Privacy Policy
Preamble
With the following privacy policy, we would like to inform you about which types of your personal data (hereinafter also referred to as “data”) we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).
The terms used are not gender-specific.
Status: June 27, 2024
Table of contents
Fischer Sports GmbH
Fischerstrasse 8
4910 Ried im Innkreis
Austria
e-mail address:
info@fischersports.com
Phone:
+43 7752 909-0
Imprint:
https://www.fischersports.com/imprint/
The following overview
summarizes the types of data processed and the purposes of their processing and
refers to the data subjects.
Types of data processed
- Inventory data.
- Payment data.
- Location data.
- Contact details.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and process data.
- Applicant data.
- Location history and movement profiles.
- Event data (Facebook).
Categories of affected persons
- Customers.
- Employees.
- Interested parties.
- Communication partner.
- Users.
- Applicants.
- Competition and contest participants.
- Business and contractual partners.
- Participants.
- Persons depicted.
Purposes of the processing
- Provision of contractual services and fulfillment of contractual obligations.
- Contact requests and communication.
- Safety measures.
- Direct marketing.
- Reach measurement.
- Tracking.
- Office and organizational procedures.
- Conversion measurement.
- Target group formation.
- Managing and responding to inquiries.
- Application procedure.
- Organizing competitions and contests.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online services and user-friendliness.
- Assessment of creditworthiness and credit standing.
- Information technology infrastructure.
Automated decisions in individual cases
- Credit report.
Relevant legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.
- Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given their consent to the processing of their personal data for one or more specific purposes.
- Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
- Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR) - Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are requested from applicants as part of the application procedure (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants so that the controller or the data subject can exercise their rights under labor law and social security and social protection law and fulfill their obligations in this regard, their processing is carried out in accordance with Art. 9 para. 2 lit. b. GDPR. GDPR, in the case of the protection of vital interests of applicants or other persons pursuant to Art. 9 para. 2 lit. c. GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee's ability to work, for medical diagnosis, health or social care or treatment or for the management of health or social care systems and services in accordance with Art. 9 para. 2 lit. h. GDPR. In the case of communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 para. 2 lit. a. GDPR.
National data
protection regulations in Austria: In addition to the data protection regulations of the GDPR, national data
protection regulations apply in Austria. These include, in particular, the
Federal Act on the Protection of Natural Persons with regard to the Processing
of Personal Data (Data Protection Act - DSG). In particular, the Data
Protection Act contains special regulations on the right to information, the
right to rectification or erasure, the processing of special categories of
personal data, processing for other purposes and transfer as well as automated
decision-making in individual cases.
Relevant legal bases
according to the Swiss Data Protection Act: If you are located in Switzerland, we process your data on the basis of the
Federal Act on Data Protection ("Swiss FADP" for short). This also
applies if our processing of your data otherwise affects you in Switzerland and
you are affected by the processing. In principle, the Swiss FADP does not
stipulate (unlike the GDPR, for example) that a legal basis for the processing
of personal data must be specified. We only process personal data if the
processing is lawful, is carried out in good faith and is proportionate (Art. 6
para. 1 and 2 of the Swiss FADP). Furthermore, we only obtain personal data for
a specific purpose that is recognizable to the data subject and only process it
in such a way that it is compatible with these purposes (Art. 6 para. 3 of the
Swiss FADP).
Note on the applicability of the GDPR and Swiss FADP: This data protection notice serves to provide information in accordance with both the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). For this reason, please note that the terms of the GDPR are used due to the broader geographical application and comprehensibility. In particular, instead of the terms "processing" of "personal data", "overriding interest" and "sensitive personal data" used in the Swiss DPA, the terms "processing" of "personal data", "legitimate interest" and "special categories of data" used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of application of the Swiss DPA.
We take appropriate
technical and organizational measures in accordance with the legal
requirements, taking into account the state of the art, the implementation
costs and the nature, scope, circumstances and purposes of the processing as
well as the different probabilities of occurrence and the extent of the threat
to the rights and freedoms of natural persons, in order to ensure a level of
protection appropriate to the risk.
The measures include, in
particular, safeguarding the confidentiality, integrity and availability of
data by controlling physical and electronic access to the data as well as the
access, input, disclosure, safeguarding of availability and its separation.
Furthermore, we have established procedures that ensure the exercise of data
subject rights, the deletion of data and responses to data threats.
Furthermore, we already take the protection of personal data into account
during the development or selection of hardware, software and processes in
accordance with the principle of data protection, through technology design and
through data protection-friendly default settings.
Shortening of the IP
address: If IP addresses are processed by us or by the service providers and
technologies used and the processing of a full IP address is not required, the
IP address is truncated (also known as "IP masking"). The last two digits
or the last part of the IP address after a dot are removed or replaced by
placeholders. The purpose of shortening the IP address is to prevent or make it
much more difficult to identify a person by their IP address.
TLS/SSL encryption (https): To protect user data transmitted via our online services, we use TLS/SSL encryption. Secure Sockets Layer (SSL) is the standard technology for securing internet connections by encrypting the data transmitted between a website or app and a browser (or between two servers). Transport Layer Security (TLS) is an updated and more secure version of SSL. Hyper Text Transfer Protocol Secure (HTTPS) is displayed in the URL when a website is secured by an SSL/TLS certificate.
As part of our processing
of personal data, the data may be transmitted to other bodies, companies,
legally independent organizational units or persons or disclosed to them. The
recipients of this data may include, for example, service providers commissioned
with IT tasks or providers of services and content that are integrated into a
website. In such cases, we observe the legal requirements and, in particular,
conclude corresponding contracts or agreements with the recipients of your data
that serve to protect your data.
Data transfer within the
group of companies: We may transfer personal data to other companies within our
group of companies or grant them access to this data. If this transfer takes
place for administrative purposes, the transfer of the data is based on our
legitimate business and commercial interests or takes place if it is necessary
to fulfill our contractual obligations or if the consent of the data subjects
or a legal permission exists.
Data transfer within the organization: We may transfer personal data to other departments within our organization or grant them access to this data. If this transfer is for administrative purposes, the transfer of the data is based on our legitimate business and commercial interests or takes place if it is necessary to fulfill our contractual obligations or if the consent of the data subjects or a legal permission exists.
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 will only take place in accordance with the legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data will only be transferred if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 para. 2 lit. c) GDPR), express consent or in the case of contractual or legally required transfer (Art. 49 para. 1 GDPR). In addition, we will inform you of the basis for third country transfers with the individual providers from the third country, whereby the adequacy decisions take precedence. Information on third country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de.
EU-US Trans-Atlantic Data
Privacy Framework: As part of the so-called "Data Privacy Framework"
(DPF), the EU Commission has also recognized the level of data protection for
certain companies from the USA as secure as part of the adequacy decision of
10.07.2023. The list of certified companies and further information on the DPF
can be found on the website of the US Department of Commerce at
https://www.dataprivacyframework.gov/. As part of the data protection
information, we will inform you which service providers we use are certified
under the Data Privacy Framework.
Disclosure of personal
data abroad: In accordance with the Swiss Data Protection Act (DSG), we only
disclose personal data abroad if adequate protection of the data subjects is
guaranteed (Art. 16 Swiss DSG). If the Federal Council has not determined adequate
protection (list: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html),
we take alternative security measures. These may include international
contracts, specific guarantees, data protection clauses in contracts, standard
data protection clauses approved by the Federal Data Protection and Information
Commissioner (FDPIC) or internal company data protection regulations recognized
in advance by the FDPIC or a competent data protection authority in another
country.
According to Art. 16 of
the Swiss DPA, exceptions may be made for the disclosure of data abroad if
certain conditions are met, including consent of the data subject, performance
of a contract, public interest, protection of life or physical integrity, data
made public or data from a register provided for by law. These disclosures are
always made in accordance with legal requirements.
The data processed by us will be deleted in accordance with the legal requirements as soon as the consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data no longer applies or it is not required for the purpose). If the data is not deleted because it is required for other and legally permissible purposes, its processing is restricted to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for the assertion, exercise or defense of legal claims or to protect the rights of another natural or legal person. As part of our data protection information, we can provide users with further information on the deletion and retention of data that applies specifically to the respective processing operations.
