Privacy Policy

Last updated: 8 December 2022

Table of Contents

Controller

Caroline Krause

Email address:

caroline@graphixisland.com

Overview of Processing Activities

The following overview summarises the types of data processed and the purposes of their processing, and refers to the data subjects concerned.

Types of Data Processed

  • Basic personal data.
  • Payment data.
  • Location data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta/communication data.

Categories of Data Subjects

  • Prospective customers.
  • Communication partners.
  • Users.
  • Business and contractual partners.

Purposes of Processing

  • Provision of contractual services and customer service.
  • Contact enquiries and communication.
  • Security measures.
  • Direct marketing.
  • Reach measurement.
  • Tracking.
  • Office and organisational procedures.
  • Affiliate tracking.
  • Managing and responding to enquiries.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offer and user-friendliness.
  • Information technology infrastructure.

Relevant Legal Bases

Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or establishment. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in this privacy policy.

  • Consent (Art. 6(1)(a) GDPR) – The data subject has given consent to the processing of their personal data for one or more specific purposes.
  • Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6(1)(c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6(1)(f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Security Measures

In accordance with the legal requirements, and taking into account the state of the art, the costs of implementation, and the nature, scope, context and purposes of processing as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we implement appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.

These measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access to, input, transfer, ensuring availability of and separation of such data. We have also established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to threats to data. 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.

TLS encryption (https): To protect the data you transmit via our online offer, we use TLS encryption. You can recognise such encrypted connections by the prefix https:// in your browser’s address bar.

Transfer 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, service providers entrusted with IT tasks, or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.

Data Processing in Third Countries

Where we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or where this occurs in the context of using third-party services or disclosing or transferring data to other persons, bodies or companies, this only takes place in accordance with the legal requirements.

Subject to express consent or a contractually or legally required transfer, we only process or have data processed in third countries with a recognised level of data protection, on the basis of contractual obligations through so-called standard contractual clauses of the EU Commission, in the presence of certifications, or on the basis of binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).

Deletion of Data

The data we process will be deleted in accordance with the legal requirements as soon as their consent for processing is revoked or other permissions no longer apply (e.g. when the purpose for processing this data no longer applies, or the data is not required for that purpose). If the data is not deleted because it is required for other, legally permissible purposes, its processing will be restricted to those purposes. This means the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons, or whose storage is necessary to assert, exercise or defend legal claims, or to protect the rights of another natural or legal person.

Our privacy notices may also contain further details on the retention and deletion of data that take precedence for the respective processing activities.

Use of Cookies

Cookies are small text files, or other means of storing information, that store information on end devices and read information from end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed or functions used within an online offer. Cookies may also be used for various purposes, e.g. for the functionality, security and convenience of online offers, as well as for creating analyses of visitor flows.

Notes on consent: We use cookies in accordance with the legal requirements. We therefore obtain prior consent from users, except where this is not legally required. Consent is, in particular, not necessary if the storage and retrieval of information, including cookies, is strictly necessary to provide users with a telemedia service they have expressly requested (i.e. our online offer). The revocable consent is clearly communicated to users and contains information on the respective use of cookies.

Notes on the legal bases under data protection law: The legal basis under data protection law on which we process users’ personal data using cookies depends on whether we ask users for consent. If users consent, the legal basis for processing your data is the consent given. Otherwise, data processed using cookies is processed on the basis of our legitimate interests (e.g. in the economic operation of our online offer and the improvement of its usability), or, where this takes place in the context of fulfilling our contractual obligations, where the use of cookies is necessary to fulfil our contractual obligations. We explain the purposes for which we process cookies in the course of this privacy policy or as part of our consent and processing procedures.

Storage period: With regard to the storage period, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their end device (e.g. browser or mobile application).
  • Persistent cookies: Persistent cookies remain stored even after the end device is closed. For example, this allows the login status to be saved, or preferred content to be displayed directly when the user visits a website again. Likewise, the user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information on the type and storage period of cookies (e.g. as part of obtaining consent), users should assume that cookies are persistent and that the storage period may be up to two years.

General notes on withdrawal and objection (opt-out): Users may withdraw their consent at any time, and may also object to processing in accordance with the legal requirements set out in Art. 21 GDPR. Users can also declare their objection via their browser settings, e.g. by disabling the use of cookies (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.

