Privacy Policy

Introduction

With the following data protection declaration we would like to inform 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 service").

The terms used are not gender-specific.

    Effective 23. October 2019

    Content overview

    Responsible

    Florian Sander
    Im Grün 10
    79098 Freiburg
    Germany

    E-Mail-address: info@focalityapp.com

    Legal information: https://www.focalityapp.com/en/legal-information/

      Overview of processing operations

      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

      • Baseline data (e.g. names, addresses).

      • Content data (e.g. text input, photographs, videos).

      • Contact data (e.g.B. E-Mail, phone numbers).

      • Meta/communication data (e.g. device information, IP addresses).

      • Usage data (e.g. visited websites, interest in content, access times).

      • Social data (data subject to social confidentiality (§ 35 SGB I) and processed, for example, by social insurance institutions, social welfare institutions or pension authorities.).

      • Location data (data indicating the location of the end device of an end user).

      • Contract data (for example, contract object, term, customer category).

      • Payment data (for example, bank details, invoices, payment history).

      Categories of persons affected

      • Employees (e.g. salaried employees, applicants, former employees).

      • Business and contractual partners.

      • Interested parties.

      • Communication partners.

      • Customers.

      • Users (e.g. website visitors, users of online services).

      Purposes of processing

      • Provision of our online services and user friendliness.

      • Visit Promotion Evaluation.

      • Office and organizational procedures.

      • Content Delivery Network (CDN).

      • Cross-Device Tracking (cross-device processing of user data for marketing purposes).

      • Direct marketing (e.g. by e-mail or post).

      • Feedback (e.g. collecting feedback via online form).

      • Interest-based and behavioural marketing.

      • Contact requests and communication.

      • Conversion measurement (measurement of the effectiveness of marketing measures).

      • Profiling (creation of user profiles).

      • Remarketing.

      • Range measurement (for exampleB. Access statistics, recognition of returning visitors).

      • Security measures.

      • Tracking (e.g. interest/behavioral profiling, use of cookies).

      • Contractual services and service.

      • Administration and response to inquiries.

      • Target group formation (determination of target groups relevant for marketing purposes or other output of content).

      Applicable legal bases

      In the following, we share the legal bases of the Basic 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.

      • A Consent (Art. 6 Para. 1 S. 1 lit. a DSGVO) - The data subject has given his/her consent to the processing of his/her personal data for one or more specific purposes.

      • Fulfilment of contract and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. a DSGVO) - The data subject has given his/her consent to the processing of his/her personal data for one or more specific purposes.

      • Fulfilment of contract and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. a DSGVO) - The data subject has given his/her consent to the processing of his/her personal data for one or more specific purposes. 6 para. 1 sentence 1 lit. b. DSGVO) - The processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures which are taken at the request of the data subject.

      • Legal obligation (Art. 6 para. 1 sentence 1 lit. c. DSGVO) - Processing is necessary to fulfil a legal obligation to which the data subject is subject.

      • Goodful interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO) - Processing is necessary to safeguard theoodful interests of the data subject or of a third party, unless the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, predominate.

      National data protection regulations in Germany: In addition to the data protection regulations of the Basic Data Protection Regulation, national regulations apply to data protection in Germany. This includes, in particular, the German Data Protection Act (Bundesdatenschutzgesetz - BDSG). In particular, the BDSG contains special provisions on the right to information, the right to deletion, the right of objection, 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, execution or termination of employment relationships as well as the consent of employees. Furthermore, state data protection laws of the individual federal states may be applied.

        Security measures

        We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, extent, 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.

        Actions shall include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to, and access to, input, dissemination, securing and separation of data. In addition, we have established procedures to ensure the exercise of data subjects' rights, the deletion of data and responses to data breaches. Furthermore, we take the protection of personal data into account as early as 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 service, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

        Transmission and disclosure of personal data

        In the context of our processing of personal data, it may happen that the data is transmitted to other places, companies, legally independent organizational units or persons or that it is disclosed to them. The recipients of this data may include, for example, payment institutions within the framework of payment transactions, 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 corresponding contracts or agreements with the recipients of your data which 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 if the processing takes place in the context of the use of third party services or the disclosure or transfer of data to other persons, bodies or companies, this shall only take place in accordance with the statutory provisions.

