Privacy Policy
This Privacy Policy informs you about the type, scope and purpose of the processing of personal data (hereinafter referred to as "Data") within our Online Offer and the web pages, functions and content associated with it as well as external online presences, such as our social media profile (hereinafter collectively referred to as "Online Offer"). With regard to the terms used, such as "personal data" or their "processing", we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Person responsible:
Petronella Luiting
Made By P8
Karschau 28
24407 Rabenkirchen-Faulück
Germany
Telephone: +049-4642-965804
E-mail: petronella.luiting@t-online.de
Types of data processed:
User-related data
Contact information
Content data
Payment data
Usage data
Metadata / communication data
Processing of special categories of data (Art. 9 para. 1 GDPR): No special categories of data are processed.
Categories of data subjects:
Customers / interested parties / suppliers.
Visitors and users of the Online Offer.
In the following we refer to the data subjects collectively also as "Users".
Purpose of processing:
Provision of the Online Offer, its contents and functions.
Provision of sales, service and customer support.
Response to contact requests and communication with Users.
Marketing, advertising and market research.
Security measures.
Last updated: 07 June 2018
Applicable legal basis
In accordance with Art. 13 GDPR, we inform you of the legal basis of our data processing. If the legal basis is not mentioned in the Privacy Policy, the following applies: The legal basis for obtaining consent is Art. 6 para. 1 point (a) and Art. 7 GDPR, the legal basis for the processing for the fulfilment of our services and the execution of contractual measures as well as responding to enquiries is Art. 6 para. 1 point (b) GDPR, the legal basis for processing to fulfil our legal obligations is Art. 6 Para. 1 point (c) GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 Para. 1 point (f) GDPR. In the event that vital interests of the data subject or another natural person require a processing of personal data, Art. 6 para. 1 point (d) GDPR applies as the legal basis.
Changes and updates to the Privacy Policy
Please inform yourself regularly about the contents of our Privacy Policy. We will adapt the Privacy Policy as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
Security measures
We shall take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk, in accordance with Art. 32 GDPR, taking into account the state of the art, implementation costs and the nature, scope, circumstances and purposes of processing and the different likelihood and severity of the risk to the rights and freedoms of natural persons; the measures shall include in particular safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, transmission, security of availability and its separation. Furthermore, we have established procedures that guarantee the exercise of rights of the data subjects, deletion of Data and reaction to Data risks. Furthermore, we already consider the protection of personal Data during the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and data protection-friendly presettings (Art. 25 GDPR).
The security measures include, in particular, the encrypted transmission of Data between your browser and our server.
Cooperation with processors and third parties
If we disclose Data to other persons and companies (processors or third parties) in the context of our processing, transmit it to them or grant them access to the Data otherwise, this is done on the basis of legal permission (e.g. if transfer of the Data to third parties, such as payment service providers in accordance with Art. 6 para. 1 point (b) GDPR is required for fulfilment of the contract), you have given your consent, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we commission third parties with the processing of Data on the basis of an "order processing contract", this is done on the basis of Art. 28 GDPR.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transfer of Data to third parties, this only takes place if it occurs for the fulfilment of our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or leave the Data in a third country only in the presence of the special requirements of Art. 44 et seq. GDPR. This means, for example, processing is carried out on the basis of special guarantees, such as the officially recognised determination of a data protection level corresponding to that of the EU (e.g. for the USA by the "Privacy Shield") or compliance with officially recognised special contractual obligations ( "standard contractual clauses").
Rights of the data subjects
You have the right to request confirmation as to whether the Data concerned is being processed and to request information about this Data as well as further information and a copy of the Data in accordance with Art. 15 GDPR.
In accordance with Art. 16 GDPR, you have the right to request the completion of Data concerning you or the rectification of inaccurate Data concerning you.
In accordance with Art. 17 GDPR, you have the right to demand that relevant Data be erased immediately or, alternatively, to demand a restriction on the processing of the Data in accordance with Art. 18 GDPR.
You have the right to request that the Data concerning you that you have provided to us be received in accordance with Art. 20 GDPR and to request its transmission to other persons responsible.
