Preamble
With the following data protection
declaration, we, itesys AG ("we" or "itesys"), would like
to inform you about the types of your personal data (hereinafter also referred
to as "data" for short) that we process, for what purposes and to
what extent "), in connection with our webshop at www.scansor.com and our
online presence. The privacy statement applies to all processing of personal
data carried out by us, both in the context of providing 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 services").
The terms used are not gender-specific.
Table of contents
- Contact information of the data
protection officer
- Overview of processing operations
- Representative in the European
Union
- Registration, Login and User
Account
- Contact and Inquiry Management
- Newsletter and Electronic
Communications
- Web Analysis, Monitoring and
Optimization
- Profiles in Social Networks
(Social Media)
- Plugins and embedded functions and
content
- Changes and Updates to the Privacy
Policy
Representative
Authorized representative: Sascha Lioi,
Managing Director
itesys AG, Langfeldstrasse 53a, 8500 Frauenfeld, Schweiz
information@itesys.ch
www.itesys.expert
Imprint: https://www.scansor.com/en-ch/Imprint/
Contact information of the data protection officer
Kai Siers
itesys AG, Langfeldstrasse 53a, 8500 Frauenfeld, Schweiz
www.itesys.expert
datenschutz@itesys.expert
Tel: +41 71 670 17 80
Representative in the European Union
Heiko Walter Bernhart
itesys DE GmbH, Viktualienmarkt 8, 80331 München, Deutschland
www.itesys.expert
datenschutz@itesys.expert
Relevant legal bases
Relevant legal bases according to the
GDPR: In the following, you will find an overview
of the legal basis of the GDPR on which we base the processing of personal
data. Please note that in addition to the provisions of the GDPR, national data
protection provisions of your or our country of residence or domicile may
apply. If, in addition, more specific legal bases are applicable in individual
cases, we will inform you of these in the data protection declaration.
- Consent (Article 6 (1) (a) GDPR) -
The data subject has given consent to the processing of his or her
personal data for one or more specific purposes.
- Performance of a contract and prior requests (Article 6 (1) (b)
GDPR) - 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.
- Compliance with a legal obligation (Article 6 (1) (c) GDPR) - Processing is necessary for compliance with a legal
obligation to which the controller is subject.
- Legitimate Interests (Article 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.
National data protection regulations in
Germany: In addition to the data protection
regulations of the GDPR, national regulations apply to data protection in
Germany. This includes in particular the Law on Protection against Misuse of
Personal Data in Data Processing (Federal Data Protection Act - BDSG). In
particular, the BDSG contains special provisions on the right to access, the
right to erase, the right to object, the processing of special categories of
personal data, processing for other purposes and transmission as well as
automated individual decision-making, including profiling. Furthermore, data
protection laws of the individual federal states may apply.
Relevant legal basis according to the
Swiss Data Protection Act: If you are located in
Switzerland, we process your data based on the Federal Data Protection Act
(abbreviated as "Swiss DPA"). This also applies if our processing of
your data otherwise affects you in Switzerland and you are affected by the
processing. The Swiss DPA does not generally provide that a legal basis for the
processing of personal data must be stated (unlike, for example, the GDPR). We
process personal data only when the processing is lawful, is conducted in good faith,
and is proportionate (Article 6 (1) and (2) of the Swiss DPA). Furthermore, we
only collect personal data for a specific purpose that is recognisable to the
person concerned and process it only in a manner that is compatible with these
purposes (Article 6 (3) of the Swiss DPA).
Reference to the applicability of the
GDPR and the Swiss DPA: These privacy notices serve
both to provide information in accordance with the Swiss Federal Act on Data
Protection (Swiss DPA) and the General Data Protection Regulation (GDPR).
Overview of processing operations
The following table summarises the types of
data processed, the purposes for which they are processed and the concerned
data subjects.
Categories of Processed Data
- Meta, communication and process
data.
Categories of Data Subjects
- Business and contractual partners.
Purposes of Processing
- Provision of contractual services
and fulfillment of contractual obligations.
- Contact requests and
communication.
- Office and organisational
procedures.
- Managing and responding to
inquiries.
- Profiles with user-related
information.
- Provision of our online services
and usability.
Security Precautions
We take appropriate technical and
organisational measures in accordance with the legal requirements, 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 risk of varying
likelihood and severity for the rights and freedoms of natural persons, in
order to ensure a level of security appropriate to the risk.
The 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, transmission, securing and separation of the data. In addition, we have
established procedures to ensure that data subjects' rights are respected, that
data is erased, and that we are prepared to respond to data threats rapidly.
Furthermore, we take the protection of personal data into account as early as
the development or selection of hardware, software and service providers, in
accordance with the principle of privacy by design and privacy by default.
TLS encryption (https): To protect your
data transmitted via our online services, we use TLS encryption. You can
recognize such encrypted connections by the prefix https:// in the address bar
of your browser.