        Without express consent or transfer required by contract or law, we will only process or have the data processed in third countries with a recognised level of data protection, including US processors certified under the Privacy Shield, or on the basis of special guarantees such as contractual obligation through so-called standard protection clauses of the EU Commission, the existence of 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 ).

        Use of Cookies

        Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user's computer. A cookie is primarily used to store information about a user during or after his visit within an online offer. The information stored can include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was viewed. The term "cookies" also includes other technologies that perform the same functions as cookies (e.g. if user information is stored using pseudonymous online identifiers, also referred to as "user IDs")

        The following cookie types and functions are distinguished:

        • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
        • Permanent cookies: Permanent cookies remain stored even after closing the browser. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users who are used to measure reach or for marketing purposes can be stored in such a cookie.
        • First Party Cookies: First Party Cookies are set by us.
        • Third Party Cookies (also: Third Party Cookies): Third Party Cookies are mainly used by advertisers (so-called third parties) to process user information.
        • Necessary (also: essential or absolutely necessary) cookies: Cookies may be absolutely necessary for the operation of a website (e.g. to store logins or other user inputs or for security reasons).
        • Statistics, marketing and personalization cookies: Cookies are also generally used to measure a user's range and when a user's interests or behaviour (e.g. viewing certain content, using functions, etc.) are stored on individual websites in a user profile. Such profiles are used, for example, to display content to users that corresponds to their potential interests. This procedure is also referred to as "tracking", i.e. tracking the potential interests of users. . If we use cookies or "tracking" technologies, we will inform you separately in our data protection declaration or within the scope of obtaining consent.

        Information on legal bases: The legal basis on which we process your personal data with the aid of cookies depends on whether we ask you for consent. If this applies 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 will be processed on the basis of our legitimate interests (e.g. in a business operation of our online service and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.

        General information on revocation and objection (opt-out): Depending on whether processing is based on a consent or legal permission, you have the option at any time to revoke a consent given or to object to the processing of your data using cookie technologies (collectively referred to as "opt-out"). You can initially declare your objection using the settings of your browser, e.g. by deactivating the use of cookies (which may also restrict the functionality of our online service). An objection to the use of cookies for online marketing purposes can also be raised by means of a variety of services, particularly in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/ or generally via http://optout.aboutads.info.

        • Processed data types: Usage data (e.g. visited websites, 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).

        • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a DSGVO), Legitimate interests (Art. 6 Para. 1 S. a DSGVO), (Art. 6 Para. 1 S. 1 DSGVO). 6 Paragraph 1 S. 1 lit. f. DSGVO).

        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") within the framework of contractual and comparable legal relationships as well as associated measures and within the framework of communication with the contractual partners (or pre-contractual), e.g, to answer inquiries.

        We process this data in order to fulfil our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with this data and the entrepreneurial organisation. Within the framework of the applicable law, we only pass on the data of the contractual partners to third parties insofar as this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or is carried out with the consent of the contractual partners (e.g. to involved 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 framework of this data protection declaration.

        What data is necessary for the aforementioned purposes, we inform the contractual partners before or in the context of the data collection, e.g. in online forms, by special marking (e.g. colors) or symbols (e.g. asterisks or the like), or personally.

        We delete the data after expiry of legal warranty and comparable obligations, i.e., in principle after expiry of 4 years, unless the data are stored in a customer account, e.g., as long as they must be kept for legal reasons of archiving (e.g. for tax purposes as a rule 10 years). Data disclosed to us by the contractual partner within the framework of an order shall be deleted in accordance with the specifications of the order, in principle 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 shall 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, in short "customer account"). If the registration of a customer account is necessary, contractual partners will be informed of this as well as of the information required for registration. The customer accounts are not public and cannot be indexed by search engines. Within the scope of the registration as well as 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 prevent any abuse of the customer account.

