Privacy Policy

Privacy Policy Introduction and Overview

We have written this privacy policy (version 27.09.2024-112876210) in order to explain to you, in accordance with the provisions of the General Data Protection Regulation (EU) 2016/679 and applicable national laws, which personal data (data for short) we as the controller – and the processors commissioned by us (e.g. providers) – process, will process in the future and what legal options you have. The terms used are to be considered gender-neutral.
In short: We provide you with comprehensive information about any of your personal data we process.

Privacy policies usually sound very technical and use legal terminology. However, this privacy policy is intended to describe the most important things to you as simply and transparently as possible. So long as it aids transparency, technical terms are explained in a reader-friendly manner, links to further information are provided and graphics are used. We are thus informing in clear and simple language that we only process personal data in the context of our business activities if there is a legal basis for it. This is certainly not possible with brief, unclear and legal-technical statements, as is often standard on the internet when it comes to data protection. I hope you find the following explanations interesting and informative. Maybe you will also find some information that you have not been familiar with.
If you still have questions, we kindly ask you to contact the responsible body named below or in the imprint, follow the existing links and look at further information on third-party sites. You can of course also find our contact details in the imprint.

Scope

This privacy policy applies to all personal data processed by our company and to all personal data processed by companies commissioned by us (processors). With the term personal data, we refer to information within the meaning of Article 4 No. 1 GDPR, such as the name, email address and postal address of a person. The processing of personal data ensures that we can offer and invoice our services and products, be it online or offline. The scope of this privacy policy includes:

• all online presences (websites, online shops) that we operate
• Social media presences and email communication
• mobile apps for smartphones and other devices

In short: This privacy policy applies to all areas in which personal data is processed in a structured manner by the company via the channels mentioned. Should we enter into legal relations with you outside of these channels, we will inform you separately if necessary.

Legal bases

In the following privacy policy, we provide you with transparent information on the legal principles and regulations, i.e. the legal bases of the General Data Protection Regulation, which enable us to process personal data.
Whenever EU law is concerned, we refer to REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016. You can of course access the General Data Protection Regulation of the EU online at EUR-Lex, the gateway to EU law, at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679.

We only process your data if at least one of the following conditions applies:

1. Consent (Article 6 Paragraph 1 lit. a GDPR): You have given us your consent to process data for a specific purpose. An example would be the storage of data you entered into a contact form.
2. Contract (Article 6 Paragraph 1 lit. b GDPR): We process your data in order to fulfill a contract or pre-contractual obligations with you. For example, if we conclude a sales contract with you, we need personal information in advance.
3. Legal obligation (Article 6 Paragraph 1 lit. c GDPR): If we are subject to a legal obligation, we will process your data. For example, we are legally required to keep invoices for our bookkeeping. These usually contain personal data.
4. Legitimate interests (Article 6 Paragraph 1 lit. f GDPR): In the case of legitimate interests that do not restrict your basic rights, we reserve the right to process personal data. For example, we have to process certain data in order to be able to operate our website securely and economically. Therefore, the processing is a legitimate interest.

Other conditions such as making recordings in the interest of the public, the exercise of official authority as well as the protection of vital interests do not usually occur with us. Should such a legal basis be relevant, it will be disclosed in the appropriate place.

In addition to the EU regulation, national laws also apply:

• In Austria this is the Austrian Data Protection Act (Datenschutzgesetz), in short DSG.
• In Germany this is the Federal Data Protection Act (Bundesdatenschutzgesetz), in short BDSG.

Should other regional or national laws apply, we will inform you about them in the following sections.

Contact details of the data protection controller

If you have any questions about data protection, you will find the contact details of the responsible person or controller below:
Hotel Lacknerhof GmbH
Georg Lackner
Unterberggasse 172, 5542 Flachau, Österreich
Authorised to represent: Georg Lackner 
E-Mail: info@lacknerhof.at 
Phone: +43 6457 23790 
Company details: https://www.lacknerhof.at/impressum/

Storage Period

It is a general criterion for us to store personal data only for as long as is absolutely necessary for the provision of our services and products. This means that we delete personal data as soon as any reason for the data processing no longer exists. In some cases, we are legally obliged to keep certain data stored even after the original purpose no longer exists, such as for accounting purposes.

If you want your data to be deleted or if you want to revoke your consent to data processing, the data will be deleted as soon as possible, provided there is no obligation to continue its storage.

We will inform you below about the specific duration of the respective data processing, provided we have further information.

Rights in accordance with the General Data Protection Regulation

In accordance with Articles 13, 14 of the GDPR, we inform you about the following rights you have to ensure fair and transparent processing of data:

• According to Article 15 DSGVO, you have the right to information about whether we are processing data about you. If this is the case, you have the right to receive a copy of the data and to know the following information:
  • for what purpose we are processing;
  • the categories, i.e. the types of data that are processed;
  • who receives this data and if the data is transferred to third countries, how security can be guaranteed;
  • how long the data will be stored;
  • the existence of the right to rectification, erasure or restriction of processing and the right to object to processing;
  • that you can lodge a complaint with a supervisory authority (links to these authorities can be found below);
  • the origin of the data if we have not collected it from you;
  • Whether profiling is carried out, i.e. whether data is automatically evaluated to arrive at a personal profile of you.
• You have a right to rectification of data according to Article 16 GDPR, which means that we must correct data if you find errors.
• You have the right to erasure (“right to be forgotten”) according to Article 17 GDPR, which specifically means that you may request the deletion of your data.
• According to Article 18 of the GDPR, you have the right to restriction of processing, which means that we may only store the data but not use it further.
• According to Article 20 of the GDPR, you have the right to data portability, which means that we will provide you with your data in a standard format upon request.
• According to Article 21 DSGVO, you have the right to object, which entails a change in processing after enforcement.
  • If the processing of your data is based on Article 6(1)(e) (public interest, exercise of official authority) or Article 6(1)(f) (legitimate interest), you may object to the processing. We will then check as soon as possible whether we can legally comply with this objection.
  • If data is used to conduct direct advertising, you may object to this type of data processing at any time. We may then no longer use your data for direct marketing.
  • If data is used to conduct profiling, you may object to this type of data processing at any time. We may no longer use your data for profiling thereafter.
• According to Article 22 of the GDPR, you may have the right not to be subject to a decision based solely on automated processing (for example, profiling).
• You have the right to lodge a complaint under Article 77 of the GDPR. This means that you can complain to the data protection authority at any time if you believe that the data processing of personal data violates the GDPR.

In short: you have rights – do not hesitate to contact the responsible party listed above with us!

If you believe that the processing of your data violates data protection law or your data protection rights have been violated in any other way, you can complain to the supervisory authority. For Austria, this is the data protection authority, whose website can be found at https://www.dsb.gv.at/. In Germany, there is a data protection officer for each federal state. For more information, you can contact the Federal Commissioner for Data Protection and Freedom of Information (BfDI). The following local data protection authority is responsible for our company:

Austria Data protection authority

Manager:Dr. Matthias Schmidl 
Address: Barichgasse 40-42, 1030 Wien 
Phone number.: +43 1 52 152-0 
E-mail address: dsb@dsb.gv.at 
Website: https://www.dsb.gv.at/

Security of data processing operations

In order to protect personal data, we have implemented both technical and organisational measures. We encrypt or pseudonymise personal data wherever this is possible. Thus, we make it as difficult as we can for third parties to extract personal information from our data.

Article 25 of the GDPR refers to “data protection by technical design and by data protection-friendly default” which means that both software (e.g. forms) and hardware (e.g. access to server rooms) appropriate safeguards and security measures shall always be placed. If applicable, we will outline the specific measures below.

TLS encryption with https

The terms TLS, encryption and https sound very technical, which they are indeed. We use HTTPS (Hypertext Transfer Protocol Secure) to securely transfer data on the Internet.
This means that the entire transmission of all data from your browser to our web server is secured – nobody can “listen in”.

We have thus introduced an additional layer of security and meet privacy requirements through technology design Article 25 Section 1 GDPR). With the use of TLS (Transport Layer Security), which is an encryption protocol for safe data transfer on the internet, we can ensure the protection of confidential information.
You can recognise the use of this safeguarding tool by the little lock-symbol , which is situated in your browser’s top left corner in the left of the internet address (e.g. examplepage.uk), as well as by the display of the letters https (instead of http) as a part of our web address.
If you want to know more about encryption, we recommend you to do a Google search for “Hypertext Transfer Protocol Secure wiki” to find good links to further information.

Communications

Communications Overview  👥 Affected parties: Anyone who communicates with us via phone, email or online form 🤝 Processed data: e. g. telephone number, name, email address or data entered in forms. You can find more details on this under the respective form of contact 📓 Purpose: handling communication with customers, business partners, etc. 📅 Storage duration: for the duration of the business case and the legal requirements ⚖️ Legal basis: Article 6 (1) (a) GDPR (consent), Article 6 (1) (b) GDPR (contract), Article 6 (1) (f) GDPR (legitimate interests)

If you contact us and communicate with us via phone, email or online form, your personal data may be processed.

The data will be processed for handling and processing your request and for the related business transaction. The data is stored for this period of time or for as long as is legally required.

Affected persons

The above-mentioned processes affect all those who seek contact with us via the communication channels we provide.

Telephone

When you call us, the call data is stored in a pseudonymised form on the respective terminal device, as well as by the telecommunications provider that is being used. In addition, data such as your name and telephone number may be sent via email and stored for answering your inquiries. The data will be erased as soon as the business case has ended and the legal requirements allow for its erasure.

Email

If you communicate with us via email, your data is stored on the respective terminal device (computer, laptop, smartphone, …) as well as on the email server. The data will be deleted as soon as the business case has ended and the legal requirements allow for its erasure.

Online forms

If you communicate with us using an online form, your data is stored on our web server and, if necessary, forwarded to our email address. The data will be erased as soon as the business case has ended and the legal requirements allow for its erasure.

Legal bases

Data processing is based on the following legal bases:

• Art. 6 para. 1 lit. a GDPR (consent): You give us your consent to store your data and to continue to use it for the purposes of the business case;
• Art. 6 para. 1 lit. b GDPR (contract): For the performance of a contract with you or a processor such as a telephone provider, or if we have to process the data for pre-contractual activities, such as preparing an offer;
• Art. 6 para. 1 lit. f GDPR (legitimate interests): We want to conduct our customer inquiries and business communication in a professional manner. Thus, certain technical facilities such email programs, Exchange servers and mobile network operators are necessary to efficiently operate our communications.

Data Processing Agreement (DPA)

In this section, we would like to explain what a Data Processing Agreement is and why it is needed. As the term “Data Processing Agreement” is quite lengthy, we will often only use the acronym DPA here in this text. Like most companies, we do not work alone, but also use the services of other companies or individuals. By involving different companies or service providers, we may pass on personal data for processing. These partners then act as processors with whom we conclude a contract, the so-called Data Processing Agreement (DPA). Most importantly for you to know is that any processing of your personal data takes place exclusively according to our instructions and must be regulated by the DPA.

Who are the processors?

As a company and website owner, we are responsible for any of your data that is processed by us. In addition to the controller, there may also be so-called processors involved. This includes any company or person who processes your personal data. More precisely and according to the GDPR’s definition, this means: Any natural or legal person, authority, institution or other entity that processes your personal data is considered a processor. Processors can therefore be service providers such as hosting or cloud providers, payment or newsletter providers or large companies such as Google or Microsoft.

To make the terminology easier to comprehend, here is an overview of the GDPR’s three roles:

Data subject (you as a customer or interested party) → Controller (we as a company and contracting entity) → Processors (service providers such as web hosts or cloud providers)

Contents of a Data Processing Agreement

As mentioned above, we have concluded a DPA with our partners who act as processors. First and foremost, it states that the processor processes the data exclusively in accordance with the GDPR. The contract must be concluded in writing, although an electronic contract completion is also considered a “written contract”. Any processing of personal data only takes place after this contract is concluded. The contract must contain the following:

• indication to us as the controller
• obligations and rights of the controller
• categories of data subjects
• type of personal data
• type and purpose of data processing
• subject and duration of data processing
• location of data processing

Furthermore, the contract contains all obligations of the processor. The most important obligations are:

• ensuring data security measures
• taking possible technical and organisational measures to protect the rights of the data subject
• maintaining a data processing record
• cooperation with the data protection authority upon request
• performing a risk analysis for any received personal data
• subprocessors may only be appointed with the written consent of the controller

You can see an example of what a DPA looks like at https://gdpr.eu/data-processing-agreement/. This link shows a sample contract.

Cookies

Cookies Overview  👥 Affected parties: visitors to the website 🤝 Purpose: depending on the respective cookie. You can find out more details below or from the software manufacturer that sets the cookie. 📓 Processed data: depends on the cookie used. More details can be found below or from the manufacturer of the software that sets the cookie. 📅 Storage duration: can vary from hours to years, depending on the respective cookie ⚖️ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What are cookies?

Our website uses HTTP-cookies to store user-specific data.
In the following we explain what cookies are and why they are used, so that you can better understand the following privacy policy.

Whenever you surf the Internet, you are using a browser. Common browsers are for example, Chrome, Safari, Firefox, Internet Explorer and Microsoft Edge. Most websites store small text-files in your browser. These files are called cookies.

It is important to note that cookies are very useful little helpers. Almost every website uses cookies. More precisely, these are HTTP cookies, as there are also other cookies for other uses. HTTP cookies are small files that our website stores on your computer. These cookie files are automatically placed into the cookie-folder, which is the “brain” of your browser. A cookie consists of a name and a value. Moreover, to define a cookie, one or multiple attributes must be specified.

Cookies store certain user data about you, such as language or personal page settings. When you re-open our website to visit again, your browser submits these “user-related” information back to our site. Thanks to cookies, our website knows who you are and offers you the settings you are familiar to. In some browsers, each cookie has its own file, while in others, such as Firefox, all cookies are stored in one single file.

The following graphic shows a possible interaction between a web browser such as Chrome and the web server. The web browser requests a website and receives a cookie back from the server. The browser then uses this again as soon as another page is requested.