Erasure of data
The data processed by us will be erased in
accordance with the statutory provisions as soon as their processing is revoked
or other permissions no longer apply (e.g. if the purpose of processing this
data no longer applies or they are not required for the purpose). If the data
is not deleted because they are required for other and legally permissible
purposes, their processing is limited to these purposes. This means that the
data will be restricted and not processed for other purposes. This applies, for
example, to data that must be stored for commercial or tax reasons or for which
storage is necessary to assert, exercise or defend legal claims or to protect
the rights of another natural or legal person. In the context of our
information on data processing, we may provide users with further information
on the deletion and retention of data that is specific to the respective
processing operation.
Rights of Data Subjects
Rights of the Data Subjects under the GDPR:
As data subject, you are entitled to various rights under the GDPR, which arise
in particular from Articles 15 to 21 of the GDPR:
- Right to Object: You have the right, on grounds arising from
your particular situation, to object at any time to the processing of your
personal data which is based on letter (e) or (f) of Article 6(1) GDPR,
including profiling based on those provisions. Where personal data are
processed for direct marketing purposes, you have the right to object at
any time to the processing of the personal data concerning you for the
purpose of such marketing, which includes profiling to the extent that it
is related to such direct marketing.
- Right of withdrawal for consents:
You have the right to revoke consents at any time.
- Right of access: You have the right
to request confirmation as to whether the data in question will be
processed and to be informed of this data and to receive further
information and a copy of the data in accordance with the provisions of
the law.
- Right to rectification: You have
the right, in accordance with the law, to request the completion of the
data concerning you or the rectification of the incorrect data concerning
you.
- Right to Erasure and Right to Restriction of Processing: In accordance with the statutory provisions, you have the
right to demand that the relevant data be erased immediately or,
alternatively, to demand that the processing of the data be restricted in
accordance with the statutory provisions.
- Right to data portability: You have
the right to receive data concerning you which you have provided to us in
a structured, common and machine-readable format in accordance with the
legal requirements, or to request its transmission to another controller.
- Complaint to the supervisory authority: In accordance with the law and without prejudice to any other
administrative or judicial remedy, you also have the right to lodge a
complaint with a data protection supervisory authority, in particular a
supervisory authority in the Member State where you habitually reside, the
supervisory authority of your place of work or the place of the alleged
infringement, if you consider that the processing of personal data
concerning you infringes the GDPR.
Rights of the data subjects under the Swiss
DPA:
As the data subject, you have the following
rights in accordance with the provisions of the Swiss DPA:
- Right to information: You have the
right to request confirmation as to whether personal data concerning you
are being processed, and to receive the information necessary for you to
assert your rights under the Swiss DPA and to ensure transparent data
processing.
- Right to data release or transfer: You
have the right to request the release of your personal data, which you
have provided to us, in a common electronic format, as well as its
transfer to another data controller, provided this does not require
disproportionate effort.
- Right to rectification: You have
the right to request the rectification of inaccurate personal data
concerning you.
- Right to object, deletion, and destruction: You have the right to object to the processing of your data, as
well as to request that personal data concerning you be deleted or
destroyed.
Use of Cookies
Cookies are small text files or other data
records that store information on end devices and read information from the end
devices. For example, to store the login status in a user account, the contents
of a shopping cart in an e-shop, the contents accessed or the functions used.
Cookies can also be used for various purposes, e.g. for purposes of
functionality, security and convenience of online offers as well as the
creation of analyses of visitor flows.
Information on consent: We use cookies in accordance with the statutory provisions.
Therefore, we obtain prior consent from users, except when it is not required
by law. In particular, consent is not required if the storage and reading of
information, including cookies, is strictly necessary in order to provide an
information society service explicitly requested by the subscriber or user.
Essential cookies usually include cookies with functions related to the display
and operability of the onlineservice, load balancing, security, storage of
users' preferences and choices or similar purposes related to the provision of
the main and secondary functions of the onlineservice requested by users. The
revocable consent will be clearly communicated to the user and will contain the
information on the respective cookie use.
Information on legal bases under data
protection law: The legal basis under data
protection law on which we process users' personal data with the use of cookies
depends on whether we ask users for consent. If users consent, the legal basis
for processing their data is their declared consent. Otherwise, the data
processed with the help of cookies is processed on the basis of our legitimate
interests (e.g. in a business operation of our online services and improvement
of its usability) or, if this is done in the context of the fulfillment of our
contractual obligations, if the use of cookies is necessary to fulfill our
contractual obligations. For which purposes the cookies are processed by us, we
do clarify in the course of this privacy policy or in the context of our
consent and processing procedures.
Retention period: With regard to the retention period, a distinction is drawn between
the following types of cookies:
- Temporary cookies (also known as "session cookies"): Temporary cookies are deleted at the latest after a user has
left an online service and closed his or her end device (i.e. browser or
mobile application).
- Permanent cookies: Permanent
cookies remain stored even after the terminal device is closed. For
example, the login status can be saved, or preferred content can be
displayed directly when the user visits a website again. Likewise, user
data collected with the help of cookies can be used for reach measurement.
Unless we provide users with explicit information about the type and
storage duration of cookies (e.g., as part of obtaining consent), users
should assume that cookies are permanent and that the storage period can
be up to two years.
