data protection

Introduction

With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also briefly referred to as "data") that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, mobile, and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offering").

The terms used are not gender-specific.

Status: 08.06.2023

Table of Contents

Controller

Owner: Jonas Hansen

Email address: lucky @ luckymes.de

Phone: 089 960 490 18

Imprint: Imprint

Contact Data Protection Officer

Owner: Jonas Hansen

Overview of Processing

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

Note: The following information includes the typical data processed and categories of data subjects (these themselves, as well as the explanations in brackets, are for clarification only and can be adjusted or deleted).

Types of Data Processed

  • Inventory data (e.g., names, addresses).
  • Content data (e.g., entries in online forms).
  • Contact data (e.g., email, phone numbers).
  • Meta/communication data (e.g., device information, IP addresses).
  • Usage data (e.g., visited websites, interest in content, access times).
  • Location data (information about the geographical position of a device or person).
  • Contract data (e.g., subject matter of contract, term, customer category).
  • Payment data (e.g., bank details, invoices, payment history).

Categories of Data Subjects

  • Business and contract partners.
  • Interested parties.
  • Communication partners.
  • Customers.
  • Users (e.g., website visitors, users of online services).

Purposes of Processing

  • Assessment of creditworthiness and solvency.
  • Provision of our online offering and user-friendliness.
  • Visit action evaluation.
  • Office and organizational procedures.
  • Cross-device tracking (cross-device processing of user data for marketing purposes).
  • Direct marketing (e.g., by email or post).
  • Interest-based and behavioral marketing.
  • Contact inquiries and communication.
  • Conversion measurement (measurement of the effectiveness of marketing measures).
  • Profiling (creation of user profiles).
  • Remarketing.
  • Reach measurement (e.g., access statistics, recognition of returning visitors).
  • Security measures.
  • Tracking (e.g., interest/behavior-based profiling, use of cookies).
  • Provision of contractual services and customer service.
  • Management and response to inquiries.
  • Target group formation (determination of target groups relevant for marketing purposes or other output of content).

Automated Decisions in Individual Cases

  • Credit report (decision based on a credit check).

Relevant Legal Bases

Below, we inform you about the legal bases of the General Data Protection Regulation (GDPR) on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations in your or our country of residence and establishment may apply. Furthermore, if more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.

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

Security Measures

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

Measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, ensuring availability, and their separation. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, the deletion of data, and responses to data breaches. We also consider the protection of personal data already during the development or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default.

SSL encryption (https): To protect your data transmitted via our online offering, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in your browser's address bar.

Transmission and Disclosure of Personal Data

In the course of our processing of personal data, it may happen that data is transmitted or disclosed to other entities, companies, legally independent organizational units, or persons. Recipients of this data may include, for example, payment institutions within the framework of payment processes, service providers commissioned with IT tasks, or providers of services and content embedded in a website. In such cases, we observe legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.

Data Processing in Third Countries

If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or if processing takes place within the framework of using third-party services or the disclosure or transmission of data to other persons, entities, or companies, this will only be done in accordance with legal requirements.

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

Use of Cookies

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

Notes on consent: We use cookies in accordance with legal provisions. Therefore, we obtain prior consent from users, unless this is not legally required. Consent is particularly not necessary if the storage and reading of information, including cookies, are absolutely necessary to provide users with a telemedia service explicitly requested by them (i.e., our online offering). The revocable consent is clearly communicated to users and contains information about the respective cookie usage.

Notes on data protection legal bases: The data protection legal basis on which we process users' personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is the given consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g., in the economic operation of our online offering and improvement of its usability) or, if this occurs within the framework of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We explain the purposes for which we process cookies in the course of this data protection declaration or within the framework of our consent and processing procedures.

Storage duration: Regarding storage duration, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their end device (e.g., browser or mobile application).
  • Persistent cookies: Persistent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user revisits a website. Likewise, the data collected from users with the help of cookies can be used for reach measurement. If we do not provide users with explicit information on the type and storage duration of cookies (e.g., within the framework of obtaining consent), users should assume that cookies are persistent and the storage duration can be up to two years.

