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Privacy policy

 

 

 

Introduction

With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as "data" for short) that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part 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 the "Online Offer").

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Status: 13 August 2019

 

Table of Contents

Introduction

Person responsible

narz systems GmbH & Co KG Am Bonnerod 1 36358 Herbstein

 

Contact Data Protection Coordinator

Waldemar Heinrich, B.Sc. datenschutz@narz.net

 

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 (e.g. names, addresses).
  • Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, curriculum vitae, certificates, as well as other information provided with regard to a specific position or voluntarily by applicants regarding their person or qualifications).
  • Content data (e.g. text entries, photographs, videos).
  • Contact data (e.g. e-mail, telephone numbers).
  • Meta/communication data (e.g., device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Contract data (e.g. subject matter of contract, term, customer category).
  • Payment data (e.g. bank details, invoices, payment history).
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Categories of data subjects

  • Employees (e.g. employees, applicants, former employees).
  • Applicants.
  • Business and contractual partners.
  • Interested parties.
  • Communication partners.
  • customers.
  • Users (e.g. website visitors, users of online services).
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Purposes of the processing

  • Provision of our online offer and user friendliness.
  • Visitor action evaluation.
  • Application procedure (establishment and possible subsequent implementation as well as possible subsequent termination of the employment relationship.).
  • Office and organisation procedures.
  • Direct marketing (e.g. by e-mail or postal mail).
  • Feedback (e.g. collecting feedback via online form).
  • Interest-based and behavioural marketing.
  • Contact requests and communication.
  • Conversion measurement (measuring the effectiveness of marketing activities).
  • Profiling (creating user profiles).
  • Remarketing.
  • Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures.
  • Tracking (e.g. interest/behavioural profiling, use of cookies).
  • Contractual performance and service.
  • Administration and response to inquiries.

 

Applicable legal basis

In the following, we share the legal bases of the General Data Protection Regulation (DSGVO) on the basis of which we process personal data. Please note that in addition to the regulations of the DSGVO, the national data protection regulations in your or our country of residence and domicile may apply.

 

  • Consent (Art. 6 (1) p. 1 lit. a DSGVO)- The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
  • Performance of a contract and pre-contractual enquiries (Art. 6 (1) p. 1 lit. b. DSGVO)- Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures carried out at the data subject's request.
  • Legal obligation (Art. 6 (1) p. 1 lit. c. DSGVO)- Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Protection of vital interests (Art. 6 (1) p. 1 lit. d. DSGVO)- Processing is necessary to protect the vital interests of the data subject or another natural person.
  • Legitimate interests (Art. 6 (1) p. 1 lit. f. DSGVO)- Processing is necessary to protect the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
  • Art. 9 (1) p. 1 lit. b DSGVO (application procedure as a pre-contractual or contractual relationship) (Insofar as special categories of personal data within the meaning of Art. 9 (1) DSGVO (e.g.. health data, such as severely disabled status or ethnic origin) are requested from applicants so that the controller or the data subject can exercise the rights accruing to him or her under employment law and social security and social protection law and fulfil his or her obligations in this regard, their processing is carried out in accordance with Art. 9 (2) lit. b. DSGVO, in the case of the protection of vital interests of the applicants or other persons pursuant to Art. 9 para. 2 lit. c. DSGVO or for the purposes of preventive health care or occupational medicine, for the assessment of the employee's fitness for work, for medical diagnostics, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 para. 2 lit. h. DSGVO. In the case of communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 para. 2 lit. a. DSGVO. DSGVO.)- .
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National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on 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, the processing for other purposes and the transmission as well as automated decision-making in individual cases including profiling. Furthermore, it regulates data processing for employment purposes (Section 26 BDSG), in particular with regard to the establishment, performance or termination of employment relationships as well as the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

 

Security 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 nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. We also have procedures in place to ensure the exercise of data subjects' rights, the deletion of data, and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

 

SSL encryption (https): In order to protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.

 

Transmission and disclosure of personal data

In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. Recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of 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 takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies, this will only be done in accordance with the legal requirements.

