Data protection
PRIVACY PROTECTION
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Introduction
With the following data protection declaration, we would like to explain to you which types of your personal data (hereinafter also referred to as "data") we process for which purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both within the framework of the provision of our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer").
The terms used are not gender specific.
As of February 23, 2022
Responsible
Lilli Le
Euckenstrasse 8c
81369 Munich
E-mail address:
Overview of processing
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
inventory data.
payment details.
Contact details.
content data.
contract data.
usage data.
Meta/Communication Data.
Event Data (Facebook).
Special Categories of Data
health data.
Categories of data subjects
Customers.
Interested persons.
communication partner.
user.
business and contractual partners.
purposes of processing
Provision of contractual services and customer service.
Contact Requests and Communication.
Safety measures.
direct marketing.
range measurement.
office and organizational procedures.
conversion measurement.
Management and response to inquiries.
feedback.
Marketing.
Profiles with user-related information.
registration procedure.
Provision of our online offer and user-friendliness.
Relevant legal bases
Below you will find an overview of the legal bases of the GDPR, on the basis of which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If more specific legal bases are relevant in individual cases, we will inform you of them in the data protection declaration.
Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR) - The person concerned has given their consent to the processing of their personal data for a specific purpose or several specific purposes.
Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR) - The processing is necessary for the fulfillment of a contract to which the data subject is a party, or for the implementation of pre-contractual measures which are required at the request of the data subject take place.
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Legal obligation (Art. 6 Para. 1 S. 1 lit. c. GDPR) - The processing is necessary to fulfill a legal obligation to which the person responsible is subject.
Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR) - Processing is necessary to safeguard the legitimate interests of the person responsible or a third party, unless the interests or fundamental rights and freedoms of the data subject, which protect personal Data require prevail.
In addition to the data protection regulations of the General Data Protection Regulation, national data protection regulations apply in Germany. This includes in particular the law on the protection against misuse of personal data in data processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (§ 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.
Safety measures
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons to ensure a level of protection appropriate to the risk.
The measures include, in particular, securing the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, disclosure, securing availability and their separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to data threats. Furthermore, we already take the protection of personal data into account when developing or selecting hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
Transmission of personal data
As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons or that it is disclosed to them. The recipients of this data can include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such a case, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.
Data processing in third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing within the framework of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies takes place, this is only done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transmission, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, if there are certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, Information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).
deletion of data
The data processed by us will be deleted in accordance with the legal requirements as soon as your consent to processing is revoked or other permissions are no longer applicable (e.g. if the purpose of processing this data no longer applies or it is not required for the purpose).
If the data is not deleted because it is required for other, legally permissible purposes, its processing will be limited to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.
Our data protection information can also contain further information on the storage and deletion of data, which apply primarily to the respective processing.
Use of cookies
Cookies are small text files or other memory notes that store information on end devices and read information from the end devices. For example, to save the login status in a user account, the content of a shopping cart in an e-shop, the content accessed or the functions used in an online offer. Cookies can also be used for various purposes, e.g. for the purpose of functionality, security and comfort of online offers as well as the creation of analyzes of visitor flows.
Notes on consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, except where not required by law. In particular, consent is not necessary if the storage and reading of the information, including cookies, is absolutely necessary in order to provide the users with a telemedia service (i.e. our online offer) that they have expressly requested. The revocable consent is clearly communicated to the users and contains the information on the respective cookie use.
Notes on legal bases under data protection law: The legal basis under data protection law on which we process the personal data of users with the help of cookies depends on whether we ask users for their consent. If the users consent, the legal basis for the processing of your data is the declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offer and improving its usability) or, if this is done in the context of fulfilling our contractual obligations, if the use of cookies is necessary to enable our to fulfill contractual obligations. We will explain the purposes for which we process cookies in the course of this data protection declaration or as part of our consent and processing processes.
Storage period: With regard to the storage period, the following types of cookies are distinguished:
Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his end device (e.g. browser or mobile application).
Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the user data collected with the help of cookies can be used to measure reach. Unless we provide users with explicit information on the type and storage period of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and the storage period can be up to two years.