 

There are both first-party cookies and third-party cookies. First-party cookies are created directly by our site, while third-party cookies are created by partner-websites (e.g. Google Analytics). Each cookie must be evaluated individually, as each cookie stores different data. The expiry time of a cookie also varies from a few minutes to a few years. Cookies are not software programs and do not contain viruses, trojans or other malware. Cookies also cannot access your PC’s information.

This is an example of how cookie-files can look:

Name: _ga
Value: GA1.2.1326744211.152112876210-9
Purpose: Differentiation between website visitors
Expiry date: after 2 years

A browser should support these minimum sizes:

• At least 4096 bytes per cookie
• At least 50 cookies per domain
• At least 3000 cookies in total

Which types of cookies are there?

The exact cookies that we use, depend on the used services, which will be outlined in the following sections of this privacy policy. Firstly, we will briefly focus on the different types of HTTP-cookies.

There are 4 different types of cookies:

Essential cookies
These cookies are necessary to ensure the basic functions of a website. They are needed when a user for example puts a product into their shopping cart, then continues surfing on different websites and comes back later in order to proceed to the checkout. These cookies ensure the shopping cart does not get deleted, even if the user closes their browser window.

Purposive cookies
These cookies collect information about user behaviour and whether the user receives any error messages. Furthermore, these cookies record the website’s loading time as well as its behaviour in different browsers.

Target-orientated cookies
These cookies ensure better user-friendliness. Thus, information such as previously entered locations, fonts sizes or data in forms stay stored.

Advertising cookies
These cookies are also known as targeting cookies. They serve the purpose of delivering customised advertisements to the user. This can be very practical, but also rather annoying.

Upon your first visit to a website you are usually asked which of these cookie-types you want to accept. Furthermore, this decision will of course also be stored in a cookie.

If you want to learn more about cookies and do not mind technical documentation, we recommend https://tools.ietf.org/html/rfc6265, the Request for Comments of the Internet Engineering Task Force (IETF) called “HTTP State Management Mechanism”.

Purpose of processing via cookies

The purpose ultimately depends on the respective cookie. You can find out more details below or from the software manufacturer that sets the cookie.

Which data are processed?

Cookies are little helpers for a wide variety of tasks. Unfortunately, it is not possible to tell which data is generally stored in cookies, but in the privacy policy below we will inform you on what data is processed or stored.

Storage period of cookies

The storage period depends on the respective cookie and is further specified below. Some cookies are erased after less than an hour, while others can remain on a computer for several years.

You can also influence the storage duration yourself. You can manually erase all cookies at any time in your browser (also see “Right of objection” below). Furthermore, the latest instance cookies based on consent will be erased is after you withdraw your consent. The legality of storage will remain unaffected until then.

Right of objection – how can I erase cookies?

You can decide for yourself how and whether you want to use cookies. Regardless of which service or website the cookies originate from, you always have the option of erasing, deactivating or only partially accepting cookies. You can for example block third-party cookies but allow all other cookies.

If you want to find out which cookies have been stored in your browser, or if you want to change or erase cookie settings, you can find this option in your browser settings:

Chrome: Clear, enable and manage cookies in Chrome 

Safari: Manage cookies and website data in Safari 

Firefox: Clear cookies and site data in Firefox 

Internet Explorer: Delete and manage cookies 

Microsoft Edge: Delete cookies in Microsoft Edge 

If you generally do not want cookies, you can set up your browser in a way to notify you whenever a cookie is about to be set. This gives you the opportunity to manually decide to either permit or deny the placement of every single cookie. This procedure varies depending on the browser. Therefore, it might be best for you to search for the instructions in Google. If you are using Chrome, you could for example put the search term “delete cookies Chrome” or “deactivate cookies Chrome” into Google.

Legal basis

The so-called “cookie directive” has existed since 2009. It states that the storage of cookies requires your consent (Article 6 Paragraph 1 lit. a GDPR). Within countries of the EU, however, the reactions to these guidelines still vary greatly. In Austria, however, this directive was implemented in Section 165 (3) of the Telecommunications Act (2021). In Germany, the cookie guidelines have not been implemented as national law. Instead, this guideline was largely implemented in Section 15 (3) of the Telemedia Act (TMG), which has been replaced by the Digital Services Act (DSA) since May 2024.

For absolutely necessary cookies, even if no consent has been given, there are legitimate interests (Article 6 (1) (f) GDPR), which in most cases are of an economic nature. We want to offer our visitors a pleasant user experience on our website. For this, certain cookies often are absolutely necessary.

This is exclusively done with your consent, unless absolutely necessary cookies are used. The legal basis for this is Article 6 (1) (a) of the GDPR.

In the following sections you will find more detail on the use of cookies, provided the used software does use cookies.

 

Customer Data

Customer Data Overview  👥Affected parties: Customers or business and contractual partners 🤝 Purpose: Performance of a contract for the provision of agreed services or prior to entering into such a contract, including associated communications. 📓 Data processed: name, address, contact details, email address, telephone number, payment information (such as invoices and bank details), contract data (such as duration and subject matter of the contract), IP address, order data 📅 Storage period: the data will be erased as soon as they are no longer required for our business purposes and there is no legal obligation to process them. ⚖️ Legal bases: Legitimate interests (Art. 6 Para. 1 lit. f GDPR), Contract (Art. 6 Para. 1 lit. b GDPR)

What is customer data?

In order to be able to offer our services and contractual services, we also process data from our customers and business partners. This data always includes personal data. Customer data is all information that is processed on the basis of contractual or pre-contractual agreements so that the offered services can be provided. Customer data is therefore all the information we collect and process about our customers.

Why do we process customer data?

There are many reasons why we collect and process customer data. The main reason is that we simply need specific data to provide our services. Sometimes for example your email address may be enough. But if you purchase a product or service, we may e. g. also need data such as your name, address, bank details or other contract data. This data will subsequently be used for marketing and sales optimisation so that we can improve our overall service for our customers and clients. Another important reason for data processing is our customer service, which is very important to us. We want you to have the opportunity to contact us at any time with questions about our offers. Thus, we may need certain data such as your email address at the very least.

What data is processed?

Exactly which data is stored can only be shown by putting them in categories. All in all, it always depends on which of our services you receive. In some cases, you may only give us your email address so that we can e. g. contact you or answer your questions. In other instances, you may purchase one of our products or services. Then we may need significantly more information, such as your contact details, payment details and contract details.

Here is a list of potential data we may receive and process:

• Name
• Contact address
• Email address
• Phone number
• Your birthday
• Payment data (invoices, bank details, payment history, etc.)
• Contract data (duration, contents)
• Usage data (websites visited, access data, etc.)
• Metadata (IP address, device information)

How long is the data stored?

We erase corresponding customer data as soon as we no longer need it to fulfill our contractual obligations and purposes, and as soon as the data is also no longer necessary for possible warranty and liability obligations. This can for example be the case when a business contract ends. Thereafter, the limitation period is usually 3 years, although longer periods may be possible in individual cases. Of course, we also comply with the statutory retention requirements. Your customer data will certainly not be passed on to third parties unless you have given your explicit consent.

Legal Basis

The legal basis for the processing of your data is Article 6 Paragraph 1 Letter a GDPR (consent), Article 6 Paragraph 1 Letter b GDPR (contract or pre-contractual measures), Article 6 Paragraph 1 Letter f GDPR (legitimate interests) and in special cases (e. g. medical services) Art. 9 (2) lit. GDPR (processing of special categories).

In the case of protecting vital interests, data processing is carried out in accordance with Article 9 Paragraph 2 Letter c. GDPR. For the purposes of health care, occupational medicine, medical diagnostics, care or treatment in the health or social sectors or for the administration of systems and services in health or social sectors, the processing of personal data takes place in accordance with Art. 9 Para. 2 lit. h. GDPR. If you voluntarily provide data of these special categories, the processing takes place on the basis of Article 9 Paragraph 2 lit. a GDPR.

Registration

Registration Overview  👥 Affected parties: Anyone who registers to create an account with us, and logs in to use the account. 📓 Processed data: Personal data such as email address, name, password and other data that is collected during registration, login and account use. 🤝 Purpose: For the provision of our services, as well as to communicate with clients or customers in the scope of our services.  📅Storage period: As long as the company account associated with the texts exists, plus a period of usually 3 years. ⚖️ Legal bases: Article 6 paragraph 1 letter b GDPR (contract), Article 6 paragraph 1 letter a GDPR (consent), Article 6 paragraph 1 letter f GDPR (legitimate interests)

If you register with us and provide any personal data, this data may be processed, possibly along with your IP address. Below you can explore what we mean by the rather broad term “personal data”.

Please only enter the data we need for the registration. In case you are registering on behalf of a third party, please only enter data for which you have the approval of the party you are registering for. If possible, use a secure password that you don’t use anywhere else and an email address that you check regularly.

In the following, we will inform you about the exact type of data processing we do. After all, we want you to feel at ease with the services we provide!

What is a registration?

When you register, we retain certain of your data in order to make it easy for you to log in with us online and use your account. An account with us has the advantage that you don’t have to re-enter everything every time. It saves time and effort and ultimately prevents any issues with the provision of our services.

Why do we process personal data?

In short, we process personal data to make account registration and usage possible for you. If we didn’t do this, you would have to enter all your data each time, wait for our approval and then enter everything again. This strenuous process would probably not only irritate us a little, but also many of our dear clients and customers.

Which data is processed?

Any data that you provided during registration or login and any data that you may enter as part of managing your account data.

During registration, we process the following types of data: 

• First name
• Last name
• Email address
• Company name
• Street + house number
• Residence
• Postcode
• Country

During your registration, we process any data you enter, such as your username and password, along with data that is collected in the background such as your device information and IP addresses.

When using your account, we process any data you enter while using the account, as well as any data that is created while you use our services.

Storage time

We store the entered data for at least as long as the account associated with the data exists with us and is in use – and as long as there are contractual obligations between you and us. In case the contract ends, we retain the data until the respective claims get time-barred. Moreover, we store your data as long as we are subject to legal storage obligations, if applicable. Following that, we keep any accounting records (invoices, contract documents, account statements, etc.) of the contract for 10 years (§ 147 AO) and other relevant business documents for 6 years (§ 247 HGB) after accrual.

Right to object

You have registered, entered data and want to revoke the data processing? Not a problem. As you can see above, you retain this right under the General Data Protection Regulation also at and after registration, login or account creation with us. Contact the Data Protection Officer above to exercise your rights. If you already have an account with us, you can easily view and manage your data and texts in your account.

Legal Basis

By completing the registration process, you enter into a pre-contractual agreement with us, with the intention to conclude a contract of use for our platform (although there is no automatic payment obligation). You invest time to enter data and register and in return, we offer you our services after you log on to our system and view your customer account. We also meet our contractual obligations. Finally, we need to be able to email registered users about important changes. Article 6(1)(b) GDPR (implementation of pre-contractual measures, fulfilment of a contract) applies.

Where applicable, we will ask for your consent, e.g. in case you voluntarily provide more data than is absolutely necessary, or in case we may ask you if we may send you advertising. Article 6 paragraph 1 lit. a GDPR (consent) applies in this matter.

We also have a legitimate interest in knowing who who our clients or customers are, in order to get in touch if required. We also need to know who is using our services and whether they are being used in accordance with our terms of use, i.e. Article 6(1)(f) GDPR (legitimate interests) applies in this matter.

Note: the following sections are to be ticked by users (as required):

Registration with real names

Since business operations require us to know who our clients or customers are, registration is only possible with your real name (full name) and not with a pseudonym.

Registration with pseudonyms

You can use a pseudonym for the registration, which means you don’t have to register with your real name. This ensures that your real name cannot be processed by us. 

Storage of the IP address

During registration, login and account use, we store your IP address for security reasons in order to be able to determine legitimate use.

Public Profile

User profiles are publicly visible, i.e. parts of the profiles can also be viewed on the Internet without the need to enter a username and password.

Two Factor Authentication (2FA)

Two Factor Authentication (2FA) offers additional security when logging in, as it prevents you from logging in without a smartphone, for example. This technical measure to secure your account protects you against the loss of data or unauthorised access, even if your username and password were leaked. During your registration process, login or within the account itself y ou can find out which 2FA is used.

Web hosting

Web hosting Overview  👥 Affected parties: visitors to the website 📓 Purpose: professional hosting of the website and security of operations 🤝 Processed data: IP address, time of website visit, browser used and other data. You can find more details on this below or at the respective web hosting provider. 📅 Storage period: dependent on the respective provider, but usually 2 weeks ⚖️ Legal basis: Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is web hosting?

Every time you visit a website nowadays, certain information – including personal data – is automatically created and stored, including on this website. This data should be processed as sparingly as possible, and only with good reason. By website, we mean the entirety of all websites on your domain, i.e. everything from the homepage to the very last subpage (like this one here). By domain we mean example.uk or examplepage.com.

When you want to view a website on a screen, you use a program called a web browser. You probably know the names of some web browsers: Google Chrome, Microsoft Edge, Mozilla Firefox, and Apple Safari.

The web browser has to connect to another computer which stores the website’s code: the web server. Operating a web server is complicated and time-consuming, which is why this is usually done by professional providers. They offer web hosting and thus ensure the reliable and flawless storage of website data.

Whenever the browser on your computer establishes a connection (desktop, laptop, smartphone) and whenever data is being transferred to and from the web server, personal data may be processed. After all, your computer stores data, and the web server also has to retain the data for a period of time in order to ensure it can operate properly.

Illustration:

 

Why do we process personal data?

The purposes of data processing are:

1. Professional hosting of the website and operational security
2. To maintain the operational as well as IT security
3. Anonymous evaluation of access patterns to improve our offer, and if necessary, for prosecution or the pursuit of claims.li>

Which data are processed?

