Privacy Policy
Preamble
With the following privacy policy, we would like to inform you
about the types of your personal data (hereinafter also
referred to as "data") that we process, for what purposes and
to what extent. The privacy policy applies to all processing of
personal data carried out by us, both in the context of the
provision of our services and in particular on our websites, in
mobile applications and within external online presences, such
as our social media profiles (hereinafter collectively referred
to as "online offer").
The terms used are not gender-specific.
Status: 25 August 2023
Table of contents
Preamble
Controller
Overview of the processing operations
Relevant legal bases
Rights of the data subjects
Business services
Online marketing
Customer reviews and evaluation procedures
Presence in social networks (social media)
Plugins and embedded functions and content
Responsible person
Jasmin Mattern
Jakob-Kaiser-Strasse 10
49088 Osnabrueck
E-mail address:
Relevant legal bases
Relevant legal bases according to the GDPR: Below you will find
an overview of the legal bases of the GDPR on the basis of
which we process personal data. Please note that in addition to
the provisions of the GDPR, national data protection
regulations may apply in your or our country of residence or
domicile. Should more specific legal bases also apply in
individual cases, we will inform you of these in the privacy
policy.
Contract fulfilment and pre-contractual enquiries (Art. 6 para.
1 sentence 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 sentence 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 sentence 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.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Act on the 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 erasure, the right to object, 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, state data protection laws of the individual federal states may apply.
Note on the applicability of the GDPR and Swiss FADP: This data
protection notice serves to provide information in accordance
with both the Swiss Federal Act on Data Protection (FADP) and
the General Data Protection Regulation (GDPR).For this reason,
please note that the terms of the GDPR are used due to the
broader geographical application and comprehensibility.In
particular, instead of the terms "processing" of "personal
data", "overriding interest" and "sensitive personal data" used
in the Swiss DPA, the terms "processing" of "personal data",
"legitimate interest" and "special categories of data" used in
the GDPR are used.However, the legal meaning of the terms will
continue to be determined in accordance with the Swiss DPA
within the scope of application of the Swiss DPA.Overview of
processing operations
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
Inventory data.
Payment data.
Contact data.
Content data.
Contract data.
Usage data.
Meta, communication and process data.
Categories of data subjects
Customers.
Interested parties.
Users.
Business and contractual partners.
Purposes of the processing
Provision of contractual services and fulfilment of contractual
obligations.
Contact enquiries and communication.
Reach measurement.
Tracking.
Office and organisational procedures.
Managing and responding to enquiries.
Feedback.
Marketing.
Profiles with user-related information.
Provision of our online services and user-friendliness.
Rights of the data subjects
Rights of data subjects under the DSGVO: As a data subject, you
are entitled to various rights under the GDPR, which arise in
particular from Art. 15 to 21 DSGVO:
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
point (e) or (f) of Article 6(1) DSGVO, including profiling
based on those provisions. If the personal data concerning you
are processed for direct marketing purposes, you have the right
to object at any time to the 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 any
consent you have given at any time.
Right to information: You have the right to request
confirmation as to whether the data in question is being
processed and to request information about this data as well as
further information and a copy of the data in accordance with
the legal requirements.
Right to rectification: You have the right to request the
completion of data concerning you or the rectification of
inaccurate data concerning you in accordance with the legal
requirements.Right to erasure and restriction of processing: In
accordance with the legal requirements, you have the right to
demand that data concerning you be erased immediately or,
alternatively, to demand a restriction of processing in
accordance with the legal requirements.Right to erasure and
restriction of processing: In accordance with the legal
requirements, you have the right to demand that data concerning
you be deleted immediately or, alternatively, to demand that
the processing of the data be restricted in accordance with the
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 in
accordance with the legal requirements or to request its
transmission to another controller.
Complaint to the supervisory authority: Without prejudice to
any other administrative or judicial remedy, you have the right
to lodge a complaint with a supervisory authority, in
particular in the Member State of your habitual residence,
place of work or place of the alleged infringement if you
consider that the processing of personal data relating to you
infringes the provisions of the DSGVO.
