Data protection declaration
introduction
With the following data protection declaration we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) which we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both 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 also referred to collectively as “online offer”).
The terms used are not gender-specific.
Status: October 20, 2019
Content overview
- introduction
- responsible person
- Overview of processing operations
- Relevant legal basis
- security measures
- Transmission and disclosure of personal data
- data processing in third countries
- Use of cookies
- Commercial and business services
- blogs and publication media
- contact us
- Surveys and questionnaires
- Provision of the online offer and web hosting
- cloud services
- Newsletter and Broadcast Communication
- competitions and contests
- Web analysis and optimization
- online marketing
- affiliate programs and affiliate links
- evaluation platforms
- presence in social networks
- plugins and embedded functions and content
- Planning, organization and auxiliary tools
- Deletion of data
- Amendment and update of the privacy policy
- rights of the data subjects>/li>
- Definitions of terms
responsible person
Sven Verborg
Gabelsbergerstraße, 9
50674 Cologne, Germany
E-Mail address>/strong>: hola@travel-dos.com
Imprint>/strong>: https://travel-dos.com/de/impressum/
Overview of the processings
The following overview summarises the types of data processed and the purposes of their processing, and refers to the data subjects.
types of data processed
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- stock data (e.g. names, addresses).
- content data (e.g. text entries, photographs, videos).
- meta/communication data (e.g. device information, IP addresses).
- Usage data (e.g. websites visited, interest in content, access times).
- Social data (data which are subject to social secrecy (§ 35 SGB I) and which are processed, for example, by social insurance agencies, social assistance agencies or pension authorities).
- location data (data indicating the location of an end user’s terminal device).
categories of persons concerned
- <Customers.
- Users (e.g. website visitors, users of online services).
Purposes of processing
- Provision of our online offer and user-friendliness.
- Cross-Device Tracking (cross-device processing of user data for marketing purposes).
- Feedback (e.g. collecting feedback via online form).
- Profiling (creating user profiles).
- <Remarketing.
- Range measurement (e.g. access statistics, recognition of returning visitors).
- tracking (e.g. interest/behaviour-related profiling, use of cookies).
- target group formation (determination of target groups relevant for marketing purposes or other output of contents).
Developing legal bases
In the following, we provide the legal basis of the basic data protection regulation (DSGVO), on the basis of which we process personal data. Please note that in addition to the regulations of the DSGVO, national data protection regulations may apply in your or our country of residence and domicile.
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- – The data subject has given his/her consent to the processing of personal data relating to him/her for one or more specific purposes.
– The processing is necessary to fulfil a legal obligation to which the controller is subject.
– The processing is necessary to protect the vital interests of the data subject or of another natural person.
– The processing is necessary to protect the legitimate interests of the controller or of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
National data protection regulations in Germany: In addition to the data protection regulations of the basic data protection regulation, national regulations on data protection apply in Germany. These include 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 regulations on the right to information, the right to deletion, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision making in individual cases including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.
security measures
We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection commensurate with the risk.
Those measures shall include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, safeguarding of availability and segregation of data relating to them. Furthermore, we have established procedures to ensure that data subjects’ rights are exercised, data is deleted and responses to data threats are made. 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, by designing technology and by using data protection-friendly default settings.
SSL encryption (https): To protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.
Transmission and disclosure of personal data
Within the scope of our processing of personal data, it happens that the data is transferred to other bodies, companies, legally independent organisational units or persons or that it is disclosed to them. The recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data which serve to protect your data.
Data transfer within the organization: We may transfer personal data to other entities within our organization or grant them access to such data. If this transfer is for administrative purposes, the transfer of the data is based on our legitimate business and economic interests or takes place if it is necessary to fulfil our contractual obligations or if the consent of the persons concerned or legal permission has been obtained.
Data processing in third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of services provided by third parties or the disclosure or transfer of data to other persons, bodies or companies, this is only done in accordance with the legal requirements.
Subject to express consent or to contractual or legal transfer requirements, we will only process or transfer the data in third countries with a recognised level of data protection, including the US processors certified under the Privacy Shield, or on the basis of special guarantees, such as contractual obligation through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).
use of cookies
Cookies are text files that contain data from websites or domains visited and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after his visit within an online offer. The stored information may include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was viewed. The term “cookies” also includes other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also known as “user IDs”).
The
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- Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
- Permanent cookies: Permanent cookies remain stored even after closing the browser. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users used for reach measurement or marketing purposes can be stored in such a cookie.
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Cookies can be absolutely necessary for the operation of a website (e.g. to save logins or other user entries or for security reasons).
Cookies can be used to store information about the user’s identity, such as the user’s name, address, e-mail address, etc.
<Statistical, marketing and personalisation cookies: Cookies are also generally used to measure reach and when a user’s interests or behaviour (e.g. viewing certain content, using functions etc.) on individual web pages are stored in a user profile. Such profiles are used to show users e.g. content that corresponds to their potential interests. This procedure is also known as “tracking”, i.e., following the potential interests of users. . If we use cookies or “tracking” technologies, we will inform you separately in our data protection declaration or when you give your consent.
Notes on legal bases: On which legal basis we process your personal data with the help of cookies depends on whether we ask you for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed with the aid of cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfil our contractual obligations.
General information on revocation and objection (Opt-Out): Depending on whether the processing is based on consent or legal permission, you have the possibility at any time to revoke a given consent or to object to the processing of your data by cookie technologies (collectively referred to as “Opt-Out”). You can initially declare your objection by means of the settings of your browser, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online service). An objection to the use of cookies for online marketing purposes can also be made by means of a variety of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/ or generally at http://optout.aboutads.info.