Even while you are visiting our website, our web server, that is the computer on which this website is saved, usually automatically saves data such as

• the full address (URL) of the accessed website (e. g. www.examplepage.uk/examplesubpage.html)
• browser and browser version (e.g. Chrome 87)
• the operating system used (e.g. Windows 10)
• the address (URL) of the previously visited page (referrer URL) (e. g. www.examplepage.uk/icamefromhere.html/)
• the host name and the IP address of the device from the website is being accessed from (e.g. COMPUTERNAME and 194.23.43.121)
• date and time
• in so-called web server log files

How long is the data stored?

Generally, the data mentioned above are stored for two weeks and are then automatically deleted. We do not pass these data on to others, but we cannot rule out the possibility that this data may be viewed by the authorities in the event of illegal conduct.

In short: Your visit is logged by our provider (company that runs our website on special computers (servers)), but we do not pass on your data without your consent!

Legal basis

The lawfulness of processing personal data in the context of web hosting is justified in Art. 6 para. 1 lit. f GDPR (safeguarding of legitimate interests), as the use of professional hosting with a provider is necessary to present the company in a safe and user-friendly manner on the internet, as well as to have the ability to track any attacks and claims, if necessary.

Hetzner Privacy Policy

We use Hetzner for our website, which is a web hosting provider, among other things. The provider of this service is the German company Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany. You can find out more about the data that is processed through the use of Hetzner in their Privacy Policy at https://www.hetzner.com/de/rechtliches/datenschutz.

Web Analytics

Web Analytics Privacy Policy Overview  👥 Affected parties: visitors to the website 🤝 Purpose: Evaluation of visitor information to optimise the website. 📓 Processed data: Access statistics that contain data such as access location, device data, access duration and time, navigation behaviour, click behaviour and IP addresses. You can find more details on this from the respective web analytics tool directly. 📅 Storage period: depending on the respective web analytics tool used ⚖️ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is Web Analytics?

We use software on our website, which is known as web analytics, in order to evaluate website visitor behaviour. Thus, data is collected, which the analytic tool provider (also called tracking tool) stores, manages and processes. Analyses of user behaviour on our website are created with this data, which we as the website operator receive. Most tools also offer various testing options. These enable us, to for example test which offers or content our visitors prefer. For this, we may show you two different offers for a limited period of time. After the test (a so-called A/B test) we know which product or content our website visitors find more interesting. For such testing as well as for various other analyses, user profiles are created and the respective data is stored in cookies.

Why do we run Web Analytics?

We have a clear goal in mind when it comes to our website: we want to offer our industry’s best website on the market. Therefore, we want to give you both, the best and most interesting offer as well as comfort when you visit our website. With web analysis tools, we can observe the behaviour of our website visitors, and then improve our website accordingly for you and for us. For example, we can see the average age of our visitors, where they come from, the times our website gets visited the most, and which content or products are particularly popular. All this information helps us to optimise our website and adapt it to your needs, interests and wishes.

Which data are processed?

The exact data that is stored depends on the analysis tools that are being used. But generally, data such as the content you view on our website are stored, as well as e. g. which buttons or links you click, when you open a page, which browser you use, which device (PC, tablet, smartphone, etc.) you visit the website with, or which computer system you use. If you have agreed that location data may also be collected, this data may also be processed by the provider of the web analysis tool.

Moreover, your IP address is also stored. According to the General Data Protection Regulation (GDPR), IP addresses are personal data. However, your IP address is usually stored in a pseudonymised form (i.e. in an unrecognisable and abbreviated form). No directly linkable data such as your name, age, address or email address are stored for testing purposes, web analyses and web optimisations. If this data is collected, it is retained in a pseudonymised form. Therefore, it cannot be used to identify you as a person.

The following example shows Google Analytics’ functionality as an example for client-based web tracking with JavaScript code.

 

The storage period of the respective data always depends on the provider. Some cookies only retain data for a few minutes or until you leave the website, while other cookies can store data for several years.

Duration of data processing

If we have any further information on the duration of data processing, you will find it below. We generally only process personal data for as long as is absolutely necessary to provide products and services. The storage period may be extended if it is required by law, such as for accounting purposes for example for accounting.

Right to object

You also have the option and the right to revoke your consent to the use of cookies or third-party providers at any time. This works either via our cookie management tool or via other opt-out functions. For example, you can also prevent data processing by cookies by managing, deactivating or erasing cookies in your browser.

Legal basis

The use of Web Analytics requires your consent, which we obtained with our cookie popup. According to Art. 6 para. 1 lit. a of the GDPR (consent), this consent represents the legal basis for the processing of personal data, such as by collection through Web Analytics tools.

In addition to consent, we have a legitimate interest in analysing the behaviour of website visitors, which enables us to technically and economically improve our offer. With Web Analytics, we can recognise website errors, identify attacks and improve profitability. The legal basis for this is Art. 6 para. 1 lit. f of the GDPR (legitimate interests). Nevertheless, we only use these tools if you have given your consent.

Since Web Analytics tools use cookies, we recommend you to read our privacy policy on cookies. If you want to find out which of your data are stored and processed, you should read the privacy policies of the respective tools.

If available, information on special Web Analytics tools can be found in the following sections.

Facebook Pixel Privacy Policy

We use Facebook’s Facebook pixel on our website. For that, we have implemented a code on our website. The Facebook pixel is a segment of a JavaScript code, which, in case you came to our website via Facebook ads, loads an array or functions that enable Facebook to track your user actions. For example, if you buy a product on our website, the Facebook pixel is triggered and stores your actions on our website in one or more cookies. These cookies enable Facebook to match your user data (customer data such as IP address, user ID) with the data of your Facebook account. After that, Facebook deletes your data again. The collected data is anonymous as well as inaccessible and can only be used for ad placement purposes. If you are a Facebook user and you are logged in, your visit to our website is automatically assigned to your Facebook user account.

We exclusively want to show our products or services to persons, who are interested in them. With the aid of the Facebook pixel, our advertising measures can get better adjusted to your wishes and interests. Therefore, Facebook users get to see suitable advertisement (if they allowed personalised advertisement). Moreover, Facebook uses the collected data for analytical purposes and for its own advertisements.

In the following we will show you the cookies, which were set on a test page with the Facebook pixel integrated to it. Please consider that these cookies are only examples. Depending on the interaction that is made on our website, different cookies are set.

Name: _fbp
Value: fb.1.1568287647279.257405483-6112876210-7
Purpose: Facebook uses this cookie to display advertising products.
Expiration date: after 3 months

Name: fr
Value: 0aPf312HOS5Pboo2r..Bdeiuf…1.0.Bdeiuf.
Purpose: This cookie is used for Facebook pixels to function properly.
Expiration date: after 3 months

Name: comment_author_50ae8267e2bdf1253ec1a5769f48e062112876210-3
Value: Name of the author
Purpose: This cookie saves the text and name of a user who e.g. leaves a comment.
Expiration date: after 12 months

Name: comment_author_url_50ae8267e2bdf1253ec1a5769f48e062
Value: https%3A%2F%2Fwww.testseite…%2F (URL of the author)
Purpose: This cookie saved the URL of the website that the user types into a text box on our website.
Expiration date: after 12 months

Name: comment_author_email_50ae8267e2bdf1253ec1a5769f48e062
Value: email address of the author
Purpose: This cookie saves the email address of the user, if they provided it on the website.
Expiration date: after 12 months

Note: The above-mentioned cookies relate to an individual user behaviour. Moreover, especially concerning the usage of cookies, changes at Facebook can never be ruled out.

If you are registered on Facebook, you can change the settings for advertisements yourself at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. If you are not a Facebook user, you can manage your user based online advertising at https://www.youronlinechoices.com/uk/your-ad-choices. You have the option to activate or deactivate any providers there.

Facebook processes data from you, among other things, in the USA. Facebook respectively Meta Platforms is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA. More information can be found at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Additionally, Facebook uses so-called Standard Contractual Clauses (Article 46(2) and (3) GDPR). Standard Contractual Clauses (SCC) are template clauses provided by the EU Commission and are designed to ensure that your data complies with European data protection standards, even when transferred and stored in third countries (such as the USA). Through the EU-US Data Privacy Framework and the Standard Contractual Clauses, Facebook commits to maintaining the European data protection level when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding Standard Contractual Clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.

The Facebook Data Processing Term, which references the Standard Contractual Clauses, can be found at https://www.facebook.com/legal/terms/dataprocessing.

If you want to learn more about Facebook’s data protection, we recommend you the view the company’s in-house data policies at https://www.facebook.com/policy.php.

Google Analytics Privacy Policy

Google Analytics Privacy Policy Overview  👥 Affected parties: website visitors 🤝 Purpose: Evaluation of visitor information to optimise the website. 📓 Processed data: Access statistics that contain data such as the location of access, device data, access duration and time, navigation behaviour and click behaviour. You can find more details on this in the privacy policy below. 📅 Storage period: Customizable, GA4 stores data for 14 months by default. ⚖️ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is Google Analytics?

On our website, we use the analytics tracking tool Google Analytics in the Google Analytics 4 (GA4) version provided by the American company Google Inc. For the European region, Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland) is responsible for all Google services. Google Analytics collects data about your actions on our website. By combining various technologies such as cookies, device IDs, and login information, you can be identified as a user across different devices. This allows your actions to be analyzed across platforms as well.

For example, when you click on a link, this event is stored in a cookie and sent to Google Analytics. With the reports we receive from Google Analytics, we can better tailor our website and service to your needs. In the following, we will provide more information about the tracking tool and specifically inform you about the data processed and how you can prevent it.

Google Analytics is a tracking tool used for website traffic analysis. The basis for these measurements and analyses is a pseudonymous user identification number. This number does not include personally identifiable information such as name or address but is used to assign events to a device. GA4 utilizes an event-based model that captures detailed information about user interactions such as page views, clicks, scrolling, and conversion events. Additionally, GA4 incorporates various machine learning features to better understand user behavior and certain trends. GA4 employs modeling through machine learning capabilities, meaning that based on the collected data, missing data can be extrapolated to optimize the analysis and provide forecasts.

In order for Google Analytics to function properly, a tracking code is embedded in the code of our website. When you visit our website, this code records various events that you perform on our website. With GA4’s event-based data model, we, as website operators, can define and track specific events to obtain analyses of user interactions. This allows us to track not only general information such as clicks or page views but also specific events that are important for our business, such as submitting a contact form or making a purchase.

Once you leave our website, this data is sent to and stored on Google Analytics servers.

Google processes the data, and we receive reports on your user behavior. These reports can include, among others, the following:

• Audience reports: Audience reports help us get to know our users better and gain a more precise understanding of who is interested in our service.
• Advertising reports: Advertising reports make it easier for us to analyze and improve our online advertising.
• Acquisition reports: Acquisition reports provide helpful information on how we can attract more people to our service.
• Behavior reports: Here, we learn about how you interact with our website. We can track the path you take on our site and which links you click on.
• Conversion reports: Conversion refers to an action you take as a result of a marketing message, such as going from being a website visitor to becoming a buyer or newsletter subscriber. Through these reports, we gain insights into how our marketing efforts resonate with you, with the aim of improving our conversion rate.
• Real-time reports: With real-time reports, we can see what is currently happening on our website. For example, we can see how many users are currently reading this text.

In addition to the above-mentioned analysis reports, Google Analytics 4 also offers the following functions:

• Event-based data model: This model captures specific events that can occur on our website, such as playing a video, making a purchase, or subscribing to our newsletter.
• Advanced analytics features: With these features, we can gain a better understanding of your behavior on our website or certain general trends. For example, we can segment user groups, conduct comparative analyses of target audiences, or track your path on our website.
• Predictive modeling: Based on the collected data, missing data can be extrapolated through machine learning to predict future events and trends. This can help us develop better marketing strategies.
• Cross-platform analysis: Data collection and analysis are possible from both websites and apps. This enables us to analyze user behavior across platforms, provided you have consented to data processing.

Why do we use Google Analytics on our website?

Our goal with this website is clear: we want to provide you with the best possible service. The statistics and data from Google Analytics help us achieve this goal.

The statistically evaluated data gives us a clear picture of the strengths and weaknesses of our website. On one hand, we can optimize our site to make it more easily found by interested people on Google. On the other hand, the data helps us better understand you as a visitor. We know exactly what we need to improve on our website in order to provide you with the best possible service. The data also helps us conduct our advertising and marketing activities in a more personalized and cost-effective manner. After all, it only makes sense to show our products and services to people who are interested in them.

What data is stored by Google Analytics?

With the help of a tracking code, Google Analytics creates a random, unique ID associated with your browser cookie. This way, Google Analytics recognizes you as a new user, and a user ID is assigned to you. When you visit our site again, you are recognized as a “returning” user. All collected data is stored together with this user ID, making it possible to evaluate pseudonymous user profiles.

To analyze our website with Google Analytics, a property ID must be inserted into the tracking code. The data is then stored in the corresponding property. For each newly created property, the default is Google Analytics 4 Property. The data storage duration varies depending on the property used.

Through identifiers such as cookies, app instance IDs, user IDs, or custom event parameters, your interactions, if you have consented, are measured across platforms. Interactions encompass all types of actions you perform on our website. If you also use other Google systems (such as a Google account), data generated through Google Analytics can be linked to third-party cookies. Google does not disclose Google Analytics data unless we, as website operators, authorize it, except when required by law.

According to Google, IP addresses are not logged or stored in Google Analytics 4. However, IP address data is used by Google for deriving location data and is immediately deleted thereafter. All IP addresses collected from users in the EU are deleted before the data is stored in a data center or on a server.

Since GA4 focuses on event-based data, the tool uses significantly fewer cookies compared to previous versions such as Google Universal Analytics. However, there are still some specific cookies used by GA4. These can include:

Name: _ga
Value: 2.1326744211.152112876210-5
Purpose: By default, analytics.js uses the _ga cookie to store the user ID. It is used to distinguish website visitors.
Expiration: After 2 years

Name: _gid
Value: 2.1687193234.152112876210-1
Purpose: This cookie is also used to distinguish website visitors.
Expiration: After 24 hours

Name: gat_gtag_UA Value: 1
Purpose: Used to reduce the request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named dc_gtm .
Expiration: After 1 minute

Note: This list cannot claim to be exhaustive, as Google may change their choice of cookies from time to time. GA4 aims to improve data privacy and offers several options for controlling data collection. For example, we can determine the storage duration ourselves and control data.