General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also object to the processing in accordance with the legal requirements in Art. 21 DSGVO (further information on the objection is provided in this data protection declaration). Users can also declare their objection using the settings in their browser.
Further information on processing processes, procedures and services:
Processing of cookie data on the basis of consent: We use a cookie consent management procedure, in the context of which the user consents to the use of cookies or the processing mentioned in the context of the cookie consent management procedure and providers can be obtained and managed and revoked by the users. The declaration of consent is stored here so that the query does not have to be repeated and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies) in order to be able to assign the consent to a user or his device. Subject to individual information about the providers of cookie management services, the following information applies: The duration of the storage of the consent can be up to two years. A pseudonymous user identifier is created and stored with the time of the consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) and the browser, system and end device used.
Business Achievements
We process data from our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners") within the framework of contractual and comparable legal relationships and related measures and within the framework of communication with the contractual partners (or pre-contractual), e.g respond.
We process this data to fulfill our contractual obligations. This includes in particular the obligations to provide the agreed services, any updating obligations and remedy in the case of warranty and other service disruptions. In addition, we process the data to protect our rights and for the purpose of the administrative tasks associated with these obligations and the corporate organization. In addition, we process the data on the basis of our legitimate interests in proper and economical business management and security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. to involve telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of the applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.
We inform the contractual partners which data is required for the aforementioned purposes before or during the data collection, e.g. in online forms, by means of special markings (e.g. colours) or symbols (e.g. asterisks or similar), or personally.
We delete the data after the expiry of statutory warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g. as long as it must be kept for legal archiving reasons (e.g. for tax purposes usually 10 years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications of the order, generally after the end of the order.
Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.
customer account
Contractual partners can create an account within our online offer (e.g. customer or user account, "customer account" for short). If it is necessary to register a customer account, contractual partners will be informed of this as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. As part of the registration and subsequent registrations and uses of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove the registration and to prevent any misuse of the customer account.
If customers have terminated their customer account, the data relating to the customer account will be deleted, subject to their retention being required for legal reasons. It is the customer's responsibility to back up their data upon termination of the customer account.
Economic analysis and market research
For business reasons and in order to be able to identify market trends, the wishes of contractual partners and users, we analyze the data we have on business transactions, contracts, inquiries, etc., whereby the group of persons concerned includes contractual partners, interested parties, customers, visitors and users of our online offer can fall.
The analyzes are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). If available, we can take into account the profiles of registered users together with their information, e.g. on services used. The analyzes serve us alone and are not disclosed externally, unless they are anonymous analyzes with summarized, i.e. anonymous values. Furthermore, we take the privacy of the users into account and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as summarized data).
Store and eCommerce
We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and associated services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution for our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such in the context of the ordering or comparable acquisition process and includes the information required for delivery or provision and billing as well as contact information in order to be able to hold any consultation.
Therapeutic Services
We process the data of our clients as well as interested parties and other clients or contractual partners (uniformly referred to as "clients") in order to be able to provide them with our services. The processed data, the type, scope, purpose and necessity of their processing are determined according to the underlying contractual and client relationship.
As part of our activities, we can also collect special categories of data, in particular information about the health of the client, possibly with reference to their sex life or sexual orientation, as well as data from which racial and ethnic origin, political opinions, religious or ideological beliefs or trade union membership. To this end, we obtain the client's express consent, if necessary, and otherwise process the special categories of data if this serves the client's health, the data is public or other legal permissions exist.
If it is necessary for the fulfillment of our contract, to protect vital interests or by law, or if the client has given their consent, we disclose or transmit the client's data to third parties or agents, such as authorities, medical facilities, laboratories, Clearing houses as well as in the field of IT, office or comparable services.
meetings and events
We process the data of the participants of the events, events and similar activities offered or organized by us (hereinafter referred to as "participants" and "events") in order to allow them to participate in the events and use the services or promotions associated with participation enable.
If we process health-related data, religious, political or other special categories of data in this context, then this is done within the scope of obviousness (e.g. in the case of thematically oriented events or is used for health care, security or with the consent of those affected).