Processing of cookie data on the basis of consent: Before we process data within the scope of the use of cookies or have them processed, we ask the users for their consent, which can be revoked at any time. Before consent has not been given, cookies are used if necessary, which are necessary for the operation of our online offer. Their use is based on our interest and the interest of the users in the expected functionality of our online offer.
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- Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Users (e.g. website visitors, users of online services).
Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Commercial and business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) within the scope of contractual and comparable legal relationships and related measures and within the scope of communication with contractual partners (or pre-contractual), e.g. to answer inquiries.
We process this data for the purpose of fulfilling our contractual obligations, securing our rights and for the purposes of the administrative tasks associated with this information as well as for business organisation. Within the framework of the applicable law, we only pass on the data of the contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations or with the consent of the contractual partners (e.g. to involved telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.
We will inform the contractual partners which data is required for the above-mentioned purposes before or during the data collection, e.g. in online forms, by special marking (e.g. colours) or symbols (e.g. asterisks or similar), or personally.
We delete the data after expiry of legal warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g., as long as it must be kept for legal archiving reasons (e.g., for tax purposes usually 10 years). We will delete data that has been disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, generally after the end of the order.
If we use third-party providers or platforms to provide our services, the terms and conditions and data protection information of the respective third-party providers or platforms apply in the relationship between the users and the providers.
Economic analyses and market research: For economic reasons and in order to be able to identify market trends, wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., whereby contractual partners, interested parties, customers, visitors and users of our online offer may fall into the group of persons concerned.
The analyses are carried out for the purpose of business management evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we can, if available, take into account the profiles of registered users together with their details, e.g. on services used. The analyses serve solely to serve us and are not disclosed externally, unless they are anonymous analyses with summarized, i.e. anonymized values. Furthermore, we respect the privacy of the users and process the data for the analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as summarized data).
The required information is marked as such within the scope of the conclusion of the order, purchase order or comparable contract and includes the information required for delivery and invoicing as well as contact information in order to be able to make any necessary arrangements.
Further information on commercial services: We process the data of our customers as well as clients (hereinafter uniformly referred to as “customers”) in order to enable them to select, acquire or commission the selected services or works as well as associated activities, and also to enable them to pay for and deliver or execute or provide them.
The required information is identified as such in the context of the conclusion of the order, purchase order or comparable contract and includes the information required for the provision of services and invoicing as well as contact information in order to be able to make any necessary arrangements.
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- 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. 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).
- Purposes of processing: Contractual services and service, contact requests and communication, office and organisational procedures, management and answering of requests, visit action evaluation, interest based and behaviour based marketing, profiling (creation of user profiles).
- Legal bases: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), Legal obligation (Art. 6 para. 1 sentence 1 lit. c. DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data are processed for the purposes of the publication medium only to the extent necessary for its presentation and for communication between authors and readers or for security reasons. In addition, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.
Comments and contributions: If users leave comments or other contributions, their IP addresses may be stored on the basis of our legitimate interests. This is done for our security in case someone leaves illegal content in comments and contributions (insults, prohibited political propaganda etc.). In this case we can be prosecuted ourselves for the comment or contribution and are therefore interested in the identity of the author.
Furthermore, based on our legitimate interests, we reserve the right to process user information for the purpose of spam detection.
On the same legal basis, we reserve the right to store the IP addresses of users for the duration of surveys and to use cookies to avoid multiple voting.
The personal information provided in the comments and contributions, any contact and website information as well as the content information will be permanently stored by us until the users object.
comment subscriptions: Users can subscribe to the follow-up comments with their consent. Users will receive a confirmation email to check if they are the owner of the email address entered. Users can unsubscribe current comment subscriptions at any time. The confirmation email will contain information about the cancellation options. For the purpose of proving the users’ consent, we store the time of subscription together with the users’ IP address and delete this information when users unsubscribe from the subscription.
You can cancel the receipt of our subscription at any time, i.e. revoke your consent. We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time.
Recall of WordPress emojis and smilies: Within our WordPress blog, graphic emojis (or smilies), i.e. small graphic files expressing feelings, are used for the efficient integration of content elements, obtained from external servers. The providers of the servers collect the IP addresses of the users. This is necessary so that the emoji files can be transmitted to the users’ browsers.
Akismet anti-spam check: We use the “Akismet” service based on our legitimate interests. With the help of Akismet, comments from real people are distinguished from spam comments. For this purpose, all comments are sent to a server in the USA, where they are analyzed and stored for four days for comparison purposes. If a comment is classified as spam, the data is stored beyond this time. This information includes the name entered, the e-mail address, the IP address, the comment content, the referrer, information on the browser used and the computer system and the time of entry.
Users are welcome to use pseudonyms or to refrain from entering their name or e-mail address. They can completely prevent the transmission of data by not using our comment system. That would be a pity, but unfortunately we do not see any alternatives that work just as effectively.
DISQUS comment function: Based on our legitimate interests in efficient, secure and user-friendly comment management, we use the DISQUS comment service.
To use the DISQUS comment function, users can log in using their own DISQUS user account or an existing social media account (e.g. OpenID, Facebook, Twitter or Google). DISQUS obtains the users’ login data from the platforms. It is also possible to use the DISQUS comment function as a guest without creating or using a user account at DISQUS or one of the specified social media providers.
We merely embed DISQUS and its functions in our website, where we can influence the comments of the users. However, the users enter into a direct contractual relationship with DISQUS, within the framework of which DISQUS processes the comments of the users and is a contact partner for any deletion of the users’ data. We refer to the DISQUS data protection statement and also point out to the users that they can assume that DISQUS will store their IP address and the time of the comment in addition to the comment content. Cookies may also be stored on the users’ computers and used to display advertising.