General notes on revocation and
objection (so-called "Opt-Out"): Users
can revoke the consents they have given at any time and object to the
processing in accordance with legal requirements. Users can restrict the use of
cookies in their browser settings, among other options (although this may also
limit the functionality of our online offering). A objection to the use of
cookies for online marketing purposes can also be made through the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.
- Legal Basis: Legitimate Interests
(Article 6 (1) (f) GDPR). Consent (Article 6 (1) (a) GDPR).
Further information on processing
methods, procedures and services used:
- Processing Cookie Data on the Basis of Consent: We use a cookie management solution in which users' consent to
the use of cookies, or the procedures and providers mentioned in the
cookie management solution, can be obtained, managed and revoked by the
users. The declaration of consent is stored so that it does not have to be
retrieved again and the consent can be proven in accordance with the legal
obligation. Storage can take place server-sided and/or in a cookie
(so-called opt-out cookie or with the aid of comparable technologies) in
order to be able to assign the consent to a user or and/or his/her device.
Subject to individual details of the providers of cookie management
services, the following information applies: The duration of the storage
of the consent can be up to two years. In this case, a pseudonymous user
identifier is formed and stored with the date/time of consent, information
on the scope of the consent (e.g. which categories of cookies and/or
service providers) as well as the browser, system and used end device; Legal
Basis: Consent (Article 6 (1) (a) GDPR).
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 context of contractual and
comparable legal relationships as well as associated actions and communication
with the contractual partners or pre-contractually, e.g. to answer inquiries.
We process this data in order to fulfill
our contractual obligations. These include, in particular, the obligations to
provide the agreed services, any update obligations and remedies in the event
of warranty and other service disruptions. In addition, we process the data to
protect our rights and for the purpose of administrative tasks associated with
these obligations and company organization. Furthermore, we process the data on
the basis of our legitimate interests in proper and economical business
management as well as security measures to protect our contractual partners and
our business operations from misuse, endangerment of their data, secrets,
information and rights (e.g. for the involvement of telecommunications,
transport and other auxiliary services as well as subcontractors, banks, tax
and legal advisors, payment service providers or tax authorities). Within the
framework of applicable law, we only disclose the data of contractual partners
to third parties to the extent that this is necessary for the aforementioned purposes
or to fulfill legal obligations. Contractual partners will be informed about
further forms of processing, e.g. for marketing purposes, within the scope of
this privacy policy.
Which data are necessary for the
aforementioned purposes, we inform the contracting partners before or in the
context of the data collection, e.g. in online forms by special marking (e.g.
colors), and/or symbols (e.g. asterisks or the like), or personally.
We delete the data after expiry of
statutory warranty and comparable obligations, i.e. in principle after expiry
of 4 years, unless the data is stored in a customer account or must be kept for
legal reasons of archiving. The statutory retention period for documents
relevant under tax law as well as for commercial books, inventories, opening
balance sheets, annual financial statements, the instructions required to
understand these documents and other organizational documents and accounting
records is ten years and for received commercial and business letters and
reproductions of sent commercial and business letters six years. 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 statements
or the management report was prepared, the commercial or business letter was
received or sent, or the accounting document was created, furthermore the
record was made or the other documents were created.
If we use third-party providers or
platforms to provide our services, the terms and conditions and privacy
policies of the respective third-party providers or platforms shall apply in
the relationship between the users and the providers.
- Processed data types: Inventory
data (e.g. names, addresses); Payment Data (e.g. bank details, invoices,
payment history); Contact data (e.g. e-mail, telephone numbers); Contract
data (e.g. contract object, duration, customer category); Usage data (e.g.
websites visited, interest in content, access times). Meta, communication
and process data (e.g. IP addresses, time information, identification
numbers, consent status).
- Data subjects: Customers;
Prospective customers. Business and contractual partners.
- Purposes of Processing: Provision
of contractual services and fulfillment of contractual obligations;
Security measures; Contact requests and communication; Office and
organisational procedures. Managing and responding to inquiries.
- Legal Basis: Performance of a
contract and prior requests (Article 6 (1) (b) GDPR); Compliance with a
legal obligation (Article 6 (1) (c) GDPR). Legitimate Interests (Article 6
(1) (f) GDPR).
Further information on processing
methods, procedures and services used:
- Customer Account: Customers can
create an account within our online offer (e.g. customer or user account,
"customer account" for short). If the registration of a customer
account is required, customers will be informed of this as well as of the
details required for registration. The customer accounts are not public
and cannot be indexed by search engines. In the course of registration and
subsequent registration and use of the customer account, we store the IP
addresses of the contractual partners along with the access times, in
order to be able to prove the registration and prevent any misuse of the
customer account. If the customer account has been terminated, the
customer account data will be deleted after the termination date, unless
it is retained for purposes other than provision in the customer account
or must be retained for legal reasons (e.g. internal storage of customer
data, order transactions or invoices). It is the customers' responsibility
to back up their data when terminating the customer Account; Legal
Basis: Performance of a contract and prior requests (Article 6 (1) (b)
GDPR).