The information required is marked as such within the framework of the conclusion of the contract, order or comparable contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations. Insofar as we have access to information from end customers, employees or other persons, we process this in accordance with the legal and contractual requirements.
Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); Contact information (e.g. email, phone numbers); Contract data (e.g. subject of the contract, term, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
Special categories of personal data: Health data (Art. 9 Para. 1 GDPR).
Affected persons: customers; Interested persons; business and contractual partners.
Purposes of processing: provision of contractual services and customer service; Safety measures; contact requests and communication; office and organizational procedures; managing and responding to inquiries; Conversion measurement (measurement of the effectiveness of marketing measures); Profiles with user-related information (creating user profiles).
Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR); Legal obligation (Art. 6 Para. 1 S. 1 lit. c. GDPR).
payment procedure
As part of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the data subjects efficient and secure payment options and use other service providers in addition to banks and credit institutions (collectively "payment service providers").
The data processed by the payment service provider includes inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered will only be processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, only information with confirmation or negative information about the payment. Under certain circumstances, the payment service provider may transmit the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. For this we refer to the terms and conditions and the data protection information of the payment service provider.
The terms and conditions and data protection notices of the respective payment service providers apply to the payment transactions, which can be accessed within the respective websites or transaction applications. We also refer to this for the purpose of further information and the assertion of revocation, information and other data subject rights.
Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); Contract data (e.g. subject of the contract, term, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses); Contact information (e.g. email, telephone numbers).
Affected persons: customers; Interested persons.
Purposes of processing: Provision of contractual services and customer service.
Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Further information on processing processes, procedures and services:
Apple Pay: payment processing services; Service Provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Website: https://www.apple.com/de/apple-pay/; Data protection declaration: https://www.apple.com/legal/privacy/de-ww/.
Giropay: payment processing services; Service provider: giropay GmbH, An der Welle 4, 60322 Frankfurt, Germany; Website: https://www.giropay.de; Data protection declaration: https://www.giropay.de/rechts/datenschutzerklaerung/.
Klarna / Sofortüberweisung: payment services; Service Provider: Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden; Website: https://www.klarna.com/de; Data protection declaration: https://www.klarna.com/de/datenschutz.
Mastercard: payment processing services; Service Provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; Website: https://www.mastercard.de/de-de.html; Data protection declaration: https://www.mastercard.de/de-de/datenschutz.html.
PayPal: payment processing services (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Website: https://www.paypal.com/de; Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
Visa: payment processing services; Service Provider: Visa Europe Services Inc., London Branch, 1 Sheldon Square, London W2 6TT, UK; Website: https://www.visa.de; Data protection declaration: https://www.visa.de/bedingungen/visa-privacy-center.html.
Provision of the online offer and web hosting
In order to be able to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security and technical maintenance services.
The data processed as part of the provision of the hosting offer may include all information relating to the users of our online offer that arises in the course of use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or on websites.
Types of data processed: content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
Affected persons: users (e.g. website visitors, users of online services).
Purposes of processing: Provision of our online offer and user-friendliness; Provision of contractual services and customer service.
Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Further information on processing processes, procedures and services:
E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as other information regarding the e-mail dispatch (e.g. the providers involved) and the content of the respective e-mails are processed. The aforementioned data can also be processed for SPAM detection purposes. We ask you to note that e-mails are generally not sent in encrypted form on the Internet. As a rule, e-mails are encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. Therefore, we cannot accept any responsibility for the transmission path of the e-mails between the sender and receipt on our server.
Collection of access data and log files: We ourselves (or our web hosting provider) collect data for every access to the server (so-called server log files). The address and name of the retrieved websites and files, date and time of retrieval, amounts of data transferred, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP Addresses and the requesting provider belong. The server log files can be used on the one hand for security purposes, e.g. to avoid overloading the server (especially in the case of abusive attacks, so-called DDoS attacks) and on the other hand to ensure server utilization and stability; Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or made anonymous. Data whose further storage is required for evidence purposes are excluded from deletion until the respective incident has been finally clarified.