Business services: We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners") in the context of contractual and comparable legal relationships and related measures and in the context of communication with the contractual partners (or pre-contractual), e.g. to answer enquiries.
We process this data in order to fulfil our contractual obligations. These include, in particular, the obligations to provide the agreed services, any updating obligations and remedies in the event of warranty and other service disruptions. In addition, we process the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations and the company organisation. In addition, we process the data on the basis of our legitimate interests in proper and efficient business management and in security measures to protect our contractual partners and our business operations from misuse, jeopardising their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. Contractual partners will be informed about other forms of processing, e.g. for marketing purposes, as part of this privacy policy.
We inform the contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special marking (e.g. colours) or symbols (e.g. asterisks or similar), or personally.
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. The statutory retention period is ten years for documents relevant under tax law as well as for trading books, inventories, opening balance sheets, annual financial statements, the work instructions required to understand these documents and other organisational documents and accounting records, and six years for commercial and business letters received and reproductions of commercial and business letters sent. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was prepared, the commercial or business letter was received or sent or the accounting document was created, the record was made or the other documents were created.
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 the users and the providers.
Processed data types: Inventory data (e.g. names, addresses);
payment data (e.g. bank details, invoices, payment history);
contact data (e.g. email, telephone numbers). Contract data
(e.g. subject matter of the contract, term, customer
category).
Data subjects: Interested parties. Business and contractual
partners.
Purposes of Processing: Provision of contractual services and
fulfilment of contractual obligations; contact requests and
communication; Office and organisational procedures. Managing
and responding to enquiries.
Legal bases: Contract fulfilment and pre-contractual enquiries
(Art. 6 Para. 1 S. 1 lit. b) DSGVO); Legal obligation (Art. 6
Para. 1 S. 1 lit. c) DSGVO). Legitimate interests (Art. 6 para.
1 sentence 1 lit. f) DSGVO).
Further information on processing processes, procedures and
services:
Agency services: We process our customers' data as part of our
contractual services, which may include, for example,
conceptual and strategic consulting, campaign planning,
software and design development/consulting or maintenance,
implementation of campaigns and processes, handling, server
administration, data analysis/consulting services and training
services; legal basis: contract fulfilment and pre-contractual
enquiries (Art. 6 para. 1 sentence 1 lit. b) DSGVO).
Online marketing
We process personal data for online marketing purposes, which
may include in particular the marketing of advertising space or
the presentation 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 data relevant for the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times and functions used. If users have consented to the collection of their location data, this can also be processed.
The IP addresses of users are also stored. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, 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 usually stored in cookies or by means of similar procedures. These cookies can generally also be read later on other websites that use the same online marketing process and analysed for the purpose of displaying content, as well as supplemented with further data and stored on the server of the online marketing process provider.
In exceptional cases, 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 process we use and the network links the user profiles with the aforementioned data. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.
In principle, we only receive access to summarised information about the success of our advertisements. However, as part 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 the conclusion of a contract with us. The conversion measurement is used solely to analyse the success of our marketing measures.
Unless otherwise stated, we ask you to assume that cookies used are stored for a period of two years.
Processed data types: Usage data (e.g. websites visited,
interest in content, access times). Meta, communication and
process data (e.g. IP addresses, time data, identification
numbers, consent status).
Data subjects: Users (e.g. website visitors, users of online
services).
Purposes of Processing: Web Analytics (e.g. access statistics,
recognition of returning visitors); Tracking (e.g. profiling
based on interests and behaviour, use of cookies); Marketing.
Profiles with user-related information (creation of user
profiles).
Security measures: IP masking (pseudonymisation of the IP
address).
Possibility of objection (opt-out): We refer you to the data protection notices of the respective providers and the opt-out options specified for the providers (so-called "opt-out"). If no explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. However, this may restrict the functions of our online offering. We therefore recommend the following additional opt-out options, which are summarised 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-territory: https://optout.aboutads.info.
Customer reviews and evaluation procedures
We participate in review and rating procedures in order to
evaluate, optimise and promote our services. If users rate us
or otherwise provide feedback via the participating review
platforms or procedures, the general terms and conditions or
terms of use and the data protection notices of the providers
also apply. As a rule, the evaluation also requires
registration with the respective providers.
