Privacy
This data protection declaration informs you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) in the context of the provision of our services and within our online offer and the websites, functions and content associated with it as well as external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Responsible
Sturfer GmbH
Sägewerkstr. 3
D-83395 Freilassing
Phone +49 8654 58996-60
Fax +49 8654 58996-69
Email info@sturfer.com
Types of data processed
– Inventory data (e.g., person master data, names or addresses).
– Contact information (e.g., email, phone numbers).
– Content data (e.g., text input, photographs, videos).
– Usage data (e.g., web pages visited, interest in content, access times).
– Meta/communication data (e.g., device information, IP addresses).
Categories of persons concerned
Visitors and users of the online offer (hereinafter we also refer to the data subjects collectively as “users”).
Purpose of processing
– Provision of the online offer, its functions and contents.
– Respond to contact requests and communicate with users.
– Safety measures.
– Reach measurement/marketing
Terminology used
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and encompasses virtually any handling of data.
“pseudonymization” means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
“profiling” means any automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.
Controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.
Relevant legal bases
In accordance with Art. 13 DSGVO, we inform you about the legal basis of our data processing. For users from the scope of the General Data Protection Regulation (GDPR), i.e. the EU and the EEC, the following applies, unless the legal basis is stated in the privacy policy:
The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 DSGVO;
The legal basis for the processing for the fulfillment of our services and implementation of contractual measures as well as answering inquiries is Art. 6 para. 1 lit. b GDPR;
The legal basis for processing to fulfill our legal obligations is Art. 6 para. 1 lit. c GDPR;
In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO as the legal basis.
The legal basis for the processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Art. 6 para. 1 lit. e GDPR.
The legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f GDPR.
The processing of data for purposes other than those for which they were collected is determined by the provisions of Art. 6 para. 4 GDPR.
The processing of special categories of data (according to Art. 9 (1) of the GDPR) is determined according to the requirements of Art. 9 (1) of the GDPR. 2 GDPR.
Security measures
We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, entry into, disclosure of, assurance of availability of and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subject rights, deletion of data, and response to data compromise. 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.
Cooperation with processors, joint controllers and third parties
If, in the course of our processing, we disclose data to other persons and companies (order processors, jointly responsible persons or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers, is necessary for the fulfillment of the contract), users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we disclose or transfer data to other companies in our group of companies or otherwise grant them access, this is done in particular for administrative purposes as a legitimate interest and, in addition, on a basis that complies with the legal requirements.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this is done in the context of using third-party services or disclosing, or transferring data to other persons or companies, this will only be done if it is done to fulfill our (pre)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or leave the data in a third country only if the legal requirements are met. This means, for example, that processing takes place on the basis of special guarantees, such as the officially recognized determination of a level of data protection that corresponds to that of the EU (e.g., for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations.
Rights of the data subjects
You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
You have accordingly. the legal requirements, the right to request that the data concerning you be completed or that the inaccurate data concerning you be corrected.
In accordance with the statutory provisions, you have the right to demand that the data concerned be deleted without delay or, alternatively, to demand restriction of the processing of the data in accordance with the statutory provisions.
You have the right to request that the data concerning you that you have provided to us be received in accordance with the law and to request that it be transferred to other data controllers.
You also have the right to file a complaint with the competent supervisory authority in accordance with the law.
RIGHT OF WITHDRAWAL
You have the right to revoke given consents with effect for the future.
Right of objection
You may object to the future processing of data relating to you at any time in accordance with the statutory provisions. The objection can be made in particular against the processing for purposes of direct advertising.
Cookies and right to object to direct advertising
Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. The primary purpose of a cookie is to store information about a user (or the device on which the cookie is stored) during or after his visit within an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the contents of a shopping cart in an online store or a login status can be stored. Permanent” or “persistent” cookies are those that remain stored even after the browser is closed. For example, the login status can be saved when users visit them after several days. Likewise, such a cookie may store the interests of users, which are used for reach measurement or marketing purposes. Third-party cookies” are cookies that are offered by providers other than the responsible party that operates the online offer (otherwise, if they are only its cookies, they are referred to as “first-party cookies”).
We may use temporary and permanent cookies, and we explain this in our privacy policy.