        If customers have terminated their customer account, the data relating to the customer account will be deleted, subject to retention, which is required for legal reasons. It is incumbent upon the customer to secure their data upon termination of the customer account.

        Economic analyses and market research: For economic reasons and in order to be able to recognise market trends, wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., whereby contractual partners, interested parties, customers, visitors and users of our online service may fall into the group of persons concerned.

        The analyses are carried out for the purpose of business management 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 and their information, e.g. on services used. The analyses serve us alone and are not disclosed externally unless they are anonymous analyses with summarised, i.e. anonymised values. Furthermore, we respect the privacy of the users and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as summarised data).

        Mobile Application: We process the data of the users of our apps, registered and any test users (hereinafter uniformly referred to as "users") in order to provide them with our contractual services and on the basis of legitimate interests to ensure the security of our app and to develop it further. The required information is identified as such in the context of the conclusion of the contract for use, order, order or comparable contract and may include the information required for the provision of services and for any billing as well as contact information in order to be able to hold any consultations. If our apps are purchased from platforms of other providers (e.g. Apple's App Store or GooglePlay), the terms and conditions and data protection notices of the respective platforms apply in the relationship between the users and the providers.

        Offer of software and platform services: We process the data of our users, registered and any test users (hereinafter uniformly referred to as "users") in order to be able to provide them with our contractual services and on the basis of legitimate interests to ensure the security of our offer and to be able to further develop it. The necessary data are marked as such in the context of the order, order or comparable conclusion of contract and include the data required for the provision of services and billing as well as contact information in order to be able to hold any consultations.

        • Processed data types: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, phone numbers), contract data (e.g. Subject matter of contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

        • Persons affected: Interested parties, business and contractual partners, customers.

        • Purposes of processing: Contractual services and service, contact enquiries and communication, office and organisational procedures, administration and answering of enquiries, security measures, evaluation of visits, interest based and behaviour related marketing, profiling (creation of user profiles).

        • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b. DSGVO), Legal obligation (Art. 6 Para. 1 S. 1 lit. c. DSGVO), Legitimate interests (Art. 6 Para. 1 S. 1 lit. c. DSGVO), Rights and obligations (Art. 6 Para. 1 S. 1 lit. c. DSGVO). 6 Paragraph 1 S. 1 lit. f. DSGVO).

        Use of online marketplaces for e-commerce

        We offer our services on online platforms operated by other service providers. In this context, the data protection notices of the respective platforms apply in addition to our data protection notices. This applies in particular with regard to the methods used on the platforms for measuring range and for interest-related marketing.

        • Processed data types: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, phone numbers), contract data (e.g. subject of contract, term, customer category), usage data (e.g. customer name, customer name, etc.).B. Visited websites, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

        • Affected persons: Customers.

        • Purposes of processing: Contractual services and service.

        • Legal basis: Performance of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. DSGVO), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. DSGVO).

        Payment service provider

        In the context of contractual and other legal relations, due to legal obligations or otherwise on basis of our entitled interests we offer efficient and safe payment possibilities to the persons concerned and use for this beside banks and credit institutes further payment service providers (summarizing "payment service provider").

        The data processed by the payment service providers includes inventory data such as name and address, bank data such as account or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient details. The information is required to complete 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, but only information with confirmation or negative information about the payment. Under certain circumstances, the data may be transmitted by the payment service provider to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the general terms and conditions and the data protection information of the payment service providers.

        For payment transactions, the terms and conditions and the data protection information of the respective payment service providers, which can be accessed within the respective websites or transaction applications, apply. We refer to these also for the purpose of further information and assertion of revocation, information and other rights affected.

        • Processed data types: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of contract, term, customer category), usage data (e.g.e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), contact data (e.g. e-mail, telephone numbers).