- Online Shop and E-Commerce: We process
the data of our customers in order to enable them to select, purchase or
order the selected products, goods and related services, as well as their
payment and delivery, or performance of other services. If necessary for
the execution of an order, we use service providers, in particular postal,
freight and shipping companies, in order to carry out the delivery or
execution to our customers. For the processing of payment transactions we
use the services of banks and payment service providers. The required
details are identified as such in the course of the ordering or comparable
purchasing process and include the details required for delivery, or other
way of making the product available and invoicing as well as contact
information in order to be able to hold any consultation; Legal Basis:
Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
Registration, Login and User Account
Users can create a user account. Within the
scope of registration, the required mandatory information is communicated to
the users and processed for the purposes 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).
Within the scope of using our registration
and login functions as well as the use of the user account, we store the IP
address and the time of the respective user action. The storage is based on our
legitimate interests, as well as the user's protection against misuse and other
unauthorized use. This data will not be passed on to third parties unless it is
necessary to pursue our claims or there is a legal obligation to do so.
Users may be informed by e-mail of
information relevant to their user account, such as technical changes.
- Processed data types: Inventory
data (e.g. names, addresses); Contact data (e.g. e-mail, telephone
numbers); Content data (e.g. text input, photographs, videos). Meta,
communication and process data (e.g. IP addresses, time information,
identification numbers, consent status).
- Data subjects: Users (e.g. website
visitors, users of online services).
- Purposes of Processing: Provision
of contractual services and fulfillment of contractual obligations;
Security measures; Managing and responding to inquiries. Provision of our
online services and usability.
- Legal Basis: Performance of a
contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests
(Article 6 (1) (f) GDPR).
Further information on processing
methods, procedures and services used:
- Registration with a real name: Due
to the nature of our community, we ask users to use our services only with
their real names. This means that the use of pseudonyms is not permitted; Legal
Basis: Performance of a contract and prior requests (Article 6 (1) (b)
GDPR).
- Deletion of data after termination: If users have terminated their user account, their data
relating to the user account will be deleted, subject to any legal
permission, obligation or consent of the users; Legal Basis:
Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
- No obligation to retain data: 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; Legal
Basis: Performance of a contract and prior requests (Article 6 (1) (b)
GDPR).
Contact and Inquiry Management
When contacting us (e.g. via mail, contact
form, e-mail, telephone or via social media) as well as in the context of
existing user and business relationships, the information of the inquiring
persons is processed to the extent necessary to respond to the contact requests
and any requested measures.
- Processed data types: Contact data
(e.g. e-mail, telephone numbers); Content data (e.g. text input,
photographs, videos); Usage data (e.g. websites visited, interest in
content, access times). Meta, communication and process data (e.g. IP
addresses, time information, identification numbers, consent status).
- Data subjects: Communication
partner (Recipients of e-mails, letters, etc.).
- Purposes of Processing: Contact
requests and communication; Managing and responding to inquiries; Feedback
(e.g. collecting feedback via online form). Provision of our online
services and usability.
- Legal Basis: Legitimate Interests
(Article 6 (1) (f) GDPR). Performance of a contract and prior requests
(Article 6 (1) (b) GDPR).
Further information on processing
methods, procedures and services used:
- Contact form: When users contact us
via our contact form, e-mail or other communication channels, we process
the data provided to us in this context to process the communicated
request; Legal Basis: Performance of a contract and prior requests
(Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Newsletter and Electronic Communications
We send newsletters, e-mails and other
electronic communications (hereinafter referred to as "newsletters")
only with the consent of the recipient or a 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. Otherwise, our
newsletters contain information about our services and us.
In order to subscribe to our newsletters,
it is generally sufficient to enter your e-mail address. We may, however, ask
you to provide a name for the purpose of contacting you personally in the
newsletter or to provide further information if this is required for the purposes
of the newsletter.
Double opt-in procedure: The registration to our newsletter takes place in general 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 no one 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 storing the login and confirmation times as
well as the IP address. Likewise the changes of your data stored with the
dispatch service provider are logged.
Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years
based on our legitimate interests before deleting them to provide evidence of
prior consent. The processing of these data is limited to the purpose of a
possible defense against claims. An individual deletion request is possible at
any time, provided that the former existence of a consent is confirmed at the
same time. In the case of an obligation to permanently observe an objection, we
reserve the right to store the e-mail address solely for this purpose in a
blocklist.
The logging of the registration process takes
place on the basis of our legitimate interests for the purpose of proving its
proper course. If we commission a service provider to send e-mails, this is
done on the basis of our legitimate interests in an efficient and secure
sending system.
Contents:
Information about us, our services,
promotions and offers.
- Processed data types: Inventory
data (e.g. names, addresses); Contact data (e.g. e-mail, telephone
numbers); Meta, communication and process data (e.g. IP addresses, time
information, identification numbers, consent status). Usage data (e.g.
websites visited, interest in content, access times).
- Data subjects: Communication
partner (Recipients of e-mails, letters, etc.).
- Purposes of Processing: Direct
marketing (e.g. by e-mail or postal).
- Legal Basis: Consent (Article 6 (1)
(a) GDPR).
- 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.