General notes on revocation and objection (Opt-Out): Depending on whether processing is based on consent or legal permission, you have the option at any time to revoke given consent or to object to the processing of your data by cookie technologies (collectively referred to as "Opt-Out"). You can declare your objection initially through your browser settings, e.g., by deactivating the use of cookies (although this may also restrict the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared via a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can obtain further objection instructions within the information provided about the service providers and cookies used.

Processing of cookie data based on consent: We use a cookie consent management procedure, within which users' consents to the use of cookies, or the processing and providers mentioned within the cookie consent management procedure, can be obtained, managed, and revoked by users. The consent declaration is stored to avoid having to repeat the request and to be able to prove consent in accordance with legal obligations. Storage can be done server-side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies) to be able to assign the consent to a user or their device. Subject to individual information about the providers of cookie management services, the following notes apply: The duration of the storage of consent can be up to two years. A pseudonymized user identifier is created and stored with the time of consent, information about the scope of consent (e.g., which categories of cookies and/or service providers), and the browser, system, and end device used.

Cookie settings / objection option:

If you use a cookie consent banner (which is recommended), you can enter the option to call it up here (e.g., a link or a so-called [shortcode] that is automatically converted into a button/link by your software).

Notes on the processing of cookie data based on consent: You should only leave this option (and otherwise delete it) if you obtain a "real" opt-in, i.e., user consent to the use of cookies (e.g., with so-called "cookie consent/opt-in banners" or within a registration process).

Since a cookie opt-in is generally necessary according to the ECJ when using marketing tools frequently used in e-commerce (e.g., Google Analytics or Facebook Pixel), this option is pre-selected.

This means that before users have given their consent, you do not use any cookies (and do not use any third-party services within your websites that themselves use cookies). At most, the use of necessary cookies that are expected by users, such as a shopping cart function in the online shop or local reach measurement with the Matomo tool, is permissible.

Commercial and Business Services

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

We process this data to fulfill our contractual obligations, to secure our rights, and for the purposes of administrative tasks associated with this information and business organization. We only disclose the data of contract partners to third parties within the scope of applicable law insofar as this is necessary for the aforementioned purposes or to fulfill legal obligations, or with the consent of the data subjects (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). Contract partners will be informed about further forms of processing, e.g., for marketing purposes, within the framework of this data protection declaration.

We inform contract partners before or during data collection, e.g., in online forms, by special marking (e.g., colors) or symbols (e.g., asterisks or similar), or personally, which data is required for the aforementioned purposes.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e., generally after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons (e.g., for tax purposes, usually 10 years). Data disclosed to us by the contract partner in the context of an order will be deleted in accordance with the provisions of the order, generally after the end of the order.

Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between users and providers.

Customer Account: Contracting parties can create an account within our online offering (e.g., customer or user account, hereinafter "customer account"). If the registration of a customer account is required, contracting parties will be informed of this, as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. As part of the registration and subsequent logins and uses of the customer account, we store the IP addresses of customers along with the access times in order to prove the registration and to prevent any misuse of the customer account.

If customers have terminated their customer account, the data relating to the customer account will be deleted, provided that their retention is not required for legal reasons. It is the customers' responsibility to back up their data upon termination of the customer account.

Economic analyses and market research: For business reasons and to identify market trends, wishes of contracting parties and users, we analyze the data available to us regarding business transactions, contracts, inquiries, etc., whereby the group of affected persons may include contracting parties, prospects, customers, visitors, and users of our online offering.

The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g., to determine customer groups with different characteristics). In doing so, we may, if available, take into account the profiles of registered users including their details, e.g., regarding services used. The analyses serve solely our purposes and are not disclosed externally, unless they are anonymous analyses with aggregated, i.e., anonymized values. Furthermore, we respect the privacy of users and process data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g., as aggregated data).

Shop and e-commerce: We process the data of our customers to enable them to select, purchase, or order the chosen products, goods, and related services, as well as their payment and delivery or execution. If required for the execution of an order, we use service providers, in particular postal, freight, and shipping companies, to carry out the delivery or execution for our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is marked as such within the order or comparable purchase process and includes the information necessary for delivery or provision and billing, as well as contact information to enable any consultation.