Profile images from Gravatar: We use the Gravatar service within our online offering and especially in our blog.
Gravatar is a service where users can register and store profile pictures and their e-mail addresses. If users leave contributions or comments on other online presences (especially blogs) with their respective e-mail addresses, their profile pictures can be displayed next to the contributions or comments. For this purpose, the e-mail address provided by users is transmitted in encrypted form to Gravatar for the purpose of checking whether a profile is stored for it. This is the only purpose of transmitting the e-mail address. It will not be used for other purposes, but will be deleted afterwards.
The use of Gravatar is based on our legitimate interests, as Gravatar enables us to offer the authors of contributions and comments the possibility to personalise their contributions with a profile picture.
By displaying the images, Gravatar is able to find out the IP address of the user, as this is necessary for communication between a browser and an online service.
If users do not want a user picture linked to their email address to appear in their comments on Gravatar, they should use an email address that is not stored with Gravatar. We would also like to point out that it is also possible to use an anonymous email address or no email address at all, if users do not want their email address to be sent to Gravatar. Users can completely prevent the transmission of data by not using our comment system.
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- Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), contract data (e.g. subject matter of the contract, duration, customer category).
Users (e.g. website visitors, users of online services).
- purposes of processing: Contractual services and service, feedback (e.g. collecting feedback via online form), security measures, administration and answering of inquiries, contact inquiries and communication, provision of our online offer and user-friendliness.
- Legal bases: Fulfilment of contracts and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO), consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), protection of vital interests (Art. 6 para. 1 sentence 1 lit. d. DSGVO).
Served services and service providers:
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- Recall WordPress emojis and smilies:Recall WordPress emojis and smilies; service provider: Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA; Website: https://automattic.com; Privacy Policy: https://automattic.com/privacy.
- Akismet anti-spam check: Akismet anti-spam check; service provider: Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA; Website: https://automattic.com; Privacy Policy: https://automattic.com/privacy.
- DISQUS comment function: Service provider: DISQUS, Inc., 301 Howard St, Floor 3 San Francisco, California- 94105, USA; website: https://disqus.com/; Privacy Policy: https://help.disqus.com/terms-and-policies/disqus-privacy-policy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TRkEAAW&status=Active; Opt-out: https://disqus.com/data-sharing-settings.
Profile pictures; service provider: Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA; Website: https://automattic.com; Privacy policy: https://automattic.com/privacy.
https://www.wordfence.com; Privacy Policy: https://www.wordfence.com/privacy-policy/; Standard contractual clauses (ensuring the level of data protection in case of processing in the third country): https://www.wordfence.com/gdpr/dpa.pdf.
contact establishment
When contacting us (e.g. via contact form, e-mail, telephone or social media), the data of the inquiring persons will be processed to the extent necessary to answer the contact inquiries and any requested measures.
The answering of contact inquiries within the scope of contractual or pre-contractual relations is carried out in order to fulfil our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of the legitimate interest in answering the inquiries.
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- Stock data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos).
Communication partner
Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
surveys and interviews
The surveys and questionnaires (hereinafter referred to as “surveys”) carried out by us are evaluated anonymously. Personal data is only processed to the extent necessary to provide and technically implement the surveys (e.g. processing of the IP address to display the survey in the user’s browser or to enable the survey to be resumed using a temporary cookie (session cookie)) or users have consented to this.
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- Processed data types: Contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Communication partners, users (e.g. website visitors, users of online services).
- purposes of processing: Contact requests and communication, direct marketing (e.g. by e-mail or post), tracking (e.g. interest/behavioural profiling, use of cookies), feedback (e.g. collecting feedback via online form).
Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Served services and service providers:
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- https://firebase.google.com; Privacy Policy:
https://policies.google.com/privacy
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- ; Privacy Shield (ensuring the level of data protection when processing data in the USA):
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active
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- ; opt-out: opt-out plugin:
http://tools.google.com/dlpage/gaoptout?hl=en
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- , settings for the display of advertising inserts:
https://adssettings.google.com/authenticated
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Provision of the online offer and web hosting
In order to provide our online services securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online services can be accessed. For these purposes we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security and technical maintenance services.
The data processed within the scope of providing the hosting offer may include all data concerning the users of our online offer, which are generated within the scope of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.
E-Mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the sending of e-mails (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of SPAM detection. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.
Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). Server log files may include the address and name of the web pages and files accessed, date and time of access, data volume transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.
The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the capacity utilisation of the servers and their stability.
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- Processed data types: Content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Users (e.g. website visitors, users of online services).
Served services and service providers:
- 1&1 IONOS: hosting platform for e-commerce / websites; service provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany; website: https://www.ionos.de; Privacy policy: https://www.ionos.de/terms-gtc/terms-privacy.
Cloud services
We use software services accessible via the Internet and running on the servers of their providers (so-called “cloud services”, also referred to as “Software as a Service”) for the following purposes: document storage and management, calendar management, e-mailing, spreadsheets and presentations, exchanging documents, content and information with specific recipients or publishing web pages, forms or other content and information, and chatting and participating in audio and video conferences.
In this context, personal data may be processed and stored on the servers of the providers if they are part of communication processes with us or otherwise processed by us as set out in this privacy policy. Such data may include, in particular, master data and contact details of users, data on procedures, contracts, other processes and their contents. The providers of the cloud services also process usage data and metadata that are used by them for security purposes and for service optimization.
If we use the cloud services to provide other users or publicly accessible websites with forms or other documents and content, the providers may store cookies on the users’ devices for web analysis purposes or to remember user settings (e.g. in the case of media control).
Notes on legal bases: If we ask for consent to use the cloud services, the legal basis for processing is consent. Furthermore, their use can be a component of our (pre-)contractual services, provided that the use of the cloud services has been agreed in this context. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient and secure administration and collaboration processes).
