Privacy Policy

(This is the privacy page. Contact information can be found here.)

Preamble

With the following privacy policy we would like to inform you about the types of your personal data (hereinafter also referred to in short as „data“) that we process, for which purposes, and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as the „online offer“).

The terms used are not gender-specific.

As of: September 13, 2024

Table of Contents

Controller

Dushan Wegner; Calle Santiago 5, 3ºIzq.; ES-38002 Santa Cruz de Tenerife, office@dushanwegner.com

Overview of Processing Operations

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

Types of Processed Data

  • Inventory data (e.g., names, addresses).
  • Content data (e.g., text entries, photographs, videos).
  • Contact data (e.g., email, telephone numbers).
  • Meta, communication and procedural data (e.g., device information, IP addresses).
  • Usage data (e.g., websites visited, interest in content, access times).
  • Location data (data indicating the location of an end user’s terminal device).
  • Contract data (e.g., subject matter of the contract, term, customer category).
  • Payment data (e.g., bank details, invoices, payment history).

Categories of Data Subjects

  • Employees (e.g., staff, applicants, former employees).
  • Business and contractual partners.
  • Interested parties.
  • Communication partners.
  • Customers.
  • Users (e.g., website visitors, users of online services).

Purposes of Processing

  • Affiliate tracking.
  • Provision of our online offer and user-friendliness.
  • Conversion tracking (measurement of visitor actions).
  • Office and organizational procedures.
  • Content Delivery Network (CDN).
  • Cross-device tracking (cross-device processing of user data for marketing purposes).
  • Direct marketing (e.g., by email or postal mail).
  • Feedback (e.g., collecting feedback via online form).
  • Interest-based and behavioral marketing.
  • Contact requests and communication.
  • Conversion measurement (measurement of the effectiveness of marketing activities).
  • 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).
  • Server monitoring and error detection.
  • Contractual services and service.
  • Management and response to inquiries.
  • Target group formation (determination of target groups relevant for marketing purposes or other output of content).

Relevant Legal Bases

In the following, we share the legal bases of the General Data Protection Regulation (GDPR) on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, the national data protection requirements in your or our country of residence and domicile may apply. Should more specific legal bases be relevant in an individual case, we will inform you of these in the privacy policy.

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

Security Measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing as well as the varying likelihood and severity of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, transfer, safeguarding of availability and segregation of the data. Furthermore, we have established procedures that ensure the exercise of data subjects‘ rights, the deletion of data, and responses to threats to the data. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.

SSL encryption (https): In order 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 bar of your browser.

Transmission and Disclosure of Personal Data

In the course of our processing of personal data, it may happen that the data is transmitted to other entities, companies, legally independent organizational 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 that serve to protect your data with the recipients of your data.

Data Processing in Third Countries

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

Subject to express consent or transmission required by contract or law, we only process or have the data processed in third countries with a recognized level of data protection, for example on the basis of special guarantees, such as a contractual obligation through so-called standard contractual clauses of the EU Commission, the existence of certifications or binding internal data protection rules (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

Use of Cookies

Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user’s computer. A cookie primarily serves to store information about a user during or after their 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 point at which a video was watched. The term „cookies“ also includes other technologies that fulfill the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also referred to as „user IDs“).

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their browser.
  • Permanent cookies: Permanent cookies remain stored even after the browser has been closed. For example, the login status can be stored, 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.
  • First-party cookies: First-party cookies are set by us ourselves.
  • Third-party cookies: Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or strictly necessary) cookies: On the one hand, cookies can be strictly necessary for the operation of a website (e.g., to store logins or other user entries or for security reasons).
  • Statistics, marketing and personalization cookies: Furthermore, cookies are usually also used in the context of reach measurement, as well as when the interests of a user or their behavior (e.g., viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles serve, for example, to display content to users that corresponds to their potential interests. This procedure is also referred to as „tracking,“ i.e., following the potential interests of users. Insofar as we use cookies or „tracking“ technologies, we will inform you separately in our privacy policy or in the context of obtaining consent.

Notes on legal bases: The legal basis on which we process your personal data with the help of cookies depends on whether we ask you for 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 help of cookies will be processed on the basis of our legitimate interests (e.g., in the commercial operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.

Storage period: Unless we provide you with explicit information on the storage period of permanent cookies (e.g., in the context of a so-called cookie opt-in), please assume that the storage period can be up to two years.