If users do not want cookies to be stored on their computer, they are asked to disable the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
A general objection to the use of cookies used for online marketing purposes can be declared for a large number of the services, especially in the case of tracking, via the U.S. site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by means of their deactivation in the browser settings. Please note that then not all functions of this online offer can be used.
Data deletion
The data processed by us will be deleted or restricted in its processing in accordance with the legal requirements. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations.
If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.
Changes and updates to the privacy policy
We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
Agency services
We process our customers’ data as part of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes/handling, server administration, data analysis/consulting services and training services.
In doing so, we process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter of contract, term), payment data (e.g., bank details, payment history), usage data and metadata (e.g., in the context of evaluating and measuring the success of marketing measures). As a matter of principle, we do not process special categories of personal data, unless these are components of commissioned processing. Data subjects include our customers, prospective customers, as well as their customers, users, website visitors or employees, and third parties. The purpose of the processing is to provide contractual services, billing and our customer service. The legal basis for the processing results from Art. 6 para. 1 lit. b DSGVO (contractual services), Art. 6 para. 1 lit. f DSGVO (analysis, statistics, optimization, security measures). We process data that are necessary for the justification and fulfillment of the contractual services and point out the necessity of their indication. Disclosure to external parties only takes place if it is required as part of an order. When processing the data provided to us within the scope of an order, we act in accordance with the instructions of the client as well as the legal requirements of a commissioned processing pursuant to §§ 3 and 4 of the German Data Protection Act. Art. 28 DSGVO and do not process the data for any other purposes than those specified in the order.
We delete the data after expiration of legal warranty and comparable obligations. the necessity of keeping the data is checked every three years; in the case of legal archiving obligations, deletion takes place after their expiry (6 years, according to § 257 para. 1 HGB, 10 years, according to § 147 para. 1 AO). In the case of data disclosed to us by the client as part of an order, we delete the data in accordance with the specifications of the order, generally after the end of the order.
External payment service providers
We use external payment service providers through whose platforms the users and we can make payment transactions (e.g., each with a link to the privacy policy, Paypal (https://www.paypal.com/de/webapps/mpp/ua/privacy-full), Klarna (https://www.klarna.com/de/datenschutz/), Skrill (https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/), Giropay (https://www.giropay.de/rechtliches/datenschutz-agb/), Visa (https://www.visa.de/datenschutz), Mastercard (https://www.mastercard.de/de-de/datenschutz.html), American Express (https://www.americanexpress.com/de/content/privacy-policy-statement.html)
In the context of the fulfillment of contracts, we use the payment service providers on the basis of Art. 6 para. 1 lit. b. GDPR on. In addition, we use external payment service providers on the basis of our legitimate interests pursuant to Art. Art. 6 par. 1 lit. f. DSGVO to provide our users with effective and secure payment options.
The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related data. The information is necessary to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e. we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the terms and conditions and data protection information of the payment service providers.
The terms and conditions and the data protection notices of the respective payment service providers apply to the payment transactions, which can be accessed within the respective websites or transaction applications. We also refer to these for further information and assertion of revocation, information and other data subject rights.
Data protection information in the application process
We process applicant data only for the purpose of and within the scope of the application process in accordance with legal requirements. The processing of the applicant data is carried out for the fulfillment of our (pre)contractual obligations in the context of the application procedure within the meaning of Art. 6 para. 1 lit. b. DSGVO Art. 6 para. 1 lit. f. DSGVO if the data processing becomes necessary for us, e.g. within the scope of legal procedures (in Germany, § 26 BDSG also applies).
The application process requires applicants to provide us with applicant information. The necessary applicant data are marked, if we offer an online form, otherwise result from the job descriptions and basically include the personal information, postal and contact addresses and the documents belonging to the application, such as cover letter, resume and the certificates. In addition, applicants may voluntarily provide us with additional information.
By submitting the application to us, applicants consent to the processing of their data for the purposes of the application process in accordance with the nature and scope set out in this privacy policy.