  • Types of data processed: Inventory data (e.g., names, addresses), payment data (e.g., bank details, invoices, payment history), contact data (e.g., email, phone numbers), contract data (e.g., subject matter of contract, term, customer category), usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
  • Affected persons: Prospects, business and contractual partners, customers.
  • Purposes of processing: Provision of contractual services and customer service, contact inquiries and communication, office and organizational procedures, management and response to inquiries, security measures, evaluation of visit actions, interest-based and behavioral marketing, profiling (creation of user profiles).
  • Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Payment service providers

Within the scope of contractual and other legal relationships, due to legal obligations or otherwise based on our legitimate interests, we offer affected persons efficient and secure payment options and use other payment service providers in addition to banks and credit institutions (collectively "payment service providers").

The data processed by the payment service providers include inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient-related information. The information is required to carry out the transactions. However, the entered data is processed only by the payment service providers and stored by them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative notification of the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. This transmission serves the purpose of identity and creditworthiness checks. For this, we refer to the terms and conditions and the data protection notices of the payment service providers.

The terms and conditions and data protection notices of the respective payment service providers, which can be accessed on their respective websites or transaction applications, apply to payment transactions. We also refer to these for further information and for exercising rights of withdrawal, information, and other data subject rights.

  • Types of data processed: Inventory data (e.g., names, addresses), payment data (e.g., bank details, invoices, payment history), contract data (e.g., subject matter of contract, term, customer category), usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
  • Affected persons: Customers, prospects.
  • Purposes of processing: Provision of contractual services and customer service.
  • Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services used and service providers:

Provision of the online offering and web hosting

To provide our online offering securely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers managed by them) the online offering can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services.

The data processed in the course of providing the hosting service may include all information concerning the users of our online offering that arises during use and communication. This regularly includes the IP address, which is necessary to deliver the content of online offerings to browsers, and all entries made within our online offering or on websites.

Email sending and hosting: The web hosting services we use also include sending, receiving, and storing emails. For these purposes, the addresses of recipients and senders, as well as other information regarding email sending (e.g., the providers involved) and the content of the respective emails, are processed. The aforementioned data may also be processed for the purpose of SPAM detection. We kindly ask you to note that emails on the Internet are generally not sent encrypted. As a rule, emails are encrypted during 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 therefore cannot assume responsibility for the transmission path of emails 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 accessed web pages and files, date and time of access, transferred data volume, notification of successful retrieval, 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, on the one hand, for security purposes, e.g., to prevent overloading of the servers (especially in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability.

  • Types of data processed: Content data (e.g., entries in online forms), usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Contacting us

When contacting us (e.g., via contact form, email, telephone, or social media), the information of the inquiring persons is processed to the extent necessary to answer the contact inquiries and any requested measures.

Responding to contact inquiries within the scope of contractual or pre-contractual relationships is done to fulfill our contractual obligations or to respond to (pre-)contractual inquiries and otherwise based on the legitimate interests in responding to inquiries.

  • Types of data processed: Inventory data (e.g., names, addresses), contact data (e.g., email, phone numbers), content data (e.g., entries in online forms), usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
  • Affected persons: Communication partners, prospects.
  • Purposes of processing: Contact inquiries and communication, administration and response to inquiries.
  • Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services used and service providers:

  • Contact form: If users contact us via our contact form, email or other communication channels, we process the data communicated to us in this context to process the communicated concern. For this purpose, we process personal data within the framework of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfillment and otherwise on the basis of our legitimate interests and the interests of the communication partners in responding to concerns and our legal retention obligations.

Newsletter and electronic notifications

We send newsletters, emails and other electronic notifications (hereinafter "newsletters") only with the recipients' consent or a legal permission. If the content of a newsletter is specifically described as part of the registration, it is decisive for the user's consent. Otherwise, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to provide your email address. However, we may ask you for a name, for personalized addressing in the newsletter, or other information, if this is necessary for the purposes of the newsletter.