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- Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Customers, employees (e.g. employees, applicants, former employees), interested parties, communication partners.
Office and organisational procedures.
Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Served services and service providers:
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- https://www.dropbox.com/de; Privacy Policy:
https://www.dropbox.com/privacy
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- ; Privacy Shield (ensuring the level of data protection when processing data in the USA):
https://www.privacyshield.gov/participant?id=a2zt0000000GnCLAA0&status=Active
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- ; Standard contractual clauses (guarantee of the level of data protection when processing in a third country):
https://www.dropbox.com/terms/business-agreement-2016
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- Google Cloud Services: Cloud storage services; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://cloud.google.com/; Privacy policy: https://www.google.com/policies/privacy; Security advice: https://cloud.google.com/security/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000000001L5AAI&status=Aktive; Standard contractual clauses (guarantee of the level of data protection in the case of processing in the third country): https://cloud.google.com/terms/data-processing-terms; Additional information on data protection: https://cloud.google.com/terms/data-processing-terms.
http://microsoft.com/de-de; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement; Security Advice: https://www.microsoft.com/en-en/trustcenter; Privacy Shield (guarantee of data protection level when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active.
Newsletter and broadband communication
We send newsletters, e-mails and other electronic notifications (hereinafter “newsletters”) only with the consent of the recipients or a legal permission. If the contents of the newsletter are specifically described in the context of a registration for the newsletter, they are decisive for the consent of the users. Furthermore, our newsletters contain information about our services and us.
To register for our newsletters, it is basically sufficient to provide your e-mail address. However, we may ask you to provide a name for the purpose of personal contact in the newsletter, or other details if these are necessary for the purposes of the newsletter.
Double-Opt-In-Procedure: The registration for our newsletter is basically done in a so-called Double-Opt-In-Procedure. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with foreign e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored by the shipping service provider are also logged.
Deletion and restriction of processing: We may store the deleted e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that we have previously given our consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time. In case of obligations to permanently observe contradictions, we reserve the right to store the e-mail address in a blacklist for this purpose alone.
The logging of the registration procedure is carried out on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.
Notes on legal bases: The dispatch of newsletters is based on the consent of the recipients or, if consent is not required, on our legitimate interests in direct marketing, if and insofar as this is permitted by law, e.g. in the case of advertising to existing customers. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests in order to prove that it was carried out in accordance with the law.
Contents: Information about us, our services, promotions and offers, latest articles.
Measurement of success: The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened, or, if we use a shipping service provider, from their server. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and the time of the retrieval, is initially collected.
This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined by means of the IP address) or the access times. This analysis also includes determining whether the newsletter is opened, when it is opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our endeavour nor, if used, that of the dispatch service provider to observe individual users. Rather, the evaluations serve to identify the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
The evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves our business interests and meets the expectations of the users.
A separate revocation of the performance measurement is unfortunately not possible, in which case the entire newsletter subscription must be cancelled or objected to.
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- Stock data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
Communication partner.
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- purposes of processing: direct marketing (e.g. by e-mail or by post).
Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Served services and service providers:
- Mailchimp: e-mail marketing platform; service provider: “Mailchimp” – Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; website: https://mailchimp.com; Privacy policy: https://mailchimp.com/legal/privacy/; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active.
Contests and competitions
We process personal data of participants in competitions and contests only in compliance with the relevant data protection regulations, insofar as the processing is contractually required for the provision, implementation and handling of the competition, the participants have consented to the processing or the processing serves our legitimate interests (e.g. in the security of the competition or the protection of our interests from misuse by possible collection of IP addresses when submitting competition entries).
If contributions of the participants are published in the context of the competitions (e.g. in the context of a vote or presentation of the competition contributions or the winners or the reporting on the competition), we point out that the names of the participants may also be published in this context. The participants can object to this at any time.
If the competition takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as “online platform”), the terms of use and data protection provisions of the respective platforms shall apply additionally. In these cases, we would like to point out that we are responsible for the information provided by the participants in the course of the competition and that enquiries regarding the competition should be addressed to us.
The participants’ data will be deleted as soon as the competition or contest has ended and the data is no longer required to inform the winners or because queries regarding the competition can be expected. In principle, the participants’ data will be deleted at the latest 6 months after the end of the competition. Data of the winners may be retained for a longer period of time, e.g. in order to be able to answer questions about the prizes or to be able to fulfil the services of the prize; in this case the retention period depends on the type of prize and is up to three years, e.g. in the case of items or services, in order to be able to process warranty claims. Furthermore, the participants’ data may be stored for longer, e.g. in the form of reports on the competition in online and offline media.
If data has also been collected for other purposes within the scope of the competition, its processing and the duration of storage are governed by the data protection information for this use (e.g. in the case of registration for the newsletter within the scope of a competition).
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- Stock data (e.g. names, addresses), content data (e.g. text entries, photographs, videos).
Purposes of processing: Conducting competitions and contests.
Web analysis and optimization
Web analysis (also known as “reach measurement”) is used to evaluate the streams of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the range analysis we can, for example, identify at what time our online offer or its functions or contents are most frequently used or invite reuse. We can also understand which areas require optimization.
In addition to web analysis, we can also use test procedures, e.g. to test and optimise different versions of our online offer or its components.
For these purposes, so-called user profiles can be created and stored in a file (so-called “cookie”) or similar procedures with the same purpose can be used. This information may include, for example, content viewed, web pages visited and elements used there, and technical information such as the browser used, the computer system used and information on times of use. If users have consented to the collection of their location data, this data may also be processed, depending on the provider.