Content Delivery Network: We use a "Content Delivery Network" (CDN). A CDN is a service with the help of which the content of an online offer, in particular large media files such as graphics or program scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet.
Wix: hosting platform for websites; Service Provider: Wix.com Ltd., 40 Nemal St., 6350671 Tel Aviv, Israel; Website: https://de.wix.com/; Privacy Policy: https://de.wix.com/about/privacy; Order processing contract: https://www.wix.com/about/privacy-dpa-users.
Registration, login and user account
Users can create a user account. As part of the registration, the users are informed of the required mandatory information and processed for the purpose of providing the user account on the basis of contractual fulfillment of obligations. The processed data includes in particular the login information (user name, password and an e-mail address).
When using our registration and login functions and when using the user account, we store the IP address and the time of the respective user action. The storage takes place on the basis of our legitimate interests as well as those of the users in protection against misuse and other unauthorized use. In principle, this data will not be passed on to third parties, unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users can be informed by email about processes that are relevant to their user account, such as technical changes.
Types of data processed: Inventory data (e.g. names, addresses); Contact information (e.g. email, phone numbers); Content data (e.g. entries in online forms); Meta/communication data (e.g. device information, IP addresses).
Affected persons: users (e.g. website visitors, users of online services).
Purposes of processing: provision of contractual services and customer service; Safety measures; Management and response to inquiries.
Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
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Further information on processing processes, procedures and services:
Registration with pseudonyms: Users may use pseudonyms as user names instead of real names.
No storage obligation for data: It is the user's responsibility to back up their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the contract period.
community features
The community functions we provide allow users to engage in conversations or other exchanges with one another. We ask you to note that the use of the community functions is only permitted in compliance with the applicable legal situation, our conditions and guidelines as well as the rights of other users and third parties.
Types of data processed: usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
Affected persons: users (e.g. website visitors, users of online services).
Purposes of processing: provision of contractual services and customer service; Safety measures.
Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Further information on processing processes, procedures and services:
Protection of your own data: Users decide for themselves which data they disclose about themselves within our online offer. For example, when users provide information about themselves or participate in conversations. We ask users to protect their data and only publish personal data with caution and to the extent necessary. In particular, we ask users to note that they must protect the access data in a very special way and use secure passwords (i.e., above all, long and random character combinations).
Single sign-on login
"Single sign-on" or "single sign-on registration or "authentication" refers to procedures that allow users to use a user account to log in to a provider of single sign-on procedures (e.g. a social network), also with our online offer. The prerequisite for single sign-on authentication is that the user is registered with the respective single sign-on provider and enters the required access data in the online form provided for this purpose, or .are already registered with the single sign-on provider and confirm the single sign-on registration via the button.
The authentication takes place directly with the respective single sign-on provider. As part of such authentication, we receive a user ID with the information that the user is logged in to the respective single sign-on provider under this user ID and an ID that we can no longer use for other purposes (so-called "user handle "). Whether additional data is transmitted to us depends solely on the single sign-on procedure used, on the selected data releases as part of the authentication and also on what data users have in the privacy or other settings of the user account with the single sign-on provider. Depending on the single sign-on provider and the choice of the user, it can be different data, usually it is the e-mail address and the user name. The password entered during the sign-on procedure with the single sign-on provider is neither visible to us nor is it stored by us.
Users are asked to note that their information stored by us can be automatically compared with their user account with the single sign-on provider, but this is not always possible or actually takes place. If, for example, the e-mail addresses of the users change, they must change them manually in their user account with us.
If agreed with the users, we can use the single sign-on registration in the context of or before the fulfillment of the contract, insofar as the users have been asked to do so, process it within the framework of consent and otherwise use it on the basis of our legitimate interests and those of the interests of the users in an effective and secure registration system.
If users decide that they no longer want to use the connection to their user account with the single sign-on provider for the single sign-on process, they must cancel this connection within their user account with the single sign-on provider. If users want to delete their data from us, they must cancel their registration with us.