Further information on processing
methods, procedures and services used:
- Measurement of opening rates and click rates: The newsletters contain a so-called "web-beacon",
i.e. a pixel-sized file, which is retrieved from our server when the
newsletter is opened or, if we use a mailing service provider, from its
server. Within the scope of this retrieval, technical information such as
information about the browser and your system, as well as your IP address
and 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 points (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. This information is assigned to the
individual newsletter recipients and stored in their profiles until the
profiles are deleted. The evaluations serve us much more 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 measurement of opening rates and click rates as well as the storage of
the measurement results in the profiles of the users and their further
processing are based on the consent of the users.
A separate objection to the performance measurement is unfortunately not
possible, in this case the entire newsletter subscription must be
cancelled or objected to. In this case, the stored profile information
will be deleted;
Legal Basis: Consent (Article 6 (1) (a) GDPR).
- Friendly: Friendly Automate is the Swiss software
for marketing automation and sending newsletters; service provider:
Friendly is an offering of
Friendly GmbH, Werkhofstrasse 5, 6052 Hergiswil, Schweiz
Website: https://friendly.ch/en/
Privacy Policy: https://friendly.ch/en/privacy
Web Analysis, Monitoring and Optimization
Web analysis is used to evaluate the
visitor traffic on our website and may include the behaviour, interests or
demographic information of users, such as age or gender, as pseudonymous
values. With the help of web analysis we can e.g. recognize, at which time our
online services or their functions or contents are most frequently used or
requested for repeatedly, as well as which areas require optimization.
In addition to web analysis, we can also
use test procedures, e.g. to test and optimize different versions of our online
services or their components.
Unless otherwise stated below, profiles,
i.e. data aggregated for a usage process, can be created for these purposes and
information can be stored in a browser or in a terminal device and read from
it. The information collected includes, in particular, websites visited and
elements used there as well as technical information such as the browser used,
the computer system used and information on usage times. If users have agreed
to the collection of their location data from us or from the providers of the
services we use, location data may also be processed.
Unless otherwise stated below, profiles,
that is data summarized for a usage process or user, may be created for these
purposes and stored in a browser or terminal device (so-called
"cookies") or similar processes may be used for the same purpose. The
information collected includes, in particular, websites visited and elements
used there as well as technical information such as the browser used, the
computer system used and information on usage times. If users have consented to
the collection of their location data or profiles to us or to the providers of
the services we use, these may also be processed, depending on the provider.
The IP addresses of the users are also
stored. However, we use any existing 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 (such as e-mail addresses or names) is stored, but pseudonyms. This means
that we, as well as 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 processes.
- Processed data types: Usage data
(e.g. websites visited, interest in content, access times). Meta,
communication and process data (e.g. IP addresses, time information,
identification numbers, consent status).
- Data subjects: Users (e.g. website
visitors, users of online services).
- Purposes of Processing: Web
Analytics (e.g. access statistics, recognition of returning visitors);
Profiles with user-related information (Creating user profiles). Provision
of our online services and usability.
- Security measures: IP Masking
(Pseudonymization of the IP address).
- Legal Basis: Consent (Article 6 (1)
(a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods,
procedures and services used:
- Google Analytics 4: We use Google
Analytics to perform measurement and analysis of the use of our online
services by users based on a pseudonymous user identification number. This
identification number does not contain any unique data, such as names or
email addresses. It is used to assign analysis information to an end
device in order to recognize which content users have accessed within one
or various usage processes, which search terms they have used, have
accessed again or have interacted with our online services. Likewise, the
time of use and its duration are stored, as well as the sources of users
referring to our online services and technical aspects of their end
devices and browsers. In the process, pseudonymous profiles of users are
created with information from the use of various devices, and cookies may
be used. Google Analytics does not log or store individual IP addresses.
Analytics does provide coarse geo-location data by deriving the following
metadata from IP addresses: City (and the derived latitude, and longitude
of the city), Continent, Country, Region, Subcontinent (and ID-based
counterparts). For EU-based traffic, IP-address data is used solely for
geo-location data derivation before being immediately discarded. It is not
logged, accessible, or used for any additional use cases. When Analytics
collects measurement data, all IP lookups are performed on EU-based
servers before forwarding traffic to Analytics servers for processing; Service
provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin
4, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f)
GDPR); Website: https://marketingplatform.google.com/intl/en/about/analytics/;
Privacy Policy: https://policies.google.com/privacy;
Data Processing Agreement: https://business.safety.google/adsprocessorterms/;
Basis for third country transfer:
EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms);
Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en,
Settings for the Display of Advertisements: https://adssettings.google.com/authenticated.
Further Information: https://privacy.google.com/businesses/adsservices (Types of processing and data processed).
- Google Tag Manager: Google Tag
Manager is a solution with which we can manage so-called website tags via
an interface and thus integrate other services into our online services
(please refer to further details in this privacy policy). With the Tag
Manager itself (which implements the tags), for example, no user profiles
are created or cookies are stored. Google only receives the IP address of
the user, which is necessary to run the Google Tag Manager; Service
provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin
4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://marketingplatform.google.com;
Privacy Policy: https://policies.google.com/privacy;
Data Processing Agreement: https://business.safety.google/adsprocessorterms.
Basis for third country transfer:
EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms).