Here we provide an overview of the main types of data collected by Google Analytics:

Heatmaps: Google creates heatmaps to show the exact areas you click on. This provides us with information about your interactions on our site.

Session Duration: Google refers to session duration as the time you spend on our site without leaving. If you are inactive for 20 minutes, the session automatically ends.

Bounce Rate: Bounce rate refers to when you view only one page on our website and then leave.

Account Creation: If you create an account or place an order on our website, Google Analytics collects this data.

Location: IP addresses are not logged or stored in Google Analytics. However, location data is derived shortly before the IP address is deleted.

Technical Information: Technical information includes your browser type, internet service provider, and screen resolution, among others.

Source of Origin: Google Analytics is interested in the website or advertisement that brought you to our site.

Additional data may include contact information, reviews, media playback (e.g., if you play a video on our site), sharing of content via social media, or adding to favorites. This list is not exhaustive and serves only as a general guide to the data storage by Google Analytics.

Where and how long are the data stored?

Google has servers distributed worldwide. You can find precise information about the locations of Google data centers at: https://www.google.com/about/datacenters/locations/?hl=en

Your data is distributed across multiple physical storage devices. This ensures faster access to data and better protection against manipulation. Each Google data center has emergency programs in place for your data. In the event of hardware failure or natural disasters, the risk of service interruption at Google remains low.

The retention period of data depends on the properties used. The storage duration is always set separately for each individual property. Google Analytics offers us four options for controlling the storage duration:

• 2 months: This is the shortest storage period.
• 14 months: By default, data is stored in GA4 for 14 months.
• 26 months: Data can also be stored for 26 months.
• Data is only deleted manually.

In addition, there is also the option for data to be deleted only if you do not visit our website within the selected time period. In this case, the retention period is reset every time you revisit our website within the defined time frame.

Once the defined period has expired, the data is deleted once a month. This retention period applies to data linked to cookies, user identification, and advertising IDs (e.g., cookies from the DoubleClick domain). Report results are based on aggregated data and are stored independently of user data. Aggregated data is a combination of individual data into larger units.

How can I delete my data or prevent data storage?

Under the data protection laws of the European Union, you have the right to access, update, delete, or restrict your data. By using the browser add-on to deactivate Google Analytics JavaScript (analytics.js, gtag.js), you can prevent Google Analytics 4 from using your data. You can download and install the browser add-on at: https://tools.google.com/dlpage/gaoptout?hl=en Please note that this add-on only disables data collection by Google Analytics.

If you want to disable, delete, or manage cookies in general, you can find the respective instructions for the most common browsers in the “Cookies” section.

Legal basis

The use of Google Analytics requires your consent, which we obtained through our cookie popup. According to Art. 6(1)(a) of the GDPR, this consent constitutes the legal basis for the processing of personal data that may occur during the collection by web analytics tools.

In addition to consent, we also have a legitimate interest in analyzing the behavior of website visitors to improve our offering technically and economically. By using Google Analytics, we can identify website errors, detect attacks, and improve efficiency. The legal basis for this is Art. 6(1)(f) of the GDPR (legitimate interests). However, we only use Google Analytics if you have given your consent.

Google processes data from you, among other things, in the USA. Google is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA. More information can be found at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Additionally, Google uses so-called Standard Contractual Clauses (Article 46(2) and (3) GDPR). Standard Contractual Clauses (SCC) are template clauses provided by the EU Commission and are designed to ensure that your data complies with European data protection standards, even when transferred and stored in third countries (such as the USA). Through the EU-US Data Privacy Framework and the Standard Contractual Clauses, Google commits to maintaining the European data protection level when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding Standard Contractual Clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.

You can find the Google Ads Data Processing Terms, which refer to the Standard Contractual Clauses, at: https://business.safety.google/intl/en/adsprocessorterms/

We hope we have provided you with the most important information regarding the data processing by Google Analytics. If you want to learn more about the tracking service, we recommend the following links: https://marketingplatform.google.com/about/analytics/terms/en/ and https://support.google.com/analytics/answer/6004245?hl=en

If you want to learn more about data processing, you can refer to the Google Privacy Policy at: https://policies.google.com/privacy?hl=en.

Data Processing Agreement (DPA) Google Analytics

In accordance with Article 28 of the General Data Protection Regulation (GDPR), we have entered into a Data Processing Agreement (DPA) with Google Analytics. What exactly a DPA is and especially what must be included in a DPA, you can read in our general section “Data Processing Agreement (DPA)”.

This contract is required by law because Google Analytics processes personal data on our behalf. It clarifies that Google Analytics may only process data they receive from us according to our instructions and must comply with the GDPR. You can find the link to the Data Processing Terms under https://business.safety.google/intl/en/adsprocessorterms/.

Google Analytics IP Anonymisation

We implemented Google Analytics’ IP address anonymisation to this website. Google developed this function, so this website can comply with the applicable privacy laws and the local data protection authorities’ recommendations, should they prohibit the retention of any full IP addresses.
The anonymisation or masking of IP addresses takes place, as soon as they reach Google Analytics’ data collection network, but before the data would be saved or processed.

You can find more information on IP anonymisation at https://support.google.com/analytics/answer/2763052?hl=en.

Google Tag Manager Privacy Policy

Google Tag Manager Privacy Policy Overview  👥 Affected parties: website visitors 🤝 Purpose: Organisation of individual tracking tools 📓 Processed data: Google Tag Manager itself does not store any data. The data record tags of the web analytics tools used. 📅 Storage period: depending on the web analytics tool used ⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is Google Tag Manager?

We use Google Tag Manager by the company Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA) for our website.
This Tag Manager is one of Google’s many helpful marketing products. With it, we can centrally integrate and manage code sections of various tracking tools, that we use on our website.

In this privacy statement we will explain in more detail, what Google Tag Manager does, why we use it and to what extent your data is processed.

Google Tag Manager is an organising tool with which we can integrate and manage website tags centrally and via a user interface. Tags are little code sections which e.g. track your activities on our website. For this, segments of JavaScript code are integrated to our site’s source text. The tags often come from Google’s intern products, such as Google Ads or Google Analytics, but tags from other companies can also be integrated and managed via the manager. Since the tags have different tasks, they can collect browser data, feed marketing tools with data, embed buttons, set cookies and track users across several websites.

Why do we use Google Tag Manager for our website?

Everybody knows: Being organised is important! Of course, this also applies to maintenance of our website. In order to organise and design our website as well as possible for you and anyone who is interested in our products and services, we rely on various tracking tools, such as Google Analytics.
The collected data shows us what interests you most, which of our services we should improve, and which other persons we should also display our services to. Furthermore, for this tracking to work, we must implement relevant JavaScript Codes to our website. While we could theoretically integrate every code section of every tracking tool separately into our source text, this would take too much time and we would lose overview. This is the reason why we use Google Tag Manager. We can easily integrate the necessary scripts and manage them from one place. Additionally, Google Tag Manager’s user interface is easy to operate, and requires no programming skills. Therefore, we can easily keep order in our jungle of tags.

What data is stored by Google Tag Manager?

Tag Manager itself is a domain that neither uses cookies nor stores data. It merely functions as an “administrator“ of implemented tags. Data is collected by the individual tags of the different web analysis tools. Therefore, in Google Tag Manager the data is sent to the individual tracking tools and does not get saved.

However, with the integrated tags of different web analysis tools such as Google Analytics, this is quite different. Depending on the analysis tool used, various data on your internet behaviour is collected, stored and processed with the help of cookies. Please read our texts on data protection for more information on the articular analysis and tracking tools we use on our website.

We allowed Google via the account settings for the Tag Manager to receive anonymised data from us. However, this exclusively refers to the use of our Tag Manager and not to your data, which are saved via code sections. We allow Google and others, to receive selected data in anonymous form. Therefore, we agree to the anonymised transfer of our website data. However, even after extensive research we could not find out what summarised and anonymous data it is exactly that gets transmitted. What we do know is that Google deleted any info that could identify our website. Google combines the data with hundreds of other anonymous website data and creates user trends as part of benchmarking measures. Benchmarking is a process of comparing a company’s results with the ones of competitors. As a result, processes can be optimised based on the collected information.

How long and where is the data stored?

When Google stores data, this is done on Google’s own servers. These servers are located all over the world, with most of them being in America. At https://www.google.com/about/datacenters/inside/locations/?hl=en you can read in detail where Google’s servers are.

In our individual data protection texts on the different tools you can find out how long the respective tracking tools store your data.

How can I delete my data or prevent data retention?

Google Tag Manager itself does not set any cookies but manages different tracking websites’ tags. In our data protection texts on the different tracking tools you can find detailed information on how you can delete or manage your data.

Please note that when using this tool, your data may also be stored and processed outside the EU. Most third countries (including the USA) are not considered secure under current European data protection law. Data must not be transferred, stored and processed to insecure third countries, unless there are suitable guarantees (such as EU standard contractual clauses) between us and the non-European service provider.

Legal basis

The use of the Google Tag Manager requires your consent, which we obtained via our cookie popup. According to Art. 6 para. 1 lit. a GDPR (consent), this consent is the legal basis for personal data processing, such as when it is collected by web analytics tools.

In addition to consent, we have a legitimate interest in analysing the behaviour of website visitors and thus technically and economically improving our offer. With the help of Google Tag Managers we can also improve profitability. The legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests). We only use Google Tag Manager if you have given us your consent.

Google processes data from you, among other things, in the USA. Google is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA. More information can be found at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Additionally, Google uses so-called Standard Contractual Clauses (Article 46(2) and (3) GDPR). Standard Contractual Clauses (SCC) are template clauses provided by the EU Commission and are designed to ensure that your data complies with European data protection standards, even when transferred and stored in third countries (such as the USA). Through the EU-US Data Privacy Framework and the Standard Contractual Clauses, Google commits to maintaining the European data protection level when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding Standard Contractual Clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.

You can find the Google Ads Data Processing Terms, which refer to the Standard Contractual Clauses, at: https://business.safety.google/intl/en/adsprocessorterms/

If you want to learn more about Google Tag Manager, we recommend their FAQs at https://support.google.com/tagmanager/?hl=en#topic=3441530.

Email-Marketing

Email Marketing Overview  👥 Affected parties: newsletter subscribers 🤝 Purpose: direct marketing via email, notification of events that are relevant to the system 📓 Processed data: data entered during registration, but at least the email address. You can find more details on this in the respective email marketing tool used. 📅 Storage duration: for the duration of the subscription ⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is Email-Marketing?

We use email marketing to keep you up to date. If you have agreed to receive our emails or newsletters, your data will be processed and stored. Email marketing is a part of online marketing. In this type of marketing, news or general information about a company, product or service are emailed to a specific group of people who are interested in it.

If you want to participate in our email marketing (usually via newsletter), you usually just have to register with your email address. To do this, you have to fill in and submit an online form. However, we may also ask you for your title and name, so we can address you personally in our emails.

The registration for newsletters generally works with the help of the so-called “double opt-in procedure”. After you have registered for our newsletter on our website, you will receive an email, via which you can confirm the newsletter registration. This ensures that you own the email address you signed up with, and prevents anyone to register with a third-party email address. We or a notification tool we use, will log every single registration. This is necessary so we can ensure and prove, that registration processes are done legally and correctly. In general, the time of registration and registration confirmation are stored, as well as your IP address. Moreover, any change you make to your data that we have on file is also logged.

Why do we use Email-Marketing?

Of course, we want to stay in contact with you and keep you in the loop of the most important news about our company. For this, we use email marketing – often just referred to as “newsletters” – as an essential part of our online marketing. If you agree to this or if it is permitted by law, we will send you newsletters, system emails or other notifications via email. Whenever the term “newsletter” is used in the following text, it mainly refers to emails that are sent regularly. We of course don’t want to bother you with our newsletter in any way. Thus, we genuinely strive to offer only relevant and interesting content. In our emails you can e.g. find out more about our company and our services or products. Since we are continuously improving our offer, our newsletter will always give you the latest news, or special, lucrative promotions. Should we commission a service provider for our email marketing, who offers a professional mailing tool, we do this in order to offer you fast and secure newsletters. The purpose of our email marketing is to inform you about new offers and also to get closer to our business goals.

Which data are processed?

If you subscribe to our newsletter via our website, you then have to confirm your membership in our email list via an email that we will send to you. In addition to your IP and email address, your name, address and telephone number may also be stored. However, this will only be done if you agree to this data retention. Any data marked as such are necessary so you can participate in the offered service. Giving this information is voluntary, but failure to provide it will prevent you from using this service. Moreover, information about your device or the type of content you prefer on our website may also be stored. In the section “Automatic data storage” you can find out more about how your data is stored when you visit a website. We record your informed consent, so we can always prove that it complies with our laws.

Duration of data processing

If you unsubscribe from our e-mail/newsletter distribution list, we may store your address for up to three years on the basis of our legitimate interests, so we can keep proof your consent at the time. We are only allowed to process this data if we have to defend ourselves against any claims.

However, if you confirm that you have given us your consent to subscribe to the newsletter, you can submit an individual request for erasure at any time. Furthermore, if you permanently object to your consent, we reserve the right to store your email address in a blacklist. But as long as you have voluntarily subscribed to our newsletter, we will of course keep your email address on file.

Withdrawal – how can I cancel my subscription?

You have the option to cancel your newsletter subscription at any time. All you have to do is revoke your consent to the newsletter subscription. This usually only takes a few seconds or a few clicks. Most of the time you will find a link at the end of every email, via which you will be able to cancel the subscription. Should you not be able to find the link in the newsletter, you can contact us by email and we will immediately cancel your newsletter subscription for you.

Legal basis

Our newsletter is sent on the basis of your consent (Article 6 (1) (a) GDPR). This means that we are only allowed to send you a newsletter if you have actively registered for it beforehand. Moreover, we may also send you advertising messages on the basis of Section 7 (3) UWG (Unfair Competition Act), provided you have become our customer and have not objected to the use of your email address for direct mail.