Double Opt-In Procedure: Registration for our newsletter generally takes place via a so-called double opt-in procedure. This means that after registration, you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register with other people's email addresses. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation, as well as the IP address. Changes to your data stored with the mailing service provider are also logged.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them, in order to be able to prove a previously given consent. The processing of this data will be limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is simultaneously confirmed. In the event of obligations for permanent observance of objections, we reserve the right to store the email address solely for this purpose in a blacklist.

The logging of the registration process is carried out on the basis of our legitimate interests for the purpose of proving its proper course. If we commission a service provider to send emails, 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, insofar as this is legally permitted, e.g., in the case of existing customer advertising. If we commission a service provider to send emails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to demonstrate that it was carried out in accordance with the law.

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

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

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

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

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

  • Types of data processed: Inventory data (e.g., names, addresses), contact data (e.g., email, phone numbers), meta/communication data (e.g., device information, IP addresses), usage data (e.g., visited websites, interest in content, access times).
  • Affected persons: Communication partners.
  • Purposes of processing: Direct marketing (e.g., via email or postal mail).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
  • Right to object (Opt-Out): You can cancel your subscription to our newsletter at any time, i.e., revoke your consent, or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options given above, preferably email.

Services used and service providers:

Web analytics, monitoring and optimization

Web analytics (also known as "reach measurement") is used to evaluate the visitor flows of our online offering and can include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, determine at what time our online offering or its functions or content are most frequently used or invite reuse. We can also identify areas that need optimization.

In addition to web analytics, we can also use testing procedures, for example, to test and optimize different versions of our online offering or its components.

For these purposes, so-called user profiles can be created and stored in a file (so-called "cookie") or similar procedures with the same purpose can be used. This information may include, for example, viewed content, visited websites and elements used there, 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, depending on the provider.

The IP addresses of users are also collected. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) are stored within the scope of web analysis, A/B testing, and optimization, but pseudonyms. This means that neither we nor the providers of the software used 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 users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g., visited web pages, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g., access statistics, recognition of recurring visitors), tracking (e.g., interest/behavioral profiling, use of cookies), evaluation of visit actions, profiling (creation of user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services used and service providers:

Online marketing

We process personal data for online marketing purposes, which may include in particular the marketing of advertising spaces or the display of advertising and other content (collectively referred to as "content") based on the potential interests of users, as well as 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 information relevant to the display of the aforementioned content about the user is stored. This information may include, for example, viewed content, visited websites, 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 collected. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) are stored within the scope of online marketing procedures, but pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual identity of the users, but only the information stored in their profiles.

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

In exceptional cases, clear data can be assigned to the profiles. This is the case if, for example, users are members of a social network whose online marketing procedure we use and the network links the user profiles with the aforementioned information. Please note that users can make additional agreements with the providers, for example, by consenting during registration.

We generally only have access to aggregated information about the success of our advertisements. However, within the scope of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to a contract conclusion with us. The conversion measurement is used solely to analyze the success of our marketing measures.

Unless otherwise stated, please assume that cookies used are stored for a period of two years.

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

  • Types of data processed: Usage data (e.g., visited web pages, interest in content, access times), meta/communication data (e.g., device information, IP addresses), location data (information on the geographical position of a device or person).
  • Affected persons: Users (e.g., website visitors, users of online services), prospects.
  • Purposes of processing: Tracking (e.g., interest/behavioral profiling, use of cookies), remarketing, evaluation of visit actions, interest-based and behavioral marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g., access statistics, recognition of recurring visitors), target group formation (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
  • Opt-out option: We refer to the privacy policies of the respective providers and the opt-out options provided for the providers. If no explicit opt-out option has been provided, you can disable cookies in your browser settings. However, this may restrict the functionality of our online offering. We therefore also recommend the following opt-out options, which are offered collectively for respective areas:a) Europe: https://www.youronlinechoices.eu.

