently take up the offers.
In summary, it is necessary for our online service that we can track whether users who are interested in affiliate links and/or the offers available with us subsequently take up the offers as a result of the affiliate links or our online platform. To this end, the affiliate links and our offers are supplemented with certain values, which can be part of the link or set in another way, for example in a cookie. These values include in particular the referring web page, the time, an online identifier of the operator of the web page on which the affiliate link appeared, an online identifier of the respective offer, an online identifier of the user, as well as tracking-specific values such as advertising material ID, partner ID and categorisations.
The online identifiers of users that we use are pseudonymous values. That is, the online identifiers do not themselves contain personal data such as names or email addresses. They merely help us determine whether the same user who clicked an affiliate link or showed interest in an offer via our online service has taken up the offer, i.e. concluded a contract with the provider, for example. However, the online identifier is personal insofar as the partner company and we both hold the online identifier together with other user data. Only in this way can the partner company inform us whether that user has taken up the offer, and we can, for example, pay out the bonus.
Registration function
Users can create a user account. As part of registration, the required mandatory details are communicated to users and processed on the basis of Art. 6 para. 1 lit. b GDPR for the purpose of providing the user account. The processed data includes in particular the login information (name, password and an email address). The data entered during registration is used for the purposes of using the user account and its intended purposes.
Users may be informed by email about information relevant to their user account, such as technical changes. If users have cancelled their user account, their data relating to the user account will be deleted, subject to any statutory retention obligation. It is the users’ responsibility to back up their data before the contract ends upon cancellation. We are entitled to irrevocably delete all user data stored during the contract period.
When users make use of our registration and login functions and their user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as users’ interest in protection against misuse and other unauthorised use. Such data is generally not passed on to third parties, unless this is necessary to pursue our claims or there is a statutory obligation to do so pursuant to Art. 6 para. 1 lit. c. DSGVO. IP addresses are anonymised or deleted after 7 days at the latest.
Comments and posts
If users leave comments or other posts, their IP addresses may be stored for 7 days on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR. This is for our own security, in case someone leaves unlawful content in comments and posts (insults, banned political propaganda, etc.). In such a case, we may be held liable for the comment or post ourselves and are therefore interested in the identity of the author.
Furthermore, we reserve the right to process users’ details to detect spam, on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. DSGVO.
On the same legal basis, we reserve the right, in the case of surveys, to store users’ IP addresses for the duration of the survey and to use cookies to prevent multiple voting.
The data provided in connection with comments and posts will be stored by us permanently, until users object.
Retrieval of profile pictures from Gravatar
Within our online offer and in particular on the blog, we use the Gravatar service provided by Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA.
Gravatar is a service where users can register and store profile pictures and their email addresses. If users leave posts or comments on other online presences (especially blogs) using the respective email address, their profile pictures can be displayed alongside the posts or comments. For this purpose, the email address provided by users is transmitted to Gravatar in encrypted form to check whether a profile is stored for it. This is the sole purpose of transmitting the email address; it is not used for other purposes and is deleted afterwards.
The use of Gravatar is based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f) DSGVO, as Gravatar allows authors of posts and comments to personalise their contributions with a profile picture.
By displaying the images, Gravatar learns the IP addresses of users, as this is necessary for communication between a browser and an online service. Further information on the collection and use of data by Gravatar can be found in Automattic’s privacy notices: https://automattic.com/privacy/.
If users do not want a user picture linked to their email address at Gravatar to appear in the comments, they should use an email address for commenting that is not registered with Gravatar. We also point out that it is possible to use an anonymous email address or none at all, if users do not wish their own email address to be sent to Gravatar. Users can prevent the transmission of data entirely by not using our comment system.
Retrieval of emojis and smilies
Within our WordPress blog, graphical emojis (or smilies), i.e. small graphic files that express feelings, are used. They are sourced from external servers. The server providers collect the users’ IP addresses. This is necessary so that the emoji files can be transmitted to users’ browsers. The emoji service is provided by Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA. Automattic’s privacy notices: https://automattic.com/privacy/. The server domains used are s.w.org and twemoji.maxcdn.com, which, to our knowledge, are so-called content delivery networks, i.e. servers that merely serve to transmit the files quickly and securely, and the users’ personal data is deleted after transmission.
The use of emojis is based on our legitimate interests, i.e. an interest in making our online offering attractive, in accordance with Art. 6 para. 1 lit. f. DSGVO.
Getting in touch
When you contact us (e.g. via contact form, email, telephone or social media), the user’s details are processed to handle the enquiry and its completion in accordance with Art. 6 para. 1 lit. b. (in the context of contractual or pre-contractual relationships) and Art. 6 para. 1 lit. f. (other enquiries) GDPR. The users’ details may be stored in a customer relationship management (“CRM”) system or a comparable enquiry management system.