If available – you can find information on special email marketing services and how they process personal data, in the following sections.

Messenger & Communication Introduction

Messenger & Communication Privacy Statement Overview  👥 Affected parties: website visitors 🤝 Purpose: for contact requests and general communications between yourself and us 📓 Processed data: Data such as name, address, email address, telephone number, general content data, plus IP address if applicable You can find more details on this under the respective tools used. 📅 Storage duration: depends on the messenger & communication functions ⚖️ Legal bases: Article 6 paragraph 1 letter a GDPR (consent), Article 6 paragraph 1 letter f GDPR (legitimate interests), Article 6 paragraph 1 sentence 1 letter b. GDPR (contractual or pre-contractual obligations)

What are Messenger & Communication functions?

We offer you various options on our website to communicate with us (e.g. messenger and chat functions, online or contact forms, email, telephone). With the use of these functions, your data will be processed and stored insofar as it is necessary to answer your inquiry and conduct any of our subsequent measures.

In addition to classic means of communication such as email, contact forms or telephone, we also use chats or messengers. The most commonly used messenger function at the moment is WhatsApp, but of course, there are many different providers who offer messenger functions for websites. If content is end-to-end encrypted, it will be indicated in our individual privacy policies or in the privacy policy of the respective provider. End-to-end encryption means that the content of a message is not visible to the provider themselves. However, information about your device, location settings and other technical data can still be processed and stored.

Why do we use Messenger & Communication functions?

The ability to communicate with you is very important to us. After all, we want to keep the conversation with you going and answer any questions you may have about our service as best we can. Needless to say, smooth communication is an important part of our service. With our practical messenger & communication functions, you always have the option to choose the ones you prefer most. In exceptional cases, however, we may not be able to answer certain questions via chat or messenger. This may be the case for internal contractual matters, for example. For matters like these, we recommend you to use other communication options such as email or telephone.

We generally assume our responsibility under data protection law, even if we use the services of any social media platform. However, the European Court of Justice has decided that in certain cases the operator of the social media platform be jointly responsible alongside us in the scope of Art. 26 GDPR. Should this be the case, we will point it out separately and work on the basis of a relevant agreement. You will find the essence of the agreement for the respective platforms below.

Please note that when using our integrated elements, your data may also be processed outside the European Union, since many providers, such as Facebook Messenger or WhatsApp, are American companies. As a result, you may not be able to claim or enforce your rights in relation to your personal data as easily.

Which data is processed?

Exactly which data is retained and processed depends on the respective messenger & communication function provider. In general, it is data such as your name, address, telephone number, email address and content data such as any information you enter into a contact form. In most cases, information about your device and IP address are also stored. Moreover, data that are transmitted via a messenger & communication function are also stored on the providers’ servers.

If you want to know exactly which data is stored and processed by the respective providers and how you can object to the data processing, you please carefully read the respective privacy policy of the company in question.

How long is data stored?

How long data is processed and stored depends primarily on the tools we use. Below you can find out more about the data processing of individual tools. The providers’ privacy policies usually state exactly which data is stored and processed and for how long. In general, we only process personal data for as long as necessary to provide our services. When data is stored in cookies, the storage period varies greatly. Data may e.g. be deleted immediately after leaving a website, or they may be stored for several years. Therefore, you should study each individual cookie in detail if you want to know more about data storage. In most cases, you will also find helpful information about individual cookies in the privacy policies of the individual providers.

Right to object

You also have the right and the option to revoke your consent to the use of cookies or third-party providers at any time. This can be done either via our cookie management tool or via other opt-out functions. For example, you can also prevent data collection by cookies by managing, deactivating or deleting the cookies in your browser. For more information, we recommend you to read the Consent section.

Since cookies may be in use with messenger & communication functions, we recommend you to read our general privacy policy on cookies. To find out exactly which of your data is stored and processed, please read the privacy policies of the respective tools.

Legal Basis

If you have consented to the data processing and storage by integrated messenger & communication functions, this consent is the legal basis for data processing (Art. 6 Para. 1 lit. a GDPR). We process your request and manage your data within the framework of contractual or pre-contractual relationships in order to fulfill our pre-contractual and contractual obligations or to answer inquiries. The basis for this is Art. 6 Para. 1 section 1 lit. b GDPR. In general, if you have given your consent, your data will also be stored and processed on the basis of our legitimate interest (Art. 6 Para. 1 lit. f GDPR) in quick and smooth communication with you or other customers and business partners.

Social Media

Social Media Privacy Policy Overview  👥 Affected parties: website visitors 🤝 Purpose: Service presentation and optimisation, staying in contact with visitors, interested parties, etc. as well as advertising 📓 Processed data: data such as telephone numbers, email addresses, contact data, data on user behaviour, information about your device and your IP address. You can find more details on this directly at the respective social media tool used. 📅 Storage period: depending on the social media platforms used ⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is Social Media?

In addition to our website, we are also active on various social media platforms. For us to be able to target interested users via social networks, user data may be processed. Additionally, elements of social media platforms may be embedded directly in our website. This is e.g. the case if you click a so-called social button on our website and are forwarded directly to our social media presence. So-called social media are websites and apps on which registered members can produce and exchange content with other members, be it openly or in certain groups and networks.

Why do we use Social Media?

For years, social media platforms have been the place where people communicate and get into contact online. With our social media presence, we can familiarise interested people better with our products and services. The social media elements integrated on our website help you switch to our social media content quickly and hassle free.

The data that is retained and processed when you use a social media channel is primarily used to conduct web analyses. The aim of these analyses is to be able to develop more precise and personal marketing and advertising strategies. The evaluated data on your behaviour on any social media platform can help to draw appropriate conclusions about your interests. Moreover, so-called user profiles can be created. Thus, the platforms may also to present you with customised advertisements. For this, cookies are usually placed in your browser, which store data on your user behaviour.

We generally assume that we will continue to be responsible under Data Protection Law, even when using the services of a social media platform. However, the European Court of Justice has ruled that, within the meaning of Art. 26 GDPR, in certain cases the operator of the social media platform can be jointly responsible with us. Should this be the case, we will point it out separately and work on the basis of a related agreement. You will then find the essence of the agreement for the concerned platform below.

Please note that when you use social media platforms or our built-in elements, your data may also be processed outside the European Union, as many social media channels, such as Facebook or Twitter, are American companies. As a result, you may no longer be able to easily claim or enforce your rights regarding your personal data.

Which data are processed?

Exactly which data are stored and processed depends on the respective provider of the social media platform. But usually it is data such as telephone numbers, email addresses, data you enter in contact forms, user data such as which buttons you click, what you like or who you follow, when you visited which pages, as well as information about your device and IP address. Most of this data is stored in cookies. Should you have a profile on the social media channel you are visiting and are logged in, data may be linked to your profile.

All data that are collected via social media platforms are also stored on the providers’ servers. This means that only the providers have access to the data and can provide you with appropriate information or make changes for you.

If you want to know exactly which data is stored and processed by social media providers and how you can object to the data processing, we recommend you to carefully read the privacy policy of the respective company. We also recommend you to contact the provider directly if you have any questions about data storage and data processing or if you want to assert any corresponding rights.

Duration of data processing 

Provided we have any further information on this, we will inform you about the duration of the data processing below. The social media platform Facebook example stores data until they are no longer needed for the company’s own purposes. However, customer data that is synchronised with your own user data is erased within two days. Generally, we only process personal data for as long as is absolutely necessary for the provision of our services and products. This storage period can also be exceeded however, if it is required by law, such as e.g. in the case of accounting.

Right to object

You also retain the right and the option to revoke your consent to the use of cookies or third-party providers such as embedded social media elements at any time. This can be done either via our cookie management tool or via other opt-out functions. You can e.g. also prevent data collection via cookies by managing, deactivating or erasing cookies in your browser.

Since cookies may be used with social media tools, we also recommend you to read our privacy policy on cookies. If you want to find out which of your data is stored and processed, we advise you to read the privacy policies of the respective tools.

Legal basis

If you have consented to the processing and storage of your data by integrated social media elements, this consent serves as the legal basis for data processing (Art. 6 para. 1 lit. a GDPR). Generally, provided you have given your consent, your data will also be stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f GDPR) in maintaining fast and good communication with you and other customers and business partners. Nevertheless, we only use the tools if you have consented. Most social media platforms also set cookies on your browser to store data. We therefore recommend you to read our privacy policy on cookies carefully and to take a look at the privacy policy or cookie policy of the respective service provider.

in the following section you can find information on special social media platforms – provided this information is available.

Facebook Privacy Policy

Facebook Privacy Policy Overview  👥 Affected parties: website visitors 🤝 Purpose: service optimisation 📓 Processed data: data such as customer data, data on user behaviour, device information and IP address. You can find more details in the Privacy Policy below. 📅 Storage period: until the data no longer serves Facebook’s purposes ⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What are Facebook tools?

We use selected Facebook tools on our website. Facebook is a social media network of the company Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland. With the aid of this tool we can provide the best possible offers to you and anyone interested in our products and services.

If your data is collected and forwarded via our embedded Facebook elements or via our Facebook page (fanpage), both we and Facebook Ireland Ltd. are responsible for this. However, should any further processing occur, then Facebook is solely responsible for this data. Our joint commitments were also set out in a publicly available agreement at https://www.facebook. com / legal / controller_addendum . It e.g. states that we must clearly inform you about the use of Facebook tools on our website. We are also responsible for ensuring that the tools are securely integrated into our website and are in accordance with the applicable privacy laws. Facebook, on the other hand, is e.g. responsible for the data security of Facebook’s products. If you have any questions about Facebook’s data collection and processing, you can contact the company directly. Should you direct the question to us, we are obliged to forward it to Facebook.

In the following we will give you an overview on the different Facebook tools, as well as on what data is sent to Facebook and how you can erase this data.

Along with many other products, Facebook also offers so called “Facebook Business Tools”. This is Facebook’s official name for its tools, but it is not very common. Therefore, we decided to merely call them “Facebook tools”. They include the following:

• Facebook-Pixel
• Social Plugins (e.g. the “Like” or “Share“ button)
• Facebook Login
• Account Kit
• APIs (application programming interface)
• SDKs (Softwart developmept kits)
• Plattform-integrations
• Plugins
• Codes
• Specifications
• Documentations
• Technologies and Services

With these tools Facebook can extend its services and is able to receive information on user activities outside of Facebook.

Why do we use Facebook tools on our website?

We only want to show our services and products to people who are genuinely interested in them. With the help of advertisements (Facebook Ads) we can reach exactly these people. However, to be able to show suitable adverts to users, Facebook requires additional information on people’s needs and wishes. Therefore, information on the user behaviour (and contact details) on our website, are provided to Facebook. Consequently, Facebook can collect better user data and is able to display suitable adverts for our products or services. Thanks to the tools it is possible to create targeted, customised ad campaigns of Facebook.

Facebook calls data about your behaviour on our website “event data” and uses them for analytics services. That way, Facebook can create “campaign reports” about our ad campaigns’ effectiveness on our behalf. Moreover, by analyses we can get a better insight in how you use our services, our website or our products. Therefore, some of these tools help us optimise your user experience on our website. With the social plugins for instance, you can share our site’s contents directly on Facebook.

What data is stored by Facebook tools?

With the use of Facebook tools, personal data (customer data) may be sent to Facebook. Depending on the tools used, customer data such as name, address, telephone number and IP address may be transmitted.

Facebook uses this information to match the data with the data it has on you (if you are a Facebook member). However, before the customer data is transferred to Facebook, a so called “Hashing” takes place. This means, that a data record of any size is transformed into a string of characters, which also has the purpose of encrypting data.

Moreover, not only contact data, but also “event data“ is transferred. These data are the information we receive about you on our website. To give an example, it allows us to see what subpages you visit or what products you buy from us. Facebook does not disclose the obtained information to third parties (such as advertisers), unless the company has an explicit permission or is legally obliged to do so. Also, “event data“ can be linked to contact information, which helps Facebook to offer improved, customised adverts. Finally, after the previously mentioned matching process, Facebook deletes the contact data.

To deliver optimised advertisements, Facebook only uses event data, if they have been combined with other data (that have been collected by Facebook in other ways). Facebook also uses event data for the purposes of security, protection, development and research. Many of these data are transmitted to Facebook via cookies. Cookies are little text files, that are used for storing data or information in browsers. Depending on the tools used, and on whether you are a Facebook member, a different number of cookies are placed in your browser. In the descriptions of the individual Facebook tools we will go into more detail on Facebook cookies. You can also find general information about the use of Facebook cookies at https://www.facebook.com/policies/cookies.

How long and where are the data stored?

Facebook fundamentally stores data, until they are no longer of use for their own services and products. Facebook has servers for storing their data all around the world. However, customer data is cleared within 48 hours after they have been matched with their own user data.

How can I erase my data or prevent data retention?

In accordance with the General Data Protection Regulation (GDPR) you have the right of information, rectification, transfer and deletion of your data.

The collected data is only fully deleted, when you delete your entire Facebook account. Deleting your Facebook account works as follows:

1) Click on settings in the top right side in Facebook.

2) Then, click “Your Facebook information“ in the left column.

3) Now click on “Deactivation and deletion”.

4) Choose “Permanently delete account“ and then click on “Continue to account deletion“.

5) Enter your password, click on “continue“ and then on “Delete account“.

The retention of data Facebook receives via our site is done via cookies (e.g. with social plugins), among others. You can deactivate, clear or manage both all and individual cookies in your browser. How this can be done differs depending on the browser you use. The following instructions show, how to manage cookies in your browser:

Chrome: Clear, enable and manage cookies in Chrome 

Safari: Manage cookies and website data in Safari 

Firefox: Clear cookies and site data in Firefox 

Internet Explorer: Delete and manage cookies 

Microsoft Edge: Delete cookies in Microsoft Edge 

If you generally do not want to allow any cookies at all, you can set up your browser to notify you whenever a cookie is about to be set. This gives you the opportunity to decide upon the permission or deletion of every single cookie.