Online Marketing
We process personal data for the purposes
of online marketing, which may include in particular the marketing of
advertising space or the display of advertising and other content (collectively
referred to as "Content") based on 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
procedure is used by which the relevant user information for the display of the
aforementioned content is stored. This information may include, for example,
content viewed, websites visited, online networks used, communication partners
and technical information such as the browser used, computer system used and
information on usage times and used functions. If users have consented to the
collection of their sideline data, these can also be processed.
The IP addresses of the users are also
stored. However, we use provided IP masking procedures (i.e. pseudonymisation
by shortening the IP address) to ensure the protection of the user's by using a
pseudonym. In general, within the framework of the online marketing process, no
clear user data (such as e-mail addresses or names) is secured, 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 similar memorizing procedures. These cookies can
later, generally also on other websites that use the same online marketing
technology, be read and analyzed for purposes of content display, as well as
supplemented with other data and stored on the server of the online marketing
technology provider.
Exceptionally, clear data can be assigned
to the profiles. This is the case, for example, if the users are members of a
social network whose online marketing technology we use and the network links
the profiles of the users in the aforementioned data. Please note that users
may enter into additional agreements with the social network providers or other
service providers, e.g. by consenting as part of a registration process.
As a matter of principle, we only gain
access to summarised information about the performance of our advertisements.
However, within the framework of so-called conversion measurement, we can check
which of our online marketing processes have led to a so-called conversion,
i.e. to the conclusion of a contract with us. The conversion measurement is
used alone for the performance analysis of our marketing activities.
Unless otherwise stated, we kindly ask you
to consider that cookies used will be stored for a period of two years.
- Processed data types: Content data
(e.g. text input, photographs, videos); Usage data (e.g. websites visited,
interest in content, access times); Meta, communication and process data
(e.g. IP addresses, time information, identification numbers, consent
status); Event Data (Facebook) ("Event Data" is data that can be
transmitted from us to Facebook, e.g. via Facebook pixels (via apps or
other means) and relates to persons or their actions; the data includes,
for example, information about visits to websites, interactions with content,
functions, installations of apps, purchases of products, etc.; Event data
is processed for the purpose of creating target groups for content and
advertising information (Custom Audiences). Event Data does not include
the actual content (such as written comments), login information, and
Contact Information (such as names, email addresses, and phone numbers).
Event Data is deleted by Facebook after a maximum of two years, the Custom
Audiences created from them with the deletion of our Facebook account).
- Data subjects: Users (e.g. website
visitors, users of online services).
- Purposes of Processing: Web
Analytics (e.g. access statistics, recognition of returning visitors);
Targeting (e.g. profiling based on interests and behaviour, use of
cookies); Conversion tracking (Measurement of the effectiveness of
marketing activities); Affiliate Tracking; Marketing; Profiles with
user-related information (Creating user profiles). Provision of our online
services and usability.
- Security measures: IP Masking
(Pseudonymization of the IP address).
- Legal Basis: Consent (Article 6 (1)
(a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing
methods, procedures and services used:
- Meta Pixel and Custom Audiences (Custom Audiences): With the help of the Meta-Pixel
(or equivalent functions, to transfer Event-Data or Contact
Information via interfaces or other software in apps), Meta is on the one
hand able to determine the visitors of our online services as a target
group for the presentation of ads (so-called "Meta ads").
Accordingly, we use Meta-Pixels to display Meta ads placed by us only to
Meta users and within the services of partners cooperating with Meta
(so-called "audience network" https://www.facebook.com/audiencenetwork/ ) who have shown an interest in our online services or who have certain
characteristics (e.g. interests in certain topics or products that are
determined on the basis of the websites visited) that we transmit to Meta
(so-called "custom audiences"). With the help of Meta-Pixels, we
also want to ensure that our Meta ads correspond to the potential interest
of users and do not appear annoying. The Meta-Pixel also enables us to
track the effectiveness of Meta ads for statistical and market research
purposes by showing whether users were referred to our website after
clicking on a Meta ad (known as "conversion tracking"); Service
provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand
Canal Harbour, Dublin 2, Ireland; Legal Basis: Consent (Article 6
(1) (a) GDPR); Website: https://www.facebook.com;
Privacy Policy: https://www.facebook.com/about/privacy;
Data Processing Agreement: https://www.facebook.com/legal/terms/dataprocessing;
Basis for third country transfer:
EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
Further Information: User event data, i.e. behavioral and interest
data, is processed for the purposes of targeted advertising and audience
building on the basis of the joint controllership agreement
("Controller Addendum", https://www.facebook.com/legal/controller_addendum).
The joint controllership is limited to the collection and transfer of the
data to Meta Platforms Ireland Limited, a company located in the EU.
Further processing of the data is the sole responsibility of Meta
Platforms Ireland Limited, which concerns in particular the transfer of
the data to the parent company Meta Platforms, Inc. in the USA (on the
basis of standard contractual clauses concluded between Meta Platforms
Ireland Limited and Meta Platforms, Inc.).