According to Art. 77 GDPR you have the further right to lodge a complaint with the competent supervisory authority.
Cancellation right
You have the right to revoke your consent according to Art. 7 para. 3 GDPR with effect for the future.
Objection right
You can object to the future processing of the Data concerning you in accordance with Art. 21 GDPR at any time. The objection may be lodged in particular against processing for direct marketing purposes.
Cookies and right of objection for direct advertising
We may use temporary and permanent cookies, i.e. small files that are stored on the User's devices (explanation of the term and function, see last section of this Privacy Policy). In part, cookies serve security purposes or are required for the operation of our Online Offer (e.g. for the presentation of the website) or to save the User's decision when confirming the cookie banner. In addition, we or our technology partners use cookies to measure reach and for marketing purposes, about which the Users will be informed in the course of the Privacy Policy.
A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/ . Furthermore, the storage of cookies can be prevented by deactivating them in the browser settings. Please note that in this case it may not be possible to use all functions of this Online Offer.
Deletion of Data
The Data processed by us will be deleted or its processing restricted in accordance with Articles 17 and 18 GDPR. Unless expressly stated in this Privacy Policy, the Data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory storage obligations. If the Data is not deleted because it is necessary for other and legally permissible purposes, its processing is restricted. This means that the Data is blocked and not processed for other purposes. This applies, for example, to Data that must be retained for commercial or tax reasons.
In accordance with legal requirements, the storage is carried out in particular for 6 years in accordance with Part 257 para. 1 HGB [German Commercial Code] (trading books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting documents, etc.) as well as for 10 years according to Part 147 para. 1 AO [German General Tax Code] (books, records, management reports, accounting documents, commercial and business letters, documents relevant for taxation, etc.).
Provision of contractual services
We process user-related data (e.g. names and addresses as well as contact information of Users) and contract data (e.g. services which have been used, names of contact persons, payment information) for the purpose of the fulfilment of our contractual obligations and services in accordance with Art. 6 para. 1 point (b) GDPR. The entries marked as mandatory in online forms are required for the conclusion of the contract.
When registering, re-registering and using our online services, we store the IP address and the time of the respective user action. The Data is stored on the basis of our legitimate interests as well as for the User's protection against misuse and other unauthorised use. A transmission of this Data to third parties does not take place in principle, unless it is necessary for the pursuit of our claims or there is a legal obligation in accordance with Art. 6 para. 1 point (C) GDPR.
Deletion takes place after the expiration of statutory warranty and comparable obligations, the necessity of the storage of the Data is checked every three years; in the case of statutory archiving obligations the deletion takes place after their expiration (in commercial law (6 years) and tax law (10 years) storage obligation); details in the customer account remain up to their deletion.
Contact
When contacting us (by contact form or e-mail), the User's details for the processing of the contact enquiry and its handling are processed in accordance with Art. 6 para. 1 point (b) GDPR.
User information can be stored in our customer relationship management system or comparable request organisation.
We delete the requests if they are no longer necessary. We review the requirement every two years; requests from customers who have a customer account are stored permanently and are linked to the customer account details for deletion. In the case of statutory archiving obligations, the deletion takes place after their expiry (in commercial law (6 years) and tax law (10 years) storage obligation).
Comments and contributions
If users leave comments or other contributions, their IP address will be stored for 7 days on the basis of our legitimate interests pursuant to Art. 6 para. 1 point (f) GDPR.
This takes place for our security, in case someone leaves unlawful content (insults, forbidden political propaganda, etc.) in comments and contributions. In this case we can ourselves be prosecuted for the comment or contribution and are, therefore, interested in the identity of the author.
Collection of access data and log files
We collect, on the basis of our legitimate interests as defined in Art. 6 para. 1 point (f) GDPR, data on each access to the server on which this service is located (so-called server log files). Access data includes the name of the requested website, file, date and time of access, volume of data transferred, notification of successful retrieval, browser type along with version, the operating system of the user, referrer URL (previously visited page), IP address, and the requesting provider.