Insofar as special categories of personal data within the meaning of Art. 9 para. 1 DSGVO are communicated, their processing is additionally carried out in accordance with Art. 9 para. 2 lit. b DSGVO (e.g. health data, such as severely disabled status or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 para. 1 DSGVO are requested from applicants, their processing is additionally carried out in accordance with Art. 9 para. 2 lit. a DSGVO (e.g. health data if this is necessary for the exercise of the profession).
If provided, applicants may submit their applications to us using an online form on our website. The data is transmitted to us encrypted according to the state of the art.
Furthermore, applicants can send us their applications via e-mail. Please note, however, that e-mails are generally not encrypted and applicants must ensure that they are encrypted themselves. Therefore, we cannot take any responsibility for the transmission path of the application between the sender and the reception on our server and therefore rather recommend to use an online form or postal delivery. Because instead of applying via the online form and e-mail, applicants still have the option of sending us their application by mail.
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 not successful, the applicants’ data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time.
Subject to a justified revocation by the applicant, the data will be deleted after the expiration of a period of six months so that we can answer any follow-up questions about the application and satisfy our obligations to provide evidence under the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with tax law requirements.
Talent Pool
As part of the application process, we offer applicants the opportunity to be included in our “talent pool” for a period of two years on the basis of consent within the meaning of Art. 6 para. 1 lit. a. and Art. 7 GDPR to be included.
The application documents in the talent pool are processed solely in the context of future job advertisements and employee searches and are destroyed at the latest after the deadline. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the current application process and that they can revoke this consent at any time for the future and declare their objection within the meaning of Art. 21 DSGVO.
DISQUS comment function
We use the comment service DISQUS on the basis of our legitimate interests in efficient, secure and user-friendly comment management pursuant to Art. 6 para. 1 lit. f. DSGVO, we use the comment service DISQUS, offered by DISQUS, Inc., 301 Howard St, Floor 3 San Francisco, California- 94105, USA. DISQUS is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law: https://www.privacyshield.gov/participant?id=a2zt0000000TRkEAAW&status=Active.
To use the DISQUS comment function, users can log in via their own DISQUS user account or an existing social media account (e.g. OpenID, Facebook, Twitter or Google). Here, the login data of the users is obtained by DISQUS from the platforms. It is also possible to use the DISQUS comment function as a guest without creating or using a user account with DISQUS or one of the specified social media providers.
We only embed DISQUS with its functions into our website, whereby we can influence the comments of the users. However, the users enter into a direct contractual relationship with DISQUS, under which DISQUS processes the users’ comments and is a contact for any deletion of the users’ data. We refer here to the privacy policy of DISQUS: https://help.disqus.com/terms-and-policies/disqus-privacy-policy and also point out to users that they can assume that DISQUS, in addition to the comment content, also stores their IP address and the time of the comment, as well as storing cookies on users’ computers and using them to display advertising. However, users may object to the processing of their data for the purpose of displaying advertisements: https://disqus.com/data-sharing-settings.
Comments and contributions
When users leave comments or other contributions, their IP addresses may be stored on the basis of our legitimate interests as defined in Art. 6 para. 1 lit. f. DSGVO are stored for 7 days. This is done for our security, in case someone leaves illegal content in comments and posts (insults, forbidden political propaganda, etc.). In this case, we ourselves may be prosecuted for the comment or post and are therefore interested in the identity of the author.
Furthermore, we reserve the right, on the basis of our legitimate interests pursuant to sec. Art. 6 par. 1 lit. f. DSGVO to process the information of the users for the purpose of spam detection.
On the same legal basis, in the case of surveys, we reserve the right to store the IP addresses of users for their duration and to use cookies to avoid multiple votes.
The personal information provided in the context of comments and contributions, any contact and website information as well as the content-related information will be stored permanently by us until the user objects.
Comment subscriptions
The follow-up comments can be made by users with their consent according to. Art. 6 par. 1 lit. a GDPR can be subscribed to. Users will receive a confirmation email to verify that they are the owner of the email address entered. Users can unsubscribe from ongoing comment subscriptions at any time. The confirmation email will include instructions on how to cancel. For the purposes of proving users’ consent, we store the time of subscription along with users’ IP address and delete this information when users unsubscribe.
You can cancel the receipt of our subscription at any time, i.e. revoke your consents. We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to be able to prove consent formerly given. The processing of this data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.