Legal basis

If you have consented to your data being processed and stored by integrated Facebook tools, this consent is the legal basis for data processing (Art. 6 para. 1 lit. a GDPR). Generally, your data is also stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f GDPR) to maintain fast and good communication with you or other customers and business partners. Nevertheless, we only use these tools if you have given your consent. Most social media platforms also set cookies on your browser to store data. We therefore recommend you to read our privacy policy about cookies carefully and to take a look at the privacy policy or Facebook’s cookie policy.

Facebook processes data from you, among other things, in the USA. Facebook respectively Meta Platforms is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA. More information can be found at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Additionally, Facebook uses so-called Standard Contractual Clauses (Article 46(2) and (3) GDPR). Standard Contractual Clauses (SCC) are template clauses provided by the EU Commission and are designed to ensure that your data complies with European data protection standards, even when transferred and stored in third countries (such as the USA). Through the EU-US Data Privacy Framework and the Standard Contractual Clauses, Facebook commits to maintaining the European data protection level when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding Standard Contractual Clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.

The Facebook Data Processing Term, which references the Standard Contractual Clauses, can be found at https://www.facebook.com/legal/terms/dataprocessing.

We hope we could give you an understanding of the most important information about the use of Facebook tools and data processing. If you want to find out more on how Facebook use your data, we recommend reading the data policies at https://www.facebook.com/about/privacy/update.

Instagram Privacy Policy

Instagram Privacy Policy Overview  👥 Affected parties: website visitors 🤝 Purpose: optimising our service 📓 Processed data: includes data on user behaviour, information about your device and IP address. More details can be found in the privacy policy below. 📅 Storage period: until Instagram no longer needs the data for its purposes ⚖️ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is Instagram?

We have integrated functions of Instagram to our website. Instagram is a social media platform of the company Instagram LLC, 1601 Willow Rd, Menlo Park CA 94025, USA. Since 2012, Instagram is a subsidiary company of Facebook Inc. and is a part of Facebook’s products. The inclusion of Instagram’s contents on our website is called embedding. With this, we can show you Instagram contents such as buttons, photos or videos directly on our website. If you open websites of our online presence, that have an integrated Instagram function, data gets transmitted to, as well as stored and processed by Instagram. Instagram uses the same systems and technologies as Facebook. Therefore, your data will be processed across all Facebook firms.

In the following, we want to give you a more detailed insight on why Instagram collects data, what data these are and how you can control data processing. As Instagram belongs to Facebook Inc., we have, on the one hand received this information from the Instagram guidelines, and on the other hand from Facebook’s Data Policy.

Instagram is one of the most famous social media networks worldwide. Instagram combines the benefits of a blog with the benefits of audio-visual platforms such as YouTube or Vimeo. To “Insta“ (how the platform is casually called by many users) you can upload photos and short videos, edit them with different filters and also share them to other social networks. Also, if you do not want to be active on Instagram yourself, you can just follow other interesting users.

Why do we use Instagram on our website?

Instagram is a social media platform whose success has skyrocketed within recent years. Naturally, we have also reacted to this boom. We want you to feel as comfortable as possible on our website. Therefore, we attach great importance to diversified contents. With the embedded Instagram features we can enrich our content with helpful, funny or exciting Instagram contents. Since Instagram is a subsidiary company of Facebook, the collected data can also serve us for customised advertising on Facebook. Hence, only persons who are genuinely interested in our products or services can see our ads.

Instagram also uses the collected data for tracking and analysis purposes. We receive summarised statistics and therefore more insight to your wishes and interests. It is important to mention that these reports do not identify you personally.

What data is stored by Instagram?

Whenever you land on one of our sites, which have Instagram functions (i.e. Instagram photos or plugins) integrated to them, your browser automatically connects with Instagram’s servers. Thereby, data is sent to, as well as saved and processed by Instagram. This always happens, whether you have an Instagram account or not. Moreover, it includes information on our website, your computer, your purchases, the advertisements you see and on how you use our offer. The date and time of your interaction is also stored. If you have an Instagram account or are logged in, Instagram saves significantly more data on you.

Facebook distinguishes between customer data and event data. We assume this is also the case for Instagram. Customer data are for example names, addresses, phone numbers and IP addresses. These data are only transmitted to Instagram, if they have been “hashed” first. Thereby, a set of data is transformed into a string of characters, which encrypts any contact data. Moreover, the aforementioned “event data“ (data on your user behaviour) is transmitted as well. It is also possible, that contact data may get combined with event data. The collected data data is matched with any data Instagram already has on you.

Furthermore, the gathered data are transferred to Facebook via little text files (cookies) which usually get set in your browser. Depending on the Instagram function used, and whether you have an Instagram account yourself, the amount of data that gets stored varies.

We assume data processing on Instagram works the same way as on Facebook. Therefore, if you have an account on Instagram or have visited www.instagram.com, Instagram has set at least one cookie. If this is the case, your browser uses the cookie to send information to Instagram, as soon as you come across an Instagram function. No later than 90 days (after matching) the data is deleted or anonymised. Even though we have studied Instagram’s data processing in-depth, we cannot tell for sure what exact data Instagram collects and retains.

In the following we will show you a list of the least cookies placed in your browser when click on an Instagram function (e.g. button or an Insta picture). In our test we assume you do not have an Instagram account, since if you would be logged in to your Instagram account, your browser would place significantly more cookies.

The following cookies were used in our test:

Name: csrftoken
Value: “”
Purpose: This cookie is most likely set for security reasons to prevent falsifications of requests. We could not find out more information on it.
Expiry date: after one year

Name: mid
Value: “”
Purpose: Instagram places this cookie to optimise its own offers and services in- and outside of Instagram. The cookie allocates a unique user ID.
Expiry date: after end of session

Name: fbsr_112876210124024
Value: no information
Purpose: This cookie stores the login request of Instagram app users. 
Expiry date: after end of session

Name: rur
Value: ATN
Purpose: This is an Instagram cookie which guarantees functionality on Instagram.
Expiry date: after end of session

Name: urlgen
Value: “{”194.96.75.33”: 1901}:1iEtYv:Y833k2_UjKvXgYe112876210”
Purpose: This cookie serves Instagram’s marketing purposes.
Expiry date: after end of session

Note: We do not claim this list to be exhaustive. The cookies that are placed in each individual case, depend on the functions embedded as well as on your use of Instagram.

How long and where are these data stored?

Instagram shares the information obtained within the Facebook businesses with external partners and persons you are globally connected with. Data processing is done according to Facebook’s internal data policy. Your data is distributed to Facebook’s servers across the world, partially for security reasons. Most of these servers are in the USA.

How can I erase my data or prevent data retention?

Thanks to the General Data Protection Regulation (GDPR), you have the right of information, rectification, transfer and deletion of your data. Furthermore, you can manage your data in Instagram’s settings. If you want to delete your data on Instagram completely, you will have to delete your Instagram account permanently.

And this is how an Instagram account can be deleted:

First, open the Instagram app. Then, navigate to your profile page, select the three bars in the top right, choose “Settings” and then click “Help”. Now, you will be redirected to the company’s website, where you must click on “Managing Your Account” and then “Delete Your Account”.

When you delete your account completely, Instagram deletes posts such as your photos and status updates. Any information other people shared about you are not a part of your account and do therefore not get deleted.

As mentioned before, Instagram primarily stores your data via cookies. You can manage, deactivate or delete these cookies in your browser. Depending on your browser, managing them varies a bit. We will show you the instructions of the most relevant browsers here.

Chrome: Clear, enable and manage cookies in Chrome 

Safari: Manage cookies and website data in Safari 

Firefox: Clear cookies and site data in Firefox 

Internet Explorer: Delete and manage cookies 

Microsoft Edge: Delete cookies in Microsoft Edge 

Generally, you can set your browser to notify you whenever a cookie is about to be set. Then you can individually decide upon the permission of every cookie.

Legal basis

If you have consented to the processing and storage of your data by integrated social media elements, this consent is the legal basis for data processing (Art. 6 para. 1 lit. a GDPR) . Generally, your data is also stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f GDPR) to maintain fast and good communication with you or other customers and business partners. We only use the integrated social media elements if you have given your consent. Most social media platforms also place cookies in your browser to store data. We therefore recommend you to read our privacy policy about cookies carefully and to take a look at the privacy policy or the cookie policy of the respective service provider.

Instagram processes data from you, among other things, in the USA. Instagram respectively Meta Platforms is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA. More information can be found at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Additionally, Instagram uses so-called Standard Contractual Clauses (Article 46(2) and (3) GDPR). Standard Contractual Clauses (SCC) are template clauses provided by the EU Commission and are designed to ensure that your data complies with European data protection standards, even when transferred and stored in third countries (such as the USA). Through the EU-US Data Privacy Framework and the Standard Contractual Clauses, Instagram commits to maintaining the European data protection level when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding Standard Contractual Clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.

We have tried to give you the most important information about data processing by Instagram. On https://help.instagram.com/519522125107875 
you can take a closer look at Instagram’s data guidelines.

Online Marketing

Online Marketing Privacy Policy Overview  👥 Affected parties: visitors to the website 🤝 Purpose: Evaluation of visitor information for website optimisation 📓 Processed data: Access statistics containing data such as access location, device data, access duration and time, navigation behaviour, click behaviour and IP addresses. Personal data such as name or email address may also be processed. You can find more details on this from the respective Online Marketing tool. 📅 Storage period: depending on the Online Marketing tools used ⚖️ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is Online Marketing?

Online Marketing refers to all measures that are carried out online to achieve marketing goals, such as increasing brand awareness or doing business transactions. Furthermore, our Online Marketing measures aim to draw people’s attention to our website. In order to be able to show our offer to many interested people, we do Online Marketing. It mostly is about online advertising, content marketing or search engine optimisation. For this, personal data is also stored and processed, to enable us to use Online Marketing efficiently and targeted. On the one hand, the data help us to only show our content to people who are interested in it. On the other hand, it helps us to measure the advertising success of our Online Marketing measures.

Why do we use Online Marketing tools?

We want to show our website to everyone who is interested in our offer. We are aware that this is not possible without conscious measures being taken. That is why we do Online Marketing. There are various tools that make working on our Online Marketing measures easier for us. These also provide suggestions for improvement via data. Thus, we can target our campaigns more precisely to our target group. The ultimate purpose of these Online Marketing tools is to optimise our offer.

Which data are processed?

For our Online Marketing to work and to measure its success, user profiles are created and data are e.g. stored in cookies (small text files). With the help of this data, we can not only advertise in the traditional way, but also present our content directly on our website in the way you prefer. There are various third-party tools that offer these functions and thus collect and store your data accordingly. The aforementioned cookies e.g. store the pages you visit on our website, how long you view these pages, which links or buttons you click or which website you came from. What is more, technical information may also be stored. This may include e.g. your IP address, the browser and device you use to visit our website or the time you accessed our website as well as the time you left. If you have agreed for us to determine your location, we can also store and process it.

Your IP address is stored in pseudonymised form (i.e. shortened). What is more, distinct data that directly identify you as a person, such as your name, address or email address, are only stored in pseudonymised for advertising and Online Marketing purposes. With this data we cannot identify you as a person and only retain the pseudonymised information that is stored in your user profile.

Under certain circumstances, cookies may also be utilised, analysed and used for advertising purposes on other websites that use the same advertising tools. Thus, your data may then also be stored on the servers of the respective provider of the advertising tool.

In rare exceptions, unique data (name, email address, etc.) may also be stored in the user profiles. This can happen, if you are for example a member of a social media channel that we use for our Online Marketing measures and if the network connects previously received data with the user profile.

We only ever receive summarised information from the advertising tools we use that do store data on their servers. We never receive data that can be used to identify you as an individual. What is more, the data only shows how well-placed advertising measures have worked. For example, we can see what measures have caused you or other users to visit our website and purchase a service or product. Based on these analyses we can improve our advertising offer in the future and adapt it more precisely to the needs and wishes of people who are interested.

Duration of data processing

Below we will inform you on the duration of data processing, provided we have this information. In general, we only process personal data for as long as is absolutely necessary to provide our services and products. Data stored in cookies are retained for different lengths of time. Some cookies are deleted after you leave a website, while others may be stored in your browser for a number of years. However, in the respective privacy policies of the respective provider, you will usually find detailed information on the individual cookies this provider uses.

Right of withdrawal

You also retain the right and the option to revoke your consent to the use of cookies or third-party providers at any time. This can be done either via our cookie management tool or via other opt-out functions. You can for example also prevent data collection by cookies if you manage, deactivate or erase cookies in your browser. The legality of the processing remains unaffected to the point of revocation.

Since Online Marketing tools usually use cookies, we also recommend you to read our privacy policy on cookies. If you want to find out which of your data is stored and processed, you should read the privacy policies of the respective tools.

Legal basis

If you have consented to the use of third-party providers, then this consent is the legal basis for the corresponding data processing. According to Art. 6 para. 1 lit. a GDPR (consent) , this consent is the legal basis for personal data processing, as may be done when data is collected by online marketing tools.

Moreover, we have a legitimate interest in measuring our online marketing activities in anonymised form, in order to use this data for optimising our offer and our Marketing. The corresponding legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests) . Nevertheless, we only use these tools if you have given your consent.

Information on special online marketing tools can be found in the following sections, provided this information is available.

Google AdSense Privacy Policy

Google AdSense Privacy Policy Overview  👥 Affected parties: website visitors 🤝 Purpose: economic success and service optimisation. 📓 Processed data: Access statistics containing data such as access location, device data, access duration and time, navigation behaviour, click behaviour and IP addresses. Personal data such as name or email address may also be processed. 📅 Storage duration: depending on the cookies used and on the retained data ⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is Google AdSense?

We use Google AdSense on this website. It is an advertising program of the company Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). With Google AdSense we can show advertisements that fit our theme. Thus, we can offer you adverts that ideally give you added value. In this privacy statement on Google AdSense we will explain to you, why we use Google AdSense on our website and which of your data is processed and saved, as well as how you can prevent this data retention.