Types of data processed: Inventory data (e.g. names, addresses); Contact information (e.g. email, telephone numbers).
Affected persons: users (e.g. website visitors, users of online services).
Purposes of processing: provision of contractual services and customer service; registration procedure.
Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Further information on processing processes, procedures and services:
Apple Single Sign-On: authentication service; Service Provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Website: https://www.apple.com/de/; Data protection declaration: https://www.apple.com/legal/privacy/de-ww/.
Google single sign-on: authentication service; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://www.google.de; Privacy Policy: https://policies.google.com/privacy; Possibility of objection (opt-out): Settings for the display of advertisements: https://adssettings.google.com/authenticated.
Contact and request management
When contacting us (e.g. via contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the details of the inquiring persons are processed to the extent necessary to answer the contact inquiries and any requested measures.
The answering of contact inquiries as well as the administration of contact and inquiry data within the framework of contractual or pre-contractual relationships takes place to fulfill our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of the legitimate interests in answering the inquiries and maintenance of User or Business Relationships.
Types of data processed: Inventory data (e.g. names, addresses); Contact information (e.g. email, phone numbers); Content data (e.g. entries in online forms).
Affected persons: communication partners.
Purposes of processing: contact requests and communication; Provision of contractual services and customer service.
Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR); Legal obligation (Art. 6 Para. 1 S. 1 lit. c. GDPR).
Further information on processing processes, procedures and services:
Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context to process the communicated request. For this purpose, we process personal data within the framework of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfillment and otherwise on the basis of our legitimate interests and the interests of the communication partners in answering the concerns and our legal storage obligations.
Chatbots and Chat Features
We offer online chat and chatbot functionality (collectively, "Chat Services") as a means of communication. A chat is an online conversation conducted with a certain timeliness. A chatbot is software that answers users' questions or informs them about messages. If you use our chat functions, we can process your personal data.
If you use our chat services within an online platform, your identification number will also be stored within the respective platform. We may also collect information about which users interact with our chat services and when. Furthermore, we store the content of your conversations via the chat services and log registration and consent processes in order to be able to prove them in accordance with legal requirements.
We point out to users that the respective platform provider can find out that and when users communicate with our chat services as well as technical information on the device used by the user and, depending on the settings of their device, also location information (so-called metadata) for the purpose of optimizing the respective services and security purposes. Likewise, the metadata of the communication via chat services (i.e. e.g. the information as to who communicated with whom) could be used by the respective platform providers in accordance with their provisions, to which we refer for further information, for marketing purposes or to display advertisements tailored to users be used.
If users agree to a chatbot activating information with regular messages, they have the option to unsubscribe from the information for the future at any time. The chatbot tells users how and with which terms they can unsubscribe from the messages. By unsubscribing from the chatbot messages, user data will be deleted from the list of message recipients.
We use the above information to operate our chat services, e.g. to address users personally, to answer their inquiries, to transmit any requested content and also to improve our chat services (e.g. to chatbots answers to frequently "teach" asked questions or recognize unanswered requests).
Notes on legal bases: We use the chat services on the basis of consent if we have previously obtained the users' consent to the processing of their data in the context of our chat services (this applies to cases in which users have asked for their consent e.g. so that a chatbot can send you regular messages). If we use chat services to answer user inquiries about our services or our company, this is done for contractual and pre-contractual communication. In addition, we use chat services on the basis of our legitimate interests in optimizing the chat services, their economic efficiency and increasing the positive user experience.
Revocation, objection and deletion: You can revoke your consent at any time or object to the processing of your data in the context of our chat services.
Types of data processed: contact details (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
Affected persons: communication partners.
Purposes of processing: contact requests and communication; Direct marketing (e.g. by email or post).
Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
music and podcasts
We use hosting and analysis offers from service providers to offer our audio content for listening or download and to receive statistical information on the retrieval of the audio content.
Types of data processed: usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
Affected persons: users (e.g. website visitors, users of online services).
Purposes of processing: range measurement (e.g. access statistics, recognition of returning visitors); Conversion measurement (measurement of the effectiveness of marketing measures); Profiles with user-related information (creating user profiles).