Akismet Anti-Spam Check
Our online offer uses the service “Akismet”, which is offered by Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA. The use is based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f) DSGVO. With the help of this service, comments from real people are distinguished from spam comments. For this purpose, all comment details are sent to a server in the USA, where they are analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data is stored beyond this time. This information includes the name entered, the email address, the IP address, the comment content, the referrer, information about the browser used as well as the computer system and the time of the entry.
More information on the collection and use of data by Akismet can be found in the privacy policy of Automattic: https://automattic.com/privacy/.
Users are welcome to use pseudonyms, or to choose not to enter their name or email address. You can completely prevent the transfer of data by not using our commenting system. That would be a shame, but unfortunately we don’t see any other alternatives that work just as effectively.
Retrieving profile pictures from Gravatar
We use the service Gravatar of Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA, within our online offer and especially in the blog.
Gravatar is a service where users can sign up and store profile pictures and their email addresses. If users leave posts or comments on other online presences (especially blogs) with the respective e-mail address, their profile pictures can thus be displayed next to the posts or comments. For this purpose, the email address provided by users is transmitted to Gravatar in encrypted form for the purpose of checking whether a profile is stored for it. This is the only purpose of sending the email address and it will not be used for any other purpose, it will be deleted afterwards.
Gravatar is used on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f) GDPR, as we use Gravatar to offer post and comment authors the possibility to personalize their posts with a profile picture.
By displaying the images, Gravatar obtains the IP address of the users, as this is necessary for a communication between a browser and an online service. More information on the collection and use of data by Gravatar can be found in the privacy policy of Automattic: https://automattic.com/privacy/.
If users do not want a user image associated with their Gravatar email address to appear in the comments, they should use an email address that is not on file with Gravatar to comment. We also point out that it is also possible to use an anonymous email address or no email address at all, if users do not want their own email address to be sent to Gravatar. Users can completely prevent the transfer of data by not using our commenting system.
Retrieve emojis and smilies
Within our WordPress blog, graphical emojis (or smilies), i.e. small graphic files that express emotions, are used, which are obtained from external servers. Here, the providers of the servers, collect the IP addresses of the users. This is necessary so that the emoji files can be transmitted to the users’ browsers. The Emojie service is provided by Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA. Privacy policy of Automattic: https://automattic.com/privacy/. The server domains used are s.w.org and twemoji.maxcdn.com. To the best of our knowledge, these are so-called content delivery networks, i.e. servers that only serve to transmit files quickly and securely, and the users’ personal data is deleted after transmission.
The use of emojis is based on our legitimate interests, i.e. interest in an attractive design of our online offer according to. Art. 6 par. 1 lit. f. GDPR.
Contact
When contacting us (e.g. by contact form, e-mail, telephone or via social media), the user’s data will be used to process the contact request and its handling according to Art. 6 para. 1 lit. b. (in the context of contractual/pre-contractual relations), Art. 6 para. 1 lit. f. (other requests) DSGVO processed… The user’s details may be stored in a customer relationship management system (“CRM system”) or comparable inquiry organization.
We delete the requests if they are no longer necessary. We review the necessity every two years; Furthermore, the legal archiving obligations apply.
Newsletter
With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.
Newsletter content: We send newsletters, e-mails and other electronic notifications with promotional information (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. Insofar as the contents of the newsletter are specifically described in the course of registration, they are decisive for the user’s consent. For the rest, our newsletters contain information about our services and us.
Double-Opt-In and logging: The registration for our newsletter takes place in a so-called double-opt-in process. I.e. after registration you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can log in with foreign e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the subscription process in accordance with legal requirements. This includes the storage of the login and confirmation time, as well as the IP address. Likewise, changes to your data stored with the shipping service provider are logged.
Registration data: To register for the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to enter a name for the purpose of personal address in the newsletter.
The dispatch of the newsletter and the associated performance measurement are based on the consent of the recipients in accordance with. Art. 6 par. 1 lit. a, Art. 7 DSGVO in conjunction with § 7 para. 2 No. 3 UWG or, if consent is not required, on the basis of our legitimate interests in direct marketing pursuant to. Art. 6 par. 1 lt. f. DSGVO in conjunction with. § 7 para. 3 UWG.