General notes on withdrawal and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to withdraw consent that has been given 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 (whereby this may also limit the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared by means of a large number of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further objection notices in the context of the information on the service providers and cookies used.

Cookie consent: This website uses its own consent tool („DW Cookies“) that sets a technically necessary cookie (dwcookiesconsent) to store your cookie consents. The dwcookiesconsent cookie stores the consents you gave when entering the website. For the legally required proof of consent, each decision is logged; in doing so, your IP address is anonymized before storage and stored irreversibly as a hash – a plaintext IP is not stored. If you would like to withdraw or change these consents, use the „Cookie Preferences“ link in the page footer or delete the cookie in your browser. When you re-enter/reload the website, you will be asked for your cookie consent again. Please click here to review and re-save your cookie settings.

Processing of cookie data on the basis of consent: Before we process or have processed data in the context of the use of cookies, we ask users for consent that can be withdrawn at any time. Before consent has been given, at most cookies are used that are strictly necessary for the operation of our online offer.

  • Types of data processed: Usage data (e.g., websites visited, interest in content, access times), meta, communication and procedural data (e.g., device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Legal bases: Consent (Art. 6(1)(a) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Commercial and Business Services

We process the 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 as well as associated measures and in the context of communication with the contractual partners (or pre-contractual), e.g., to answer inquiries.

We process this data in order to fulfill our contractual obligations, to safeguard our rights, and for the purposes of the administrative tasks associated with this information as well as the business organization. We only pass on the contractual partners‘ data to third parties within the framework of applicable law insofar as this is necessary for the aforementioned purposes or to fulfill legal obligations or takes place with the consent of the data subjects (e.g., to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners are informed about further forms of processing, e.g., for marketing purposes, within the framework of this privacy policy.

We inform the contractual partners which data is required for the aforementioned purposes before or in the context of the data collection, e.g., in online forms, by means of special marking (e.g., colors) or symbols (e.g., asterisks or similar), or in person.

We delete the data after 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 reasons of archiving (e.g., for tax purposes generally 10 years). Data disclosed to us by the contractual partner within the framework of an order we delete in accordance with the specifications 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 privacy notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.

Shop and e-commerce: We process the data of our customers in order to enable them to select, purchase or order the chosen products, goods and associated services, as well as their payment and delivery or execution.

The required information is marked as such in the context of the order or comparable purchase process and includes the information required for delivery or provision and billing as well as contact information in order to be able to make any inquiries.

Artistic and literary services: We process the data of our clients in order to enable them to select, purchase or commission the chosen services or works as well as associated activities, as well as their payment and delivery or execution or provision.

The required information is marked as such in the context of the order, purchase or comparable conclusion of a contract and includes the information required for delivery and billing as well as contact information in order to be able to make any inquiries.

Publication activity: We process the data of our contact partners, interview partners and other persons who are the subject of our journalistic, editorial and journalistic as well as related activities. In this context, we refer to the applicability of protective provisions on freedom of expression and freedom of the press pursuant to Art. 85 GDPR in conjunction with the respective national laws. The processing serves to fulfill our commissioned activities and otherwise takes place in particular on the basis of the public interest in information and media offerings.

Use of Online Marketplaces for E-Commerce

We offer our services on online platforms operated by other service providers. In this context, in addition to our privacy notices, the privacy notices of the respective platforms apply. This applies in particular with regard to the procedures used on the platforms for reach measurement and interest-based marketing.

  • Types of data processed: 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), usage data (e.g., websites visited, interest in content, access times), meta, communication and procedural data (e.g., device information, IP addresses).
  • Data subjects: Customers.
  • Purposes of processing: Contractual services and service.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Services and service providers being used

Payment Service Providers

In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the data subjects efficient and secure payment options and, for this purpose, use, in addition to banks and credit institutions, other payment service providers (collectively „payment service providers“).

The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract-, sum- and recipient-related information. The information is required in order to carry out the transactions. However, the entered data is only processed by the payment service providers and stored with them. That is, 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 is transmitted by the payment service providers to credit agencies. The purpose of this transmission is the identity and creditworthiness check. In this regard, we refer to the terms and conditions and the privacy notices of the payment service providers.

The terms and conditions and the privacy notices of the respective payment service providers, which can be accessed within the respective websites or transaction applications, apply to the payment transactions. We also refer to these for further information and the assertion of 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 the contract, term, customer category), usage data (e.g., websites visited, interest in content, access times), meta, communication and procedural data (e.g., device information, IP addresses), contact data (e.g., email, telephone numbers).
  • Data subjects: Customers, interested parties.
  • Purposes of processing: Contractual services and service.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Services and service providers being used:

Provision of the Online Offer and Web Hosting

In order to be able to provide our online offer securely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers managed by them) the online offer 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 context of providing the hosting offer may include all information relating to the users of our online offer that arises in the context of use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or from websites.