The IP addresses of users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect the users. In general, the data stored in the context of web analysis, A/B testing and optimization are not clear user data (such as e-mail addresses or names), 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 procedures.
Notes on legal bases: If we ask the users for their consent to the use of third party providers, the legal basis for the processing of data is consent. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
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- Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Users (e.g. website visitors, users of online services).
- Purposes of processing:Range measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behaviour-related profiling, use of cookies), visitor action evaluation, profiling (creation of user profiles).
Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Served services and service providers:
Online marketing
We process personal data for online marketing purposes, 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 procedures are used, by means of which the user information relevant for the presentation of the aforementioned content is stored. This information may include, for example, the content viewed, web pages visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed.
The IP addresses of users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect the users. In general, the online marketing procedure does not store any clear user data (such as e-mail addresses or names), but pseudonyms. This means that we as well as the providers of the online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles.
As a rule, the information in the profiles is stored in the cookies or by means of similar procedures. These cookies can later be read out and analysed for the purpose of presenting content on other websites that use the same online marketing procedure, and can also be supplemented with additional data and stored on the server of the online marketing procedure provider.
As an exception, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing procedure we use and the network connects the profiles of the users in the aforementioned data. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.
As a matter of principle, we only receive access to summarized information about the success of our advertisements. However, we can check in the context of so-called conversion measurements which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyse the success of our marketing measures.
Notes on legal bases: If we ask users to give their consent to the use of third party providers, the legal basis for processing data is consent. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
Facebook pixel: On the one hand, the Facebook pixel enables Facebook to determine the visitors of our online offer as a target group for the presentation of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to ensure that the Facebook ads placed by us are only shown to those users on Facebook and within the services of partners cooperating with Facebook (so-called “Audience Network” https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offering or who have certain characteristics (e.g. interest in certain topics or products, which can be seen from the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of the users and do not appear to be annoying. The Facebook Pixel also allows us to track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook ad (so-called “conversion measurement”).
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- Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (data indicating the location of an end user’s terminal device), social data (data subject to social secrecy (§ 35 SGB I) and processed by e.g. social insurance carriers, social welfare institutions or pension authorities).
Users (e.g. website visitors, users of online services), interested parties, customers, employees (e.g. employees, applicants, former employees), communication partners.
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- purposes of processing: Tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, visitor action evaluation, interest-based and behaviour-based marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g.e.g. access statistics, recognition of returning visitors), target group formation (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes).
Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
- Possibility of objection (Opt-Out): We refer to the data protection notices of the respective providers and the possibilities of objection (so-called “Opt-Out”) indicated to the providers. If no explicit opt-out option has been specified, it is possible to switch off cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary form for the respective areas:a) Europe: https://www.youronlinechoices.eu.
(b) Canada: https://www.youradchoices.ca/choices.
(c) USA: https://www.aboutads.info/choices.
(d) Cross-area: http://optout.aboutads.info.
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Served services and service providers:
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- Google Tag Manager is a solution that allows us to manage so-called website tags via an interface (and thus integrate Google Analytics and other Google marketing services into our online offering, for example). The Tag Manager itself (which implements the tags) does not process any personal data of the users. With regard to the processing of users’ personal data, we refer to the following information on Google services. Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website:
https://marketingplatform.google.com
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- ; Privacy Policy:
https://policies.google.com/privacy
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- ; Privacy Shield (ensuring the level of data protection when processing data in the USA):
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active
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Online marketing and web analytics; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; opt-out: opt-out plugin: http://tools.google.com/dlpage/gaoptout?hl=en, settings for the display of advertising inserts: https://adssettings.google.com/authenticated.
https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- Google Optimize: Use of Google Analytics data for the purpose of improving areas of our online offering and better aligning our marketing measures with the potential interests of users; service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://optimize.google.com; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; opt-out: opt-out plugin: http://tools.google.com/dlpage/gaoptout?hl=en, settings for the display of advertising inserts: https://adssettings.google.com/authenticated.
- Google Adsense with personalized ads: We use the service Google Adsense with personalized ads, with the help of which ads are displayed within our online offer and we receive a remuneration for their display or other use ; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- Facebook pixels: Facebook pixels; service provider: https://www.facebook.com, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Opt-out: https://www.facebook.com/settings?tab=ads.
- LinkedIn: Insights Tag / Conversion measurement; service provider: LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA; website: https://www.linkedin.com; Security measures: IP masking (pseudonymisation of the IP address); Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Cookie Policy: https://www.linkedin.com/legal/cookie_policy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active; Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
https://twitter.com/de; Privacy Policy: https://twitter.com/de/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active; Opt-out: https://twitter.com/personalization.
affiliate programs and affiliate links
In our online offer we include so-called affiliate links or other references (which may include discount codes, for example) to the offers and services of third parties (collectively referred to as “affiliate links”). If users follow the affiliate links, or subsequently take advantage of the offers, we may receive commission or other benefits from these third parties (collectively, “commission”).
In order to be able to track whether users have taken advantage of the offers of an affiliate link we have set up, it is necessary for the respective third party providers to learn that users have followed an affiliate link set up within our online offering. The assignment of the affiliate links to the respective business transactions or other actions (e.g. purchases) serves the sole purpose of the commission settlement and is cancelled as soon as it is no longer necessary for the purpose.
For the purposes of the aforementioned assignment of affiliate links, the affiliate links may be supplemented by certain values which are a component of the link or may be stored elsewhere, e.g. in a cookie. These values can include in particular the initial website (referrer), the time, an online identification of the operator of the website on which the affiliate link was located, an online identification of the respective offer, the type of link used, the type of offer and an online identification of the user.
Notes on legal bases: If we ask the users for their consent to the use of third party providers, the legal basis for processing data is consent. Furthermore, their use can be a component of our (pre-)contractual services, provided that the use of the third party providers has been agreed within this framework. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
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- Processed data types: Contract data (e.g. object of contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history).