Log file information is stored for a maximum of seven days for security reasons (e.g. to investigate misuse or fraud) and then deleted. Data whose further storage is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
Online presence in social media
We maintain online presence within social networks and platforms in order to communicate with customers, interested parties and active users and to inform them about our services. When calling the respective networks and platforms, the terms and conditions and the data processing guidelines apply to their respective operators.
Unless otherwise stated in our Privacy Policy, we process Users' Data as long as they communicate with us within social networks and platforms, e.g. write posts on our online presence or send us messages.
Cookies & reach measurement
Cookies are information that is transferred from our web server or third-party web servers to the User's web browser and stored there for later retrieval. Cookies can be small files or other types of information storage.
We may use "session cookies" which are only stored on our website for the duration of your current visit (e.g. in order to store your login status or the shopping cart function and, therefore, enable the use of our Online Offer at all). A randomly generated unique identification number, a so-called session ID, is stored in a session cookie. A cookie also contains information about its origin and the storage period. These cookies cannot store any other data. Session cookies are deleted when you have finished using our Online Offer and log out or close your browser, for example.
Users will be informed about the use of cookies in the context of pseudonymous reach measurement within the scope of this Privacy Policy.
If Users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Cookies already saved can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this Online Offer.
You can object to the use of cookies for reach measurement and advertising purposes via the deactivation page of the network advertising initiative (http://optout.networkadvertising.org/) and additionally the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).
Google Analytics
We may use on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our Online Offer within the meaning of Art. 6 para. 1 point (f) GDPR) Google Analytics, a web analytics service of Google LLC ("Google"). Google uses cookies. The information generated by the cookie about the User's use of the Online Offer is generally transmitted to and stored on a Google server in the USA.
Google is certified under the Privacy Shield Agreement, thereby guaranteeing compliance with European data protection laws (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our Online Offer by the User, to compile reports on the activities within this Online Offer and to provide us with other services related to the use of this Online Offer and the Internet. Pseudonymous usage profiles of Users may be created from the processed Data in this respect.
We use Google Analytics to display advertisements displayed within Google and its affiliate advertising services only to those Users who have shown an interest in our Online Offer or who have certain characteristics (e.g. interests in specific topics or products determined by the web pages visited by them) that we submit to Google (so-called “remarketing” or “Google Analytics audiences”). With the assistance of Remarketing Audiences we want to also ensure that our ads are in keeping with the Users’ possible interests, rather than being seen as a nuisance.
We only use Google Analytics with activated IP anonymisation. This means that Google truncates the IP addresses of Users within the member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and be truncated there.
The IP address transmitted by the User's browser is not associated with any other data held by Google. The Users can prevent cookies from being stored using the appropriate settings of their browser software; the Users can likewise prevent Google from collecting and processing the Data generated by cookies relating to their use of the Online Offer by downloading and installing the browser plug-in which is available via the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
More information on Google’s data usage and your browser setting and revocation options can be found on the following Google websites: https://www.google.com/intl/de/policies/privacy/partners ("How Google uses information from sites or apps that use our services"), https://policies.google.com/technologies/ads ("Use of data for advertising purposes"), https://adssettings.google.com/authenticated ("Control the information Google uses to show you ads").
Google remarketing/marketing services
We may use on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our Online Offer as defined in Art. 6 para. 1 point (f) GDPR) the marketing and remarketing services (‘Google Marketing Services’ for short) of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (‘Google’).
Google is certified under the Privacy Shield Agreement, thereby guaranteeing compliance with European data protection laws (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google Marketing Services allow us to show ads for and on our website in a more targeted manner, showing Users only those ads that are potentially of interest to them. If a User is shown ads for products in which they showed an interest on other websites, this is known as remarketing. To this end, Google executes a code as soon as a User views our website or other websites for which Google Marketing Services have been activated, thereby incorporating so-called (re)marketing tags (invisible graphics or code, also referred to as web beacons) into the website. This allows a customised cookie, i.e. a small file, to be stored on the User’s device (comparable technologies may also be used instead of cookies). The cookies can be placed by various domains including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file records which web sites the User visits, what Content they express an interest in and which offers they click on, together with technical information relating to the browser and operating system, the referrer URL, the visit time and other details regarding use of the Online Offer. The User’s IP address is likewise logged; please note that with regard to Google Analytics, IP addresses within member states of the European Union or in other signatory states to the Agreement on the European Economic Area are truncated and are only transmitted to a Google server in the USA in exceptional cases and then truncated. The User’s IP address is not combined with other User Data within other Google services. Google may combine the aforementioned information with such information from other sources. When Users subsequently visit other websites, they can be shown ads which are tailored to their interests.