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). The server log files may include the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user’s operating system, the 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 avoid overloading 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.

Content Delivery Network: We use a „Content Delivery Network“ (CDN). A CDN is a service with the help of which the content of an online offer, in particular large media files, such as graphics or program scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the internet.

  • Types of data processed: Content data (e.g., text entries, photographs, videos), usage data (e.g., websites visited, interest in content, access times), meta, communication and procedural data (e.g., device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Content Delivery Network (CDN), server monitoring and error detection.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Services and service providers being used

Blogs and Publication Media

We use blogs or comparable means of online communication and publication (hereinafter „publication medium“). The data of the readers is processed for the purposes of the publication medium only insofar as it is necessary for its presentation and the communication between authors and readers or for security reasons. In other respects, we refer to the information on the processing of the visitors of our publication medium within the framework of this privacy notice.

Comments and posts: When users leave comments or other posts, their IP addresses may be stored on the basis of our legitimate interests. This is done for our security, in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be held liable for the comment or post and are therefore interested in the identity of the author.

Furthermore, we reserve the right, on the basis of our legitimate interests, to process the users‘ information for the purpose of spam detection.

On the same legal basis, we reserve the right, in the case of surveys, to store the users‘ IP addresses for their duration and to use cookies in order to avoid multiple votes.

The information on the person communicated in the context of the comments and posts, any contact and website information, as well as the content information, is stored by us permanently until the objection of the users.

  • Types of data processed: Inventory data (e.g., names, addresses), contact data (e.g., email, telephone numbers), content data (e.g., text entries, photographs, videos), usage data (e.g., websites visited, interest in content, access times), meta, communication and procedural data (e.g., device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Contractual services and service, feedback (e.g., collecting feedback via online form).
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Contact and Inquiry Management

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

The answering of the contact inquiries in the context of contractual or pre-contractual relationships takes place to fulfill our contractual obligations or to answer (pre-)contractual inquiries and otherwise on the basis of the legitimate interests in answering the inquiries.

  • Types of data processed: Inventory data (e.g., names, addresses), contact data (e.g., email, telephone numbers), content data (e.g., text entries, photographs, videos).
  • Data subjects: Communication partners.
  • Purposes of processing: Contact requests and communication.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Cloud Services

We use software services accessible via the internet and executed 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, sending of emails, spreadsheets and presentations, exchange of documents, content and information with certain recipients or publication of web pages, forms or other content and information, as well as chats and participation in audio and video conferences.

In this context, personal data may be processed and stored on the servers of the providers, insofar as this is part of communication processes with us or is otherwise processed by us, as set out in the context of this privacy policy. This data may include, in particular, master data and contact data of the users, data on transactions, contracts, other processes and their contents. The providers of the cloud services also process usage data and metadata, which they use for security purposes and for service optimization.

Insofar as we use the cloud services to provide forms or other documents and content for other users or publicly accessible websites, the providers may store cookies on the users‘ devices for the purposes of web analysis or to remember the users‘ settings (e.g., in the case of media control).

Notes on legal bases: Insofar as we ask for consent to the use of the cloud services, the legal basis of the processing is the consent. Furthermore, their use may be a component of our (pre-)contractual services, insofar as the use of the cloud services has been agreed in this context. Otherwise, the users‘ data is processed on the basis of our legitimate interests (i.e., interest in efficient and secure administration and collaboration processes).

  • Types of data processed: Inventory data (e.g., names, addresses), contact data (e.g., email, telephone numbers), content data (e.g., text entries, photographs, videos), usage data (e.g., websites visited, interest in content, access times), meta, communication and procedural data (e.g., device information, IP addresses).
  • Data subjects: Customers, employees (e.g., staff, applicants, former employees), interested parties, communication partners.
  • Purposes of processing: Office and organizational procedures.
  • Legal bases: Consent (Art. 6(1)(a) GDPR), performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Services and service providers being used

Newsletter and Electronic Notifications

We send newsletters, emails and other electronic notifications (hereinafter „newsletter“) only with the consent of the recipients or on the basis of a legal permission. Insofar as the contents of the newsletter are specifically described in the context of a registration for the newsletter, they are decisive for the consent of the users. In other respects, our newsletters contain information about our services and us.