 

Subject to express consent or contractually or legally required transfer, we process or have the data processed only in third countries with a recognized level of data protection, which include the US processors certified under the "Privacy Shield", or on the basis of special guarantees, such as contractual obligation by so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection rules (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 ).

 

Use of cookies

Cookies" are small files that are stored on users' devices. Various data can be stored by means of cookies. The information can include, for example, the language settings on a website, the login status, a shopping cart or where a video was watched.

 

Cookies are also generally used when a user's interests or behaviour (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that matches their potential interests. This process is also referred to as "tracking", i.e., tracking the potential interests of users. We also include in the term cookies other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also referred to as "user IDs").

 

Insofar as we use cookies or "tracking" technologies, we will inform you separately in our data protection declaration.

 

Notes on legal basis:The legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is your declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfil our contractual obligations.

 

Revocation and objection (opt-out):Regardless of whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent you have given or to object to the processing of your data by cookie technologies (collectively referred to as "opt-out").

 

You can initially declare your objection by means of your browser settings, e.g. by deactivating the use of cookies (whereby this may also restrict the functionality of our online offer).

 

An objection to the use of cookies for online marketing purposes can bedeclared

by means of a variety of services, especially in the case of tracking, via the US-American site www.aboutads.info/choices/

or

the EU site www.youronlinechoices.com

or generally onhttp://optout.aboutads.info.

 

Processing of cookie data on the basis of consent: Before we process or have processed data in the context of the use of cookies, we ask users for consent that can be revoked at any time. Before consent has been given, cookies are only used if they are necessary for the operation of our online offer. Their use is based on our interest and the interest of the users in the expected functionality of our online offer.

 

  • Types of data processed: usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: users (e.g. website visitors, users of online services).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
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Commercial and business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners") in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer inquiries.

 

We process this data to fulfil our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as for business organisation. Within the framework of the applicable law, we only pass on the data of the contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or with the consent of the contractual partners (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about further 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 in the course of data collection, e.g. in online forms, by means of special marking (e.g. colours) or symbols (e.g. asterisks or similar), or in person.

 

We delete the data after expiry of legal warranty and comparable obligations, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. as long as it must be kept for legal archiving reasons (e.g. for tax purposes generally 10 years). We delete data disclosed to us by the contractual partner within the scope 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.

 

Craft services: We process the data of our customers as well as clients (hereinafter uniformly referred to as "Customers") in order to enable them to select, purchase or commission the selected services or works as well as related activities as well as their payment and delivery or execution or performance.

 

The required information is identified as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for delivery and billing as well as contact information in order to be able to hold any consultations.

 

Offer of software and platform services: We process the data of our users, registered users and any test users (hereinafter uniformly referred to as "users") in order to be able to provide our contractual services to them as well as on the basis of legitimate interests in order to ensure the security of our offer and to be able to develop it further. The required information is identified as such in the context of the order, purchase order or comparable contract conclusion 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.

 

Technical services: We process the data of our customers as well as clients (hereinafter uniformly referred to as "customers") in order to enable them to select, acquire or commission the selected services or works as well as related activities as well as their payment and delivery or execution or performance.

 

The information required is identified as such in the context of the conclusion of the order, purchase order or similar contract and includes the details required for the provision of the service and invoicing, as well as contact information in order to be able to hold any consultations.

 

  • Types of data processed: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of contract, term, customer category).
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  • Data subjects: prospective customers, business and contractual partners.
  • Purposes of processing: Contractual performance and service, contact requests and communication, office and organizational procedures, administration and response to requests.
  • Legal basis: Contractual performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
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Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data are processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. In all other respects, please refer to the information on the processing of visitors to our Publication Medium within this Privacy Notice.

 

Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.

 

Furthermore, we reserve the right, on the basis of our legitimate interests, to process users' details for the purpose of spam detection.

 

On the same legal basis, we reserve the right, in the case of surveys, to store the IP addresses of users for their duration and to use cookies to avoid multiple votes.

 

The personal information provided in the context of comments and contributions, any contact and website information as well as the content-related information will be permanently stored by us until the user objects.