The User’s details are processed within the Google Marketing Services using pseudonyms. In other words, Google does not record or process the User’s name or email address, for example, and instead processes the relevant Data within pseudonym-based user profiles using cookies. This means the ads are not managed for and shown to a specifically identifiable person from Google’s perspective, but for and to the cookie owner irrespective of who this cookie owner is. This does not apply if the User has explicitly allowed Google to process their Data without this pseudonymisation. The information collected by the Google Marketing Services regarding a User is sent to Google and stored on Google servers in the USA.
The Google Marketing Services used by us include the online ad program Google AdWords. With Google AdWords, each AdWords customer is assigned a different conversion cookie.. Cookies can, therefore, not be traced via the websites of AdWords customers. The information collected with the aid of the cookie is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. The AdWords customers learn the total number of Users who clicked on their ad and who were forwarded to a website featuring a conversion tracking tag. They do not, however, receive any information with which a User can be personally identified.
We can also use the Google Optimizer service. Google Optimizer allows us to understand, in the context of so-called "A/B testing", how different changes have an impact on a website (e.g. changes to the input fields, design etc.). Cookies are stored on the Users' devices for testing purposes. Only pseudonymous User Data is processed.
We can additionally use Google Tag Manager to incorporate Google’s analysis and marketing services into our website and manage them.
More information on Google’s use of Data for marketing purposes can be found on this overview page: https://policies.google.com/technologies/ads Google’s Privacy Policy can be found at https://policies.google.com/privacy
If you wish to revoke your consent to interest-based advertising by the Google Marketing Services, you can do so using the settings and opt-out options offered by Google: https://adssettings.google.com/authenticated .
Facebook, Custom Audiences and Facebook Marketing services
Our Online Offer may use on the basis of our legitimate interests in the analysis, optimisation and economic operation of our Online Offer the so-called Facebook Pixel belonging to the social network Facebook, which is run by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are resident in the EU, by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”).
Facebook is certified under the Privacy Shield Agreement, thereby guaranteeing compliance with European data protection laws (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
The Facebook Pixel enables Facebook to identify visitors to our Online Offer as the target group for the presentation of so-called Facebook Ads. Accordingly, we use the Facebook Pixel to present the Facebook Ads placed by us only to those Facebook users who have also expressed an interest in our Online Offer or who have certain characteristics (e.g. interests in specific topics or products determined by the web pages visited by them) that we submit to Facebook (so called “Custom Audiences”). With the assistance of the Facebook Pixel we want to also ensure that our Facebook Ads are in keeping with the Users’ possible interests, rather than being seen as a nuisance. Additionally, the Facebook Pixel allows us to understand the effectiveness of Facebook Ads for statistical and market research purposes by allowing us to see whether Users were taken to our website upon clicking on a Facebook Ad (so-called Conversion).
Facebook processes the Data in accordance with its data policy. Accordingly, general information on the presentation of Facebook Ads can be found in Facebook’s data policy: https://www.facebook.com/policy.php. For specific information and details about the Facebook Pixel and how it works, visit the help section of Facebook: https://www.facebook.com/business/help/651294705016616.
You may revoke your consent to the Facebook Pixel collecting data and using it to present Facebook Ads. To set which types of ads are displayed to you within Facebook you can access the page created by Facebook and follow the instructions there regarding the settings for use-based advertising: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e. they are applied to all devices such as desktop computers and mobile devices.
You can also object to the use of cookies for reach measurement and advertising purposes via the deactivation page of the network advertising initiative (http://optout.networkadvertising.org/) and additionally the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).