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Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
- Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw your consent at any time.
- Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with the legal requirements.
- Right to rectification: In accordance with the statutory provisions, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
- Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
- Right to data portability: You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request its transmission to another controller.
- Complaint to a supervisory authority: In accordance with the statutory provisions
and without prejudice to any other administrative or judicial remedy, you
also have the right to lodge a complaint with a data protection
supervisory authority, in particular a supervisory authority in the Member
State in which you are habitually resident, the supervisory authority of
your place of work or the place of the alleged infringement, if you
consider that the processing of personal data relating to you infringes
the GDPR.
Rights of data subjects under the Swiss DPA:
As a data subject, you have the following rights in accordance with the provisions of the Swiss Data Protection Act:
- Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed and to receive the information necessary for you to exercise your rights under this law and to ensure transparent data processing.
- Right to data surrender or transfer: You have the right to request the surrender of your personal data that you have provided to us in a commonly used electronic format.
- Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
- Right to object, erasure and destruction: You have the right to object to the processing of your data and to request that the personal data concerning you be erased or destroyed.
Cookies are small text
files or other storage notes that store information on end devices and read
information from the end devices. For example, to store the login status in a
user account, the contents of a shopping cart in an e-shop, the content accessed
or the functions of an online offer used. Cookies can also be used for various
purposes, e.g. to ensure the functionality, security and convenience of online
services and to analyze visitor flows.
Notes on consent: We use cookies in accordance with the statutory
provisions. We therefore obtain prior consent from users, unless this is not
required by law. In particular, consent is not required if the storage and
reading of information, including cookies, is absolutely necessary in order to
provide the user with a telemedia service expressly requested by them (i.e. our
online offer). Strictly necessary cookies generally include cookies with
functions that serve the display and operability of the online service, load
balancing, security, storage of user preferences and selection options or
similar purposes related to the provision of the main and secondary functions
of the online service requested by the user. The revocable consent is clearly
communicated to the users and contains the information on the respective use of
cookies.
Information on legal
bases under data protection law: The legal basis under data protection law on which we process users'
personal data with the help of cookies depends on whether we ask users for
their consent. If users give their consent, the legal basis for processing
their data is their declared consent. Otherwise, the data processed using
cookies is processed on the basis of our legitimate interests (e.g. in the
commercial operation of our online offering and improving its usability) or, if
this is done in the context of fulfilling our contractual obligations, if the
use of cookies is necessary to fulfill our contractual obligations. We explain
the purposes for which we process cookies in the course of this privacy policy
or as part of our consent and processing procedures.
Storage period: With regard to the storage period, a distinction is made between the following types of cookies:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their end device (e.g. browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after
the end device is closed. For example, the login status can be saved or
preferred content can be displayed directly when the user visits a website
again. The user data collected with the help of cookies can also be used
to measure reach. If we do not provide users with explicit information on
the type and storage duration of cookies (e.g. when obtaining consent),
users should assume that cookies are permanent and can be stored for up to
two years.
General information on revocation and objection (so-called "opt-out"): Users can revoke the consent they have given at any time and object to processing in accordance with the legal requirements. Among other things, users can restrict the use of cookies in their browser settings (although this may also restrict the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.
- Processed data types: Usage data (e.g. websites visited, interest in content, access times).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offer and user-friendliness.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence
1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence
1 lit. a) GDPR).
Further information on processing operations, procedures and services:
- CookieHub: Cookie consent and management solutions; Service provider: CookieHub ehf, Hafnargata 55, 230 Reykjanesbær, Iceland; Website: https://www.cookiehub.com/. Privacy Policy: https://www.cookiehub.com/de/datenschutzrichtlinie.
- Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the consent of users to the use of cookies or the processing and providers mentioned in the cookie consent management procedure can be obtained, managed and revoked by users. The declaration of consent is stored so that it does not have to be requested again and the consent can be proven in accordance with the legal obligation. Consent can be stored on the server and/or in a cookie (so-called opt-in cookie or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: Consent may be stored for up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Cookie opt-out: In the footer of our website you will find a link that you can use to change your cookie settings and revoke your consent; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
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 and associated measures and
in the context of communication with the contractual partners (or
pre-contractual), e.g. to answer inquiries.
We process this data in
order to fulfill our contractual obligations. These include, in particular, the
obligations to provide the agreed services, any updating obligations and
remedies in the event of warranty and other service disruptions. In addition,
we process the data to safeguard our rights and for the purpose of the
administrative tasks associated with these obligations and the company
organization. In addition, we process the data on the basis of our legitimate
interests in proper and efficient business management and in security measures
to protect our contractual partners and our business operations from misuse,
threats to their data, secrets, information and rights (e.g. to involve
telecommunications, transport and other auxiliary services as well as
subcontractors, banks, tax and legal advisors, payment service providers or tax
authorities). Within the framework of applicable law, we only pass on the data
of contractual partners to third parties to the extent that this is necessary
for the aforementioned purposes or to fulfill legal obligations. Contractual
partners will be informed about other forms of processing, e.g. for marketing
purposes, as part of this privacy policy.
We inform the contractual
partners which data is required for the aforementioned purposes before or
during data collection, e.g. in online forms, by means of special marking (e.g.
colors) or symbols (e.g. asterisks or similar), or personally.
We delete the data after
the expiry of statutory warranty and comparable obligations, i.e. generally
after 4 years, unless the data is stored in a customer account, e.g. as long as
it must be retained for legal archiving reasons. The statutory retention period
is ten years for documents relevant under tax law as well as for trading books,
inventories, opening balance sheets, annual financial statements, the work
instructions required to understand these documents and other organizational
documents and accounting records, and six years for commercial and business
letters received and reproductions of commercial and business letters sent. The
period begins at the end of the calendar year in which the last entry was made
in the book, the inventory, the opening balance sheet, the annual financial
statements or the management report was prepared, the commercial or business
letter was received or sent or the accounting document was created, the record
was made or the other documents were created.
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.
- Processed data types: Inventory data (e.g. names, addresses); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. email, telephone numbers); Contract data (e.g. subject matter of contract, duration, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Persons affected: Customers; interested parties. Business and contractual partners.
- Purposes of Processing: Provision of contractual services and performance of contractual obligations; Security measures; Contact requests and communication; Office and organizational procedures; Managing and responding to inquiries; Conversion tracking (Measurement of the effectiveness of marketing activities). Profiles with user-related information (creation of user profiles).
- Legal basis: Fulfilment of contract and pre-contractual
inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art.
6 para. 1 sentence 1 lit. c) GDPR). Legitimate
interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Customer account: Customers can create an account within our online offering (e.g. customer or user account, "customer account" for short). If it is necessary to register a customer account, customers will be informed of this and of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. As part of the registration process and subsequent logins and use of the customer account, we store the IP addresses of customers together with the access times in order to be able to prove registration and prevent any misuse of the customer account. If the customer account has been terminated, the customer account data will be deleted after the termination date, unless it is stored for purposes other than provision in the customer account or must be stored for legal reasons (e.g. internal storage of customer data, order processes or invoices). It is the customer's responsibility to back up their data when the customer account is terminated; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- Wish list: Customers can create a product/wish list. In this case, the products are stored as part of the fulfillment of our contractual obligations until the account is deleted, unless the product list entries are removed by the customer or we expressly inform the customer of different storage periods; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- Economic analyses and market research: For economic reasons and in order to be able to identify market trends and the wishes of contractual partners and users, we analyze the data we have on business transactions, contracts, inquiries, etc., whereby the group of data subjects may include contractual partners, interested parties, customers, visitors and users of our online offering. The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). If available, we can take into account the profiles of registered users, including their details, e.g. on services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarized, i.e. anonymized values. Furthermore, we take into account the privacy of users and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as summarized data); legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Store and e-commerce: We process the data of our customers to enable them to select, purchase or order the selected products, goods and associated services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution for our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such in the context of the order or comparable purchase process and includes the information required for delivery or provision and billing as well as contact information in order to be able to hold any consultation; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
We offer our services on
online platforms that are operated by other service providers. In this context,
the data protection notices of the respective platforms apply in addition to
our data protection notices. This applies in particular with regard to the
execution of the payment process and the procedures used on the platforms to
measure reach and for interest-based marketing.