- Facebook Ads: Placement of ads within the Facebook
platform and analysis of ad results; Service provider: Meta
Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour,
Dublin 2, Ireland; Legal Basis: Legitimate Interests (Article 6 (1)
(f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Basis for third country transfer: EU-US Data Privacy Framework (DPF); Opt-Out:
Wir verweisen auf die Datenschutz- und Werbeeinstellungen im Profil des
Nutzers auf der Facebook-Plattform sowie auf das Einwilligungsverfahren
von Facebook und die Kontaktmöglichkeiten von Facebook zur Ausübung von
Informations- und sonstigen Betroffenenrechten in der Datenschutzerklärung
von Facebook. Further Information: User event data, i.e. behavioral and interest data, is
processed for the purposes of targeted advertising and audience building
on the basis of the joint controllership agreement ("Controller
Addendum", https://www.facebook.com/legal/controller_addendum).
The joint controllership is limited to the collection and transfer of the
data to Meta Platforms Ireland Limited, a company located in the EU.
Further processing of the data is the sole responsibility of Meta
Platforms Ireland Limited, which concerns in particular the transfer of
the data to the parent company Meta Platforms, Inc. in the USA (on the
basis of standard contractual clauses concluded between Meta Platforms
Ireland Limited and Meta Platforms, Inc.).
- Google Ads and Conversion Tracking: Online marketing process for purposes of placing content and
advertisements within the provider's advertising network (e.g., in search
results, in videos, on web pages, etc.) so that they are displayed to
users who have a presumed interest in the ads. Furthermore, we measure the
conversion of the ads, i.e. whether the users took them as a reason to
interact with the ads and make use of the advertised offers (so-called
conversion). However, we only receive anonymous information and no
personal information about individual users; Service provider:
Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal
Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests (Article
6 (1) (f) GDPR); Website: https://marketingplatform.google.com;
Privacy Policy: https://policies.google.com/privacy;
Basis for third country transfer:
EU-US Data Privacy Framework (DPF); Further Information:
Types of processing and data processed: https://privacy.google.com/businesses/adsservices.
Google Ads Controller-Controller Data Protection Terms and standard
contractual clauses for data transfers to third countries: https://business.safety.google/adscontrollerterms.
- Instagram Ads: Placement of ads
within the Instagram platform and analysis of ad results; Service
provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand
Canal Harbour, Dublin 2, Ireland; Legal Basis: Consent (Article 6
(1) (a) GDPR); Website: https://www.instagram.com;
Privacy Policy: https://instagram.com/about/legal/privacy;
Basis for third country transfer:
EU-US Data Privacy Framework (DPF); Opt-Out: We refer to the
data protection and advertising settings in the user's profile on the
Instagram platform as well as Instagram's consent procedure and Instagram's
contact options for exercising information and other data subject rights
in Instagram's privacy policy. Further Information: User event
data, i.e. behavioral and interest data, is processed for the purposes of
targeted advertising and audience building on the basis of the joint
controllership agreement ("Controller Addendum", https://www.facebook.com/legal/controller_addendum).
The joint controllership is limited to the collection and transfer of the
data to Meta Platforms Ireland Limited, a company located in the EU.
Further processing of the data is the sole responsibility of Meta
Platforms Ireland Limited, which concerns in particular the transfer of
the data to the parent company Meta Platforms, Inc. in the USA (on the
basis of standard contractual clauses concluded between Meta Platforms
Ireland Limited and Meta Platforms, Inc.).
Profiles in Social Networks (Social Media)
We maintain online presences within social
networks and process user data in this context in order to communicate with the
users active there or to offer information about us.
We would like to point out that user data
may be processed outside the European Union. This may entail risks for users,
e.g. by making it more difficult to enforce users' rights.
In addition, 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
associated interests of users. The user profiles can then be used, for example,
to place advertisements within and outside the networks which are presumed to
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 be stored in the user profiles
independently of the devices used by the users (especially if the users are
members of the respective networks or will become members later on).
For a detailed description of the
respective processing operations and the opt-out options, please refer to the
respective data protection declarations and information provided by the
providers of the respective networks.
Also in the case of requests for
information and the exercise of rights of data subjects, we point out that
these can be most effectively pursued with the providers. Only the providers
have access to the data of the users and can directly take appropriate measures
and provide information. If you still need help, please do not hesitate to
contact us.
- Processed data types: Contact data
(e.g. e-mail, telephone numbers); Content data (e.g. text input,
photographs, videos); Usage data (e.g. websites visited, interest in
content, access times). Meta, communication and process data (e.g. IP
addresses, time information, identification numbers, consent status).
- Data subjects: Users (e.g. website
visitors, users of online services).
- Purposes of Processing: Contact
requests and communication; Feedback (e.g. collecting feedback via online
form). Marketing.
- Legal Basis: Legitimate Interests
(Article 6 (1) (f) GDPR).