Facebook Social Plugins
We use on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our Online Offer as defined in Art. 6 para. 1 point (f) GDPR) the Social Plugins (‘Plugins’) of the social network facebook.com, which is run by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The plug-ins can comprise interaction elements or contents (e.g. videos, graphics or text contributions) and can be recognised by one of the Facebook logos (e.g. white "f" on a blue tile, the terms “Like”, or a thumbs up sign) or feature the phrase “Facebook Social Plug-In”. A list of and the appearance of Facebook Social Plugins can be found here: https://developers.facebook.com/docs/plugins/.
Facebook is certified under the Privacy Shield Agreement, thereby guaranteeing compliance with European data protection laws (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
When a User accesses a function of this Online Offer containing such a Plugin, their device establishes a direct link with Facebook’s servers. The Plugin contents are sent directly to the User’s device by Facebook and are incorporated into the Online Offer by the device. Usage profiles of Users may be created from the processed Data in this respect. We, therefore, have no control over the volume of Data collected by Facebook with the aid of this Plugin and, therefore, notify the Users on the basis of what we know.
When the Plugins are incorporated, Facebook is notified when a User views the corresponding page of the Online Offer. If the User is logged in to Facebook, Facebook can assign this visit to their Facebook account. If Users interact with the Plugins, for example by clicking on the ‘Like’ button or adding a comment, the relevant information is sent directly to Facebook by their device and saved there. If the User is not a member of Facebook, Facebook is nevertheless able to determine and log their IP address. According to Facebook, only anonymised IP addresses are logged in Germany.
Users can learn about the purpose and extent of Facebook’s data collection and its further processing and use, and about the corresponding rights and settings for the protection of their privacy in Facebook’s data privacy notice: https://www.facebook.com/about/privacy/.
If a User is a Facebook member and does not wish Facebook to collect Data on them via this Online Offer or combine such Data with their Facebook membership details, they must log out of Facebook prior to using our Online Offer and must delete their cookies. Other settings can be selected and consents to the use of Data for advertising purposes revoked within the Facebook profile settings at: https://www.facebook.com/settings?tab=ads or via the US website http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are applied to all devices such as desktop computers and mobile devices.
Incorporation of third-party services and contents
On the basis of the legitimate interests (interest in the analysis, optimisation and economic operation of our Online Offer as defined in Art. 6 para. 1 point(f) GDPR), contents and service offers from third parties may be used within our Online Offer to integrate their contents and services, such as videos or fonts (hereinafter collectively referred to as “Content”). This is always subject to the third-party supplier being aware of the User’s IP address, as they are unable to send Content to the User’s browser without an IP address. The User’s IP address is, therefore, required in order for the Content to be shown. We endeavour to only use Content from providers who only use the IP addresses to deliver the respective Content. Third-party providers may also use pixel tags (invisible graphics, also known as web beacons) for statistical or marketing purposes. Pixel tags allow information, such as our website’s traffic, to be evaluated. In addition, the pseudonymous information may be stored in cookies on the User's device and may include, but is not limited to, technical information about the browser and the operating system, referring websites, time of visit, and other information regarding the use of our Online Offer and be linked to such information from other sources.
The following statement provides an overview of third-party providers as well as their contents and links to their privacy policies, which contain further information on data processing and rights of revocation, some of which were mentioned above (so-called opt-outs):
If our customers make use of third-party payment services (e.g. PayPal or "immediate transfer" - an online payment system, the terms and conditions and privacy notices of the respective third-party providers apply, these can be viewed within the respective websites or transaction applications.
Maps provided by the Google Maps service of third-party provider Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
Videos on the YouTube platform of the third-party supplier Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://policies.google.com/privacy, Opt-out: https://adssettings.google.com/authenticated.
Within our Online Offer, functions of the service or Twitter platform (hereinafter referred to as “Twitter”) may be incorporated. Twitter is offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The functions include the presentation of our posts within Twitter within our Online Offer, the link to our profile in Twitter and the possibility to interact with the posts and functions of Twitter, and to measure whether users reach our Online Offer via the ads placed by us in Twitter (so-called conversion tracking). Twitter is certified under the Privacy Shield Agreement, thereby guaranteeing compliance with European data protection laws (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active). Privacy policy: https://twitter.com/de/privacy, Opt-out: https://twitter.com/personalization.