Services used and service providers:

  • Facebook Pixel and audience targeting (Custom Audiences): With the help of the Facebook Pixel (or comparable functions for transmitting event data or contact information via interfaces in apps), Facebook is able to determine the visitors to our online offering as a target group for the display of advertisements (so-called "Facebook Ads"). Accordingly, we use the Facebook Pixel to display Facebook Ads placed by us only 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 visited websites) 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 users and do not appear annoying. With the help of the Facebook Pixel, we can also understand the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called "conversion measurement"); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Standard Contractual Clauses (guaranteeing data protection level for processing in third countries): The "Facebook EU Data Transfer Addendum" (https://www.facebook.com/legal/EU_data_transfer_addendum) applies in the case of commissioned processing by Facebook as the basis for the processing of event data of EU citizens in the USA and the inclusion in the "Facebook Platform Terms" (https://developers.facebook.com/terms) with regard to the independent processing of event data by Facebook for advertising purposes; Further information: The "Data Processing Terms" (https://www.facebook.com/legal/terms/dataprocessing/update) apply with regard to event data that Facebook processes on behalf of companies to provide reports and analyses; Furthermore, the "Controller Addendum" applies as an agreement on joint responsibility (Art. 26 para. 1 sentence 3 GDPR), which is relevant in the case of independent processing of event data by Facebook for targeting purposes and improving and securing Facebook products.
  • Google Ad Manager: We use the "Google Marketing Platform" (and services such as "Google Ad Manager") to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.). The Google Marketing Platform is characterized by the fact that ads are displayed in real time based on presumed user interests. This allows us to display ads for and within our online offering more targeted, in order to present users only ads that potentially match their interests. If, for example, a user is shown ads for products they have been interested in on other online offerings, this is referred to as "remarketing"; 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; Further information: Types of processing and processed data: https://privacy.google.com/businesses/adsservices; Data processing terms for Google advertising products: Information on the services data processing terms between controllers and standard contractual clauses for third country data transfers: https://business.safety.google/adscontrollerterms; if Google acts as a processor, data processing terms for Google advertising products and standard contractual clauses for third country data transfers: https://business.safety.google/adsprocessorterms.
  • Google Ads and conversion measurement: We use the "Google Ads" online marketing method to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.), so that they are displayed to users who have a presumed interest in the ads (so-called "conversion"). Furthermore, we measure the conversion of the ads. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page tagged with a "conversion tracking tag". However, we ourselves do not receive any information that would allow us to identify users; 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; Further information: Types of processing and processed data: https://privacy.google.com/businesses/adsservices; Data processing terms for Google advertising products: Information on the services data processing terms between controllers and standard contractual clauses for third country data transfers: https://business.safety.google/adscontrollerterms.

Presences in social networks (Social Media)

We maintain online presences within social networks and process user data within this framework to communicate with users active there or to offer information about ourselves.

We point out that user data may be processed outside the European Union. This may result in risks for users, for example, because the enforcement of user rights could be made more difficult.

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

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

Also, in the case of information requests and the assertion of data subject rights, we point out that these can be most effectively asserted with the providers. Only the providers have access to the user data and can directly take appropriate measures and provide information. Should you nevertheless require assistance, you can contact us.

  • Types of data processed: Inventory data (e.g., names, addresses), contact data (e.g., email, telephone numbers), content data (e.g., entries in online forms), usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Contact requests and communication, tracking (e.g., interest-based/behavioral profiling, use of cookies), remarketing, reach measurement (e.g., access statistics, recognition of recurring visitors).
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services used and service providers:

Plugins and embedded functions and content

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

The integration always requires that the third-party providers of this content process the IP address of the users, as they would not be able to send the content to the users' browsers without the IP address. The IP address is therefore necessary for the display of this content or functions. We endeavor to use only such content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. Through "pixel tags", information such as visitor traffic on the pages of this website can be evaluated. The pseudonymous information can also be stored in cookies on the users' device and contain, among other things, technical information about the browser and operating system, referring websites, visiting time, and other information about the use of our online offering, as well as be linked to such information from other sources.