- Processed data types: Inventory data (e.g. names, addresses); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. email, telephone numbers); Contract data (e.g. subject matter of contract, duration, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Persons affected: Customers.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Marketing.
- Legal bases: Contract fulfillment and pre-contractual
inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Amazon: Online marketplace for e-commerce; Service provider: Amazon EU S.à r.l. (Société à responsabilité limitée), 38 avenue John F. Kennedy, L-1855 Luxembourg; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.amazon.de/Data protection declaration: https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010. Basis for transfer to third countries: EU-US Data Privacy Framework (DPF).
As part of our business
activities, we use additional services, platforms, interfaces or plug-ins from
third-party providers ("services" for short) in compliance with legal
requirements. Their use is based on our interests in the proper, lawful and
economic management of our business operations and our internal organization.
- Processed data types: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); contract data (e.g. subject matter of the contract, duration, customer category).
- Data subjects: Customers; interested parties; users (e.g. website visitors, users of online services). Business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Office and organizational procedures.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence
1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Quivers: Omnichannel fulfillment, omnichannel sales; Service provider: Quivers Inc, 50 W Broadway, Ste 333, PMB 89865, Salt Lake City, Utah 84101-2027, USA; Website: https://www.quivers.com/. Privacy policy: https://www.quivers.com/privacy-policy/. Basis for third country transfer: EU-US Data Privacy Framework (DPF).
As part of contractual
and other legal relationships, due to legal obligations or otherwise on the
basis of our legitimate interests, we offer the data subjects efficient and
secure payment options and use other service providers in addition to banks and
credit institutions (collectively referred to as "payment service
providers").
The data processed by the
payment service providers includes inventory data, such as the name and
address, bank data, such as account numbers or credit card numbers, passwords,
TANs and checksums, as well as contract, total and recipient-related information.
The information is required to carry out the transactions. However, the data
entered is only processed by the payment service providers and stored by them.
This means that we do not receive any account or credit card-related
information, but only information with confirmation or negative information
about the payment. Under certain circumstances, the data may be transmitted by
the payment service providers to credit agencies. The purpose of this
transmission is to check identity and creditworthiness. Please refer to the
general terms and conditions and the data protection information of the payment
service providers.
Payment transactions are
subject to the terms and conditions and data protection notices of the
respective payment service providers, which can be accessed on the respective
websites or transaction applications. We also refer to these for further
information and the assertion of rights of revocation, information and other
rights of data subjects.
- Processed data types: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of the contract, duration, customer category); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Persons affected: Customers. Interested parties.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations.
- Legal basis: Contract fulfillment and pre-contractual
inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing operations, procedures and services:
- Giropay: Payment services (technical connection of online payment methods); Service provider: giropay GmbH, An der Welle 4, 60322 Frankfurt, Germany; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.giropay.de. Privacy Policy: https://www.giropay.de/rechtliches/datenschutzerklaerung/.
- Klarna: Payment services (technical connection of online payment methods); Service provider: Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.klarna.com/de. Privacy policy: https://www.klarna.com/de/datenschutz.
- Mastercard: Payment services (technical connection of online payment methods); Service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.mastercard.de/de-de.html. Privacy policy: https://www.mastercard.de/de-de/datenschutz.html.
- Mollie: Payment services (technical connection of online payment methods); Service provider: Mollie B.V., Keizersgracht 126, 1015 CW Amsterdam, Netherlands; Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.mollie.com/de. Privacy Policy: https://www.mollie.com/de/privacy.
- PayPal: Payment services (technical connection of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.paypal.com/de. Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
- Stripe: Payment services (technical connection of online payment methods); Service provider: Stripe, Inc, 510 Townsend Street, San Francisco, CA 94103, USA; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://stripe.comData protection declaration: https://stripe.com/de/privacy. Basis for third country transfer: EU-US Data Privacy Framework (DPF).
- Visa: Payment services (technical connection of online payment methods); Service provider: Visa Europe Services Inc, London Branch, 1 Sheldon Square, London W2 6TT, UK; Legal basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.visa.de. Privacy Policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html.
If we make advance
payments or enter into comparable economic risks (e.g. when ordering on
account), we reserve the right to obtain identity and creditworthiness
information for the purpose of assessing the credit risk on the basis of
mathematical-statistical procedures from specialized service companies (credit
agencies) in order to safeguard our legitimate interests.
We process the
information received from the credit agencies on the statistical probability of
a payment default as part of an appropriate discretionary decision on the
establishment, execution and termination of the contractual relationship. We
reserve the right to refuse payment on account or any other advance payment in
the event of a negative result of the credit check.
The decision as to
whether we make advance payments is made in accordance with the legal
requirements solely on the basis of an automated decision in individual cases,
which our software makes on the basis of the information provided by the credit
agency.
If we obtain express
consent from contractual partners, the legal basis for the credit report and
the transmission of the customer's data to the credit agencies is consent. If
no consent is obtained, the credit information is provided on the basis of our
legitimate interests in the security of our payment claims.
- Processed data types: Inventory data (e.g. names, addresses); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. email, telephone numbers); Contract data (e.g. subject matter of contract, duration, customer category).
- Persons affected: Customers.
- Purposes of processing: Assessment of creditworthiness and credit standing.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Automated decisions in individual cases: Credit information (decision based on a
credit check).
Further information on processing operations, procedures and services:
- Credit check as a prerequisite for the provision of payment options: The provision of payment options, e.g. payment on account or payment by installments, may be made dependent on the result of the customer's credit check. In this case, we ask customers to consent to the credit check procedure; legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
We process users' data in
order to provide them with our online services. For this purpose, we process
the user's IP address, which is necessary to transmit the content and functions
of our online services to the user's browser or end device.
- Processed data types: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence
1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Internex: Web hosting; Service provider: internex GmbH, Registered office: Lagerstraße 15, 3950 Gmünd, Austria, Office address: 1090 Vienna, Alserbachstraße 30, Austria; Website: https://www.internex.at/. Privacy policy: https://www.internex.at/de/datenschutz-erklaerung/.
- Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called "web host"); legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Provision of online offer on own/ dedicated server hardware: For the provision of our online offer, we use server hardware operated by us as well as the associated storage space, computing capacity and software; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files". The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files may be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks) and to ensure the utilization of the servers and their stability; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
We process the data of
users of our application to the extent necessary to provide users with the
application and its functionalities, to monitor its security and to develop it
further. We may also contact users in compliance with legal requirements if communication
is necessary for the purposes of administration or use of the application.
Otherwise, we refer to the data protection information in this privacy policy
with regard to the processing of user data.
Legal basis: The processing of data required to provide the
functionalities of the application serves to fulfill contractual obligations.
This also applies if the provision of the functions requires user authorization
(e.g. release of device functions). If the processing of data is not necessary
for the provision of the functionalities of the application, but serves the
security of the application or our business interests (e.g. collection of data
for the purpose of optimizing the application or security purposes), it is
carried out on the basis of our legitimate interests. If users are expressly asked
for their consent to the processing of their data, the data covered by the
consent is processed on the basis of the consent.
Notes on application
functions:
Location data and
location history: Recording of distances traveled, distance climbed, time
taken, speed and timing, which are stored in the users' profile and can be
shared with friends or the public.
Pseudonymous identifier: Evaluation of which functions of the application are used by users and how often, which serves to improve user-friendliness and the display of advertisements.
- Processed data types: Inventory data (e.g. names, addresses); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of contract, term, customer category); location data (information on the geographical position of a device or person). Location history and movement profiles (collection of location data and position changes over a certain period of time).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations.
- Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a)
GDPR); contract fulfillment and pre-contractual inquiries (Art. 6 para. 1
sentence 1 lit. b) GDPR). Legitimate interests
(Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Commercial use: We process the data of the users of our application, registered users and any test users (hereinafter uniformly referred to as "users") in order to be able to provide them with our contractual services and on the basis of legitimate interests in order to ensure the security of our application and to be able to develop it further. The required information is identified as such in the context of the conclusion of the usage, order, purchase order or comparable contract and may include the information required for the provision of services and for any billing as well as contact information in order to be able to hold any consultations; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- Storage of a universally unique identifier (UUID): The application stores a so-called Universally Unique Identifier (UUID) for the purpose of analyzing the use and functionality of the application and storing the user's settings. This identifier is generated when this application is installed (but is not linked to the device, so it is not a device identifier in this sense), remains stored between the start of the application and its updates and is deleted when users remove the application from their device.