        • Persons affected: Customers, prospects.

        • Purposes of processing: Contractual achievements and service.

        • Legal bases:Fulfilment of contract and pre-contractual inquiries (art. 6 exp. 1 S. 1 lit. b. DSGVO), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. DSGVO).

        Services and service providers used:

        Registration and Login

        Users may create a user account. During the registration process, users are provided with the required mandatory information and processed for the purpose of providing the user account on the basis of contractual fulfilment of obligations. The processed data includes in particular the login information (name, password and an e-mail address). The data entered during registration will be used for the purpose of using the user account and its purpose.

        The users can be informed by e-mail about processes that are relevant to their user account, such as technical changes. If users have terminated their user account, their data will be deleted with regard to the user account, subject to a statutory retention obligation. It is the responsibility of the users to secure 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 term of the contract.

        When using our registration and login functions as well as 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 a protection against misuse and other unauthorized use. These 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.

        • Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, phone numbers), content data (e.g. text input, photographs, videos), meta/communication data (e.g. device information, IP addresses).

        • Affected persons: Users (e.g. website visitors, users of online services).

        • Purposes of processing: Contractual services and service, security measures, administration and response to inquiries.

        • Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a DSGVO), performance of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b DSGVO), legitimate interests (Art. 6 Para. 1 S. 1 lit. f DSGVO).

        Contact

        When contacting us (e.g. by contact form, e-mail, telephone or via social media), the data of the inquiring persons will be processed insofar as this is necessary to answer the contact enquiries and any requested measures.

        Response to contact enquiries within the framework of contractual or pre-contractual relationships is made in order to fulfil our contractual obligations or to answer (pre)contractual enquiries and otherwise on the basis of the legitimate interests in answering the enquiries.

        • Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, phone numbers), content data (e.g. text input, photographs, videos), usage data (e.g.e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

        • Persons affected: Communication partner.

        • Purposes of processing: Contact enquiries and communication.

        • Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

        surveys and surveys

        The surveys and surveys we conduct (hereinafter referred to as "surveys") are evaluated anonymously. Personal data is only processed insofar as this is necessary for the provision and technical execution of the surveys (e.g. processing the IP address in order to display the survey in the user's browser or to enable a resumption of the survey with the aid of a temporary cookie (session cookie)) or if the user has consented.

        Information on legal bases: If we ask the participants for their consent to the processing of their data, this is the legal basis for the processing, otherwise the processing of the participants' data takes place on the basis of our legitimate interests in carrying out an objective survey.

        • Processed data types: Contact data (e.g. e-mail, phone numbers), content data (e.g. text input, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

        • Affected persons: Communication partners, users (e.g. website visitors, users of online services).

        • Purposes of processing: Contact requests and communication, direct marketing (e.g. by e-mail or post), tracking (e.g. (e.g. collection of feedback via online form).

        • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a DSGVO), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. DSGVO).

        Provision of the online service and web hosting

        In order to provide our online service safely and efficiently, we make use of the services of one or more web hosting providers whose servers (or servers managed by them) can access the online service. 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 within the framework of the provision of the hosting offer may include all information relating to the users of our online offer that is collected within the scope of use and communication. This regularly includes the IP address, which is necessary in order 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 webhosting services used by us 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 regarding the sending of e-mails (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for SPAM detection purposes. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted during transport, but not on the servers from which they are sent and received (unless a so-called end-to-end encryption method is used). 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 logfiles: We (or our webhosting provider) collect data on each access to the server (so-called server logfiles). The server log files may include the address and name of the web pages and files accessed, the date and time of access, data volumes 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 logfiles can be used for security purposes, e.g. to avoid server overload (especially in case of abusive attacks, so-called DDoS attacks) and to ensure server utilization and stability.

        Content-Delivery-Network: We use a "Content-Delivery-Network" (CDN). A CDN is a service with the help of which the contents of an online offer, especially 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.