Further information on processing processes, procedures and services:
Spotify: Spotify - music hosting and widget; Service Provider: Spotify AB, Regeringsgatan 19, SE-111 53 Stockholm, Sweden; Website: https://www.spotify.com/de; Data protection declaration: https://www.spotify.com/de/legal/privacy-policy/.
Promotional communication via e-mail, post, fax or telephone
We process personal data for the purposes of advertising communication, which can take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.
The recipients have the right to revoke their consent at any time or to object to advertising communication at any time.
After revocation or objection, we can store the data required to prove consent for up to three years on the basis of our legitimate interests before we delete them. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time.
Types of data processed: Inventory data (e.g. names, addresses); Contact information (e.g. email, telephone numbers).
Affected persons: communication partners.
Purposes of processing: direct marketing (e.g. by email or post).
Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Customer reviews and rating methods
We participate in review and rating processes to evaluate, optimize, and promote our services. If users rate us via the rating platforms or methods involved or give us feedback in any other way, the general terms and conditions of business or terms of use and the data protection notices of the providers also apply. As a rule, the evaluation also requires registration with the respective providers.
In order to ensure that the reviewers have actually used our services, we transmit the data required for this with regard to the customer and the service used to the respective rating platform (including name, e-mail address and order number or article number). This data is only used to verify the authenticity of the user.
Types of data processed: contract data (e.g. subject matter of contract, term, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
Affected persons: customers; Users (e.g. website visitors, users of online services).
Purposes of processing: feedback (e.g. collecting feedback via online form); Marketing.
Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Further information on processing processes, procedures and services:
Evaluation widget: We integrate so-called "evaluation widgets" into our online offer. A widget is a function and content element integrated into our online offer that displays variable information. It can e.g. in the form of a seal or comparable element, sometimes also " Badge". The corresponding content of the widget is displayed within our online offer, but it is retrieved from the servers of the respective widget provider at that moment. This is the only way to always show the current content, especially the respective Current rating. To do this, a data connection must be established from the website called up within our online offer to the widget provider's server and the widget provider receives certain technical data (access data, including IP address) that are necessary for the content of the widget to be displayed can be delivered to the user's browser Ter information that users have visited our online offer. This information can be stored in a cookie and used by the widget provider to identify which online offers that participate in the evaluation process have been visited by the user. The information may be stored in a user profile and used for advertising or market research purposes.
Presence in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that user data can be processed outside of the European Union. This can result in risks for users, for example because it could make it more difficult to enforce user rights.
Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created based on usage behavior and the resulting interests of users. The usage profiles can in turn be used, for example, to place advertisements inside and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behavior and the interests of the users are stored. Furthermore, data can also be stored in the usage profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
For a detailed description of the respective forms of processing and the possibility of objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.
Also in the case of requests for information and the assertion of data subject rights, we would like to point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can take appropriate measures and provide information directly. If you still need help, you can contact us.
Types of data processed: contact details (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
Affected persons: users (e.g. website visitors, users of online services).
Purposes of processing: contact requests and communication; Feedback (e.g. collecting feedback via online form); Marketing.
Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Further information on processing processes, procedures and services:
Instagram: social network; Service Provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy.
Facebook pages: Profiles within the social network Facebook - We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not further processing) of data from visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see “Things Done and Provided by You and Others” in the Facebook Data Policy: https:// www.facebook.com/policy), as well as information about the devices used by the users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under "Device information" in the Facebook data policy: https: //www.facebook.com/policy). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services called "Page Insights" to site operators so that they can gain insights into how people are using their Pages and interact with the content associated with them. We have concluded a special agreement with Facebook ("Information on Page Insights", https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook itself has declared its willingness to fulfill the rights of the data subject (i.e. users can, for example, send information or requests for deletion directly to Facebook). The rights of users (in particular to information, deletion, objection and complaints to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information on page insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data); Service Provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Standard contractual clauses (ensuring the level of data protection when processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; More information: Joint Controllership Agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data.