Users (e.g. website visitors, users of online services), customers.
Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Served services and service providers:
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- https://www.amazon.de; Privacy policy:
https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010
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- ; Privacy Shield (guarantee of data protection level for processing of data in the USA):
https://www.privacyshield.gov/participant?id=a2zt0000000TOWQAA4&status=Active
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- AWIN partner program (formerly Zanox and Affilinet): service provider: AWIN AG, Eichhornstr. 3, 10785 Berlin, Germany; website: https://www.awin.com/de; Privacy policy: https://www.awin.com/de/rechtliches/privacy-policy-DACH.
Service Provider: Booking.com B.V., Herengracht 597, 1017 CE Amsterdam, The Netherlands; website: https://www.booking.com; Privacy Policy: https://www.booking.com/content/privacy.de.html.
Service Provider: Digistore24 GmbH, St.-Godehard-Straße 32, 31139 Hildesheim, Germany; Website: https://www.digistore24.com; Privacy policy: https://www.digistore24.com/page/privacy.
Service provider: eBay Partner Network, Inc., 2145 Hamilton Ave., San Jose, CA 95125, USA; website: https://partnernetwork.ebay.de; Privacy policy: https://partnernetwork.ebay.de/legal#privacy-policy.
Service Provider: Tradedoubler GmbH, Herzog-Wilhelm-Strasse 26, 80331 Munich, Germany; Website: https://www.tradedoubler.com/de; Privacy Policy: https://www.tradedoubler.com/de/privacy-policy.
evaluation platforms
We participate in evaluation procedures to evaluate, optimize and promote our services. If users evaluate or otherwise provide feedback to us via the participating evaluation platforms or procedures, the general terms and conditions of business or use and the data protection notices of the providers also apply. As a rule, evaluation also requires registration with the respective providers.
In order to ensure that the persons evaluating have actually made use of our services, we transmit, with the consent of the customer, the necessary data regarding the customer and the service used to the respective evaluation platform (including name, e-mail address and order number or item number). This data is used solely to verify the authenticity of the user.
Rating widget: We integrate so-called “rating widgets” into our online offer. A widget is a functional and content element integrated into our online offer that displays variable information. It can, for example, be displayed in the form of a seal or comparable element, sometimes also called a “badge”. In this case, the corresponding content of the widget is displayed within our online offer, but at that moment it is retrieved from the servers of the respective widget provider. This is the only way to always show the current content, especially the current rating. For this purpose, a data connection must be established from the website called up within our online offer to the widget provider’s server and the widget provider receives certain technical data (access data, including IP address), which are necessary to deliver the widget’s content to the user’s browser.
Furthermore, the widget provider receives information about the fact that users have visited our website. This information may be stored in a cookie and used by the widget provider to recognize which online offers participating in the evaluation process have been visited by the user. The information may be stored in a user profile and used for advertising or market research purposes.
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- Contract data (e.g. object of contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Customers, users (e.g. website visitors, users of online services).
- Purposes of processing: Feedback (e.g. collecting feedback via online form), reach measurement (e.g. access statistics, recognition of returning visitors), visit action evaluation, interest based and behavioral marketing, profiling (creating user profiles).
Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
presence in social networks
We maintain online presences within social networks in order to communicate with the users active there or to offer information about us there.
Please note that user data may be processed outside the European Union. This can result in risks for the users, because the enforcement of the users’ rights could be made more difficult. With regard to US providers that are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we would like to point out that they thereby undertake to comply with the data protection standards of the EU.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behaviour and interests of the users are stored. Furthermore, data may also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to these).
For a detailed description of the respective forms of processing and the possibilities of objection (opt-out), please refer to the data protection declarations and information provided by the operators of the respective networks.
Also in the case of requests for information and the assertion of data subject rights, we would like to point out that these can most effectively be asserted with the providers. Only the providers have access to the data of the users and can take appropriate measures and provide information directly. Should you nevertheless require assistance, please contact us.
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- Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Users (e.g. website visitors, users of online services).
Contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors), affiliate tracking.
Served services and service providers:
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- <Instagram, social network, service provider: Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA; Website:
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- ; Privacy policy:
http://instagram.com/about/legal/privacy
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https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Opt-out: Settings for advertisements: https://www.facebook.com/settings?tab=ads; Additional privacy notice: agreement on joint processing of personal data on Facebook pages: https://www.facebook.com/legal/terms/page_controller_addendum, Privacy policy for Facebook pages: https://www.facebook.com/legal/terms/information_about_page_insights_data.
https://www.linkedin.com; Privacy Shield: https://www.linkedin.com/legal/privacy-policy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active; Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
https://www.pinterest.com; Privacy policy: https://about.pinterest.com/de/privacy-policy; Opt-out: https://about.pinterest.com/de/privacy-policy.
<SlideShare: platform for presentations; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Privacy Shield (guarantee of the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active.
- TikTok: Social network; Service provider: musical.ly Inc., 10351 Santa Monica Blvd #310, Los Angeles, CA 90025 USA; Website: https://www.tiktok.com; Privacy policy: https://www.tiktok.com/de/privacy-policy.
https://twitter.com/de/privacy, (Settings) https://twitter.com/personalization; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.
https://policies.google.com/privacy; Privacy Shield (ensuring level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; Opt-out: https://adssettings.google.com/authenticated.
https://www.xing.de; Privacy policy: https://privacy.xing.com/de/datenschutzerklaerung.
Plugins and embedded functions and content
We include in our online offer functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as “third party providers”). These may be, for example, graphics, videos or social media buttons as well as contributions (hereinafter uniformly referred to as “content”).