We delete enquiries once they are no longer required. We review the need for retention every two years; statutory archiving obligations also apply.
Newsletter
The following information explains the contents of our newsletter as well as the sign-up, dispatch and statistical evaluation procedures, and informs you of your rights to object. By subscribing to our newsletter, you agree to receive it and to the procedures described.
Newsletter content: We send newsletters, emails and other electronic notifications containing promotional information (hereinafter “newsletter”) only with the recipients’ consent or with statutory permission. Where the content of the newsletter is specifically described as part of a subscription, that content is decisive for users’ consent. Otherwise, our newsletters contain information about our services and about us.
Double opt-in and logging: Subscription to our newsletter takes place using a so-called double opt-in procedure. That is, after subscribing, you will receive an email asking you to confirm your subscription. This confirmation is necessary so that nobody can subscribe using someone else’s email address. Newsletter subscriptions are logged in order to be able to demonstrate the subscription process in accordance with legal requirements. This includes storing the time of subscription and confirmation, as well as the IP address. Changes to your data stored with the dispatch service provider are also logged.
Registration data: To subscribe to the newsletter, it is sufficient for you to provide your email address. Optionally, we ask you to provide a name so that we can address you personally in the newsletter.
The dispatch of the newsletter and the success measurement associated with it are based on the recipients’ consent pursuant to Art. 6(1)(a) and Art. 7 GDPR in conjunction with § 7(2) No. 3 UWG (German Unfair Competition Act), or, where consent is not required, on our legitimate interests in direct marketing pursuant to Art. 6(1)(f) GDPR in conjunction with § 7(3) UWG.
The logging of the registration process is based on our legitimate interests pursuant to Art. 6(1)(f) GDPR. Our interest is in using a user-friendly and secure newsletter system that serves both our business interests and meets users’ expectations, and which also allows us to provide proof of consent.
Cancellation/withdrawal – You may cancel receipt of our newsletter at any time, i.e. withdraw your consent. A link to cancel the newsletter can be found at the end of each newsletter. 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 demonstrate 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 a consent is confirmed at the same time.
Newsletter – success measurement
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 that provider’s server. As part of this retrieval, technical information such as details about the browser and your system, as well as your IP address and the time of retrieval, are initially collected.
This information is used to technically improve the services, based on the technical data or the target groups and their reading behaviour, determined by the retrieval locations (which can be identified with the help of the IP address) or the access times. Statistical surveys also include establishing whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our aim, nor, where used, that of the dispatch service provider, to monitor individual users. Rather, the evaluations serve us to recognise the reading habits of our users and to adapt our content to them or to send different content in line with the interests of our users.
Unfortunately, it is not possible to withdraw from success measurement separately; in this case, the entire newsletter subscription must be cancelled.
Hosting and email dispatch
The hosting services we use provide the following: infrastructure and platform services, computing capacity, storage space and database services, email dispatch, security services and technical maintenance services, which we use for the purpose of operating this online offer.
In this context, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, and meta and communication data of customers, prospects and visitors to this online offering, on the basis of our legitimate interests in the efficient and secure provision of this online offering pursuant to Art. 6(1)(f) GDPR in conjunction with Art. 28 GDPR (conclusion of a data processing agreement).
Collection of access data and log files
We, or our hosting provider, collect data on every access to the server on which this service is located (so-called server log files) on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR. The access data includes the name of the retrieved web page or file, date and time of retrieval, amount of data transferred, notification of successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
For security reasons (e.g. to investigate misuse or fraudulent activity), log file information is stored for a maximum of 7 days and then deleted. Data whose further retention is required for evidential purposes is exempt from deletion until the respective incident has been finally resolved.
Content Delivery Network by Cloudflare
We use a so-called “Content Delivery Network” (CDN) provided by Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA. Cloudflare is certified under the Privacy Shield agreement and thereby provides a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnZKAA0&status=Active).
A CDN is a service with the help of which content of our online offering, particularly large media files such as graphics or scripts, is delivered more quickly by means of regionally distributed servers connected via the internet. Users’ data is processed solely for the aforementioned purposes and to maintain the security and functionality of the CDN.
The use is based on our legitimate interests, i.e. interest in the secure and efficient provision, analysis and optimisation of our online offering pursuant to Art. 6(1)(f) GDPR.
For further information, please see Cloudflare’s privacy policy: https://www.cloudflare.com/security-policy.