- Storage of a pseudonymous identifier: We use a pseudonymous identifier so that we can provide the application and ensure its functionality. The identifier is a mathematical value (i.e. no clear data such as names are used) that is assigned to a device and/or the installation of the application installed on it. This identifier is generated when this application is installed, remains stored between the start of the application and its updates and is deleted when users remove the application from the device.
- Processing of location data: As part of the use of our application, the location data collected by the device used or otherwise entered by the user is processed. The use of location data requires user authorization, which can be revoked at any time. The use of location data only serves to provide the respective functionality of our application, as described to users, or its typical and expected functionality.
- Location history and movement profiles: Based on the location data collected as part
of the use of our application, a location history is created, from which
the geographical movements of the devices used over a period of time are
derived (and may allow conclusions to be drawn about the movement profile
of the users). The location history
is only used to provide the respective functionality of our application,
according to its description to the users, or its typical and expected
functionality.
Further information on the #livetoski app:
- As part of the app, we enable you to call up and display the following information: Ski performance, recommendations for ski selection and link to the dealer search, news area, ranking list, recording and evaluation of ski activities.
- You can access this privacy policy at any time under the "Profile" menu item within the app.
- Information collected during the download: When downloading the app, certain required information is transmitted to the app store you have selected (Google Play or Apple App Store), in particular the user name, e-mail address, customer number of your account, time of download, payment information and individual device identification number may be processed. This data is processed exclusively by the respective app store and is beyond our control.
- Information that is collected automatically: As part of your use of the app, we collect certain data automatically that is required for the use of the app. This includes: Version of your operating system, the name of your device model, any data contained in a recording, the time the data was transmitted, the version of the App used. This data is automatically transmitted to us, but not stored, (1) to provide you with the service and the associated functions; (2) to improve the functions and performance features of the app and (3) to prevent and eliminate misuse and malfunctions. This data processing is justified by the fact that (1) the processing is necessary for the performance of the contract between you as the data subject and us pursuant to Art. 6 para. 1 lit. b) GDPR for the use of the app, or (2) we have a legitimate interest in ensuring the functionality and error-free operation of the app and in being able to offer a service in line with the market and your interests, which outweighs your rights and interests in the protection of your personal data within the meaning of Art. 6 para. 1 lit. f) GDPR.
- Creation of a user account (registration) and login: When you create a user account or log in, we use your access data e-mail address and password to grant you access to your user account and to manage it ("mandatory data"). Mandatory information in the context of registration is marked with an asterisk and is required for the conclusion of the user contract. If you do not provide this data, you will not be able to create a user account.
In addition, you can provide the following voluntary information as part of
the registration process: Date of birth, gender, weight in kg, height in cm, skiing
ability (ski level) and newsletter permission.
We use the mandatory information to authenticate you when you log in and to
follow up on requests to reset your password. We process and use the data you
enter during registration or login (1) to verify your authorization to manage
the user account; (2) to enforce the app's terms of use and all associated
rights and obligations; and (3) to contact you to send you technical or legal
notices, updates, security messages or other messages relating to the
management of the user account.
We use voluntary information to display it within the app in accordance
with your settings and to make it accessible to other users of the app at your
request.
This data processing is justified by the fact that (1) the processing is
necessary for the performance of the contract between you as the data subject
and us pursuant to Art. 6 para. 1 lit. b) GDPR for the use of the app, or (2)
we have a legitimate interest in ensuring the functionality and error-free
operation of the app, which outweighs your rights and interests in the
protection of your personal data within the meaning of Art. 6 para. 1 lit. f)
GDPR.
- Use of the app: When you use the app, we collect the personal data described below to enable you to use the functions conveniently. If you wish to use our app, we collect the following data, which is technically necessary for us to offer you the functions of our app and to ensure stability and security (legal basis is Art. 6 para. 1 lit. f) GDPR):
-IP address
-Date and time of the request
-Time zone difference to Greenwich Mean Time (GMT)
-Amount of data transferred in each case
-operating system and its interface
We also need your device identification, unique number of the end device
(IMEI = International Mobile Equipment Identity), unique number of the network
subscriber (IMSI = International Mobile Subscriber Identity), mobile phone
number (MSISDN), MAC address for WLAN use, name of your mobile end device,
e-mail address.
You can also enter, manage and edit various information and activities in
the app. This information includes, in particular, data for product
recommendations.
The app also requires the following authorizations:
-Internet access: This is required to save your entries and activities on our servers.
-Location access: This is required so that your activities can be collected, tracked and stored in the app and on our servers.
-Photo library (for profile
picture)
Usage data is processed and used to provide the service. This data processing is justified by the fact that the processing is necessary for the performance of the contract between you as the data subject and us pursuant to Art. 6 para. 1 lit. b) GDPR for the use of the app.
Our application is
obtained via special online platforms operated by other service providers
(so-called "app stores"). In this context, the data protection
notices of the respective app stores apply in addition to our data protection
notices. This applies in particular with regard to the procedures used on the
platforms to measure reach and interest-based marketing as well as any
obligation to pay costs.
- Processed data types: Inventory data (e.g. names, addresses); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. email, telephone numbers); Contract data (e.g. subject matter of the contract, duration, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status); Content data (e.g. entries in online forms).
- Data subjects: Customers; users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Marketing.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence
1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Apple App Store: App and software sales platform; Service provider: Apple Inc, Infinite Loop, Cupertino, CA 95014, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.apple.com/de/ios/app-store/. Privacy Policy: https://www.apple.com/legal/privacy/de-ww/.
- Google Play: App and software sales platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://play.google.com/store/apps?hl=de. Privacy Policy: https://policies.google.com/privacy.
Users can create a user
account. As part of the registration process, users are provided with the
required mandatory information and processed for the purpose of providing the
user account on the basis of contractual obligations. The processed data includes
in particular the login information (user name, password and an e-mail
address).
As part of the use of our
registration and login functions as well as the use of the user account, we
store the IP address and the time of the respective user action. The storage is
based on our legitimate interests as well as those of the users in protection
against misuse and other unauthorized use. This data is not passed on to third
parties unless it is necessary to pursue our claims or there is a legal
obligation to do so.
Users can be informed by
email about processes that are relevant to their user account, such as
technical changes.
- Processed data types: inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; security measures; managing and responding to inquiries. Provision of our online services and user-friendliness.
- Legal bases: Contract fulfillment and pre-contractual
inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Registration with pseudonyms: Users may use pseudonyms as usernames instead of real names; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- Setting the visibility of profiles: Users can use settings to determine the extent to which their profiles are visible or accessible to the public or only to certain groups of people; legal basis: fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- Deletion of data after termination: If users have terminated their user account, their data will be deleted with regard to the user account, subject to a legal permission, obligation or consent of the users; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- No obligation to retain data: It is the responsibility of users to back up their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
The community functions
provided by us allow users to enter into conversations or otherwise exchange
information with each other. Please note that the use of the community
functions is only permitted in compliance with the applicable legal situation,
our terms and conditions and guidelines as well as the rights of other users
and third parties.
- Processed data types: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Security measures.
- Legal basis: Contract fulfillment and pre-contractual
inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing operations, procedures and services:
- Setting the visibility of posts: Users can use settings to determine the extent to which the posts and content they create are visible or accessible to the public or only to certain persons or groups; legal basis: fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- Right to delete content and information: The deletion of posts, content or information provided by users is permitted to the extent necessary after proper consideration if there are concrete indications that they constitute a violation of legal regulations, our specifications or the rights of third parties; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
When contacting us (e.g.
by post, contact form, email, telephone or via social media) and in the context
of existing user and business relationships, the data of the inquiring persons
will be processed to the extent necessary to answer the contact requests and
any requested measures.
- Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status); Inventory data (e.g. names, addresses); Payment data (e.g. bank details, invoices, payment history); Contract data (e.g. subject matter of the contract, duration, customer category).