The advertising program Google AdSense has been around since 2003. As opposed to Google Ads (previously: Google AdWords) it is not possible to advertise on Google AdSense oneself. Google AdSense displays advertisements on websites, such as ours. The biggest advantage of this web service compared to some others, is that Google AdSense only shows ads to you which match our website’s contents. Google has its own algorithm which calculates what ads are shown to you. Of course, we only want to show you ads that interest you and provide you added value. Google checks which advertisements are suitable for our users, considering your interests, your user behaviour and our offer. At this point we want to mention that we are not responsible for the choice of the ads. We merely offer advertising space on our website, while Google selects the displayed ads. Moreover, since August 2013 the ads are customised to the respective user interface. This means, that no matter if you visit our website with your smartphone, your PC or your laptop, the ads adjust to your terminal device.

Why do we use Google AdSense on our website?

The operation of a high-quality website requires tremendous dedication and commitment. We are essentially never finished with working on our website. This is, because we continuously maintain and keep our website up to date. Of course, we want to achieve economic success with this work. Therefore, we decided for to use advertisements as a source of revenue. It is most important to us however, that we do not disrupt your visit to our website with these advertisements. Thence, with the aid of Google AdSense, only adverts that are tailored to you and our themes are shown.

Like with Google’s indexation for a website, a bot examines both, the matching content and the offers on our website. Then, the ads are adapted to and presented on the website. Alongside the contextual overlaps between the ads and website offer, AdSense also supports interest-based targeting. This means, that Google also uses your data to offer advertising that is tailored to you. That way you receive ads that ideally offer you added value, and it gives us a higher chance of earning a bit.

What data is stored by Google AdSense?

Google AdSense uses cookies to display ads that are customised to you. Cookies are little text files, that store certain information on your computer.

Cookies are supposed to enable improved advertisements in AdSense. They do not contain any personally identifiable data. However, it should be considered that Google does not view data such as “Pseudonymous Cookie-IDs” (name or other identification feature is replaced with a pseudonym) or IP addresses as personally identifiable information. Although, within the framework of the GDPR, this data can be classified as personal data. Following every impression (every time you see an ad), every click and any other activity that leads to a call on its servers, Google AdSense sends a cookie to the browser. The cookie is then saved in the browser, provided the browser accepts it.

Under certain circumstances, third parties can place cookies in your browser, and read them or use web beacons, to store data they receive through the display of ads on the website. Web beacons are little graphics that analyse and a record the log file. This analysis allows a statistical evaluation for the online marketing.

Through this cookie, Google can collect certain information on your user behaviour on our website. These include:

• Information on how you interact with an ad (clicks, impressions, mouse movements)
• Information if an ad has already been displayed in your browser. This data helps to prevent an ad from showing multiple times.

Thereby, Google evaluates and analyses data on the displayed advertising material along with your IP address. Primarily, Google uses the data to measure the effectiveness of an ad and improve the advertising offer. Moreover, the data does not get linked to your personal data which Google might have received via other Google services.

In the following we will introduce you to the cookies that Google AdSense uses for tracking purposes. Please note, that we will refer to a test website, which only has Google AdSense installed to it:

Name: uid
Value: 891269189112876210-8
Purpose: The cookie is stored under the domain adform.net. It provides a uniquely assigned user ID that is generated automatically and collects data on the activity on our website.
Expiry date: after 2 months

Name: C
Value: 1
Purpose: This cookie identifies if your browser accepts cookies. The cookie is stored under the domain track.adform.net.
Expiry date: after 1 month

Name: cid
Value: 8912691894970695056,0,0,0,0
Purpose: This cookie is saved under the domain track.adform.net. It stands for the client ID and is used to offer you improved advertisements. It can forward more relevant adverts to the user and helps to improve reports on campaign performance.
Expiry date: after 2 months

Name: IDE
Value: zOtj4TWxwbFDjaATZ2TzNaQmxrU112876210-1
Purpose: The cookie is stored under the domain doubleclick.net. It serves the purpose of registering your actions following an impression or a click on the ad. Thus, it can be measured how our visitors like an ad.
Expiry date: after 1 month

Name: test_cookie
Value: not specified
Purpose: With the „test_cookies“ it can be verified, if your browser even supports cookies. The cookie is saved under the domain doubleclick.net.
Expiry date: after 1 month

Name: CT592996
Value:733366
Purpose: It is saved under the domain adform.net. The cookie is placed upon your click on an ad. We could not find any further information on the use of this cookie.
Expiry date: after one hour

Note: This list does not claim to be exhaustive, as Google frequently change the choice of their cookies.

How long and where is the data stored?

Google retains your IP address, as well as various activities you perform on the website. Cookies store this information with the interactions on our website. According to Google, the company collects and saves the given information securely on its internal servers in the USA.

If you do not have a Google account or are not logged in, Google usually stores the collected data on your browser with a unique identification (ID). The IDs saved in cookies serve e.g. for providing personalised advertisements. If you are logged into a Google account, Google can gather personal information.

You can delete certain data that is saved by Google anytime (see next section). Much of the information saved in cookies get automatically deleted after a specific time. However, there are also data which are retained by Google for a longer period. This is the case, when Google must store certain data for an undefined, longer period due to economical or legal necessities.

How can I erase my data or prevent data retention?

You can always clear or deactivate cookies that are on your computer. How exactly this can be done depends on the browser.

Here you can find an instruction on how you can manage cookies in your browser:

Chrome: Clear, enable and manage cookies in Chrome 

Safari: Manage cookies and website data in Safari 

Firefox: Clear cookies and site data in Firefox 

Internet Explorer: Delete and manage cookies 

Microsoft Edge: Delete cookies in Microsoft Edge 

If you generally do not want to allow any cookies, you can set your browser to notify you whenever a potential cookie is about to be set. This lets you decide to either permit or deny the placement of every single cookie. By downloading and installing the browser plugin at https://support.google.com/ads/answer/7395996, any advertising cookies get deactivated as well. Please note, that deactivating these cookies does not stop advertisements, it only inhibits personalised adverts.

If you have a Google account, you can deactivate personalised adverts on the website https://adssettings.google.com/authenticated. You will continue to see ads, but they will stop being customised to your interests. Nevertheless, the ads are displayed based on a few factors, such as your location, the browser type and the used search terms.

Legal basis

If you have consented to the use of Google AdSense, your consent is the legal basis for the corresponding data processing. According to Art. 6 paragraph 1 lit. a (Consent) your consent is the legal basis for the processing of personal data as may occur when collected by Google AdSense.

We also have a legitimate interest in using Google AdSense to optimise our online service and our marketing measures. The corresponding legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests). Nevertheless, we only use Google AdSense if you have given your consent to it.

Google processes data from you, among other things, in the USA. Google is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA. More information can be found at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Additionally, Google uses so-called Standard Contractual Clauses (Article 46(2) and (3) GDPR). Standard Contractual Clauses (SCC) are template clauses provided by the EU Commission and are designed to ensure that your data complies with European data protection standards, even when transferred and stored in third countries (such as the USA). Through the EU-US Data Privacy Framework and the Standard Contractual Clauses, Google commits to maintaining the European data protection level when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding Standard Contractual Clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.

The Google Ads Data Processing Terms, which reference the standard contractual clauses, can be found at https://business.safety.google/intl/en/adsprocessorterms/.

You can learn more about what data Google generally collects and what they are used for at https://policies.google.com/privacy?hl=en-GB.

External Online Platforms Introduction

External Online Platforms Privacy Policy Overview  👥 Affected parties: website visitors or visitors to the external online platforms 🤝 Purpose: Presentation and optimisation of our service, as well as establishing contact with visitors & interested parties 📓 Data processed: data such as phone numbers, email addresses, contact details, user behaviour data, information about your device and your IP address. More details can be found directly with the respective platform used. 📅 Storage duration: depends on the platforms used ⚖️ Legal bases: Article 6 paragraph 1 lit. a GDPR (consent), Article 6 paragraph 1 lit. f GDPR (legitimate interests)

What are external online platforms?

In order to be able to offer our services or products outside of our website, we also use external platforms. These are mostly online marketplaces such as Amazon or eBay. In addition to our responsibility for data protection, the data privacy regulations of the external platforms used also apply. This especially applies when our products are purchased via such a platform, i. e. if there is a payment process. Furthermore, most platforms also use your data to optimise their own marketing measures. For example, the platform can use the collected data to tailor advertisements to the interests of customers and website visitors.

Why do we use external online platforms?

In addition to our website, we also want to display our offer on other platforms in order to reach more customers. External online marketplaces such as Amazon, eBay or Digistore24 offer large sales websites that show our products to people who may not know our website. Moreover, built-in elements on our site may also lead to an external online platform. Any data that is processed and stored by the respective online platform is used by the business to log the payment process and also to conduct web analyses.

The aim of these analyses is to enable the development of more precise and personal marketing and advertising strategies. Depending on your interaction with a platform, the evaluated data may be used to draw appropriate conclusions about your interests and to create a so-called user profile on you. This also allows the platforms to show customised advertisements or products to you. For this purpose, cookies are usually set in your browser in order to store data on your usage behaviour.

Please note that when using the platforms or our built-in elements, your data may also be processed outside the European Union, since online platforms such as Amazon or eBay are American companies. As a result, you may not be able to claim or enforce your rights in relation to your personal data as easily.

Which data is processed?

Exactly which data is stored and processed depends on the respective external platform. But usually, it is data such as phone numbers, email addresses, data you enter in a contact form, along with user data (e. g. which buttons you click and which pages you view during your visit), as well as information about your device and IP address. In most cases, the majority of this data is stored in cookies. If you have a profile on an external platform and are logged in there, your data can be linked to any such profile. The collected data is stored on the servers of the platforms used, where it is processed. You can find out exactly how an external platform stores, manages and processes data in the respective privacy policy. If you have any questions about data storage and data processing, or if you want to assert corresponding rights, we recommend that you contact the platform directly.

Duration of data processing

We will inform you below about the duration of data processing, provided we have further information on this. For example, Amazon stores data until it is no longer needed for its own purposes. Generally, we only process your personal data as long as is absolutely necessary for the provision of our services and products.

Right to object

You also have the right and the opportunity to revoke your consent to the use of cookies at any time. This can be done either via our cookie management tool or via opt-out functions on the respective external platform. You can also prevent data collection through cookies by managing, deactivating or erasing the cookies in your browser.

As cookies may be used, we also recommend our general privacy policy on cookies. To find out exactly which of your data is stored and processed, you should read the privacy policies of the respective external platforms.

Legal Basis

If you have consented to your data being processed and stored by external platforms, this consent is the legal basis for data processing (Art. 6 Para. 1 lit. a GDPR). In general, if you have consented, your data will also be stored and processed on the basis of our legitimate interest (Art. 6 Para. 1 lit. f GDPR) in fast and good communication with you as well as other customers and business partners. If there are integrated elements of external platforms on our website, we only use them if you have given your consent.

Information on specific external platforms – if available – can be found in the following sections.

Online Map Services Introduction

Online Map Services Privacy Policy Overview  👥 Affected parties: website visitors 🤝 Purpose: Improvement of user experience 📓 Processed data: the data that is processed depends heavily on the services used. Usually, it is your IP address, location data, search queries and/or technical data. You can find more details on this under the respective tools used. 📅 Storage duration: depends on the tools used ⚖️ Legal bases: Article 6 paragraph 1 lit. a GDPR (consent), Article 6 paragraph 1 lit. f GDPR (legitimate interests)

What are Online Map Services?

We also use online map services for our website as an extended service. Google Maps is probably the service you are most familiar with. But there are also other providers out there that specialise in creating digital maps. These services allow the display of locations, route maps or other geographical information directly via our website. Thanks to an integrated map service, you no longer have to leave our website to e. g. view the route to a location. In order to ensure that the online map can run on our website, we have integrated map sections within our HTML code. This way the services can display street maps, the earth’s surface, or aerial or satellite imagery. If you use the built-in map service, your data will be transferred to the tool used, where it will be retained. This may also include your personal data.

Why do we use Online Map Services on our website?

Generally speaking, it is imperative for us to offer you a pleasant time on our website. Of course, we know that you will most likely only enjoy your time here if you can easily find your way around and find all the information you need quickly and easily. Therefore, we decided that an online map system may be a significant optimisation of our website’s service. After all, you can use the map system to easily view route descriptions, locations or any other points of interest – without leaving our site. Needless to say, it is certainly also very practical that you can easily see where our company headquarters are so that you can find us quickly and safely. As you can see, there are just a lot of advantages – and we clearly consider online map services on our website to be part of our customer service.

What data is stored by Online Map Services?

If you open a page on our website with an online map function installed, your personal data may be transmitted to the relevant service, where it may be stored. This usually includes your IP address, which may also be used to determine your approximate location. In addition to your IP address, data such as the search terms you entered, as well as your longitude and latitude coordinates will be stored. If you e. g. enter an address for route planning, this data will also be stored. This data is not stored by us but instead on the servers of the integrated tools. You can think of it like this: You may be on our website, but when you interact with a mapping service, that interaction is actually happening on their website. Moreover, in order for the service to function properly, at least one cookie is usually set in your browser. As an example, Google Maps also uses cookies to record user behaviour, with which it can optimise its own service and offer personalised advertising. You can find out more about cookies in our “Cookies” section.

How long and where is the data stored?

Every online map service processes different user data. Provided we have further information, we will inform you about the duration of data processing in the corresponding sections on the individual tools below. Generally, personal data is only retained for as long as is necessary to provide the service. Google Maps e. g. stores certain data for a specified period of time, but you must erase other data yourself. At Mapbox, for example, your IP address is stored for 30 days after which it is deleted. As you can see, each tool stores data for different lengths of time. We thus recommend you take a closer look at the privacy policies of the tools used.

The providers may use cookies to store data on your user behaviour in relation to their map services. You can find more information about cookies in our “Cookies” section, but in the individual providers’ privacy policies you can most probably also find out which cookies may be used. In most cases, however, this is only an indicative list and is not exhaustive.