In order to subscribe to our newsletters, it is generally sufficient for you to provide your email address. However, we may ask you to provide a name, for the purpose of personal address in the newsletter, or further information, insofar as this is necessary for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter generally takes place in a so-called double opt-in procedure. That is, 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 the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise, the changes to your data stored with the shipping service provider are logged.

Deletion and restriction of processing: We may store the unsubscribed email 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 consent that was formerly given. The processing of this data is restricted to the purpose of a possible defense 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 the case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a blocking list (so-called „blacklist“).

The logging of the registration procedure takes place on the basis of our legitimate interests for the purposes of proving its proper course. Insofar as we commission a service provider with the sending of emails, this takes place on the basis of our legitimate interests in an efficient and secure sending system.

Notes on legal bases: The sending of the newsletter takes place on the basis of the consent of the recipients or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and insofar as this is permitted by law, e.g., in the case of existing customer advertising. Insofar as we commission a service provider with the sending of emails, this takes place on the basis of our legitimate interests. The registration procedure 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.

Analysis and success measurement: 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. In the context of this retrieval, technical information is initially collected, such as information about the browser and your system, as well as your IP address and the time of retrieval.

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 behavior on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes the determination of whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our endeavor nor, if used, that of the shipping service provider, to observe individual users. Rather, the evaluations serve us to recognize the reading habits of our users and to adapt our content to them or to send different content in accordance with the interests of our users.

The evaluation of the newsletter and the success measurement take place, 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, which serves both our business interests and meets the expectations of the users.

A separate withdrawal of the success 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, telephone numbers), meta, communication and procedural data (e.g., device information, IP addresses), usage data (e.g., websites visited, interest in content, access times).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g., by email or postal mail).
  • Legal bases: Consent (Art. 6(1)(a) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
  • Objection option (opt-out): You can cancel the receipt of our newsletter at any time, i.e., withdraw your consents 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, for this purpose.

Services and service providers being used

Web Analysis, Monitoring and Optimization

Web analysis (also referred to as „reach measurement“) serves to evaluate the visitor flows of our online offer and may comprise behavior, interests or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online offer or its functions or content are used most frequently, or invite reuse. Likewise, we can understand which areas require optimization.

In addition to web analysis, we may also use test procedures, e.g., to test and optimize 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, websites visited and elements used there, as well as technical information, such as the browser used, the computer system used, and information on usage times. Insofar as users have consented to the collection of their location data, this may also be processed depending on the provider.

The users‘ IP addresses are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect the users. In general, no clear data of the users (such as email addresses or names) is stored in the context of web analysis, A/B testing and optimization, but pseudonyms. That is, 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: Insofar as we ask the users for their consent to the use of the third-party providers, the legal basis for the processing of data is the consent. Otherwise, the users‘ data is 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 refer you to the information on the use of cookies in this privacy policy.

VG Wort / Scalable Central Measurement Procedure: We use „session cookies“ of VG Wort, Munich, to measure accesses to texts in order to record the copying probability. Session cookies are small units of information that a provider stores in the working memory of the visitor’s computer. A randomly generated unique identification number, a so-called session ID, is stored in a session cookie. In addition, a cookie contains the information about its origin and the storage period. Session cookies cannot store any other data. These measurements are carried out by Kantar Germany GmbH according to the Scalable Central Measurement Procedure (SZM). They help to determine the copying probability of individual texts for the remuneration of statutory claims of authors and publishers. We do not collect any personal data via cookies.

In the Scalable Central Measurement Procedure, anonymous measured values are collected. To recognize computer systems, the access count measurement uses either a session cookie or a signature created from various automatically transmitted pieces of information of your browser. IP addresses are only processed in anonymized form. The procedure was developed in compliance with data protection. The sole aim of the procedure is to determine the copying probability of individual texts. At no time are individual users identified. Your identity always remains protected. You do not receive any advertising via the system.

  • Types of data processed: Usage data (e.g., websites visited, interest in content, access times), meta, communication and procedural data (e.g., device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors), tracking (e.g., interest/behavior-based profiling, use of cookies), conversion tracking (measurement of visitor actions), profiling (creation of user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6(1)(a) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Services and service providers being used

Affiliate Programs and Affiliate Links

Into our online offer we integrate so-called affiliate links or other references (which may include, for example, search masks, widgets or discount codes) to the offers and services of third-party providers (collectively referred to as „affiliate links“). When users follow the affiliate links or subsequently take up the offers, we may receive a commission or other benefits from these third-party providers (collectively referred to as „commission“).