- Data subjects: Communication partners; customers; interested parties; users (e.g. website visitors, users of online services). Business and contractual partners.
- Purposes of Processing: Contact requests and communication; Managing and responding to inquiries; Feedback (e.g. collecting feedback via online form); Provision of our online services and usability; Provision of contractual services and fulfillment of contractual obligations; Conversion tracking (Measurement of the effectiveness of marketing activities). Marketing.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence
1 lit. f) GDPR). Contract performance and pre-contractual inquiries (Art.
6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing operations, procedures and services:
- Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data provided to us in this context to process the communicated request; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Salesforce Service Cloud: Customer management as well as process and sales support with personalized customer care with multi-channel communication, i.e. management of customer inquiries from different channels as well as analysis and feedback functions; Service provider: salesforce.com Deutschland GmbH, Erika-Mann-Str. 31, 80636 Munich, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.salesforce.com/en; Privacy Policy: https://www.salesforce.com/de/company/privacy; Data processing agreement: https://www.salesforce.com/company/privacy/; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses ("International Transfers of EU Personal Data to Salesforce's Services": https://www.salesforce.com/content/dam/web/en_us/www/documents/legal/Agreements/EU-Data-Transfer-Mechanisms-FAQ.pdf). Further information: Data transfer impact assessment: https://www.salesforce.com/content/dam/web/en_us/www/documents/legal/Privacy/dpia-and-salesforce-services.pdf.
We offer online chats and
chatbot functions (collectively referred to as "chat services") as a
means of communication. A chat is an online conversation conducted with a
certain degree of timeliness. A chatbot is software that answers users' questions
or informs them about messages. If you use our chat functions, we may process
your personal data.
If you use our chat
services within an online platform, your identification number will also be
stored within the respective platform. We may also collect information about
which users interact with our chat services and when. Furthermore, we store the
content of your conversations via the chat services and log registration and
consent processes in order to be able to prove these in accordance with legal
requirements.
We would like to point
out to users that the respective platform provider may find out that and when
users communicate with our chat services and may collect technical information
about the user's device and, depending on the settings of their device, location
information (so-called metadata) for the purpose of optimizing the respective
services and for security purposes. The metadata of communication via chat
services (i.e. e.g. information on who has communicated with whom) may also be
used by the respective platform providers for marketing purposes or to display
advertising tailored to users in accordance with their provisions, to which we
refer for further information.
If users declare their
willingness to a chatbot to activate information with regular messages, they
have the option to unsubscribe from the information for the future at any time.
The chatbot informs users how and with which terms they can unsubscribe from
the messages. By unsubscribing from the chatbot messages, user data is deleted
from the list of message recipients.
We use the aforementioned
data to operate our chat services, e.g. to address users personally, to answer
their queries, to transmit any requested content and also to improve our chat
services (e.g. to "teach" chatbots answers to frequently asked
questions or to recognize unanswered queries).
Notes on legal bases: We use the chat services on the basis of consent
if we have previously obtained permission from users to process their data in
the context of our chat services (this applies to cases in which users are
asked for consent, e.g. so that a chatbot can send them regular messages). If
we use chat services to answer users' inquiries about our services or our
company, this is done for contractual and pre-contractual communication.
Otherwise, we use chat services on the basis of our legitimate interests in
optimizing the chat services, their cost-effectiveness and enhancing the
positive user experience.
Revocation, objection and deletion: You can revoke your consent or object to the processing of your data in the context of our chat services at any time.
- Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Affected persons: Communication partner.
- Purposes of processing: contact requests and communication; direct marketing (e.g. by email or post).
- Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a)
GDPR); contract fulfillment and pre-contractual inquiries (Art. 6 para. 1
sentence 1 lit. b) GDPR). Legitimate interests
(Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Salesforce Chat Bot: Chatbot; Service provider: Salesforce.com
Germany GmbH, Erika-Mann-Str. 31, 80636 Munich, Germany; Data processing
agreement: https://www.salesforce.com/content/dam/web/en_us/www/documents/legal/Agreements/data-processing-addendum.pdf;
Basis for third country transfers: EU-US Data Privacy Framework (DPF),
Standard Contractual Clauses (https://www.salesforce.com/content/dam/web/en_us/www/documents/legal/Agreements/scc-amendment.pdf);
Further information: Data Transfer Impact Assessment &
Salesforce Services: https://www.salesforce.com/content/dam/web/en_us/www/documents/legal/Privacy/dpia-and-salesforce-services.pdf; Website: https://www.salesforce.com/de. Privacy Policy: https://www.salesforce.com/de/company/privacy.
We use platforms and
applications of other providers (hereinafter referred to as "conference
platforms") for the purpose of conducting video and audio conferences,
webinars and other types of video and audio meetings (hereinafter collectively
referred to as "conference"). When selecting the conference platforms
and their services, we observe the legal requirements.
Data processed by
conference platforms: As part of
participation in a conference, the conference platforms process the
participants' personal data listed below. The scope of the processing depends
on which data is required in the context of a specific conference (e.g.
specification of access data or clear names) and which optional information is
provided by the participants. In addition to processing for the purpose of
holding the conference, the conference platforms may also process participants'
data for security purposes or service optimization. The processed data includes
personal data (first name, surname), contact information (e-mail address,
telephone number), access data (access codes or passwords), profile pictures,
information on professional position/function, the IP address of the Internet
access, information on the participants' end devices, their operating system,
the browser and its technical and language settings, information on the content
of the communication processes, i.e. entries in chats and audio and video data,
as well as the use of other available functions (e.g. surveys). The content of
communications is encrypted to the extent technically provided by the
conference providers. If the participants are registered as users with the conference
platforms, further data may be processed in accordance with the agreement with
the respective conference provider.
Logging and
recordings: If text entries,
participation results (e.g. from surveys) and video or audio recordings are
logged, this will be communicated transparently to the participants in advance
and they will be asked for their consent where necessary.
Data protection
measures for participants: Please
refer to the conference platforms' data protection notices for details on the
processing of your data by the conference platforms and select the optimum
security and data protection settings for you in the conference platform
settings. Please also ensure data and privacy protection in the background of
your recording for the duration of a video conference (e.g. by informing
roommates, locking doors and, if technically possible, using the function to
make the background unrecognizable). Links to the conference rooms and access
data must not be passed on to unauthorized third parties.
Notes on legal bases: If, in addition to the conference platforms, we
also process users' data and ask users for their consent to use the conference
platforms or certain functions (e.g. consent to the recording of conferences),
the legal basis for processing is this consent. Furthermore, our processing may
be necessary to fulfill our contractual obligations (e.g. in participant lists,
in the case of processing of conference results, etc.). Otherwise, user data is
processed on the basis of our legitimate interests in efficient and secure
communication with our communication partners.
- Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. email, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Communication partners; users (e.g. website visitors, users of online services). Depicted persons.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; contact requests and communication. Office and organizational procedures.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence
1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Cisco WebEx: conferencing and communication software; service provider: Webex Communications Deutschland GmbH, Hansaallee 249, c/o Cisco Systems GmbH, 40549 Düsseldorf, parent company: Cisco Systems, Inc. 170 West Tasman Dr., San Jose, CA 95134, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.webex.com/de; Privacy Policy: https://www.cisco.com/c/de_de/about/legal/privacy-full.html. Basis for transfer to third countries: EU-US Data Privacy Framework (DPF).
- Microsoft Teams: Conferencing and communication software; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-365Data protection declaration: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter. Basis for third country transfers: EU-US Data Privacy Framework (DPF), standard contractual clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
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 details provided there.
In principle, the
required information includes personal details such as name, address, contact
details and proof of the qualifications required for the position. On request,
we will be happy to provide additional information on what details are required.
If provided, applicants
can send us their applications using an online form. The data is transmitted to
us in encrypted form in accordance with the state of the art. Applicants can
also send us their applications by e-mail. Please note, however, that e-mails
are generally not sent encrypted on the Internet. 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 receipt 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 legal requirements.
Applicants are welcome to
contact us about how to submit their application or send it to us by post.