The logging of the registration process takes place on the basis of our legitimate interests in accordance with. Art. 6 par. 1 lit. f GDPR. We are interested in using a user-friendly and secure newsletter system that serves our business interests, meets the expectations of users, and allows us to prove consent.
Cancellation/Revocation – You can cancel the receipt of our newsletter at any time, i.e. revoke your consents. You will find a link to cancel the newsletter at the end of each newsletter. We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to be able to prove consent formerly given. The processing of this data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.
Newsletter – Mailchimp
The newsletter is sent using the dispatch service provider “MailChimp”, a newsletter dispatch platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view the privacy policy of the shipping service provider here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC d/b/a MailChimp is certified under the Privacy Shield agreement, thereby providing a guarantee of compliance with the European level of data protection(https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active). The shipping service provider is used on the basis of our legitimate interests in accordance with. Art. 6 par. 1 lit. f. DSGVO and a contract processing agreement pursuant to. Art. 28 par. 3 p. 1 DSGVO used.
The dispatch service provider may use the data of the recipients in pseudonymous form, i.e. without assignment to a user, to optimize or improve its own services, e.g. to technically optimize the dispatch and presentation of the newsletter or for statistical purposes. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.
Hosting and emailing
The hosting services used by us serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services, which we use for the purpose of operating this online offering.
In doing so, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer in accordance with the German Data Protection Act. Art. 6 par. 1 lit. f DSGVO in conjunction with. Art. 28 DSGVO (conclusion of order processing contract).
Collection of access data and log files
We, or rather our hosting provider, collects data on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO data about each access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Log file information is stored for security reasons (e.g. for the clarification of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further retention is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.
Content delivery network from Cloudflare
We use a so-called “Content Delivery Network” (CDN), offered by Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA. Cloudflare is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law(https://www.privacyshield.gov/participant?id=a2zt0000000GnZKAA0&status=Active).
A CDN is a service with the help of which the content of our online offer, in particular large media files such as graphics or scripts, can be delivered more quickly with the help of regionally distributed servers connected via the Internet. The processing of users’ data is carried out solely for the aforementioned purposes and to maintain the security and functionality of the CDN.
The use is based on our legitimate interests, i.e. interest in a secure and efficient provision, analysis and optimization of our online offer in accordance with. Art. 6 par. 1 lit. f. GDPR.
For more information, please see Cloudflare’s privacy policy: https://www.cloudflare.com/security-policy.
Google Tag Manager
Google Tag Manager is a solution that allows us to manage so-called website tags via an interface (and thus, for example, integrate Google Analytics and other Google marketing services into our online offering). The Tag Manager itself (which implements the tags) does not process any personal data of the users. With regard to the processing of users’ personal data, reference is made to the following information on Google services. Usage Guidelines: https://www.google.com/intl/de/tagmanager/use-policy.html.
Google Analytics
We use Google Analytics, a web analytics service provided by Google LLC (“Google”), on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 (1) lit. f. DSGVO) Google Analytics, a web analytics service provided by Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by the user is usually transmitted to a Google server in the USA and stored there.
Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law(https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Thereby, pseudonymous usage profiles of the users can be created from the processed data.
We use Google Analytics only with IP anonymization enabled. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user’s browser is not merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offer to Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
For more information about Google’s use of data, settings and opt-out options, please refer to Google’s privacy policy(https://policies.google.com/privacy) and the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
Users’ personal data is deleted or anonymized after 14 months.
Jetpack (WordPress Stats)
We use the plugin Jetpack (here the sub-function “WordPress Stats”) on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO). DSGVO) the plugin Jetpack (here the sub-function “WordPress Stats”), which embeds a tool for statistical analysis of visitor traffic and is provided by Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA. Jetpack uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site.
The information generated by the cookie about your use of this website is stored on a server in the USA. In the process, user profiles can be created from the processed data, whereby these are only used for analysis purposes and not for advertising purposes. For more information, see Automattic’s privacy policy: https://automattic.com/privacy/ and notes on Jetpack cookies: https://jetpack.com/support/cookies/.