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

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

Notes on legal bases: Insofar as we ask the users for their consent to the use of the third-party providers, the legal basis for the processing of data is the consent. Furthermore, their use may be a component of our (pre-)contractual services, insofar as the use of the third-party providers has been agreed in this context. Otherwise, the users‘ data is 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 refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: Contract data (e.g., subject matter of the contract, term, customer category), usage data (e.g., websites visited, interest in content, access times), meta, communication and procedural data (e.g., device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Affiliate tracking.
  • Legal bases: Consent (Art. 6(1)(a) GDPR), performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Services and service providers being used

Presence in Social Networks (Social Media)

We maintain online presences within social networks and, in this context, process users‘ data in order to communicate with the users active there or to offer information about us.

We point out that in doing so, users‘ data may be processed outside the territory of the European Union. This may result in risks for the users, because, for example, the enforcement of the users‘ rights could thereby 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 point out that they thereby commit to complying with the EU data protection standards.

Furthermore, the users‘ data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior 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 behavior and the interests of the users are stored. Furthermore, data can also be stored in the usage profiles independently of the devices used by the users (in particular, if the users are members of the respective platforms and are logged in to them).

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

Also in the case of requests for information and the assertion of data subject rights, we point out that these can be asserted most effectively with the providers. Only the providers each have access to the users‘ data and can directly take appropriate measures and provide information. Should you nevertheless need help, 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., text entries, photographs, videos), usage data (e.g., websites visited, interest in content, access times), meta, communication and procedural data (e.g., device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Contact requests and communication, tracking (e.g., interest/behavior-based profiling, use of cookies), remarketing, reach measurement (e.g., access statistics, recognition of returning visitors).
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Services and service providers being used:

Plug-ins and Embedded Functions and Content

We integrate into 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 can be, for example, graphics, videos or social media buttons as well as posts (hereinafter uniformly referred to as „content“).

The integration always presupposes that the third-party providers of this content process the users‘ IP address, since without the IP address they could not send the content to their browser. The IP address is thus necessary for the presentation 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 referred to as „web beacons“) for statistical or marketing purposes. Through the „pixel tags,“ information such as the visitor traffic on the pages of this website can be evaluated. The pseudonymous information may also be stored in cookies on the users‘ device and may contain, among other things, technical information about the browser and operating system, about referring websites, about the visit time, as well as further information on the use of our online offer, as well as be linked to such information from other sources.

Notes on legal bases: Insofar as we ask the users for their consent to the use of the third-party providers, the legal basis for the processing of data is the consent. Otherwise, the users‘ data is 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 refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g., websites visited, interest in content, access times), meta, communication and procedural data (e.g., device information, IP addresses), contact data (e.g., email, telephone numbers), content data (e.g., text entries, photographs, videos), inventory data (e.g., names, addresses).
  • Data subjects: Users (e.g., website visitors, users of online services), communication partners.
  • Purposes of processing: Provision of our online offer and user-friendliness, contact requests and communication, direct marketing (e.g., by email or postal mail), tracking (e.g., interest/behavior-based profiling, use of cookies), interest-based and behavioral marketing, profiling (creation of user profiles), reach measurement (e.g., access statistics, recognition of returning visitors), feedback (e.g., collecting feedback via online form), contractual services and service, security measures, management and response to inquiries.
  • Legal bases: Consent (Art. 6(1)(a) GDPR), legitimate interests (Art. 6(1)(f) GDPR), performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).

Services and service providers being used:

Deletion of Data

The data processed by us is deleted in accordance with the legal requirements as soon as the consents permitted for processing are withdrawn or other permissions cease to apply (e.g., if the purpose of processing this data no longer applies or it is not required for the purpose).

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

Further notes on the deletion of personal data may also be provided in the context of the individual privacy notices of this privacy policy.

Changes and Updates to the Privacy Policy

We ask you to inform yourself regularly about the content of our privacy policy. We adapt the privacy policy as soon as the changes to 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 another individual notification.

Insofar as we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.