Further information on processing
methods, procedures and services used:
- Facebook-Seiten: Profiles within
the social network Facebook - We are jointly responsible (so called
"joint controller") with Meta Platforms Ireland Limited for the
collection (but not the further processing) of data of visitors to our
Facebook page. This data includes information about the types of content
users view or interact with, or the actions they take (see "Things
that you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/policy), and
information about the devices used by users (e.g., IP addresses, operating
system, browser type, language settings, cookie information; see
"Device Information" in the Facebook Data Policy: https://www.facebook.com/policy). As
explained in the Facebook Data Policy under "How we use this
information?" Facebook also collects and uses information to provide
analytics services, known as "page insights," to site operators
to help them understand how people interact with their pages and with
content associated with them. We have concluded a special agreement with
Facebook ("Information about Page-Insights", https://www.facebook.com/legal/terms/page_controller_addendum),
which regulates in particular the security measures that Facebook must
observe and in which Facebook has agreed to fulfill the rights of the
persons concerned (i.e. users can send information access or deletion
requests directly to Facebook). The rights of users (in particular to
access to information, erasure, 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 Basis:
Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.facebook.com; Privacy
Policy: https://www.facebook.com/about/privacy;
Basis for third country transfer:
EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (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 the
data to Meta Platforms Ireland Limited, a company located in the EU.
Further processing of the data is the sole responsibility of Meta
Platforms Ireland Limited, which concerns in particular the transfer of the
data to the parent company Meta Platforms, Inc. in the USA (on the basis
of standard contractual clauses concluded between Meta Platforms Ireland
Limited and Meta Platforms, Inc.).
- TikTok: Social network / video
plattform; Service provider: TikTok Technology Limited, 10
Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information
Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United
Kingdom, EC1A 9HP; Legal Basis: Legitimate Interests (Article 6 (1)
(f) GDPR); Website: https://www.tiktok.com.
Privacy Policy: https://www.tiktok.com/de/privacy-policy.
Plugins and embedded functions and content
Within our online services, we integrate
functional and content elements that are obtained from the servers of their
respective providers (hereinafter referred to as "third-party
providers"). These may, for example, be graphics, videos or city maps
(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 parties may
also use so-called pixel tags (invisible graphics, also known as "web
beacons") for statistical or marketing purposes. The "pixel
tags" can be used to evaluate information such as visitor traffic on the
pages of this website. The pseudonymous information may also be stored in
cookies on the user's device and may include technical information about the
browser and operating system, referring websites, visit times and other
information about the use of our website, as well as may be linked to such
information from other sources.
- Processed data types: Usage data
(e.g. websites visited, interest in content, access times); Meta,
communication and process data (e.g. IP addresses, time information,
identification numbers, consent status); Inventory data (e.g. names,
addresses); Contact data (e.g. e-mail, telephone numbers); Content data
(e.g. text input, photographs, videos). Location data (Information on the
geographical position of a device or person).
- Data subjects: Users (e.g. website
visitors, users of online services).
- Purposes of Processing: Provision
of our online services and usability. Provision of contractual services
and fulfillment of contractual obligations.
- Legal Basis: Legitimate Interests
(Article 6 (1) (f) GDPR).
Further information on processing
methods, procedures and services used:
- Google Maps: We integrate the maps
of the service "Google Maps" from the provider 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 Basis: Legitimate
Interests (Article 6 (1) (f) GDPR); Website: https://mapsplatform.google.com/;
Privacy Policy: https://policies.google.com/privacy.
Basis for third country transfer:
EU-US Data Privacy Framework (DPF).
- reCAPTCHA: We integrate the
"reCAPTCHA" function to be able to recognise whether entries
(e.g. in online forms) are made by humans and not by automatically operating
machines (so-called "bots"). The data processed may include IP
addresses, information on operating systems, devices or browsers used,
language settings, location, mouse movements, keystrokes, time spent on
websites, previously visited websites, interactions with ReCaptcha on
other websites, possibly cookies and results of manual recognition
processes (e.g. answering questions asked or selecting objects in images).
The data processing is based on our legitimate interest to protect our
online services from abusive automated crawling and spam; Service
provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin
4, Ireland, , parent company: Google LLC, 1600 Amphitheatre Parkway,
Mountain View, CA 94043, USA; Legal Basis: Legitimate Interests (Article
6 (1) (f) GDPR); Website: https://www.google.com/recaptcha/;
Privacy Policy: https://policies.google.com/privacy;
Basis for third country transfer:
EU-US Data Privacy Framework (DPF). Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the Display of
Advertisements: https://adssettings.google.com/authenticated.
- YouTube videos: Video contents; Service
provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin
4, Ireland, , parent company: Google LLC, 1600 Amphitheatre Parkway,
Mountain View, CA 94043, USA; Legal Basis: Legitimate Interests
(Article 6 (1) (f) GDPR); Website: https://www.youtube.com;
Privacy Policy: https://policies.google.com/privacy;
Basis for third country transfer:
EU-US Data Privacy Framework (DPF). Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the Display of
Advertisements: https://adssettings.google.com/authenticated.
Changes and Updates to the Privacy Policy
We kindly ask you to inform yourself
regularly about the contents of our data protection declaration. We will adjust
the privacy policy as changes in our data processing practices make this
necessary. We will inform you as soon as the changes require your cooperation
(e.g. consent) or other individual notification.
If we provide addresses and contact
information of companies and organizations in this privacy policy, we ask you
to note that addresses may change over time and to verify the information
before contacting us.
Last Update: 29. August 2023