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

  • Types of data processed: Usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses), location data (information on the geographical position of a device or person), content data (e.g., entries in online forms), inventory data (e.g., names, addresses), contact data (e.g., email, telephone numbers).
  • Affected persons: Users (e.g., website visitors, users of online services), communication partners.
  • Purposes of processing: Provision of our online offering and user-friendliness, provision of contractual services and customer service, contact inquiries and communication, tracking (e.g., interest-based/behavioral profiling, use of cookies), interest-based and behavioral marketing, profiling (creation of user profiles), security measures, administration and response to inquiries.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR), consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR).

Services used and service providers:

  • Facebook Plugins and Content: Facebook Social Plugins and content – This may include content such as images, videos or texts and buttons with which users can share content from this online offering within Facebook. The list and appearance of the Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/ – We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt, in the context of a transfer (but not the further processing), of "Event Data" that Facebook collects using the Facebook Social Plugins (and content embedding functions) executed on our online offering, or receives in the context of a transfer for the following purposes: a) Display of content and advertising information that corresponds to the presumed interests of users; b) Delivery of commercial and transactional messages (e.g., addressing users via Facebook Messenger); c) Improvement of ad delivery and personalization of functions and content (e.g., improving the recognition of which content or advertising information presumably corresponds to the interests of users). We have concluded a special agreement with Facebook ("Controller Addendum", https://www.facebook.com/legal/controller_addendum), which specifically regulates which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill data subject rights (i.e., users can, for example, address information or deletion requests directly to Facebook). Note: If Facebook provides us with metrics, analyses and reports (which are aggregated, i.e., contain no information about individual users and are anonymous to us), this processing does not take place within the framework of joint responsibility, but on the basis of a data processing agreement ("Data Processing Terms", https://www.facebook.com/legal/terms/dataprocessing), the "Data Security Terms" (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of standard contractual clauses ("Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy.
  • Google Fonts: We integrate the fonts ("Google Fonts") of the provider Google, whereby user data is used solely for the purpose of displaying the fonts in the users' browser. The integration takes place on the basis of our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform display, and taking into account possible licensing restrictions for their integration; 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://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy.
  • Google Maps: We integrate the maps of the "Google Maps" service from the provider Google. The data processed may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually done within 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://cloud.google.com/maps-platform; Privacy Policy: https://policies.google.com/privacy; Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for displaying advertisements: https://adssettings.google.com/authenticated.
  • reCAPTCHA: We integrate the "reCAPTCHA" function to detect whether entries (e.g., in online forms) are made by humans and not by automatically acting machines (so-called "bots"). The data processed may include IP addresses, information about operating systems, devices or browsers used, language settings, location, mouse movements, keyboard strokes, time spent on websites, previously visited websites, interactions with ReCaptcha on other websites, possibly cookies, and results of manual recognition processes (e.g., answering questions asked or selecting objects in images); 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; Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for displaying advertisements: https://adssettings.google.com/authenticated.
  • YouTube Videos: Video content; 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.youtube.com; Privacy Policy:https://policies.google.com/privacy; Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for displaying advertisements: https://adssettings.google.com/authenticated.
  • Vimeo: Video content; Service provider: Vimeo Inc., Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA; Website: https://vimeo.com; Privacy Policy: https://vimeo.com/privacy; Opt-out option: We point out that Vimeo may use Google Analytics and refer in this regard to the privacy policy (https://policies.google.com/privacy) as well as the opt-out options for Google Analytics (https://tools.google.com/dlpage/gaoptout?hl=de) or Google's settings for data use for marketing purposes (https://adssettings.google.com/).

    • Deletion of Data

    The data processed by us will be deleted in accordance with legal requirements as soon as consents given for their processing are revoked or other permissions cease to apply (e.g., if the purpose of processing this data has lapsed or they are no longer necessary for the purpose).

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

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

    Amendment and Update of the Privacy Policy

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

    If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and we ask you to check the information before contacting them.