LinkedIn: social network; Service Provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Standard contractual clauses (ensuring the level of data protection when processing in third countries): https://legal.linkedin.com/dpa; Objection option (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out; Order processing contract: https://legal.linkedin.com/dpa.
Xing: social network; Service provider: XING AG, Dammtorstrasse 29-32, 20354 Hamburg, Germany; Website: https://www.xing.de; Data protection declaration: https://privacy.xing.com/de/datenschutzerklaerung.
Plugins and embedded functions and content
We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These can be, for example, graphics, videos or city maps (hereinafter referred to as "content" ).
The integration always presupposes that the third-party providers of this content process the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is therefore required for the display of this content or functions. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers can also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user's device and contain, among other things, technical information about the browser and the operating system, websites to be referred to, the time of the visit and other information on the use of our online offer and can also be linked to such information from other sources.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
Types of data processed: usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses); Inventory data (e.g. names, addresses); Contact information (e.g. email, phone numbers); Content data (e.g. entries in online forms); Event data (Facebook) ("Event data" is data that can be transmitted from us to Facebook, e.g. via Facebook pixels (via apps or other means) and relates to people or their actions; Data includes, for example, information about visits to websites, interactions with content, functions, installation of apps, purchases of products, etc. The event data is processed in order to form target groups for content and advertising information (custom audiences); event data do not contain the actual content (such as comments written), no login information and no contact information (i.e. no names, e-mail addresses and telephone numbers).Event data will be deleted by Facebook after a maximum of two years formed target groups with the deletion of our Facebook account).
Affected persons: users (e.g. website visitors, users of online services).
Purposes of processing: Provision of our online offer and user-friendliness; Provision of contractual services and customer service; Marketing; Profiles with user-related information (creating user profiles).
Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Further information on processing processes, procedures and services:
Facebook plugins and content: Facebook social plugins and content - This can include content such as images, videos or text and buttons with which users can share content from this online offer within Facebook. The list and appearance of Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/ - We are jointly responsible with Meta Platforms Ireland Limited for collection or receipt as part of a transmission (but not the further processing) of "event data" that Facebook collects using the Facebook social plugins (and embedding functions for content) that are executed on our online offer or receives as part of a transmission for the following purposes: a) Display of content and advertising information that match the presumed interests of users; b) Delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) Improving the delivery of ads and personalizing functions and content (e.g. improving the recognition of which content or advertising information presumably corresponds to the interests of users). We have concluded a special agreement with Facebook ("Addendum for those responsible", https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook. com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the rights of the data subject (i.e. users can, for example, send information or requests for deletion directly to Facebook). Note: If Facebook provides us with measurements, analyzes and reports (which are aggregated, i.e. do not contain any information about individual users and are anonymous to us), then this processing does not take place within the framework of joint responsibility, but on the basis of an order processing contract ("Data Processing Terms " , https://www.facebook.com/legal/terms/dataprocessing) , the "Data Security Conditions" (https://www.facebook.com/legal/terms/data_security_terms) and with regard to processing in the USA of standard contractual clauses ("Facebook-EU data transfer addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaints to the competent supervisory authority) are guaranteed by the agreements with Facebook not restricted; Service Provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https ://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy.
Google Fonts: We integrate the fonts ("Google Fonts") from the provider Google, whereby the user data is used solely for the purpose of displaying the fonts in the user's browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform representation and taking into account possible licensing restrictions for their integration; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy.
Google Maps: We integrate the maps of the service “Google Maps” from the provider Google. The processed data may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually as part of the settings on their mobile devices); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://cloud.google.com/maps-platform; Privacy Policy: https://policies.google.com/privacy; Objection option (opt-out): opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.
LinkedIn plugins and content: LinkedIn plugins and content This can include content such as images, videos or text and buttons with which users can share content from this online offer within LinkedIn; Service Provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Standard contractual clauses (ensuring the level of data protection when processing in third countries): https://legal.linkedin.com/dpa; Objection option (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out; Order processing contract: https://legal.linkedin.com/dpa.
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YouTube videos: video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Objection option (opt-out): opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.