Further information on processing procedures and services:

  • Processing of cookie data on the basis of consent: We use a cookie consent management procedure, within the framework of which users’ consent to the use of cookies, or the processing operations and providers named as part of the cookie consent management procedure, can be obtained, and managed and withdrawn by users. The declaration of consent is stored so that the request does not have to be repeated and so that consent can be proven in accordance with the legal obligation. Storage may take place server-side and/or in a cookie (a so-called opt-in cookie, or using comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual details on the providers of cookie management services, the following applies: the duration of storage of consent may be up to two years. A pseudonymous user identifier is created and stored together with the time of consent, details of the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used.
  • Borlabs Cookie: Cookie consent management; Service provider: Hosted locally on our own server, no data is shared with third parties; Website: https://de.borlabs.io/borlabs-cookie/; Further information: An individual user ID, language, the types of consent given and the time they were given are stored server-side and in a cookie on the user’s device.
  • To manage the cookies and similar technologies we use (tracking pixels, web beacons, etc.) and the related consents, we use the consent tool “Real Cookie Banner”. Details on how “Real Cookie Banner” works can be found at <a href=”https://devowl.io/en/rcb/data-processing/” rel=”noreferrer” target=”_blank”>https://devowl.io/en/rcb/data-processing/</a>. The legal bases for the processing of personal data in this context are Art. 6(1)(c) GDPR and Art. 6(1)(f) GDPR. Our legitimate interest is the management of the cookies and similar technologies we use and the related consents. The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we cannot manage your consents.

Business Services

We process the data of our contractual and business partners, e.g. customers and prospective customers (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 prior to entering into a contract), e.g. to respond to enquiries.

We process this data in order to fulfil our contractual obligations. This includes, in particular, the obligations to provide the agreed services, any obligations to provide updates, and remedies in the event of warranty and other service disruptions. In addition, we process the data to safeguard our rights and for the purpose of administrative tasks associated with these obligations, as well as for corporate organisation. We also process the data on the basis of our legitimate interests in the proper and economical management of our business, as well as in security measures to protect our contractual partners and our business operations from misuse, and from threats to their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other ancillary services, as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the scope of applicable law, we only disclose the data of contractual partners to third parties insofar as this is necessary for the aforementioned purposes or to fulfil legal obligations. Contractual partners are informed of other forms of processing, e.g. for marketing purposes, within the scope of this privacy policy.

We inform contractual partners which data is required for the aforementioned purposes prior to, or in the course of, data collection, e.g. in online forms, through special markings (e.g. colours) or symbols (e.g. asterisks or similar), or in person.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. for as long as it must be retained for statutory archiving reasons. Under German commercial and tax law, the statutory retention period is ten years for tax-relevant documents as well as for commercial books, inventories, opening balance sheets, annual financial statements, the working instructions and other organisational documents required to understand these documents, and accounting vouchers, and six years for received commercial and business letters and copies of sent commercial and business letters. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statement or the management report was prepared, the commercial or business letter was received or sent, or the accounting voucher was created, or the record was made, or the other documents were created.

Where we use third-party providers or platforms to provide our services, the terms and conditions and privacy notices of the respective third-party providers or platforms apply to the relationship between users and providers.

  • Types of data processed: Basic personal data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. email, phone numbers); contract data (e.g. subject matter of the contract, duration, customer category).
  • Data subjects: Prospective customers; business and contractual partners.
  • Purposes of processing: Provision of contractual services and customer service; contact enquiries and communication; office and organisational procedures; managing and responding to enquiries.
  • Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR); Legal obligation (Art. 6(1)(c) GDPR); Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing procedures and services:

  • Agency services: We process our clients’ data as part of our contractual services, which may include, for example, conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consulting services, and training services; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR).

Provision of the Online Offer and Web Hosting

We process user data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or end device.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses); content data (e.g. entries in online forms).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); security measures.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing procedures and services:

  • Provision of the online offer on rented storage space: To provide our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also referred to as a “web host”); Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
  • Collection of access data and log files: Access to our online offer is logged in the form of so-called “server log files”. 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. Server log files can be used, on the one hand, for security purposes, e.g. to prevent server overload (particularly in the case of abusive attacks, so-called DDoS attacks), and on the other hand, to ensure the utilisation of the servers and their stability; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further retention is required for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified.
  • STRATO: Email services (provision of email mailboxes and sending of emails via SMTP, including the automatic notifications of our contact form); Service provider: STRATO AG, Pascalstraße 10, 10587 Berlin, Germany; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.strato.de; Privacy policy: https://www.strato.de/datenschutz; Data processing agreement: Provided by the service provider.
  • Raidboxes: Web hosting (provision of storage space, computing capacity, server caching and software for operating this website; servers located in Germany); Service provider: Raidboxes GmbH, Hafenstraße 32, 48153 Münster, Germany; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://raidboxes.io; Privacy policy: https://raidboxes.io/legal/privacy/; Data processing agreement: Provided by the service provider.