Facebook Pixel, Custom Audiences and Facebook Conversion
Within our online offer, the so-called “Facebook pixel” of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are a resident of the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), is used due to our legitimate interests in the analysis, optimization and economic operation of our online offer and for these purposes.
Facebook is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law(https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
With the help of the Facebook pixel, it is possible for Facebook to determine the visitors of our online offer as a target group for the display of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display Facebook ads placed by us only to Facebook users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of the users and do not have a harassing effect. With the help of the Facebook pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion”).
The processing of the data by Facebook takes place within the framework of Facebook’s data usage policy. Accordingly, general guidance on the display of Facebook Ads, in Facebook’s Data Use Policy: https://www.facebook.com/policy. Specific information and details about the Facebook Pixel and how it works can be found in Facebook’s help section: https://www.facebook.com/business/help/651294705016616.
You can object to the collection by the Facebook pixel and use of your data to display Facebook ads. To set which types of advertisements are displayed to you within Facebook, you can visit the page set up by Facebook and follow the instructions there regarding the settings for usage-based advertising: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
You may further object to the use of cookies used for reach measurement and advertising purposes via the Network Advertising Initiative opt-out page(http://optout.networkadvertising.org/) and additionally the U.S. website(http://www.aboutads.info/choices) or the European website(http://www.youronlinechoices.com/uk/your-ad-choices/).
Online presence in social media
We maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services there.
We would like to point out that in the process, user data may be processed outside the area of the European Union. This may give rise to risks for users because, for example, it could make it more difficult to enforce users’ rights. With regard to U.S. providers certified under the Privacy Shield, we point out that they thereby undertake to comply with EU data protection standards.
Furthermore, user data is usually processed for market research and advertising purposes. For example, usage profiles can be created from the usage behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to display advertisements within and outside the platforms that presumably correspond to the users’ interests. For these purposes, cookies are usually stored on the users’ computers, in which the usage behavior and interests of the users are stored. Furthermore, data may also be stored in the usage profiles irrespective of the devices used by the users (in particular if the users are members of the respective platforms and are logged in to them).
The processing of users’ personal data is based on our legitimate interests in effectively informing users and communicating with users pursuant to Art. 6 para. 1 lit. f. DSGVO. If the users are asked by the respective providers of the platforms for consent to the aforementioned data processing, the legal basis of the processing is Art. 6 para. 1 lit. a., Art. 7 DSGVO.
For a detailed description of the respective processing and the opt-out options, please refer to the information of the providers linked below.
Also in the case of requests for information and the assertion of user rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data in each case and can take appropriate measures and provide information directly. If you still need help, then you can contact us.
– Facebook, -pages, -groups, (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) on the basis of a Agreement on joint processing of personal data – Privacy Policy: https://www.facebook.com/about/privacy/, specifically for pages: https://www.facebook.com/legal/terms/information_about_page_insights_data, opt-out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.
– Google/ YouTube (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – Privacy Policy: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
– Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – Privacy Policy/ Opt-Out: http://instagram.com/about/legal/privacy/.
– Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) – Privacy Policy: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.
– Pinterest (Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA) – Privacy Policy/ Opt-Out: https://about.pinterest.com/de/privacy-policy.
– LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland) – Privacy Policy https://www.linkedin.com/legal/privacy-policy, Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active.
– Xing (XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany) – Privacy Policy/ Opt-Out: https://privacy.xing.com/de/datenschutzerklaerung.
– Wakalet (Wakelet Limited, 76 Quay Street, Manchester, M3 4PR, United Kingdom) – Privacy Policy/ Opt-Out: https://wakelet.com/privacy.html.
– Soundcloud (SoundCloud Limited, Rheinsberger Str. 76/77, 10115 Berlin, Germany) – Privacy Policy/ Opt-Out: https://soundcloud.com/pages/privacy.
Integration of third-party services and content
Within our online offer, we use content or service offers of third-party providers on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) content or service offers from third-party providers in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).
This always assumes that the third-party providers of this content are aware of the IP address of the user, since without the IP address they would not be able to send the content to their browser. The IP address is thus required for the display of this content. We endeavor to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be combined with such information from other sources.
Youtube
We integrate the videos of the platform “YouTube” of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.