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Xing plugins and buttons: Xing plugins and buttons - This can include content such as images, videos or text and buttons with which users can share content from this online offer within Xing; Service provider: XING AG, Dammtorstrasse 29-32, 20354 Hamburg, Germany; Website: https://www.xing.com; Data protection declaration: https://privacy.xing.com/de/datenschutzerklaerung.
Management, organization and support tools
We use services, platforms and software from other providers (hereinafter referred to as "third-party providers") for the purposes of organization, administration, planning and the provision of our services. When selecting third-party providers and their services, we observe the legal requirements.
In this context, personal data can be processed and stored on the servers of third-party providers. Various data may be affected by this, which we process in accordance with this data protection declaration. This data can include, in particular, master data and contact details of users, data on transactions, contracts, other processes and their content.
If users are referred to the third-party providers or their software or platforms as part of communication, business or other relationships with us, the third-party providers can process usage data and metadata for security purposes, for service optimization or for marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Furthermore, their use can be part of our (pre)contractual services, provided that the use of third-party providers has been agreed in this context. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
Types of data processed: content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses); Inventory data (e.g. names, addresses); Contact information (e.g. email, telephone numbers).
Affected persons: communication partners; Users (e.g. website visitors, users of online services).
Purposes of processing: contact requests and communication.
Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Further information on processing processes, procedures and services:
WeTransfer: transfer of files over the Internet; Service Provider: WeTransfer BV, Oostelijke Handelskade 751, Amsterdam, 1019 BW, The Netherlands; Website: https://wetransfer.com; Privacy Policy: https://wetransfer.com/legal/privacy.
Change and update of the privacy policy
We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as the changes in the data processing we carry out make this necessary. We will inform you as soon as the changes require your participation (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this data protection declaration, please note that the addresses can change over time and ask you to check the information before contacting us.
Rights of data subjects
As a data subject, you have various rights under the GDPR, which result in particular from Art. 15 to 21 GDPR:
Right of objection: You have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data, which is based on Article 6 Paragraph 1 lit. e or f GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed in order to operate direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct advertising.
Right of withdrawal for consent: You have the right to withdraw your consent at any time.
Right to information: You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with legal requirements.
Right to rectification: In accordance with legal requirements, you have the right to request the completion of the data concerning you or the correction of incorrect data concerning you.
Right to erasure and restriction of processing: You have the right, in accordance with the legal requirements, to request that the data concerning you be deleted immediately, or alternatively to request a restriction of the processing of the data in accordance with the legal requirements.
Right to data portability: You have the right to receive the data that you have provided to us in accordance with the legal requirements in a structured, common and machine-readable format or to request that it be transmitted to another person responsible.
Complaint to supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, your place of work or the place of the alleged infringement, if you believe that the processing of data concerning you personal data violates the provisions of the GDPR.
definitions of terms
This section provides you with an overview of the terms used in this data protection declaration. Many of the terms are taken from the law and defined above all in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended primarily for understanding. The terms are sorted alphabetically.
Conversion measurement: The conversion measurement (also known as "visit action evaluation") is a method with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the user's device within the website on which the marketing measures take place and then called up again on the target website. For example, this allows us to understand whether the ads we placed on other websites were successful.
Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special features, are an expression of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any type of automated processing of personal data that consists of using this personal data to identify certain personal aspects relating to a natural person (depending on the type of profiling, different information regarding demographics, behavior and interests, such as interaction with websites and their content, etc.) can be analyzed, evaluated or predicted (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
Range measurement: The range measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offer and can include the behavior or interests of visitors in certain information, such as website content. With the help of the range analysis, website owners can, for example, see at what time visitors visit their website and what content they are interested in. This allows them, for example, to better adapt the content of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for range analysis purposes in order to recognize returning visitors and thus obtain more precise analyzes of the use of an online offer.
Responsible: The "responsible person" is the natural or legal person, authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data.
Processing: "Processing" is any process or series of processes carried out with or without the aid of automated processes in connection with personal data. The term goes far and covers practically every handling of data, be it collection, evaluation, storage, transmission or deletion.