        • Processed data types: Content data (e.g. text input, photographs, videos), usage data (e.g. visited websites, interest in content, access times), meta/communication data (e.g.B. Device information, IP addresses).

        • Affected persons: Users (e.g. website visitors, users of online services).

        • Purposes of processing: Content Delivery Network (CDN).

        • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

        Services and service providers used:

        Newsletter and Wide Area Communications

        We do not send newsletters, e-mails and other electronic communications (hereinafter "Newsletters") without the recipient's consent or legal permission. Insofar as the contents of the newsletter are specifically described within the framework of registration, they are decisive for the consent of the user. In addition, our newsletters contain information on our services and us.

        In order to subscribe to our newsletters, it is sufficient to enter 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 information, if this is necessary for the purposes of the newsletter.

        Double-Opt-In-Procedure: The subscription to our newsletter is always done in a so-called Double-Opt-In-Procedure. This means that you will receive an e-mail after registration asking you to confirm your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. The registrations for 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 the changes of your data stored with the Versanddienstleister are logged.

        Deletion and limitation of processing: We may store the unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to provide evidence of prior consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time. In the case of obligations to permanently observe contradictions, we reserve the right to store the e-mail address solely for this purpose in a black list.

        The registration procedure is recorded on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. 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 dispatch system.

        Notes on legal bases: The newsletter is sent on the basis of the recipient's consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, provided and to the extent that this is permitted by law, e.g. in the case of existing customer advertising. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process will be recorded on the basis of our legitimate interests to demonstrate that it was conducted in accordance with the law.

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

        Success measurement: The newsletters contain a so-called "web-beacon", i.e. a pixel-sized file, which is retrieved from our server or, if we use a dispatch service provider, from its server when the newsletter is opened. In the course of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, are first collected.

        This information is used for the technical improvement of our newsletter on the basis of technical data or 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 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 the individual newsletter recipients. However, it is neither our endeavour nor, if used, that of the dispatch service provider to observe individual users. Rather, the evaluations serve us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

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

        A separate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled or contradicted.

        • Processed data types: 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. Visited websites, interest in content, access times).

        • Affected persons: Communication partners.

        • Purposes of processing: Direct marketing (e.g. by e-mail or post), measurement of range (e.g. Access statistics, recognition of returning visitors), tracking (e.g. interest/behavioural profiling, use of cookies), profiling (creation of user profiles).

        • Legal basis: Consent (Art. 6 Par. 1 S. 1 lit. a DSGVO), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. DSGVO).

        • Opposition (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 contact options listed above, preferably e-mail.

        Services and service providers used:

        web analysis and optimization

        The web analysis (also referred to as "range measurement") is used to evaluate the flow of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the range analysis we can, for example, recognize at which time our online offer or its functions or contents are most frequently used or invite for re-use. We can also determine which areas require optimisation.

        In addition to web analysis, we can also use test procedures, e.g. to test and optimize different versions of our online offering or its components.

        For these purposes, so-called user profiles can be created and stored in a file (so-called "cookie") or similar procedures with the same purpose can be used. This information may include, for example, content viewed, web pages visited and elements and technical data used there, such as the browser used, the computer system used and information on times of use. If users have consented to the collection of their location data, these may also be processed, depending on the provider.

        The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect the user. In general, within the framework of web analysis, A/B testing and optimisation, no user data (e.g. e-mail addresses or names) is stored, but pseudonyms. This means that both we and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

        Information on legal bases: If we ask the users for their consent to the use of third party providers, the legal basis of the processing of data is consent. Otherwise, user data will be 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 draw your attention to the information on the use of cookies in this data protection declaration.

        • Affected persons: Users (e.g. website visitors, users of online services).

        • Purposes of processing:Range measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g.e.g. interest/behavioural profiling, use of cookies), visitor action evaluation, profiling (creation of user profiles).

        • Security measures: IP masking (pseudonymisation of the IP address).

        • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a DSGVO), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. DSGVO).