Processing of special
categories of data: Insofar as
special categories of personal data (Art. 9 para. 1 GDPR, e.g. health data,
such as severely disabled status or ethnic origin) are requested from
applicants or communicated by them as part of the application procedure, their
processing is carried out so that the controller or the data subject can
exercise the rights arising from labor law and social security and social
protection law and fulfill his or her obligations in this regard. In the case
of the protection of the vital interests of applicants or other persons or for
the purposes of preventive health care or occupational medicine, for the
assessment of the employee's fitness for work, for medical diagnosis, for the
provision of health or social care or treatment or for the management of health
or social care systems and services.
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 applicant's data will be deleted. Applicants' data will also
be deleted if an application is withdrawn, which applicants are entitled to do
at any time. Subject to a justified withdrawal by the applicant, the deletion
will take place after a period of six months at the latest, so that we can
answer any follow-up questions about the application and meet our obligations
to provide evidence under the regulations on equal treatment of applicants.
Invoices for any reimbursement of travel expenses will be archived in
accordance with tax regulations.
Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the ongoing application process and that they can revoke their consent at any time for the future.
- Processed data types: Inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); 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 personal or qualification information provided by applicants with regard to a specific position or voluntarily).
- Persons concerned: Applicants.
- Purposes of processing: Application procedure (justification and possible subsequent implementation and possible subsequent termination of the employment relationship).
- Legal basis: Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR).
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 storage and management of content (e.g. document storage
and management, exchange of documents, content and information with specific
recipients or publication of content and information).
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 this privacy policy. This data may include, in particular,
master data and contact data of users, data on transactions, contracts, other
processes and their content. Cloud service providers also process usage data
and metadata that they use for security purposes and to optimize their
services.
If we use cloud services
to provide other users or publicly accessible websites with forms or other
documents and content, the providers may store cookies on users' devices for
the purposes of web analysis or to remember user settings (e.g. in the case of
media control).
- Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. email, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Affected persons: Customers; employees (e.g. employees, applicants, former employees); interested parties. Communication partners.
- Purposes of processing: Office and organizational procedures. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence
1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Microsoft cloud services: cloud storage, cloud infrastructure services and cloud-based application software; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://microsoft.com/de-deData protection declaration: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter; Order processing contract: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third country transfers: EU-US Data Privacy Framework (DPF), standard contractual clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
- Nextcloud (hosting on own server): Cloud storage service in which the operation and storage of the processed data takes place on a server managed by us; Service provider: Nextcloud GmbH, Hauptmannsreute 44a, 70192 Stuttgart, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://nextcloud.com/de/. Privacy policy: https://nextcloud.com/de/privacy/.
We only send newsletters,
emails and other electronic notifications (hereinafter "newsletter")
with the consent of the recipient or with legal permission. If the contents of
the newsletter are specifically described when registering for the newsletter,
they are decisive for the user's consent. Otherwise, our newsletters contain
information about our services and us.
To subscribe to our
newsletters, it is generally sufficient to provide your e-mail address.
However, we may ask you to provide a name so that we can address you personally
in the newsletter, or other information if this is necessary for the purposes
of the newsletter.
Double opt-in
procedure: Registration for our
newsletter is always carried out in a so-called double opt-in procedure. This
means that after registering you will receive an e-mail 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 registration process in accordance with
legal requirements. This includes storing the time of registration and confirmation
as well as the IP address. Changes to your data stored by the mailing service
provider are also logged.
Deletion and
restriction of processing: We may
store the unsubscribed e-mail addresses for up to three years on the basis of
our legitimate interests before deleting them in order to be able to prove that
consent was previously given. The processing of this data is limited to the
purpose of a possible defense against claims. An individual request for erasure
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 block list
solely for this purpose.
The registration process
is logged on the basis of our legitimate interests for the purpose of verifying
that it is carried out properly. 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.
Contents:
Information about us, our services, promotions and offers.
- Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. email, telephone numbers); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status); Usage data (e.g. websites visited, interest in content, access times).
- Data subjects: Communication partners; users (e.g. website visitors, users of online services).
- Purposes of processing: Direct marketing (e.g. by email or post). Provision of contractual services and fulfillment of contractual obligations.
- Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Possibility of objection (opt-out): 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 unsubscribe from the newsletter either at the end of
each newsletter or you can use one of the contact options listed above,
preferably e-mail.
Further information on processing operations, procedures and services:
- Measurement of opening and click rates: The 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. As part of this retrieval, technical information,
such as information about the browser and your system, as well as your IP
address and the time of retrieval, is 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 behavior 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. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. The evaluations help us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
The measurement of opening rates and click rates as well as the storage of the measurement results in the user profiles and their further processing are carried out on the basis of the user's consent.
Unfortunately, it is not possible to revoke the performance measurement separately; in this case, the entire newsletter subscription must be canceled or objected to. In this case, the stored profile information will be deleted;
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). - Prerequisite for the use of free services: Consent to the sending of mailings may be made a condition for the use of free services (e.g. access to certain content or participation in certain promotions). If users wish to take advantage of the free service without subscribing to the newsletter, please contact us.
- Salesforce: E-mail dispatch and automation services; Service
provider: salesforce.com Germany GmbH, Erika-Mann-Str. 31, 80636
Munich, Germany; Legal basis: Legitimate interests (Art. 6 para. 1
sentence 1 lit. f) GDPR); Website: https://www.salesforce.com/de; Privacy Policy: https://www.salesforce.com/de/company/privacy; Data processing agreement:
https://www.salesforce.com/content/dam/web/en_us/www/documents/legal/Agreements/data-processing-addendum.pdf;
Basis for third country transfers: EU-US Data Privacy Framework
(DPF), Standard Contractual Clauses (https://www.salesforce.com/content/dam/web/en_us/www/documents/legal/Agreements/scc-amendment.pdf);
Further information: Data transfer impact assessment &.
Salesforce Services: https://www.salesforce.com/content/dam/web/en_us/www/documents/legal/Privacy/dpia-and-salesforce-services.pdf.
We process personal data
for the purposes of advertising communication, which may take place via various
channels, such as e-mail, telephone, post or fax, in accordance with legal
requirements.
Recipients have the right
to withdraw their consent at any time or to object to advertising communication
at any time.
After revocation or
objection, we store the data required to prove the previous authorization for
contacting or sending up to three years after the end of the year of revocation
or objection on the basis of our legitimate interests. The processing of this
data is limited to the purpose of a possible defense against claims. On the
basis of the legitimate interest in permanently observing the revocation or
objection of the user, we also store the data required to avoid renewed contact
(e.g. depending on the communication channel, the e-mail address, telephone
number, name).
- Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers).
- Affected persons: Communication partner.
- Purposes of processing: Direct marketing (e.g. by email or post).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
We process personal data
of participants in competitions and contests only in compliance with the
relevant data protection regulations, insofar as the processing is
contractually required for the provision, execution and handling of the
competition, the participants have consented to the processing or the
processing serves our legitimate interests (e.g. in the security of the
competition or the protection of our interests against misuse through the
possible collection of IP addresses when submitting competition entries).
If participants'
contributions are published as part of the competitions (e.g. as part of a vote
or presentation of the competition entries or winners or reporting on the
competition), we would like to point out that the names of the participants may
also be published in this context. Participants can object to this at any time.
If the competition takes
place within an online platform or a social network (e.g. Facebook or
Instagram, hereinafter referred to as "online platform"), the terms
of use and data protection provisions of the respective platforms also apply.
In these cases, we would like to point out that we are responsible for the
information provided by the participants as part of the competition and that
inquiries regarding the competition should be directed to us.
Participants' data will
be deleted as soon as the competition or contest has ended and the data is no
longer required to inform the winners or because no further queries about the
competition are to be expected. In principle, participants' data will be deleted
no later than 6 months after the end of the competition. Winners' data may be
retained for longer, e.g. in order to answer queries about the prizes or to
fulfill the prize; in this case, the retention period depends on the type of
prize and is up to three years for items or services, e.g. in order to be able
to process warranty claims. Furthermore, participants' data may be stored for
longer, e.g. in the form of reporting on the competition in online and offline
media.
If data is also collected
for other purposes as part of the competition, its processing and retention
period will be based on the data protection information for this use (e.g. in
the case of registration for the newsletter as part of a competition).
- Processed data types: inventory data (e.g. names, addresses); content data (e.g. entries in online forms); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Affected persons: Competition and contest participants.