The integration always requires that the third party providers of such content process the IP address of the users, as without the IP address they would not be able to send the content to their browsers. The IP address is therefore required for the display of these contents or functions. We make every effort to use only such content whose respective providers use the IP address only to deliver the content. Third party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain technical information about the browser and operating system, websites to be referred to, the time of visit and other details about the use of our online offer, as well as being linked to such information from other sources.
Notes on legal bases: If we ask the users for their consent to the use of third party providers, the legal basis for the processing of data is consent. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
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- Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), inventory data (e.g. names, addresses).
Users (e.g. website visitors, users of online services), communication partners.
- purposes of processing: provision of our online offer and user-friendliness, tracking (e.g. interest/behavioural profiling, use of cookies), feedback (e.g. collecting feedback via online form), contractual services and service, contact requests and communication, direct marketing (e.g.direct marketing (e.g. by e-mail or postal mail), interest based and behavioral marketing, profiling (creation of user profiles), reach measurement (e.g. access statistics, recognition of returning visitors), security measures, administration and response to inquiries.
Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO), performance of contracts and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO).
Served services and service providers:
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- AddThis: AddThis – Functions for sharing content in social networks, AddThis uses the personal information of users for the provision and execution of the sharing functions. Furthermore, AddThis may use pseudonymous information of users for marketing purposes ; service providers: AddThis, 1595 Spring Hill Rd Suite 300 Vienna, VA 22182, USA; Website: http://www.addthis.com; Privacy policy: http://www.addthis.com/privacy; Opt-out: http://www.addthis.com/privacy/opt-out.
- Facebook Social Plugins: Facebook Social Plugins – This can include content such as pictures, videos or texts and buttons with which users can share content from this online offer within Facebook. The list and appearance of the Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/; service provider: https://www.facebook.com, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Opt-Out: Settings for advertisements: https://www.facebook.com/settings?tab=ads.
https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TRkEAAW&status=Active.
- Google Maps: We integrate the maps of the service “Google Maps” of the provider Google. The processed data may include, in particular, IP addresses and location data of the users, which, however, cannot be collected without their consent (usually in the context of the settings of their mobile devices). Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://maps.google.de; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TRkEAAW&status=Active; Opt-out: Opt-out plugin: http://tools.google.com/dlpage/gaoptout?hl=en, settings for the display of advertising inserts: https://adssettings.google.com/authenticated.
- Contents from Getty Images: Integration of Getty Images – images; service provider: Getty Images, Inc., 605 5th Avenue South, Suite 400, Seattle, Washington 98104, USA; website: https://www.gettyimages.de; Privacy Policy: https://www.gettyimages.de/company/privacy-policy; Privacy Shield (guarantee of data protection level for data processing in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TNchAAG&status=Active.
https://www.instagram.com, Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Privacy policy: http://instagram.com/about/legal/privacy.
https://www.instagram.com; Privacy Shield: https://www.linkedin.com/legal/privacy-policy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active; Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
<MyFonts: Fonts; data processed in the context of font retrieval includes the identification number of the web font project (anonymized), the URL of the licensed website linked to a customer number to identify the licensee and the licensed web fonts, and the referrer URL; the anonymized web font project identification number is stored in encrypted log files containing such data for 30 days to determine the monthly number of page views; after such extraction and storage of the number of page views, the log files are deleted; service provider: Monotype Imaging Holdings Inc, 600 Unicorn Park Drive, Woburn, Massachusetts 01801, USA; Web site: https://www.myfonts.co; Privacy Policy: https://www.myfonts.com/info/legal/#Privacy.
- OpenStreetMap: We integrate the maps of the service \”OpenStreetMap\”, which are offered on the basis of the Open Data Commons Open Database License (ODbL) by the OpenStreetMap Foundation (OSMF). The user data is used by OpenStreetMap exclusively for the purpose of displaying the map functions and temporarily storing the selected settings. This data may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (as a rule, this is done as part of the settings of their mobile devices). Service provider: OpenStreetMap Foundation (OSMF); website: https://www.openstreetmap.de; Privacy policy: https://wiki.openstreetmap.org/wiki/Privacy_Policy.
https://www.pinterest.com; Privacy Policy: https://about.pinterest.com/de/privacy-policy.
- ReCaptcha: We include the function \”ReCaptcha\” for the recognition of bots, e.g. when entering data in online forms. The behavioral data of users (e.g. mouse movements or queries) are evaluated in order to be able to distinguish people from bots. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://www.google.com/recaptcha/; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TRkEAAW&status=Active; Opt-out: Opt-out plugin: http://tools.google.com/dlpage/gaoptout?hl=en, settings for the display of advertising inserts: https://adssettings.google.com/authenticated.
- Shariff: We use the data protection safe “Shariff” buttons. “Shariff” was developed to provide more privacy on the net and to replace the usual “Share” buttons of social networks. It is not the user’s browser, but the server on which this online offer is located that connects to the server of the respective social media platforms and queries, for example, the number of Likes. The user remains anonymous. More information about the Shariff project can be found at the developers of the magazine c’t: https://www.heise.de/ct/artikel/Shariff-Social-Media-Buttons-mit-Datenschutz-2467514.html; service provider: Heise Medien GmbH & Co KG, Karl-Wiechert-Allee 10, 30625 Hanover, Germany; Website: https://www.heise.de/ct/artikel/Shariff-Social-Media-Buttons-mit-Datenschutz-2467514.html; Privacy policy: https://www.heise.de/Datenschutzerklaerung-der-Heise-Medien-GmbH-Co-KG-4860.html.
- SlideShare presentations: Integration of SlideShare presentations; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Privacy Shield (guarantee of the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active.