 

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: users (e.g. website visitors, users of online services).
  • Purposes of processing: contractual performance and service, feedback (e.g. collecting feedback via online form), security measures, managing and responding to requests.
  • Legal basis: Contractual performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO), Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Protection of Vital Interests (Art. 6 para. 1 p. 1 lit. d. DSGVO).
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Contacting

When contacting us (e.g. via contact form, email, telephone or via social media), the information provided by the inquiring person is processed to the extent necessary to respond to the contact requests and any measures requested.

 

The response to the contact requests in the context of contractual or pre-contractual relationships is carried out to fulfil our contractual obligations or to respond to (pre)contractual requests and otherwise on the basis of legitimate interests in responding to the requests.

 

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos).
  • Data subjects: communication partners.
  • Purposes of processing: contact requests and communication.
  • Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
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Provision of the online offer and web hosting

In order 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 services and technical maintenance services.

 

The data processed in the course of providing the hosting service may include all information relating to the users of our online service that is generated in the course of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

 

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 further information concerning the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of identifying SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, 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 assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.

 

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

 

The server log files may be used for security purposes, e.g. to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and to ensure server utilization and stability.

 

  • Types of data processed: content data (e.g. text entries, photographs, videos), usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: users (e.g. website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
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Application procedure

The application procedure requires that applicants provide us with the data necessary for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the details provided there.

 

In principle, the required information includes personal details such as name, address, contact details and proof of the qualifications required for a position. Upon request, we will be happy to provide additional information as to which details are required.

 

If provided, applicants can submit their applications to us using an online form. The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications by e-mail. Please note, however, that e-mails sent via the Internet are generally not encrypted. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of the application between the sender and receipt on our server.

 

For the purposes of applicant search, submission of applications and selection of applicants, we may make use of third party applicant management, or recruitment software and platforms and services, subject to legal requirements.

 

Applicants are welcome to contact us regarding the method of submission of the application or to send us the application by post.

 

Processing of special categories of data: Insofar as special categories of personal data within the meaning of Art. 9 (1) DSGVO (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants as part of the application process, in order for the controller or the data subject to fulfil the obligations incumbent on him or her under employment law and the law of the country in which he or she is employed. If the data subject is asked to provide information about his or her health, such as severe disabilities or ethnic origin, in order for the data controller or the data subject to exercise his or her rights under employment, social security and social protection law and to comply with his or her obligations in this regard, the processing of such information is carried out in accordance with Article 9(2)(b) of the GDPR. DSGVO, in the case of the protection of vital interests of the applicants or other persons pursuant to Art. 9 para. 2 lit. c. DSGVO or for the purposes of preventive health care or occupational medicine, for the assessment of the employee's fitness for work, for medical diagnostics, for care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 para. 2 lit. h. DSGVO. In the case of a communication of the special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 (2) lit. a. DSGVO.

 

Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is not successful, the applicants' data will be deleted. Applicants' data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. The deletion will take place, subject to legitimate withdrawal by applicants, no later than the expiry of a period of six months to enable us to answer any follow-up questions about the application and to meet our obligations to provide evidence under the Equal Treatment of Applicants Regulations. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements.

 

Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the current application process and that they can revoke their consent at any time for the future.

 

Duration of data retention in the applicant pool in months: 2 years

 

  • Types of data processed: Applicant data (e.g. personal details, postal and contact addresses, the documents relating to the application and the information contained therein, such as cover letter, CV, certificates and other information relating to a specific position or voluntarily provided by applicants on their person or qualifications).
  • Data subjects: applicants.
  • Purposes of processing: Application procedure (establishment and possible subsequent implementation as well as possible subsequent termination of the employment relationship).
  • Legal basis: Art. 9 para. 1 p. 1 lit. b DSGVO (application procedure as a pre-contractual or contractual relationship) (Insofar as special categories of personal data within the meaning of Art. 9 para. 1 DSGVO (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants so that the controller or the data subject can exercise the rights accruing to him or her under employment law and social security and social protection law and fulfil his or her obligations in this regard, their processing is carried out in accordance with Art. 9 (2) lit. b. DSGVO, in the case of the protection of vital interests of the applicants or other persons pursuant to Art. 9 para. 2 lit. c. DSGVO or for the purposes of preventive health care or occupational medicine, for the assessment of the employee's fitness for work, for medical diagnostics, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 para. 2 lit. h. DSGVO. In the case of communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 para. 2 lit. a. DSGVO).
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Cloud services

We use software services accessible via the Internet and running on the servers of their providers (so-called "cloud services", also referred to as "software as a service") for the following purposes: document storage and management, calendar management, e-mailing, spreadsheets and presentations, exchange of documents, content and information with specific recipients or publication of web pages, forms or other content and information, as well as chats and participation in audio and video conferences.