- Purposes of the processing: Organization of competitions and contests.
- Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
We conduct surveys and
interviews in order to collect information for the communicated purpose of the
survey or interview. The surveys and questionnaires (hereinafter
"surveys") we conduct are evaluated anonymously. Personal data is
only processed to the extent that this is necessary for the provision and
technical implementation of the surveys (e.g. processing of the IP address to
display the survey in the user's browser or to enable the survey to be resumed
with the help of a cookie).
- Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Affected persons: Communication partner. Participants.
- Purposes of processing: Feedback (e.g. collecting feedback via online form).
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence
1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- SurveyMonkey: Conducting online surveys; Service provider: SurveyMonkey Inc, 1 Curiosity Way, San Mateo, California 94403, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.surveymonkey.deData protection declaration: https://www.surveymonkey.de/mp/policy/privacy-policy/?ut_source=footer. Basis for transfer to third countries: EU-US Data Privacy Framework (DPF).
Web analysis (also
referred to as "reach measurement") is used to evaluate the flow of
visitors to our online offering and may include behavior, interests or
demographic information about visitors, such as age or gender, as pseudonymous
values. With the help of reach analysis, we can, for example, recognize at what
time our online offer or its functions or content are most frequently used or
invite reuse. We can also understand which areas require optimization.
In addition to web
analysis, we may also use test procedures, e.g. to test and optimize different
versions of our online offering or its components.
Unless otherwise stated
below, profiles, i.e. data summarized for a usage process, can be created for
these purposes and information can be stored in a browser or in an end device
and read out from it. The information collected includes, in particular, websites
visited and the elements used there as well as 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 from us or from
the providers of the services we use, location data may also be processed.
The IP addresses of users
are also stored. However, we use an IP masking procedure (i.e. pseudonymization
by shortening the IP address) to protect users. In general, no clear user data
(such as e-mail addresses or names) is stored in the context of web analysis,
A/B testing and optimization, but pseudonyms. This means that neither we nor
the providers of the software used know the actual identity of the users, but
only the information stored in their profiles for the purposes of the
respective processes.
- Processed data types: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online services and user-friendliness.
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence
1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Azure Application Insights: Web analytics; Service provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Website: https://learn.microsoft.com/en-us/connectors/applicationinsights/. Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement. Basis for third country transfer: EU-US Data Privacy Framework (DPF)
- AudioEye: Web analytics; Service provider: AudioEye, Inc, 5210 E. Williams Circle, Tucson, AZ 85711, USA; Website: https://www.audioeye.com/. Privacy policy: https://www.audioeye.com/privacy-policy/.
- Google Analytics 4: We use Google Analytics to measure and analyze the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or e-mail addresses. It is used to assign analysis information to an end device in order to recognize which content users have called up within one or more usage processes, which search terms they have used, which they have called up again or which they have interacted with our online offering. The time of use and its duration are also stored, as well as the sources of the users who refer to our online offering and technical aspects of their end devices and browsers. Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: City (and the city's inferred latitude and longitude), Continent, Country, Region, Subcontinent (and ID-based counterparts). For EU traffic, IP address data is used exclusively for this derivation of geolocation data before it is immediately deleted. It is not logged, is not accessible and is not used for other purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/Data protection declaration: https://policies.google.com/privacyOrder processing contract: https://business.safety.google/adsprocessorterms/; Basis for third country transfers: EU-US Data Privacy Framework (DPF), standard contractual clauses (https://business.safety.google/adsprocessorterms); Possibility of objection (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=deSettings for the display of advertisements: https://adssettings.google.com/authenticated. Further information: https://business.safety.google/adsservices/ (types of processing and data processed).
- Matomo (without cookies): Matomo is a data protection-friendly web analysis software that is used without cookies and in which returning users are recognized with the help of a so-called "digital fingerprint", which is stored anonymously and changed every 24 hours; With the "digital fingerprint", user movements within our online offer are recorded with the help of pseudonymized IP addresses in combination with user-side browser settings in such a way that it is not possible to draw conclusions about the identity of individual users. The user data collected through the use of Matomo is only processed by us and is not shared with third parties; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Website: https://matomo.org/.
We process personal data
for online marketing purposes, which may include in particular the marketing of
advertising space or the presentation of advertising and other content
(collectively referred to as "content") based on the potential interests
of users and the measurement of 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
information relevant for the presentation of the aforementioned content is
stored. This information may include, for example, content viewed, websites
visited, online networks used, but also communication partners and technical
information such as the browser used, the computer system used and information
on usage times and functions used. If users have consented to the collection of
their location data, this can also be processed.
The IP addresses of users
are also stored. However, we use available IP masking procedures (i.e.
pseudonymization by shortening the IP address) to protect users. In general, no
clear user data (such as e-mail addresses or names) is stored as part of the online
marketing process, but pseudonyms. This means that neither we nor the providers
of the online marketing processes know the actual identity of the users, but
only the information stored in their profiles.
The information in the
profiles is generally stored in cookies or by means of similar procedures.
These cookies can generally also be read later on other websites that use the
same online marketing process and analyzed for the purpose of displaying content
as well as supplemented with further data and stored on the server of the
online marketing process provider.
In exceptional cases,
clear data may be assigned to the profiles. This is the case, for example, if
the users are members of a social network whose online marketing processes we
use and the network links the user profiles with the aforementioned data. Please
note that users can make additional agreements with the providers, e.g. by
giving their consent during registration.
In principle, we only
receive access to summarized information about the success of our
advertisements. However, as part of so-called conversion measurements, we can
check which of our online marketing procedures have led to a so-called
conversion, i.e., for example, to the conclusion of a contract with us. The
conversion measurement is used solely to analyze the success of our marketing
measures.
Unless otherwise stated,
we ask you to assume that cookies used are stored for a period of two years.
- Processed data types: Content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status); event data (Facebook) ("event data" is data that can be transmitted by us to Facebook via Facebook pixels (via apps or other means), for example, and relates to individuals or their actions; the data includes, for example, information about visits to websites, interactions with content, installations of apps, purchases of products, etc.; the event data is used for the purpose of forming target groups for content and advertising information, etc.; the event data is processed for the purpose of forming target groups for content and advertising information. For example, information about visits to websites, interactions with content, functions, app installations, product purchases, etc.; the event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); event data does not include the actual content (such as comments written), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data is deleted by Facebook after a maximum of two years, and the target groups formed from it are deleted when our Facebook account is deleted.)
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of Processing: Web Analytics (e.g. access statistics, recognition of returning visitors); Targeting (e.g. profiling based on interests and behavior, use of cookies); Conversion tracking (Measurement of the effectiveness of marketing activities); Custom Audiences; Marketing; Profiles with user-related information (Creating user profiles). Provision of our online services and user-friendliness.
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Possibility of objection (opt-out): We refer you to the data protection notices
of the respective providers and the opt-out options specified for the
providers (so-called "opt-out"). If no explicit opt-out option
has been specified, you have the option of deactivating 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 summarized 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-territory: https://optout.aboutads.info.
Further information on processing operations, procedures and services:
- Meta pixel and target group formation (custom audiences): With the help of the Meta pixel (or comparable functions, for the transmission of event data or contact information by means of interfaces in apps), it is possible for the Meta company to determine the visitors of our online offer as a target group for the display of advertisements (so-called "meta ads"). Accordingly, we use the meta pixel to display the meta ads placed by us only to those users on Meta platforms and within the services of partners cooperating with Meta (so-called "audience network"). https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offering or who have certain characteristics (e.g. interest in certain topics or products that can be seen from the websites visited) that we transmit to Meta (so-called "custom audiences"). With the help of the meta pixel, we also want to ensure that our meta ads correspond to the potential interest of users and are not annoying. With the help of the meta pixel, we can also track the effectiveness of the meta ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a meta ad (so-called "conversion measurement"); service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.facebook.comData protection declaration: https://www.facebook.com/about/privacy; Order processing contract: https://www.facebook.com/legal/terms/dataprocessing; Basis for third country transfers: EU-US Data Privacy Framework (DPF), standard contractual clauses (https://www.facebook.com/legal/EU_data_transfer_addendum); Further information: Event user data, i.e. behavioral and interest data, is processed for the purposes of targeted advertising and audience targeting on the basis of the joint controllership agreement ("Controller Addendum", https://www.facebook.com/legal/controller_addendum). The joint controllership is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.)