Rights of Data Subjects

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

  • Right to object: You have the right, on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you which is based on Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw consents that have been given at any time.
  • Right of access: You have the right to request confirmation as to whether data concerning you is being processed and to information about this data as well as to further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the legal requirements, you have the right to request the completion of the data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to request that data concerning you be deleted without delay, or alternatively, in accordance with the legal requirements, to request a restriction of the processing of the data.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us, in accordance with the legal requirements, in a structured, commonly used and machine-readable format, or to request its transmission to another controller.
  • Complaint to a supervisory authority: In accordance with the legal requirements, you also have the right 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 are of the opinion that the processing of personal data concerning you infringes the GDPR.

Definitions of Terms

In this section, you will find 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 GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are sorted alphabetically.

  • Affiliate tracking: In the context of 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 subsequently take up the offers (e.g., buy goods or use services). To this end, it is necessary that the providers can track whether users who are interested in certain offers subsequently take these up at the instigation of the affiliate links. Therefore, for the functionality of affiliate links, it is necessary that they be supplemented with certain values that become part of the link or are stored otherwise, e.g., in a cookie. The values include, in particular, the source website (referrer), the time, an online identifier of the operators of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as tracking-specific values, such as, for example, advertising medium ID, partner ID and categorizations.
  • Conversion tracking (measurement of visitor actions): „Conversion tracking“ (German „Besuchsaktionsauswertung“) refers to a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users‘ devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, we can thereby understand whether the advertisements placed by us on other websites were successful.
  • Content Delivery Network (CDN): A „Content Delivery Network“ (CDN) is a service with the help of which the content of an online offer, in particular large media files, such as graphics or program scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the internet.
  • Cross-device tracking: Cross-device tracking is a form of tracking in which behavioral and interest information of the users is recorded across devices in so-called profiles by assigning an online identifier to the users. As a result, the user information can be analyzed independently of the browsers or devices used (e.g., mobile phones or desktop computers), usually for marketing purposes. With most providers, the online identifier is not linked to clear data, such as names, postal addresses or email addresses.
  • IP masking: „IP masking“ refers to 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 to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing procedures, in particular in online marketing.
  • Interest-based and behavioral marketing: One speaks of interest- and/or behavior-based marketing when potential interests of users in advertisements and other content are predetermined as precisely as possible. This is done on the basis of information about their prior behavior (e.g., visiting certain websites and dwelling on them, purchasing behavior or interaction with other users), which is stored in a so-called profile. For these purposes, cookies are usually used.
  • Conversion measurement: Conversion measurement is a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users‘ devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, we can thereby understand whether the advertisements placed by us on other websites were 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“ refers to any form of automated processing of personal data consisting of the use of such personal data to analyze, evaluate or predict 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) (e.g., the interests in certain content or products, the click behavior on a website or the whereabouts). For the purposes of profiling, cookies and web beacons are frequently used.
  • Reach measurement: Reach measurement (also referred to as web analytics) serves to evaluate the visitor flows of an online offer and may comprise the behavior or interests of the visitors in certain information, such as content of websites. With the help of reach analysis, website owners can, for example, recognize at what time visitors visit their website and which content they are interested in. As a result, they can, for example, better adapt the content of the website to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are frequently used in order to recognize returning visitors and thus obtain more precise analyses on the use of an online offer.
  • Remarketing: One speaks of „remarketing“ or „retargeting“ when, for example, for advertising purposes, it is noted which products a user was interested in on a website, in order to remind the user of these products on other websites, e.g., in advertisements.
  • Server monitoring and error detection: With the help of server monitoring and error detection, we ensure the availability and integrity of our online offer and use the processed data to technically optimize our online offer. Performance, utilization and comparable technical values are processed, which provide information about the stability and any anomalies of our online offer. In the case of errors and anomalies, individual requests of the users of our online offer are recorded in order to identify and remedy sources of problems.
  • Tracking: One speaks of „tracking“ when the behavior of users can be followed across multiple online offers. As a rule, behavioral and interest information with regard to the online offers used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can subsequently be used, for example, to display advertisements to the users that are likely to correspond to their interests.
  • Controller: A „controller“ refers to the natural or legal person, public authority, agency or other body which, alone or jointly with others, decides on the purposes and means of the processing of personal data.
  • Processing: „Processing“ is 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 any handling of data, be it the collection, evaluation, storage, transmission or deletion.
  • Target group formation: One speaks of target group formation (or „custom audiences“) when target groups are determined for advertising purposes, e.g., the display 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 in which they viewed the products. One speaks in turn of „lookalike audiences“ (or similar target groups) when the content assessed as suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were formed. For the purposes of forming custom audiences and lookalike audiences, cookies and web beacons are usually used.