        Online marketing

        We process personal data for the purposes of online marketing, which may include in particular the marketing of advertising space or the presentation of advertising and other content (collectively referred to as "content") on the basis of the potential interests of users and the measurement of their 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 user information relevant for the presentation of the aforementioned contents 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 times of use. If users have consented to the collection of their location data, these can also be processed.

        The IP addresses of the users are also stored. However, we use available IP masking methods (i.e. pseudonymisation by shortening the IP address) to protect users. In general, the online marketing process does not store any user data (such as e-mail addresses or names), but pseudonyms. This means that we as well as the providers of 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 the cookies or using similar procedures. These cookies can later generally be used on other websites that use the same online marketing process, read and analyzed for content presentation purposes, supplemented with additional data and stored on the server of the online marketing process provider.

        Exceptionally, plain 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 procedures we use and the network connects the profiles of the users in the aforementioned data. We kindly ask you to note that users can make additional agreements with the providers, e.g. by giving their consent during registration.

        We only get 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. to a contract being concluded with us, for example. The conversion measurement is used solely to analyze the success of our marketing measures.

        Information on legal bases: If we ask the users for their consent to the use of third party providers, the legal basis of the processing of data is consent. Otherwise, user data will be 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 draw your attention to the information on the use of cookies in this data protection declaration.

        Facebook pixel: With the help of the Facebook pixel it is possible for Facebook on the one hand to determine the visitors of our online offer as a target group for the presentation of ads (so-called "Facebook ads"). Accordingly, we use the Facebook pixel to display Facebook ads placed by us only to those Facebook users on Facebook and within the services of partners cooperating with Facebook (so-called "Audience Network" https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offering or who have certain characteristics (e.g. interest in certain topics or products that can be seen from the websites visited) that we transmit to Facebook (so-called "Custom Audiences"). With the help of Facebook pixels, we also want to ensure that our Facebook ads correspond to the potential interest of the users and do not appear annoying. Using Facebook pixels, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were directed to our website after clicking on a Facebook ad (known as "conversion measurement").

        • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (data indicating the location of an end user's end device), social data (data subject to social confidentiality (§ 35 SGB I) and e.g. (e.g., social security institutions, social welfare institutions, or health care authorities.).

        • Affected persons: Users (e.g., website visitors, users of online services), interested parties, customers, employees (e.g., employees, applicants, former employees), communication partners.

        • Purposes of processing: Tracking (e.g., tracking). Interest/behavioral profiling, use of cookies), remarketing, visitor action evaluation, interest based and behavioral marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), range measurement (e.g. access statistics, recognition of returning visitors), target group formation (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes).

        • Security measures: IP masking (pseudonymisation of the IP address).

        • Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a DSGVO), Legitimate interests (Art. 6 Para. 1 DSGVO), Rights and obligations (Art. 6 Para. 1 DSGVO). 1 p. 1 lit. f. DSGVO).

        • Opposition possibility (Opt-Out): We refer to the data protection notices of the respective providers and the opposition possibilities (so-called "Opt-Out"). If no explicit opt-out option has been specified, it is possible to deactivate cookies in the settings of your browser. 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 areas: a) Europe: https://www.youronlinechoices.eu. b) Kanada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-area: http://optout.aboutads.info.

        Services and service providers in use:

        Presences in social networks

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

        We would like to point out that user data may be processed outside the territory of the European Union. This may entail risks for users, e.g. because it may 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 would like to point out that they are thus obligated to comply with the data protection standards of the EU.

        Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the resulting interests of users. The usage profiles can also 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 user's computer in which the user's usage behaviour and interests are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged on to them).

        For a detailed description of the respective forms of processing and the possibilities for 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 rights of data subjects, we 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 directly take appropriate measures and provide information. Should you nevertheless need help, you can contact us.

        • Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, phone numbers), content data (e.g. text input, photographs, videos), 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, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, range measurement (e.g. access statistics, recognition of returning visitors).

        • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

        Services and service providers in use:

        Plugins and embedded functions as well as content

        We include in our online offer functional and content elements which are obtained from the servers of their respective providers (hereinafter referred to as "third party providers"). These may be, for example, graphics, videos or social media buttons as well as contributions (hereinafter uniformly referred to as "content").

        The integration always presupposes that the third-party providers of this content process the IP address of the user, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents or functions. We strive to use only those contents, whose respective offerers use the IP address only for the distribution of the contents. Third party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. 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, websites to be referred to, visiting times and other information about the use of our online services as well as may be linked to such information from other sources.

        Information on legal bases: If we ask the users for their consent to the use of third party providers, the legal basis of the processing of data is consent. Otherwise, user data will be 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 draw your attention to the information on the use of cookies in this data protection declaration.

        • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), contact data (e.g. e-mail, phone numbers), content data (e.g. text input, photographs, videos), inventory data (e.g. names, addresses).

        • Affected persons: Users (e.g. website visitors, users of online services), communication partners.

        • Purposes of processing: Provision of our online services and user-friendliness, contractual services and service, tracking (e.g. interest/behaviour-related profiling, use of cookies), feedback (e.g. Collecting feedback via online forms), contact requests and communication, direct marketing (e.g. by e-mail or postal mail), interest-based and behavioral marketing, profiling (creation of user profiles), security measures, administration and response to requests.

        • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. DSGVO), consent (Art. 6 Para. 1 S. 1 lit. a DSGVO), fulfilment of contract and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b. DSGVO).

        Services and service providers in use:

        Planning, organisation and auxiliary tools

        We use services, platforms and software of other providers (hereinafter referred to as "third parties") for the purposes of organisation, administration, planning and provision of our services. When selecting third party providers and their services, we observe the legal requirements.

        In this context, personal data may be processed and stored on the servers of third parties. This may affect various data that we process in accordance with this data protection declaration. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents.

        If users are referred to third party providers or their software or platforms in the context of communication, business or other relationships with us, the third party providers may process usage data and metadata for security purposes, service optimization or marketing purposes. We therefore ask you to observe the data protection information of the respective third party providers.

        Information on legal bases: If we ask the users for their consent to the use of third party providers, the legal basis of the processing of data is consent. Furthermore their use can be a component of our (pre)contractual achievements, provided that the employment of the third offerers was agreed upon in this framework. Otherwise, user data will be 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 draw your attention to the information on the use of cookies in this data protection declaration.

        • Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, phone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. Visited websites, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

        • Affected persons: Communication partners, users (e.g. website visitors, users of online services).

        • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a DSGVO), performance of contract and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b DSGVO), legitimate interests (Art. 6 Para. 1 S. 1 lit. f DSGVO).

        Deletion of data

        The data processed by us will be deleted in accordance with the statutory provisions as soon as their permissions for processing are revoked or other permissions no longer apply (e.g, if the purpose of processing this data is no longer applicable or if it is not necessary 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. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be stored 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.

        Further information on the deletion of personal data may also be provided within the framework of the individual data protection notices of this data protection declaration.

          Change and update of the privacy policy

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

          Rights of the persons concerned

          You are entitled to various rights under the DSGVO, in particular arising from Art. 15 to 18 and 21 DS-GVO:

          • 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 takes place on the basis of Art. 6 para. 1 lit. e or f DS-GVO; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct advertising, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such advertising; this also applies to profiling insofar as it is connected with such direct advertising.
          • Right of revocation in the case of consents: You have the right to revoke consents given at any time.
          • Right of access: You have the right to request confirmation as to whether the data concerned will be processed and to request information about this data as well as further information and a copy of the data in accordance with the statutory provisions.
          • Right of correction: In accordance with the statutory provisions, you have the right to request the completion of the data concerning you or the correction of the incorrect data concerning you.
          • Right to deletion and limitation of processing: You have the right, in accordance with the statutory provisions, to demand that the data concerning you be deleted immediately, or alternatively, in accordance with the statutory provisions, to demand a limitation of processing of the data.
          • Right to Data Transferability: 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: In accordance with the statutory provisions, 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 presumed infringement, if you are of the opinion that the processing of your personal data violates the DSGVO.