Google Tag Manager
Google Tag Manager is a solution with which we can manage so-called website tags via an interface (and thus, for example, integrate Google Analytics and other Google marketing services into our online offer). The Tag Manager itself (which implements the tags) does not process any personal data of users. With regard to the processing of users’ personal data, please refer to the following information on Google services. Usage policies: https://www.google.com/intl/de/tagmanager/use-policy.html.
Google Analytics
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use Google Analytics, a web analytics service provided by Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by users is generally transmitted to a Google server in the USA and stored there.
Google is certified under the Privacy Shield agreement and thereby provides a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate users’ use of our online offering, to compile reports on activities within this online offering and to provide us with further services associated with the use of this online offering and internet use. In doing so, pseudonymous usage profiles of users may be created from the processed data.
We only use Google Analytics with IP anonymisation activated. This means that users’ IP addresses are truncated by Google within Member States of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transferred to a Google server in the USA and truncated there.
The IP address transmitted by the user’s browser is not merged with other data from Google. Users can prevent the storage of cookies by adjusting their browser software settings accordingly. Users can also prevent the collection of data generated by the cookie and relating to their use of the online offer, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
Alternatively, you can deactivate Google Analytics by clicking the following link: Deactivate Google Analytics
Further information on data use by Google, settings and opt-out options can be found in Google’s privacy policy (https://policies.google.com/technologies/ads) and in the settings for displaying advertisements by Google (https://adssettings.google.com/authenticated).
Users’ personal data is deleted or anonymised after 14 months.
Audience building with Google Analytics
We use Google Analytics so that the adverts placed by Google and its partners within its advertising services are only shown to users who have shown an interest in our online offer or who have certain characteristics (e.g. interests in particular topics or products, determined by the websites visited) that we transmit to Google (so-called “remarketing” or “Google Analytics audiences”). With the help of remarketing audiences, we also want to ensure that our adverts match the potential interests of users.
Google AdSense with non-personalised adverts
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).
Google is certified under the Privacy Shield agreement and thereby provides a guarantee that it will comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
We use the AdSense service, with the help of which adverts are displayed on our website and we receive remuneration for their display or other use. For these purposes, usage data such as clicks on an advert and users’ IP addresses are processed, whereby the last two digits of the IP address are truncated. Therefore, users’ data is processed in a pseudonymised form.
We use AdSense with non-personalised adverts. In this case, adverts are not displayed on the basis of user profiles. Non-personalised adverts are not based on previous user behaviour. Targeting uses contextual information, including broad geographic targeting (e.g. at town or city level) based on the current location, the content of the current website or app, and current search terms. Google prohibits all personalised targeting, including demographic targeting and targeting based on user lists.
Further information on data use by Google, settings and opt-out options can be found in Google’s privacy policy (https://policies.google.com/technologies/ads) and in the settings for displaying advertisements by Google (https://adssettings.google.com/authenticated).
Google Ads and conversion measurement
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).
Google is certified under the Privacy Shield agreement and thereby provides a guarantee that it will comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
We use the online marketing method Google “AdWords” to place adverts in the Google advertising network (e.g. in search results, in videos, on websites, etc.), so that they are shown to users who presumably have an interest in the adverts. This allows us to display adverts for and within our online offering more precisely, in order to show users only adverts that potentially match their interests. If, for example, users are shown adverts for products they have shown interest in on other online offerings, this is referred to as “remarketing”. For these purposes, when our and other websites on which the Google advertising network is active are accessed, Google immediately executes code and so-called (re)marketing tags (invisible graphics or code, also known as “web beacons”) are embedded in the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies may be used instead of cookies). This file records which websites the user has visited, which content they are interested in and which offers the user has clicked, as well as technical information about the browser and operating system, referring websites, visit time and other details about the use of the online offering.
Furthermore, we receive an individual “conversion cookie”. The information obtained with the help of the cookie is used by Google to create conversion statistics for us. However, we only learn the anonymous total number of users who clicked on our advert and were redirected to a page tagged with a conversion tracking tag. We do not, however, receive any information that would allow users to be personally identified.
Users’ data is processed pseudonymously within the Google advertising network. That is, Google does not store or process, for example, users’ names or email addresses, but processes the relevant data on a cookie basis within pseudonymous user profiles. From Google’s perspective, adverts are therefore not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who that cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymisation. The information collected about users is transmitted to Google and stored on Google’s servers in the USA.
Further information on data use by Google, settings and opt-out options can be found in Google’s privacy policy (https://policies.google.com/technologies/ads) and in the settings for displaying advertisements by Google (https://adssettings.google.com/authenticated).
Facebook pixel, Custom Audiences and Facebook conversion
On the basis of our legitimate interests in analysis, optimisation and the economic operation of our online offer, and for these purposes, the so-called “Facebook Pixel” of the social network Facebook is used. It is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA or, if you are resident in the EU, by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”).