Google Fonts
We integrate the fonts (“Google Fonts”) of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.
Google ReCaptcha
We integrate the function for the recognition of bots, e.g. for entries in online forms (“ReCaptcha”) of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.
Google Maps
We integrate the maps of the service “Google Maps” of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The processed data may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually executed within the settings of their mobile devices). The data may be processed in the USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.
Use of Facebook social plugins
We use social plugins (“plugins”) of the social network facebook.com on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. f. DSGVO) social plugins (“plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”).
This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within Facebook. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
Facebook is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law(https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
When a user calls up a function of this online offer that contains such a plugin, his or her device establishes a direct connection with the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated by the user into the online offer. In doing so, usage profiles of the users can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects with the help of this plugin and therefore inform users according to our level of knowledge.
By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user is logged into Facebook, Facebook can assign the visit to his Facebook account. When users interact with the plugins, for example by clicking the Like button or posting a comment, the corresponding information is transmitted from your device directly to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to obtain and store his or her IP address. According to Facebook, only an anonymized IP address is stored in Germany.
The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the related rights and settings options for protecting the privacy of users, can be found in the privacy policy of Facebook: https://www.facebook.com/about/privacy/.
If a user is a Facebook member and does not want Facebook to collect data about him or her via this online offering and link it to his or her membership data stored on Facebook, he or she must log out of Facebook and delete his or her cookies before using our online offering. Further settings and objections to the use of data for advertising purposes, are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
Within our online offer, functions and contents of the service Twitter, offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, may be integrated. This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within Twitter.
If the users are members of the Twitter platform, Twitter can assign the call of the above-mentioned content and functions to the profiles of the users there. Twitter is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law(https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active). Privacy Policy: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization.
Within our online offer, functions and contents of the service Instagram, offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA, may be integrated. This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within Instagram. If the users are members of the Instagram platform, Instagram can assign the call-up of the above-mentioned content and functions to the users’ profiles there. Privacy policy of Instagram: http://instagram.com/about/legal/privacy/.
Within our online offer, functions and contents of the service Pinterest, offered by Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA, may be integrated. This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within Pinterest. If the users are members of the Pinterest platform, Pinterest can assign the call of the above-mentioned content and functions to the profiles of the users there. Privacy policy of Pinterest: https://about.pinterest.com/de/privacy-policy.
Within our online offer, functions and contents of the service LinkedIn, offered by LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland, may be integrated. This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offering within LinkedIn. If the users are members of the LinkedIn platform, LinkedIn can assign the call of the above-mentioned content and functions to the profiles of the users there. LinkedIn privacy policy: https://www.linkedin.com/legal/privacy-policy.. LinkedIn is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law(https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active). Privacy Policy: https://www.linkedin.com/legal/privacy-policy, Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Google+
Within our online offer, functions and contents of the platform Google+, offered by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”), may be integrated. This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within Google. If the users are members of the Google+ platform, Google can assign the call of the above content and functions to the profiles of the users there.
Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law(https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). For more information about Google’s use of data, settings and opt-out options, please refer to Google’s privacy policy(https://policies.google.com/technologies/ads) and the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
Calendly
You have the possibility to book an appointment on my website. I use the online calendar “Calendly” to request and select an appointment. “Calendly” is a service provided by Calendly, LLC, 3423 Piedmont Road NE, Atlanta, GA 30305-1754, United States.
When you press the corresponding booking button, you will be automatically connected to my appointment account at Calendly. After choosing your appointment, confirming it and entering your contact details and concerns, you will receive an email from Calendly confirming your appointment.
The information you provide in the Calendly form, including the data you enter there, will be stored by me for the purpose of processing your request and in case of follow-up questions. This data remains with me until you request us to delete it, revoke your consent to store it or the purpose for storing the data no longer applies (e.g. appointment made). Mandatory legal provisions – in particular retention periods – remain unaffected.
Furthermore, I have completed a “Data Processing Addendum” with Calendly. This is a contract in which Calendly undertakes to protect my users’ data, to process it on my behalf in accordance with its data protection provisions and, in particular, not to pass it on to third parties. You can view more information about Calendly and Calendly’s privacy policy here: https://calendly.com/pages/privacy