In this context, personal data may be processed and stored on the providers' servers to the extent that such data is part of communication processes with us or is otherwise processed by us as set out in this Privacy Policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents. The cloud service providers also process usage data and metadata used by them for security purposes and service optimization.

 

If we use the cloud services to provide forms or other documents and content to other users or publicly accessible websites, the providers may store cookies on the users' devices for the purposes of web analysis or to remember the users' settings (e.g. in the case of media control).

 

Notes on legal bases: where we ask for consent to use cloud services, the legal basis for processing is consent. Furthermore, their use may be a component of our (pre)contractual services, provided that the use of the cloud services has been agreed within this framework. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient and secure management and collaboration processes)

 

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: customers, employees (e.g. employees, applicants, former employees), prospective customers, communication partners.
  • Purposes of processing: office and organisational procedures.
  • Legal bases: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
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Services used and service providers:

 

Newsletter and broad communication

We send newsletters, e-mails and other electronic notifications (hereinafter "newsletter") only with the consent of the recipients or a legal permission. If the contents of the Newsletter are specifically described in the course of a registration, they are decisive for the consent of the users. Apart from that, our newsletters contain information about our services and us.

 

In order to subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name, for the purpose of a personal address in the newsletter, or further details, if these are necessary for the purposes of the newsletter.

 

Double-Opt-In-Procedure: The registration for our newsletter is always done in a so-called Double-Opt-In-Procedure. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The registrations to the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise, changes to your data stored with the dispatch service provider are logged.

 

Deletion and restriction of processing: Wemay store unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that consent was previously given. Processing of this data will be limited to the purpose of possible defence of claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a blacklist for this purpose alone.

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

 

Notes on legal basis: The newsletter is sent on the basis of the recipients' consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of advertising to existing customers. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to demonstrate that it has been carried out in accordance with the law.

 

Content: Information about us, our services, promotions and offers.

 

Performance measurement: The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened, or, if we use a shipping service provider, from their server. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and the time of the retrieval, are initially collected.

 

This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor, if used, that of the dispatch service provider to observe individual users. The evaluations serve us rather to recognize the reading habits of our users and to adapt our contents to them or to send different contents according to the interests of our users.

 

The evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves both our business interests and meets the expectations of the users.

 

Unfortunately, a separate revocation of the performance measurement is not possible, in which case the entire newsletter subscription must be cancelled, or it must be contradicted.

 

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
  • Data subjects: communication partners.
  • Purposes of processing: direct marketing (e.g. by e-mail or post).
  • Legal grounds: consent (Art. 6 para. 1 p. 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
  • Opt-out: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the above contact options, preferably e-mail, for this purpose.
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Online marketing

We process personal data for online marketing purposes, including but not limited to the display of promotional and other content (collectively, "Content") based on potential user interests and measuring its effectiveness.

 

For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar procedures are used, by means of which the information about the user relevant to the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed.

 

The IP addresses of users are also stored. However, we use IP masking procedures (i.e., pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that we, as well as the providers of the online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles.

 

The information in the profiles is usually stored in cookies or by means of similar procedures. These cookies can later generally be read on other websites that use the same online marketing procedure and analysed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.

 

Exceptionally, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing procedure we use and the network links the profiles of the users in the aforementioned data. We ask you to note that users may enter into additional agreements with the providers, e.g. by giving their consent as part of the registration process.

 

In principle, we only receive access to summarized information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to a conclusion of a contract with us. The conversion measurement is used solely to analyse the success of our marketing measures.