Facebook is certified under the Privacy Shield agreement and thereby provides a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
With the help of the Facebook pixel, Facebook is able, firstly, to determine the visitors to our online offering as a target group for the display of adverts (so-called “Facebook Ads”). Accordingly, we use the Facebook pixel to show the Facebook Ads we place only to Facebook users who have shown an interest in our online offering or who have certain characteristics (e.g. interests in particular topics or products, determined on the basis of 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 match users’ potential interests and do not come across as intrusive. Furthermore, with the help of the Facebook pixel, we can track the effectiveness of Facebook adverts for statistical and market research purposes, by seeing whether users were redirected to our website after clicking on a Facebook advert (so-called “conversion”).
Facebook processes data in accordance with Facebook’s Data Policy. Accordingly, general information on the display of Facebook ads can be found in Facebook’s Data Policy: https://www.facebook.com/policy. Specific information and details on the Facebook Pixel and how it works can be found in Facebook’s Help Centre: https://www.facebook.com/business/help/651294705016616.
You can object to the collection of data by the Facebook Pixel and the use of your data to display Facebook ads. To set which types of advertisements are shown to you within Facebook, you can visit the page set up by Facebook and follow the instructions there on settings for usage-based advertising: https://www.facebook.com/settings?tab=ads. The settings apply across platforms, i.e. they are applied to all devices, such as desktop computers or mobile devices.
Facebook Pixel Opt-out: Disable Facebook Pixel
You can also object to the use of cookies used for audience measurement and advertising purposes via the deactivation page of the Network Advertising Initiative (http://optout.networkadvertising.org/) and additionally via the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).
Online presences in social media
We maintain online presences within social networks and platforms in order to communicate with customers, prospects and users active there and to inform them about our services.
We point out that, in this context, users’ data may be processed outside the European Union. This may pose risks for users, as, for example, enforcing users’ rights could be made more difficult. With regard to US providers certified under the Privacy Shield, we note that they undertake to comply with EU data protection standards.
Furthermore, users’ data is generally processed for market research and advertising purposes. For example, usage profiles can be created from users’ usage behaviour and the interests resulting from it. These usage profiles can in turn be used, for example, to display adverts within and outside the platforms that presumably match users’ interests. For these purposes, cookies are generally stored on users’ computers, in which usage behaviour and users’ interests are stored. Furthermore, data may also be stored in the usage profiles independently of the devices used by users (particularly if users are members of the respective platforms and are logged in to them).
The processing of users’ personal data is based on our legitimate interests in providing users with effective information and communicating with them pursuant to Art. 6(1)(f) GDPR. If users are asked by the respective providers for consent to data processing (i.e. they declare their agreement, for example by ticking a checkbox or confirming a button), the legal basis for processing is Art. 6(1)(a) and Art. 7 GDPR.
For a detailed description of the respective processing and the options to object (opt-out), please refer to the provider information linked below.
Please note that, also in the case of requests for information and the assertion of user rights, these are most effectively asserted with the providers. Only the providers have access to users’ data and can take appropriate measures and provide information directly. Should you nevertheless need help, you are welcome to contact us.
– Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) – Privacy policy: https://www.facebook.com/about/privacy/, Opt-out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.
– Google/ YouTube (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – Privacy policy: https://policies.google.com/privacy, Opt-out: https://adssettings.google.com/authenticated, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
– Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – Privacy policy/ Opt-Out: http://instagram.com/about/legal/privacy/.
– Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) – Privacy policy: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.
– Pinterest (Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA) – Privacy policy/ Opt-Out: https://about.pinterest.com/de/privacy-policy.
Integration of third-party services and content
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offering within the meaning of Article 6(1)(f) GDPR), we embed content or service offerings from third-party providers within our online offering in order to integrate their content and services, such as videos or fonts (hereinafter collectively referred to as “content”).
This always presupposes that the third-party providers of this content perceive the IP address of users, since without the IP address they could not send the content to their browser. The IP address is therefore necessary for displaying this content. We endeavour to only use content whose respective providers use the IP address solely for delivering the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to 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 technical information about the browser and operating system, referring websites, time of visit and other details about the use of our online offer, and may also be combined with such information from other sources.
YouTube
We embed the videos of the “YouTube” platform provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.
Google Fonts
We integrate the fonts (“Google Fonts”) provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.
Google ReCaptcha
We integrate the function for recognising bots, e.g. when entering data into online forms (“ReCaptcha”), provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.
Google Maps
We integrate the maps of the “Google Maps” service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The data processed may include, in particular, IP addresses and location data of users, which are not collected without their consent (usually given within the settings of their mobile devices). The data may be processed in the USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.