Blogs and Publishing Media

We use blogs or comparable means of online communication and publication (hereinafter “publishing medium”). Readers’ data is only processed for the purposes of the publishing medium to the extent necessary for its presentation and for communication between authors and readers, or for security reasons. For the rest, we refer to the information on the processing of visitors to our publishing medium within this privacy policy.

  • Types of data processed: Basic personal data (e.g. names, addresses); contact data (e.g. email, phone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and customer service; feedback (e.g. collecting feedback via an online form); provision of our online offer and user-friendliness.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Contact and Enquiry Management

When contacting us (e.g. via contact form, email, telephone or social media) as well as in the context of existing user and business relationships, the information provided by the person making the enquiry is processed insofar as this is necessary to respond to the contact enquiry and any measures requested.

  • Types of data processed: Contact data (e.g. email, phone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partners.
  • Purposes of processing: Contact enquiries and communication; managing and responding to enquiries; feedback (e.g. collecting feedback via an online form); provision of our online offer and user-friendliness.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR).

Further information on processing procedures and services:

  • Contact form: If users contact us via our contact form, email or other means of communication, we process the data communicated to us in this context in order to handle the matter raised; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Newsletters and Electronic Notifications

We send newsletters, emails and other electronic notifications (hereinafter “newsletter”) only with the consent of the recipients or on the basis of a legal permission. Insofar as the contents of a newsletter are specifically described as part of a sign-up, they are decisive for the users’ consent. Otherwise, our newsletters contain information about our services and about us.

To sign up for our newsletters, it is generally sufficient to provide your email address. However, we may ask you to provide a name for the purpose of personal address in the newsletter, or other information, insofar as this is required for the purposes of the newsletter.

Double opt-in procedure: Signing up for our newsletter generally takes place using a so-called double opt-in procedure. This means that after signing up, you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register using someone else’s email address. Newsletter sign-ups are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation, as well as the IP address. Changes to your data stored with the dispatch service provider are also logged.

Deletion and restriction of processing: We may store unsubscribed email 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. 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 consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a block list.

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving that it was carried out properly. Insofar as we engage a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system.

Content:

Information about us, our services, promotions and offers.

  • Types of data processed: Basic personal data (e.g. names, addresses); contact data (e.g. email, phone 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 email or post).
  • Legal bases: Consent (Art. 6(1)(a) GDPR).
  • Right to object (opt-out): You can cancel receipt of our newsletter at any time, i.e. withdraw your consent or object to further receipt. You can find a link to cancel the newsletter either at the end of each newsletter, or you can otherwise use one of the contact options given above, preferably email, for this purpose.

Further information on processing procedures and services:

  • Measurement of open and click rates: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server, or, if we use a dispatch service provider, from its server, when the newsletter is opened. As part 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, is initially collected. This information is used to technically improve our newsletter based on the technical data or on target groups and their reading behaviour, based on their retrieval locations (which can be determined using the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened and – This text section must be unlocked with a premium licence.
  • Legal bases: Consent (Art. 6(1)(a) GDPR).

Web Analytics, Monitoring and Optimisation

Web analytics (also referred to as “reach measurement”) is used to evaluate visitor flows to our online offer and may include pseudonymous values relating to behaviour, interests or demographic information about visitors, such as age or gender. With the help of reach analysis, we can, for example, identify at what time our online offer, or its functions or content, are used most frequently, or invite repeat use. Likewise, we can determine which areas require optimisation.

In addition to web analytics, we may also use testing procedures, e.g. to test and optimise different versions of our online offer or its components.

Unless otherwise stated below, profiles may be created for these purposes, i.e. data summarised for a usage process, and information may be stored in and read from a browser or an end device. The information collected includes, in particular, the websites visited and the elements used there, as well as technical information such as the browser used, the computer system used, and information on usage times. Where users have consented to the collection of their location data, either to us or to the providers of the services we use, location data may also be processed.

The IP addresses of users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no plain-text user data (such as email addresses or names) is stored as part of web analytics, A/B testing and optimisation, only pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, only the information stored in their profiles for the purposes of the respective procedures.

  • 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).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles); tracking (e.g. interest/behaviour-based profiling, use of cookies); provision of our online offer and user-friendliness.
  • Security measures: IP masking (pseudonymisation of the IP address).
  • Legal bases: Consent (Art. 6(1)(a) GDPR).