          Definitions of terms

          This section provides an overview of the terms used in this privacy statement. Many of the terms are taken from the law and defined above all in Art. 4 DSGVO. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.

          • Visit Promotion Evaluation: "Conversion Tracking" refers to a procedure by which the effectiveness of marketing measures can be determined. As a rule, a cookie is stored on the devices of the users within the websites on which the marketing measures take place and then called up again on the target website. For example, we can track whether the ads we placed on other websites were successful).
          • Content Delivery Network (CDN): A "Content Delivery Network" (CDN) is a service that can be used to deliver online content, especially large media files such as graphics or program scripts, faster and more securely with the help of regionally distributed servers connected via the Internet.
          • Cross-Device Tracking: Cross-Device Tracking is a form of tracking in which information on the behaviour and interests of users is recorded in so-called profiles across all devices by assigning users an online identifier. This means that user information can usually be analysed for marketing purposes regardless of the browser or device used (e.g. mobile phone or desktop computer). With most providers, the online identification is not linked to plain data such as names, postal addresses or e-mail addresses.
          • IP-Masking: "IP-Masking" is a method by which the last octet, i.e. the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymizing processing methods, especially in online marketing.
          • Interest-based and behavioural marketing: Interest-based and/or behavioural marketing is the term used when potential interests of users in advertisements and other content are defined as precisely as possible. This is done on the basis of information on their previous behaviour (e.g. visiting certain websites and staying on them, purchasing 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 by which the effectiveness of marketing measures can be determined. As a rule, a cookie is stored on the devices of the users within the websites on which the marketing measures take place and then called up again on the target website. For example, we can track 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 any person who, directly or indirectly, in particular by attribution to an identifier such as a name, an identification number, location data, an online identifier (e.g.B. Cookie) or to one or more specific characteristics which are an expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
          • Profiling: "Profiling" means any automated processing of personal data consisting of the use of such personal data to analyse, evaluate or predict certain personal aspects relating to an individual (including, depending on the type of profiling, information relating to age, gender, location and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people).For example, interests in certain content or products, click behaviour on a website, or whereabouts.) Cookies and web beacons are often used for profiling purposes.
          • Range measurement: Range measurement (also referred to as web analytics) is used to evaluate the visitor flows of an online offer and can include the behaviour or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can recognize, 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 purposes of range analysis, pseudonymous cookies and web beacons are often used to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
          • Remarketing: "Remarketing" or "Retargeting" is the term used, for example, to indicate for advertising purposes which products a user is interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
          • Tracking: "Tracking" is the term used when the behaviour of users can be traced across several online offers. As a rule, behavioural and interest information is stored in cookies or on the servers of the tracking technology providers with regard to the online offers used (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
          • Responsible: A "responsible party" is a natural or legal person, public authority, agency or other body that alone or jointly with others determines the purposes and means of the processing of personal data.
          • Processing: "Processing" means any operation carried out with or without the aid of automated procedures or any such series of operations relating to personal data. The term is broad and covers virtually every handling of data, be it collection, analysis, storage, transmission or erasure.
          • Target group formation: Target group formation (or "Custom Audiences") is the term used when target groups are determined for advertising purposes, e.g. insertion of advertisements. For example, it can be concluded from a user's interest in certain products or topics on the Internet that this user is interested in advertisements for similar products or the online shop in which he viewed the products. Lookalike audiences" (or similar target audiences) are those content that is considered appropriate is displayed to users whose profiles or interests are believed to match the users for whom the profiles were created. Cookies and web beacons are usually used to create custom audiences and lookalike audiences.

          This privacy policy is based on a text generated by the privacy policy generator of Dr. Thomas Schwenke and has been customized by the website / app provider.

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