    Rights of Data Subjects

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

    • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
    • Right to withdraw consent: You have the right to withdraw given consents at any time.
    • Right of access: You have the right to request confirmation as to whether data in question are being processed, and to information about these data as well as further information and a copy of the data in accordance with legal requirements.
    • Right to rectification: In accordance with legal requirements, you have the right to request the completion of incomplete data concerning you or the rectification of inaccurate data concerning you.
    • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to demand that data concerning you be erased without undue delay, or alternatively to demand a restriction of the processing of the data in accordance with legal requirements.
    • Right to data portability: You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, or to demand their transmission to another controller, in accordance with legal requirements.
    • Right to lodge a complaint with a supervisory authority: You also have the right, in accordance with legal requirements, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

    Definitions

    This section provides an overview of the terminology used in this privacy policy. Many of the terms are taken from the law and are defined primarily in Art. 4 GDPR. The legal definitions are binding. The following explanations, however, are primarily intended to aid understanding. The terms are sorted alphabetically.

    • Conversion Tracking: "Conversion Tracking" refers to a method by which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users' devices within the websites where the marketing measures take place and then retrieved again on the target website. For example, we can thus track whether the advertisements we have placed on other websites have been successful.
    • Credit Report: Automated decisions are based on automatic data processing without human intervention (e.g., in the case of an automatic rejection of a purchase on account, an online credit application or an online application process without any human intervention. Such automated decisions are only permissible under Art. 22 GDPR if data subjects consent, if they are necessary for the fulfillment of a contract or if national laws permit these decisions.
    • Cross-Device Tracking: Cross-device tracking is a form of tracking in which users' behavioral and interest information is collected across devices in so-called profiles by assigning an online identifier to users. This allows user information to be analyzed for marketing purposes, regardless of the browsers or devices used (e.g., mobile phones or desktop computers). With most providers, the online identifier is not linked to clear data, such as names, postal addresses or email addresses.
    • IP Masking: "IP masking" is a method in which the last octet, i.e., the last two numbers of an IP address, is deleted so that the IP address can no longer serve for the unique identification of a person. Therefore, IP masking is a means of pseudonymizing processing procedures, especially in online marketing.
    • Interest-based and behavioral marketing: Interest-based and/or behavioral marketing refers to the precise pre-determination of potential user interests in advertisements and other content. This is done based on information about their previous behavior (e.g., visiting certain websites and staying on them, purchasing behavior or interaction with other users), which is stored in a so-called profile. Cookies are usually used for these purposes.
    • Conversion Measurement: Conversion measurement is a method by which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users' devices within the websites where the marketing measures take place and then retrieved again on the target website. For example, we can thus track whether the advertisements we have placed on other websites have been successful.
    • Personal Data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
    • Profiling: "Profiling" means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person (depending on the type of profiling, this includes information concerning age, gender, location data and movement data, interaction with websites and their content, purchasing behavior, social interactions with other people) to analyze, evaluate or predict them (e.g., interest in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
    • Reach Measurement: Reach measurement (also referred to as web analytics) is used to evaluate the visitor flows of an online offering and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, website owners can, for example, determine when visitors visit their website and what content they are interested in. This allows them, for example, to better adapt the content of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis to recognize returning visitors and thus obtain more accurate analyses of the use of an online offering.
    • Remarketing: "Remarketing" or "retargeting" refers to the process where, for advertising purposes, it is noted which products a user has shown interest in on a website, in order to remind the user of these products on other websites, e.g., in advertisements.
    • Location Data: Location data is generated when a mobile device (or another device with the technical prerequisites for location determination) connects to a radio cell, WLAN or similar technical intermediaries and location determination functions. Location data serves to indicate the geographically determinable position of the respective device on Earth. Location data can, for example, be used to display map functions or other location-dependent information.
    • Tracking: "Tracking" refers to the ability to track users' behavior across multiple online offerings. As a rule, behavioral and interest information regarding the online offerings used is stored in cookies or on the servers of the providers of tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
    • Controller: "Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
    • Processing: "Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it collecting, evaluating, storing, transmitting or deleting.
    • Target Group Formation: Target group formation (or "Custom Audiences") refers to the determination of target groups for advertising purposes, e.g., displaying 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 they viewed the products. "Lookalike Audiences" (or similar target groups) refers to the display of content deemed suitable to users whose profiles or interests are presumably similar to the users from whom the profiles were created. Cookies and web beacons are generally used for the formation of Custom Audiences and Lookalike Audiences.