- Soundcloud Music Player Widget: Soundcloud Music Player Widget; service provider: SoundCloud Limited, Rheinsberger Str. 76/77, 10115 Berlin, Germany; Website: https://soundcloud.com; Privacy policy: https://soundcloud.com/pages/privacy.
Spotify Music Player Widget; Service Provider: Spotify AB, Regeringsgatan 19, SE-111 53 Stockholm, Sweden; Website: https://www.spotify.com/de; Privacy policy: https://www.spotify.com/de/legal/privacy-policy/.
https://twitter.com/de; Privacy policy: https://twitter.com/de/privacy.
- Typekit fonts from Adobe: We integrate the fonts (\”Typekit fonts\”) of the provider Adobe, whereby the data of the users are used solely for the purpose of displaying the fonts in the users’ browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform presentation and taking into account possible licensing restrictions for their integration. service provider: Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Ireland; website: https://www.adobe.com/de; Privacy Policy: https://www.adobe.com/de/privacy.html; Privacy Shield (guarantee of the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TNo9AAG&status=Active.
https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; opt-out: opt-out plugin: http://tools.google.com/dlpage/gaoptout?hl=en, settings for the display of advertising inserts: https://adssettings.google.com/authenticated.
- Xing plugins and buttons: Xing plugins and buttons – This can include content such as images, videos or text and buttons with which users can share content from this online offering within Xing. Service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Website: https://www.xing.com; Privacy policy: https://privacy.xing.com/de/datenschutzerklaerung.
https://vimeo.com; Privacy policy: https://vimeo.com/privacy; Opt-out: We would like to point out that Vimeo can use Google Analytics and refer you to the privacy policy (https://policies.google.com/privacy) and the opt-out options for Google Analytics (http://tools.google.com/dlpage/gaoptout?hl=de) or Google’s settings for the use of data for marketing purposes (https://adssettings.google.com/)..
Planning, organization and auxiliary tools
We use the services, platforms and software of other providers (hereinafter referred to as “third party providers”) for the purposes of organizing, managing, planning and providing our services. When selecting third-party providers and their services, we observe the legal requirements.
In this context, personal data may be processed and stored on the servers of the third party providers. This may affect various data which we process in accordance with this data protection declaration. This data may include, in particular, master data and contact details of users, data on procedures, contracts, other processes and their contents.
If users are referred to the third-party providers or their software or platforms in the course of communication, business or other relations with us, the third-party providers may process usage data and metadata for security, service optimization or marketing purposes. We therefore request that you observe the data protection notices of the respective third-party providers.
Notes on legal bases: Insofar as we ask users for their consent to use the third-party providers, the legal basis for processing data is consent. Furthermore, their use can be a component of our (pre-)contractual services, provided that the use of the third party providers has been agreed within this framework. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
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- Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Communication partners, users (e.g. website visitors, users of online services).
Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Served services and service providers:
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- https://doodle.com/de; Privacy policy:
https://doodle.com/de/datenschutzrichtlinie
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- WeTransfer: Transfer of files via the Internet; service provider: WeTransfer BV, Oostelijke Handelskade 751, Amsterdam, 1019 BW, Netherlands; website: https://wetransfer.com; Privacy policy: https://wetransfer.com/legal/privacy.
Deletion of data
The data processed by us will be deleted in accordance with the legal requirements as soon as their consent permitted for processing is revoked or other permissions cease to apply (e.g. if the purpose for processing these data ceases to apply or if they are not necessary for the purpose).
Unless the data are deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose retention is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.
Further information on the deletion of personal data can also be provided in the individual data protection notes of this data protection declaration.
Change and update of the data protection declaration
We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes make it necessary for you to cooperate (e.g. consent) or to receive other individual notification.
Rights of the persons concerned
As data subjects, they are entitled to various rights under the DSGVO, which result in particular from Articles 15 to 18 and 21 DS-GVO:
Definitions of terms
This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined above all in Art. 4 DSGVO. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.
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- Affiliate tracking: As part of the affiliate tracking, links with the help of which the linking websites refer users to websites with product or other offers are logged. The operators of the respective linking websites can receive a commission if users follow these so-called affiliate links and then take advantage of the offers (e.g. buy goods or services). For this purpose, it is necessary for the providers to be able to track whether users who are interested in certain offers subsequently take notice of them at the instigation of the affiliate links. Therefore, for affiliate links to work, it is necessary to add certain values to them, which become part of the link or are stored elsewhere, e.g. in a cookie. These values include, in particular, the initial website (referrer), the time, an online identification of the operator of the website on which the affiliate link was located, an online identification of the respective offer, an online identification of the user as well as tracking specific values, such as advertising material ID, partner ID and categorizations.
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“Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “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 website address, a telephone number, an e-mail address, a postal address, etc.).cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behaviour or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, identify at what time visitors visit their website and what content they are interested in. This enables them to better adapt the contents of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis purposes in order to recognise returning visitors and thus obtain more precise analyses of the use of an online offering.
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<Remarketing” or “retargeting” is used when, for example, it is noted for advertising purposes in which products a user on a website is interested, in order to remind the user of these products on other websites, e.g. in advertisements.
<Controller’ shall mean any natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
<Processing: “processing” means any operation or set of operations, whether or not performed by automatic means, which is performed upon personal data. The term is broad and covers virtually all processing of data, whether it be collection, analysis, storage, communication or deletion.
One speaks of target group formation (or “custom audiences”) when target groups are determined for advertising purposes, e.g. insertion of advertisements. For example, based on a user’s interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online shop where he/she viewed the products. Lookalike Audiences” (or similar target groups) is, in turn, when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating custom audiences and lookalike audiences.
Compiled with free data protection generator.de by Dr. Thomas Schwenke