In order to ensure that the reviewers have actually used our services, we transmit the necessary data relating to the customer and the service used (including name, email address and order number or item number) to the relevant review platform with the customer's consent. This data is used solely to verify the authenticity of the user.
Processed data types: 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 and process data (e.g. IP addresses, time data,
identification numbers, consent status).
Data subjects: Customers. Users (e.g. website visitors, users
of online services).
Purposes of processing: Feedback (e.g. collecting feedback via
online form). Marketing.
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1
lit. f) DSGVO).
Further information on processing processes, procedures and
services:
Rating widget: We integrate so-called "rating widgets" into our online offering. A widget is a functional and content element integrated into our online offering that displays variable information. It can, for example, be displayed in the form of a seal or comparable element, sometimes also called a "badge". Although the corresponding content of the widget is displayed within our online offering, it is retrieved from the servers of the respective widget provider at that moment. Only in this way can the current content always be shown, especially the current rating. For this purpose, a data connection must be established from the website accessed within our online offering to the widget provider's server and the widget provider receives certain technical data (access data, including IP address) that is necessary for the content of the widget to be delivered to the user's browser.
Furthermore, the widget provider receives information that
users have visited our website. This information can be stored
in a cookie and used by the widget provider to recognise which
online offers that participate 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; Legal basis: Legitimate interests (Art. 6 para.
1 sentence 1 lit. f) DSGVO).
Presence in social networks (social media)
We maintain online presences within social networks and process
user data in this context in order to communicate with the
users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users' rights.
Furthermore, user data is generally processed within social networks for market research and advertising purposes. For example, user profiles can be created based on user behaviour and the resulting interests of users. The user profiles can in turn be used, for example, to place adverts within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are generally stored on the user's computer, in which the user's usage behaviour and interests are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
For a detailed description of the respective forms of processing and the opt-out options, please refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can take appropriate measures and provide information directly. Should you nevertheless require assistance, you can contact us.
Processed data types: Contact data (e.g. e-mail, telephone
numbers); Content data (e.g. entries in online forms); Usage
data (e.g. websites visited, interest in content, access
times). Meta, communication and process data (e.g. IP
addresses, time data, identification numbers, consent
status).
Data subjects: Users (e.g. website visitors, users of online
services).
Purposes of Processing: Contact requests and communication;
Feedback (e.g. collecting feedback via online form).
Marketing.
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1
lit. f) DSGVO).
Further information on processing processes, procedures and
services: LinkedIn: Social network; Service provider: LinkedIn
Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2,
Ireland; Legal basis: Legitimate interests (Art. 6 para. 1
sentence 1 lit. f) DSGVO); Website: https://www.linkedin.com;
Privacy Policy: https://www.linkedin.com/legal/privacy-policy;
Data processing agreement: https://legal.linkedin.com/dpa;
Basis for third country transfers: Standard Contractual Clauses
(https://legal.linkedin.com/dpa). Option to object (opt-out):
https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Plugins and embedded functions and content
We incorporate 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").
These may be, for example, graphics, videos or city maps
(hereinafter uniformly referred to as "content"). The
integration always requires that the third-party providers of
this content process the IP address of the user, as they would
not be able to send the content to their browser without the IP
address. The IP address is therefore required to display this
content or function. We endeavour to only use content whose
respective providers only use the IP address 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
analyse information such as visitor traffic on the pages of
this website. The pseudonymous information may also be stored
in cookies on the user's device and may contain, among other
things, technical information about the browser and operating
system, referring websites, time of visit and other information
about the use of our online offer, as well as being linked to
such information from other sources.
Processed data types: Usage data (e.g. websites visited,
interest in content, access times); meta, communication and
process data (e.g. IP addresses, time data, identification
numbers, consent status); inventory data (e.g. names,
addresses); contact data (e.g. email, telephone numbers).
Content data (e.g. entries in online forms).
Data subjects: Users (e.g. website visitors, users of online
services).
Purposes of processing: Provision of our online services and
user-friendliness.
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1
lit. f) DSGVO).