Further information on processing procedures and services:

Affiliate Programmes and Affiliate Links

Our online offer includes so-called affiliate links or other references (which may include, for example, search forms, widgets or discount codes) to the offers and services of third-party providers (collectively referred to as “affiliate links”). If users follow the affiliate links, or subsequently make use of the offers, we may receive a commission or other benefit from these third-party providers (collectively referred to as “commission”).

In order to track whether users have made use of the offers of an affiliate link we use, it is necessary for the respective third-party providers to know that users have followed an affiliate link used within our online offer. The assignment of affiliate links to the respective transactions or other actions (e.g. purchases) serves solely the purpose of commission accounting and is cancelled as soon as it is no longer required for that purpose.

For the purposes of the aforementioned assignment of affiliate links, the affiliate links may be supplemented with certain values that form part of the link or may be stored elsewhere, e.g. in a cookie. These values may include, in particular, the originating website (referrer), the time, an online identifier of the operators of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer, and an online identifier of the user.

Notes on legal bases: Where we ask users for their consent to the use of 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. an interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Types of data processed: Contract data (e.g. subject matter of the contract, duration, customer category); 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: Affiliate tracking.
  • Legal bases: Consent (Art. 6(1)(a) GDPR); legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing procedures and services:

Presence on Social Networks (Social Media)

We maintain online presences within social networks and, in doing so, process user data in order to communicate with users active there or to offer information about us.

We would like to point out that user data may be processed outside the European Union in this context. This may result in risks for users, as this could, for example, make it more difficult to enforce users’ rights.

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

For a detailed description of the respective forms of processing and the options for objection (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.

Also in the case of requests for information and the exercise of data subject rights, we would like to point out that these can be asserted most effectively with the providers. Only the providers have access to users’ data in each case and can take corresponding measures and provide information directly. Should you nevertheless require assistance, you can contact us.

  • Types of data processed: Contact data (e.g. email, phone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Contact enquiries and communication; feedback (e.g. collecting feedback via an online form); marketing.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing procedures and services:

  • Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
  • Facebook pages: Profiles within the Facebook social network – We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (so-called “fan page”). This data includes information on the types of content that users view or interact with, or the actions they take (see “Things others do and provide” in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see “Device information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, so-called “Page Insights”, to page operators so that they can gain insights into how people interact with their pages and the content connected to them. We have entered into a special agreement with Facebook (“Information about Page Insights”, https://www.facebook.com/legal/terms/page_controller_addendum), which in particular sets out which security measures Facebook must comply with and in which Facebook has agreed to fulfil the rights of data subjects (i.e. users can, for example, direct requests for information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information about Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Standard contractual clauses (guaranteeing the level of data protection when processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Further information: Joint controllership agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data. The joint controllership is limited to the collection and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, particularly with regard to the transfer of data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
  • LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Data processing agreement: https://legal.linkedin.com/dpa; Standard contractual clauses (guaranteeing the level of data protection when processing in third countries): https://legal.linkedin.com/dpa; Right to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • X (formerly Twitter): Social network; Service provider: X Corp., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Privacy policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
  • YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Privacy policy: https://policies.google.com/privacy; Right to object (opt-out): https://adssettings.google.com/authenticated.

Plugins and Embedded Functions and Content

We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may include, for example, graphics, videos or city maps (hereinafter collectively referred to as “content”).

Integration always requires that the third-party providers of this content process the user’s IP address, as without the IP address they could not send the content to the user’s browser. The IP address is therefore required to display this content or functions. We endeavour to use only content whose respective providers use the IP address solely to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. These “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 include, among other things, technical information about the browser and operating system, referring websites, time of visit, and other details about the use of our online offer, and may also be combined with such information from other sources.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses); basic personal data (e.g. names, addresses); contact data (e.g. email, phone numbers); content data (e.g. entries in online forms); location data (information on the geographic position of a device or a person).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness; profiles with user-related information (creation of user profiles).
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing procedures and services:

  • Google Fonts (retrieved from the Google server): Retrieval of fonts (and symbols) for the purpose of technically secure, maintenance-free and efficient use of fonts and symbols with regard to up-to-dateness and load times, their uniform display, and consideration of possible licence restrictions. The font provider is informed of the user’s IP address so that the fonts can be made available in the user’s browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) is transmitted, which is necessary for providing the fonts depending on the devices used and the technical environment. This data may be processed on a server of the font provider in the USA – When visiting our online offer, users’ browsers send HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving the fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) of Google Fonts and then the fonts specified in the CSS. These HTTP requests include (1) the IP address used by the respective user to access the internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user agent, which describes the browser and operating system versions of website visitors, as well as the referrer URL (i.e. the website on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers, and they are not analysed. The Google Fonts Web API logs details of the HTTP requests (requested URL, user agent, and referrer URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wishes to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must adapt the font generated for the respective browser type. The user agent is primarily logged for debugging purposes and used to generate aggregated usage statistics, which are used to measure the popularity of font families. These aggregated usage statistics are published on the Google Fonts “Analytics” page. Finally, the referrer URL is logged so that the data can be used for production maintenance and an aggregated report on top integrations can be generated based on the number of font requests. According to its own statements, Google does not use any of the information collected by Google Fonts to create profiles of end users or to serve targeted advertisements; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy; Further information: https://developers.google.com/fonts/faq/privacy.
  • Google Maps: We integrate the maps of the “Google Maps” service provided by Google. The data processed may include, in particular, IP addresses and location data of users; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy.
  • YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Right to object (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout, settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • Vimeo: Video content; Service provider: Vimeo Inc., Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://vimeo.com; Privacy policy: https://vimeo.com/privacy; Right to object (opt-out): Please note that Vimeo may use Google Analytics; for this, please refer to the privacy policy (https://policies.google.com/privacy) as well as the opt-out options for Google Analytics (https://tools.google.com/dlpage/gaoptout) or Google’s settings for data use for marketing purposes (https://adssettings.google.com/).

Amendment and Updating of this Privacy Policy

We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require an action on your part (e.g. consent) or any other individual notification.

Where we provide addresses and contact information for companies and organisations in this privacy policy, please note that these addresses may change over time, and we ask that you verify the details before making contact.

Rights of Data Subjects

As a data subject, you have various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

  • Right to object: You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you which is based on Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If personal data concerning you is processed for direct marketing purposes, 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 of withdrawal for consents: You have the right to withdraw any consent given at any time.
  • Right of access: You have the right to request confirmation as to whether the data concerned is being processed, and to be provided with information about this data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to request that data concerning you be deleted without delay, or alternatively, in accordance with the legal requirements, to request a restriction on the processing of the data.
  • Right to data portability: You have the right to receive data concerning you which you have provided to us, in accordance with the legal requirements, in a structured, commonly used and machine-readable format, or to request its transfer to another controller.
  • Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Definitions

This section gives you an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined, in particular, in Art. 4 GDPR. The legal definitions are binding. The explanations below, on the other hand, are primarily intended to aid understanding. The terms are listed in alphabetical order.

  • Affiliate tracking: As part of affiliate tracking, links that linking websites use to refer users to websites with product or other offers are logged. The operators of the respective linking websites may receive a commission if users follow these so-called affiliate links and subsequently make use of the offers (e.g. buy goods or use services). For this purpose, it is necessary for providers to be able to track whether users who are interested in certain offers subsequently make use of them as a result of the affiliate links. Therefore, for affiliate links to function, it is necessary for them to be supplemented with certain values that become part of the link or are stored elsewhere, e.g. in a cookie. These values include, in particular, the originating website (referrer), the time, an online identifier of the operators of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as tracking-specific values such as advertising material ID, partner ID and categorisations.
  • 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. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, comprises any type of automated processing of personal data consisting of the use of such personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may involve various information relating to demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website, or place of residence). Cookies and web beacons are frequently used for profiling purposes.
  • Reach measurement: Reach measurement (also referred to as web analytics) is used to evaluate visitor flows to an online offer and may include the behaviour or interests of visitors in certain information, such as website content. With the help of reach analysis, website owners can, for example, determine at what time visitors visit their website and in which content they are interested. This allows them, for example, to better adapt the website’s content to the needs of their visitors. Pseudonymous cookies and web beacons are frequently used for reach analysis purposes to recognise returning visitors and thus obtain more accurate analyses of the use of an online offer.
  • Location data: Location data is created when a mobile device (or another device with the technical prerequisites for location determination) connects to a mobile network cell, a WLAN, or similar technical means and functions of location determination. Location data is used to indicate the geographically determinable position on Earth at which the respective device is located. Location data can be used, for example, to display map functions or other location-dependent information.
  • Tracking: “Tracking” refers to the ability to trace the behaviour of users across several online offers. As a rule, behavioural and interest information relating to the online offers used is stored in cookies or on the 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: The “controller” refers to 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” is any operation or set of operations carried out with or without the aid of automated procedures in connection with personal data. The term is broad and encompasses virtually any handling of data, whether collecting, analysing, storing, transmitting or deleting it.