We maintain online
presences within social networks and process user data in this context in order
to communicate with the users active there or to offer information about us.
We would like to point
out that user data may be processed outside the European Union. This may result
in risks for users because, for example, it could make it more difficult to
enforce users' rights.
Furthermore, user data
within social networks is generally processed for market research and
advertising purposes. For example, user profiles can be created based on user
behavior and the resulting interests of users. The user profiles can in turn be
used, for example, to place advertisements within and outside the networks that
presumably correspond to the interests of the users. For these purposes,
cookies are generally stored on the user's computer, in which the user's usage
behavior and interests are stored. Furthermore, data can also be stored in the
user profiles independently of the devices used by the users (especially if the
users are members of the respective platforms and are logged in to them).
For a detailed
description of the respective forms of processing and the opt-out options,
please refer to the data protection declarations and information provided by
the operators of the respective networks.
In the case of requests
for information and the assertion of data subject rights, we would also like to
point out that these can be asserted most effectively with the providers. Only
the providers have access to the users' data and can take appropriate measures
and provide information directly. If you still need help, you can contact us.
- Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Contact requests and communication; feedback (e.g. collecting feedback via online form). Marketing.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence
1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com. Privacy Policy: https://instagram.com/about/legal/privacy.
- Facebook pages: Profiles within the social network Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.comData protection declaration: https://www.facebook.com/about/privacy; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum); Further information: We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see under "Things you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under "Device information" in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services, known as "Page Insights", for page operators to help them understand how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook ("Information on Page Insights", https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information on Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data). The joint responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which relates in particular to the transfer of data to the parent company Meta Platforms, Inc. in the USA.
- LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited
Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate
interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.comData protection declaration: https://www.linkedin.com/legal/privacy-policy; Basis for transfer to third countries: EU-US
Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.linkedin.com/dpa); Possibility of objection (opt-out):
https://www.linkedin.com/psettings/guest-controls/retargeting-opt-outFurther information: We are jointly responsible with LinkedIn
Ireland Unlimited Company for the collection (but not the further
processing) of visitors' data for the purpose of creating the Page
Insights of our LinkedIn profiles.
This data includes information about the types of content users view or interact with, or the actions they take, as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data) and information from the user's profile, such as job function, country, industry, hierarchy level, company size and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn's data protection information: https://www.linkedin.com/legal/privacy-policy
We have concluded a special agreement with LinkedIn Ireland ("Page Insights Joint Controller Addendum (the 'Addendum')", https://legal.linkedin.com/pages-joint-controller-addendum), which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to LinkedIn). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection of data by and transfer to Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of Ireland Unlimited Company, which relates in particular to the transfer of data to the parent company LinkedIn Corporation in the USA. - X: Social network; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Privacy policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
- Vimeo: Social network and video platform; Service provider: Vimeo Inc, Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://vimeo.com. Privacy Policy: https://vimeo.com/privacy.
- YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Privacy Policy: https://policies.google.com/privacyBasis for transfer to third countries: EU-US Data Privacy Framework (DPF). Option to object (opt-out): https://adssettings.google.com/authenticated.
We incorporate functional
and content elements into our online offering that are obtained from the
servers of their respective providers (hereinafter referred to as
"third-party providers"). These may be, for example, graphics, videos
or city maps (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 they would not be able to send the content to their browser
without the IP address. The IP address is therefore required to display this
content or function. We endeavor 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. Pixel tags can be used to
analyze 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 being linked to such information from
other sources.
- Processed data types: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offer and user-friendliness. Provision of contractual services and fulfillment of contractual obligations.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence
1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offering that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of displaying or user-friendliness of our online offering). The respective providers collect the IP address of the users and can process it for the purpose of transmitting the software to the user's browser and for security purposes, as well as for the evaluation and optimization of their offer. - We integrate software into our online offering that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of displaying or user-friendliness of our online offering). The respective providers collect the IP address of the users and may process it for the purpose of transmitting the software to the user's browser and for security purposes, as well as for the evaluation and optimization of their offer; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- reCAPTCHA: We integrate the "reCAPTCHA" function in order to be able to recognize whether entries (e.g. in online forms) are made by humans and not by automatically acting machines (so-called "bots"). The processed data may include IP addresses, information on operating systems, devices or browsers used, language settings, location, mouse movements, keyboard strokes, time spent on websites, previously visited websites, interactions with ReCaptcha on other websites, possibly cookies and results of manual recognition processes (e.g. answering questions asked or selecting objects in images). Data processing is carried out on the basis of our legitimate interest in protecting our online offering from abusive automated crawling and spam; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.google.com/recaptcha/Data protection declaration: https://policies.google.com/privacy; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF). Possibility of objection (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.
- YouTube videos: Video content; YouTube videos are integrated via a special domain (recognizable by the component "youtube-nocookie") in the so-called "extended data protection mode", whereby no cookies are collected on user activities in order to personalize the video playback. Nevertheless, information about the user's interaction with the video (e.g. remembering the last playback point) may be stored; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.youtube.comData protection declaration: https://policies.google.com/privacy. Basis for transfer to third countries: EU-US Data Privacy Framework (DPF).
- maptiler: We integrate the maps of the "maptiler" service of the provider MapTiler AG; Service provider: MapTiler AG, Höfnerstrasse 98, 6314 Unterägeri, Switzerland; Website: https://www.maptiler.com/. Privacy policy: https://www.maptiler.com/privacy-policy/.
We use services,
platforms and software from other providers (hereinafter referred to as
"third-party providers") for the purposes of organizing, managing,
planning and providing our services. When selecting third-party providers and
their services, we observe the legal requirements.
In this context, personal
data may be processed and stored on the servers of third-party providers. This
may affect various data that we process in accordance with this privacy policy.
This data may include, in particular, master data and contact data of users,
data on transactions, contracts, other processes and their content.
If users are referred to
the third-party providers or their software or platforms in the context of
communication, business or other relationships with us, the third-party
providers may process usage data and metadata for security purposes, service
optimization or marketing purposes. We therefore ask you to observe the data
protection notices of the respective third-party providers.
- Processed data types: Content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Communication partners; users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and
fulfillment of contractual obligations. Office and
organizational procedures.
We ask you to inform
yourself regularly about the content of our privacy policy. We will adapt the
privacy policy as soon as changes to 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.
If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.
This section provides you with an overview of the terms used in this privacy policy. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.
- Credit information: Automated decisions are based on automatic data processing without human intervention (e.g. in the case of an automatic rejection of a purchase on account, an online credit application or an online application process without any human intervention). According to Art. 22 GDPR, such automated decisions are only permitted if the data subject consents, if they are necessary for the performance of a contract or if national laws permit these decisions.
- Conversion measurement: Conversion measurement (also known as "visit action evaluation") is a process that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user's device within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we placed on other websites were successful.
- Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); an identifiable natural person is 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. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any type of automated processing of personal data that consists of using this personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information relating to demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
- Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online offers can, for example, recognize at what time users visit their websites and what content they are interested in. This allows them to better adapt the content of their websites to the needs of their visitors, for example. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
- Location data: Location data is generated when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, a WLAN or similar technical means and functions of location determination. Location data is used to indicate the geographically determinable position on earth at which the respective device is located. Location data can be used, for example, to display map functions or other location-dependent information.
- Location history and movement profiles: Location history (also referred to as a "movement profile") is the collection of location data over a certain period of time. Location history allows conclusions to be drawn about the geographical movements (i.e. changes in position) of devices and their users.
- Tracking: The term "tracking" is used when the behavior of users can be tracked across several online offerings. As a rule, behavioral and interest information is stored in cookies or on the servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
- Controller: The "controller" is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
- Processing: "Processing" means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it collection, analysis, storage, transmission or deletion.
- Target group formation: Target group formation (custom audiences) is the term used when target groups are determined for advertising purposes, e.g. the display of advertisements. For example, based on a user's interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online store in which they viewed the products. In turn, "lookalike audiences" (or similar target groups) are when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating custom audiences and lookalike audiences.