 

Notes on legal bases: If we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: users (e.g. website visitors, users of online services), interested parties.
  • Purposes of processing: tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, visit action evaluation, interest-based and behavioural marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures: IP masking (pseudonymisation of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
  • Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the objection options given to the providers (so-called \"opt-out\"). If no explicit opt-out option has been specified, you have the option of deactivating cookies in your browser settings. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for the respective regions:a) Europe: https://www.youronlinechoices.eu. b) Canada: www.youradchoices.ca/choices.c) USA: www.aboutads.info/choices.d) Cross-territory: http://optout.aboutads.info.
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Services used and service providers:

 

Presence in social networks

We maintain online presences within social networks in order to communicate with users active there or to offer information about us there.

 

We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users' rights. With regard to US providers that are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we point out that they thereby undertake to comply with EU data protection standards.

 

Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the computers of the users, in which the usage behavior and the interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).

 

For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.

 

In the case of requests for information and the assertion of data subject rights, we also point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

 

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: users (e.g. website visitors, users of online services).
  • Purposes of processing: contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
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Services used and service providers:

 

Plugins and embedded functions and content

We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These can be, for example, graphics, videos or social media buttons as well as posts (hereinafter uniformly referred to as "content").

 

The integration always requires that the third-party providers of this content process the IP address of the user, as without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content or functionality. We endeavour to use only such content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as being linked to such information from other sources.

 

Notes on legal basis: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

 

  • 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 data (e.g. e-mail, telephone numbers), content data (e.g. text input, photographs, videos).
  • Data subjects: users (e.g. website visitors, users of online services), communication partners.
  • Purposes of processing: provision of our online offer and user-friendliness, contractual performance and service, security measures, administration and response to enquiries, contact requests and communication, direct marketing (e.g. by e-mail or post), tracking (e.g. interest/behaviour-based profiling, use of cookies), interest-based and behaviour-based marketing, profiling (creation of user profiles).
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO), consent (Art. 6 para. 1 p. 1 lit. a DSGVO), contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO).
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Services used and service providers:

 

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose).

 

If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. That is, the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.

 

Further information on the deletion of personal data can also be found in the individual data protection notices of this data protection declaration.

 

Modification and updating of the data protection declaration

We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

 

Rights of the data subjects

As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 18 and 21 of the GDPR:

 

  • Right to object: you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) of the DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.
  • Right to revoke consent: You have the right to revoke any consent you have given at any time.
  • Right to information: You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
  • Right torectification: you have the right to request, in accordance with the law, that data concerning you be completed or that inaccurate data concerning you be rectified.
  • Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data concerning you be erased without delay or, alternatively, to request restriction of the processing of the data in accordance with the law.
  • Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements, or to demand its transfer to another responsible party.
  • Complaint to the supervisory authority: You also 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 personal data concerning you violates the GDPR.
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Definitions

This section provides you with an overview of the terms used in this Privacy Policy. Many of the terms are taken from the law and defined primarily in Article 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are sorted alphabetically.

  • Visitaction evaluation:"Visit action evaluation" (English "conversion tracking") refers to a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users' devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we have placed on other websites have been successful).
  • IP masking:"IP masking" is a method of deleting the last octet, i.e., the last two numbers of an IP address, so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing methods, especially in online marketing
  • Interest-based and behavioural marketing: Interest-based and/or behavioural marketing is when potential interests of users in ads and other content are predetermined as accurately as possible. This is done on the basis of information about their previous behaviour (e.g. visiting certain websites and staying on them, buying behaviour or interaction with other users), which is stored in a so-called profile. Cookies are generally used for these purposes.
  • Conversion measurement: Conversion measurement is a method used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users' devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we have placed on other websites have been 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 reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiling:"Profiling" is any form of automated processing of personal data that consists of using that personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information relating to age, gender, location data and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Reachmeasurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and may include visitors' behavior or interests in certain information, such as web page content. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Remarketing:"Remarketing" or "retargeting" is when, for example, for advertising purposes, it is noted which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Tracking: We speak of "tracking" when the behaviour of users can be traced across several online offers. As a rule, behavioural and interest information relating to the online offers used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can subsequently be used, for example, to display advertisements to users that are likely to correspond to their interests.
  • Controller: a "controller" is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
  • Processing:"processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually any handling of data, whether collection, analysis, storage, transmission or erasure.