Right to object

You always have the possibility and the right to access your personal data and to object to its use and processing. You can also revoke the consent you gave to us at any time. This is usually easiest through the cookie consent tool. However, there are other opt-out tools that you can use. You can also manage, erase or deactivate any cookies set by the used providers yourself with just a few mouse clicks. However, this may lead to some service functions stopping to work as usual. It also depends on your browser how you can manage cookies there. In our “Cookies” section you will find links to instructions of the most popular browsers.

Legal Basis

If you have agreed to the use of an online map service, the legal basis for the corresponding data processing is this consent. According to Article 6 Paragraph 1 lit. (consent) this consent is the legal basis for the processing of personal data as may occur when collected by an online map service.

We also have a legitimate interest in using an online map service to optimise our service on our website. The corresponding legal basis for this is Article 6 (1) (f) GDPR (legitimate interests). However, we only use an online map service if you have given your consent. We definitely wanted to stress this point once again.

You can find information on specific online map services – if available – in the following sections.

Google Maps Privacy Policy

Google Maps Privacy Policy Overview  👥 Affected parties: website visitors 🤝 Purpose: service optimisation 📓 Processed data: data such as entered search terms, IP address as well as latitude and longitude coordinates. You can find more details on this in the Privacy Policy below. 📅 Storage duration: depending on the retained data ⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is Google Maps?

On our website we use Google Maps of the company Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). With the use of Google Maps, we can show you locations in a better way and can therefore adjust our service to your needs. Due to the utilisation of Google Maps, data gets transferred to Google and is saved on Google’s servers. In the following, we want to explain in detail what Google Maps is, why we use this Google service, what data is stored and how you can prevent this.

Google Maps is an internet maps service of the company Google Inc. With Google Maps you can search for exact locations of cities, sights, accommodations or businesses online via a PC, a tablet or an app. If businesses are represented on Google My Business, the respective location as well as other information about the company are shown there. In order to show route directions, a location’s map sections can be integrated in a website through a HTML-code. Google Maps depicts the earth’s surface as either a road map or as air and satellite images. Due to the street view and high-quality satellite images, it is possible for exact representations to be made.

Why do we use Google Maps on our website?

The efforts we make on this page have the goal of giving you a useful and meaningful experience on our website. Through the integration of Google Maps, we can offer you essential information on various locations. Therefore, you can spot our office address with one glance. Furthermore, the route directions always show you the best and fastest way to us. You can retrieve the route directions for traveling either by car, by public transport, on foot or by bike. The integration of Google Maps is a part of our customer service.

What data is stored by Google Maps?

For Google Maps to offer its full services, the company must collect and store your data. This includes your entered search terms, your IP-address as well as your longitude and latitude coordinates. When you use the route-planner function, the entered start address is stored also. However, this data retention happens on Google Maps‘ websites. We can only inform you about it but cannot influence it in any way. Since we have included Google Maps on our website, Google will set at least one cookie (Name: NID) into your browser. This cookie saves data on your user behaviour. Google primarily uses this data to optimise ist own services and to provide you with individual, personalised advertisements.

The following cookies are set in your browser due to the integration of Google Maps:

Name: NID
Value: 188=h26c1Ktha7fCQTx8rXgLyATyITJ112876210-5
Purpose: Google uses NID in order to adjust advertisments to your Google searches. With the cookie’s help Google “remembers“ your most frequently entered search queries or your previous interaction with ads. That way you always receive customised adertisments. The cookie contains a unique ID, wich Google uses to collect your personal settings for advertising porposes.
Expiration date: after 6 months

Note: We cannot guarantee completeness of the information on saved data. This is, because especially concerning the use of cookies, changes can happen anytime. To identify the cookie NID, a test page was created, to which Google Maps was included.

How long and where is the data stored?

There are Google servers in data centres across the entire planet. However, most servers are in America. For this reason, your data is widely stored in the USA. Here you can read in detail about where the Google servers are located: https://www.google.com/about/datacenters/locations/?hl=en

Google distributes data to various data carriers. This makes it possible to retrieve the data faster and to better protect it from possible attempted manipulations. Every server has emergency programs. Thus, should for example a problem with Google’s hardware occur or should a natural disaster impact the servers, any data will quite certainly stay protected.

Moreover, Google saves some data for a specified period. With some other data on the other hand, Google only offers the opportunity for deleting it manually. Furthermore, the company anonymises information (e.g. advertising data) in server logs, by deleting a part of the IP-address and cookie information after 9 to 18 months.

How can I erase my data, or prevent data retention?

Due to the automatic delete function for location and activity data, which was introduced in 2019, information that is used for determining your location and web or app activity is saved for either 3 or 18 months, depending on your preferred decision, and is deleted thereafter. Furthermore, it is possible to delete this data manually from your browser history via your Google account anytime. If you want to prevent the determination of your location altogether, you must pause the category “Web and app activity” in your Google account. Click on “Data and personalisation” and then choose the option “Activity controls”. Here you can switch the activities on or off.

Moreover, in your browser you can deactivate, delete or manage individual cookies. This function can differ a little, depending on what browser you are using. The following instructions will show you how to manage cookies in your browser:

Chrome: Clear, enable and manage cookies in Chrome 

Safari: Manage cookies and website data in Safari 

Firefox: Clear cookies and site data in Firefox 

Internet Explorer: Delete and manage cookies 

Microsoft Edge: Delete cookies in Microsoft Edge 

If you generally do not want to permit any cookies, you can set up your browser in a way that ensures you get informed whenever a cookie is about to be placed. That way you can decide to either permit or refuse every single cookie.

Please note, that when using this tool, your data may also be stored and processed outside the EU. Most third countries (including the USA) are not considered secure under current European data protection law. Data to insecure third countries must not simply be transferred to, stored and processed there unless there are suitable guarantees (such as EU Standard Contractual Clauses) between us and the non-European service provider.

Legal basis

If you have consented to the use of Google Maps, your consent is the legal basis for the corresponding data processing. According to Art. 6 paragraph 1 lit. a GDPR (consent) this consent is the legal basis for the processing of personal data, as can occur when processed by Google Maps.

We also have a legitimate interest in using Google Maps to optimise our online service. The corresponding legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests). Nevertheless, we only use Google Maps if you have given your consent to it.

Google processes data from you, among other things, in the USA. Google is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA. More information can be found at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Additionally, Google uses so-called Standard Contractual Clauses (Article 46(2) and (3) GDPR). Standard Contractual Clauses (SCC) are template clauses provided by the EU Commission and are designed to ensure that your data complies with European data protection standards, even when transferred and stored in third countries (such as the USA). Through the EU-US Data Privacy Framework and the Standard Contractual Clauses, Google commits to maintaining the European data protection level when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding Standard Contractual Clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.

The Google Ads Data Processing Terms, which reference the standard contractual clauses, can be found at https://business.safety.google/intl/en/adsprocessorterms/.

If you want to find out more about Google’s data processing, we recommend you to read the company’s own Privacy Policy at https://policies.google.com/privacy?hl=en-GB.

Online Booking Systems Introduction

Online Booking Systems Privacy Policy Overview  👥 Affected parties: website visitors 🤝 Purpose: improvement of user experience and organisation 📓 Processed data: depends heavily on the services used. Usually, data such as IP address, contact and payment details and/or technical data is processed. You can get more details on this directly from the respective tools used. 📅 Storage duration: depends on the tools used ⚖️ Legal bases: Article 6 paragraph 1 lit. a GDPR (consent), Article 6 paragraph 1 lit. f GDPR (legitimate interests)

What is an online booking system?

We use one or more booking systems which enable you to make bookings via our website. That way e.g. appointments can easily be created online. A booking system is a software application integrated into our website that displays available resources (such as available appointments) and allows you to book – and usually, also pay – directly online. You’ve probably already come across many such booking systems from the restaurant or hotel industry. However, such systems are actually used in a wide variety of industries. Depending on the tool and settings, booking systems can be used both by us internally, as well as by customers like yourself. In most cases, your personal data is also collected and stored.

Bookings usually work as follows: You will find a booking system on our website, through which you can book an appointment directly with one click. Then you will enter your data and usually also be able to pay immediately. You may also have the option to enter various information about yourself into a form. Please be aware that any information you enter may be stored and managed in a database.

Why do we use an online booking system?

In a way, we also consider our website a free service for you. We want you to receive helpful information on our site and feel comfortable on there. This also includes an online service that makes it as easy as possible for you to book appointments or services. Gone are the days when you had to wait days for booking confirmations via phone or email. With an online booking system, you can get everything done after just a few clicks and get on with your day. The system also makes it easier for us to manage all bookings and appointments. Therefore, we consider a booking system absolutely sensible for both you and ourselves.

Which data is processed?

In this general introduction about booking systems, we naturally cannot tell you exactly what data is processed for which system. It always depends on the tool used, as well as the functions and possibilities it contains. What is more, in addition to the conventional booking function, many booking systems also offer a range of other features. For example, many systems also have an external online payment system (e.g. Stripe, Klarna or Paypal) and an integrated calendar synchronisation function. Accordingly, different data and different amounts of data can be processed, depending on the included functions. Usually, data such as your IP address, name and contact details, technical device information and the time of your booking are processed. If you also make a payment via the system, your bank details such as your account number, credit card number, passwords, TANs etc. will also be stored and passed on to the respective payment provider. We recommend you carefully read the respective privacy policy of the tool used, so that you know which of your data is processed specifically.

Duration of data processing

Each booking system stores data for different lengths of time. Therefore, we cannot yet give any specific information about the duration of data processing in this instance. In general, however, personal data is only stored for as long as is absolutely necessary to provide the services. Booking systems usually also use cookies, which store information for different lengths of time. While some cookies are erased immediately after leaving the site, others can be stored for a number of years. You can find out more about this in our “Cookies” section. Please also take a look at the respective privacy policies of the providers. There you should find answers on how long your data will be stored specifically.

Right to object

If you have consented to data processing by a booking system, you always retain the option and the right to revoke this consent. So please, always be aware that you have rights in relation to your personal data and that you can exercise these rights at any time. Thus, if you do not agree to the processing of your personal data, then none of your personal data may be processed. It is that simple. The easiest way to revoke data processing is via a cookie consent tool or via other available opt-out functions. You can, for example, manage data retention by cookies directly in your browser. Until you withdraw your consent, the lawfulness of data processing remains unaffected.

Legal Basis

If you have agreed that booking systems may be used, this consent is the legal basis for the corresponding data processing. According to Article 6 (1) (a) GDPR (consent), your consent represents the legal basis for the processing of personal data, as it may occur through the use of booking systems.

Furthermore, we also have a legitimate interest in using booking systems because we use them to extend our customer service and to optimise our internal booking organisation. The corresponding legal basis for this is Article 6 (1) (f) GDPR (legitimate interests). However, we strongly want to emphasise once more that we only use these tools if you have given your consent.

You can find information on different booking systems – if available – in the following sections.

Explanation of the terminology used

We always strive to make our privacy policy as clear and comprehensible as possible. However, this is not always easy, especially when it comes to technical and legal matters. It is often sensible to use legal terms (such as ‘personal data)’ or certain technical terms (such as ‘cookies’ or ‘IP address’). But we don’t want to use such terms without any explanation. This is why you will find an alphabetical list of important terms used below. These are terms we may not yet have sufficiently explained in the privacy policy. In case we have adopted any of these terms from the GDPR which are definitions, we will also list the GDPR texts here and add our own further explanations if necessary.

Processor

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

Explanation: As a company and a website owner, we are responsible for all your data we process (i. e. the ‘controller’). In addition to the controller, there may also be so-called processors. This includes any company or person who processes personal data on our behalf. In addition to service providers such as tax consultants, processors can also be hosting or cloud providers, payment or newsletter providers or large companies such as Google or Microsoft.

Consent

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

Explanation: With websites, such consent is usually given via a cookie consent tool. You’ve most certainly come across these. Whenever you visit a website for the first time, you will usually be asked via a banner whether you agree or consent to the data processing. You can usually also make individual settings and thus decide for yourself which level of data processing you want to allow. If you do not give your consent, no personal data may be processed. Consent can of course also be given in writing, i.e. not via a tool.

Data concerning health

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“Data concerning health” means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;

Explanation: Health data includes all stored information relating to your own health. It is often data that is also noted in patient files. This includes, for example, which medication you are using, X-rays, your entire medical history or your vaccination statuses.

Personal Data

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“personenal data” means any information relating to an identified or identifiable natural person (‘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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Explanation: Personal data is all data that can identify you as a person. This is usually data such as:

• name
• address
• email address
• postal address
• phone number
• birthday
• identification numbers such as social security number, tax identification number, ID card number or matriculation number
• banking data such as account number, credit information, account balances and more.

According to the European Court of Justice (ECJ), your IP address is also personal data. IT experts can use your IP address to determine at least the approximate location of your device and subsequently your location as the connection owner. Therefore, storing an IP address also requires a legal basis within the scope of the GDPR. There are also so-called “special categories” of personal data, which are particularly worthy of protection. These include:

• racial and ethnic origin
• political opinions
• religious or ideological beliefs
• Union membership
• genetic data such as data obtained from blood or saliva samples
• biometric data (this is information about psychological, physical or behavioural characteristics that can identify an individual).
  health Data
• Data relating to sexual orientation or sex life

Profiling

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;

Explanation: Profiling collects various personal data about an individual in order to learn more about that individual. On the internet, profiling is often used for advertising purposes or for credit checks. Web and advertising analysis programs e. g. collect data about your behaviour and interests on a website. This results in a special user profile that can be used to target advertising to specific target groups.

 

Controller

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“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; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

Explanation: In our example, we are responsible for the processing of your personal data and are therefore the “controller”. If we pass on collected data to other service providers for processing, they are considered “contract processors”. For this, a “Data Processing Agreement (DPA)” must be concluded.

 

Processing

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Note: When we talk about processing in our Privacy Policy, we talk about any type of data processing. As mentioned above in the original GDPR declaration, this includes not only the collection but also the storage and processing of data.

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