Bare Hands

Privacy policy

Table of contents

Privacy Policy Introduction and Overview

We have written this privacy policy (version 16.03.2023-112447860) in order to explain to you, in accordance with the provisions of the General Data Protection Regulation (EU) 2016/679 and applicable national laws, which personal data (data for short) we as the controller – and the processors commissioned by us (e.g. providers) – process, will process in the future and what legal options you have. The terms used are to be considered gender-neutral.
In short: We provide you with comprehensive information about any of your personal data we process.

Privacy policies usually sound very technical and use legal terminology. However, this privacy policy is intended to describe the most important things to you as simply and transparently as possible. So long as it aids transparency, technical terms are explained in a reader-friendly manner, links to further information are provided and graphics are used. We are thus informing in clear and simple language that we only process personal data in the context of our business activities if there is a legal basis for it. This is certainly not possible with brief, unclear and legal-technical statements, as is often standard on the internet when it comes to data protection. I hope you find the following explanations interesting and informative. Maybe you will also find some information that you have not been familiar with.
If you still have questions, we kindly ask you to contact the responsible body named below or in the imprint, follow the existing links and look at further information on third-party sites. You can of course also find our contact details in the imprint.

Scope

This privacy policy applies to all personal data processed by our company and to all personal data processed by companies commissioned by us (processors). With the term personal data, we refer to information within the meaning of Article 4 No. 1 GDPR, such as the name, email address and postal address of a person. The processing of personal data ensures that we can offer and invoice our services and products, be it online or offline. The scope of this privacy policy includes:

  • all online presences (websites, online shops) that we operate
  • Social media presences and email communication
  • mobile apps for smartphones and other devices

In short: This privacy policy applies to all areas in which personal data is processed in a structured manner by the company via the channels mentioned. Should we enter into legal relations with you outside of these channels, we will inform you separately if necessary.

Legal bases

In the following privacy policy, we provide you with transparent information on the legal principles and regulations, i.e. the legal bases of the General Data Protection Regulation, which enable us to process personal data.
Whenever EU law is concerned, we refer to REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016. You can of course access the General Data Protection Regulation of the EU online at EUR-Lex, the gateway to EU law, at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679.

We only process your data if at least one of the following conditions applies:

  1. Consent (Article 6 Paragraph 1 lit. a GDPR): You have given us your consent to process data for a specific purpose. An example would be the storage of data you entered into a contact form.
  2. Contract (Article 6 Paragraph 1 lit. b GDPR): We process your data in order to fulfill a contract or pre-contractual obligations with you. For example, if we conclude a sales contract with you, we need personal information in advance.
  3. Legal obligation (Article 6 Paragraph 1 lit. c GDPR): If we are subject to a legal obligation, we will process your data. For example, we are legally required to keep invoices for our bookkeeping. These usually contain personal data.
  4. Legitimate interests (Article 6 Paragraph 1 lit. f GDPR): In the case of legitimate interests that do not restrict your basic rights, we reserve the right to process personal data. For example, we have to process certain data in order to be able to operate our website securely and economically. Therefore, the processing is a legitimate interest.

Other conditions such as making recordings in the interest of the public, the exercise of official authority as well as the protection of vital interests do not usually occur with us. Should such a legal basis be relevant, it will be disclosed in the appropriate place.

In addition to the EU regulation, national laws also apply:

  • In Austria this is the Austrian Data Protection Act (Datenschutzgesetz), in short DSG.
  • In Germany this is the Federal Data Protection Act (Bundesdatenschutzgesetz), in short BDSG.

Should other regional or national laws apply, we will inform you about them in the following sections.

Storage Period

It is a general criterion for us to store personal data only for as long as is absolutely necessary for the provision of our services and products. This means that we delete personal data as soon as any reason for the data processing no longer exists. In some cases, we are legally obliged to keep certain data stored even after the original purpose no longer exists, such as for accounting purposes.

If you want your data to be deleted or if you want to revoke your consent to data processing, the data will be deleted as soon as possible, provided there is no obligation to continue its storage.

We will inform you below about the specific duration of the respective data processing, provided we have further information.

Rights in accordance with the General Data Protection Regulation

In accordance with Articles 13, 14 of the GDPR, we inform you about the following rights you have to ensure fair and transparent processing of data:

  • According to Article 15 DSGVO, you have the right to information about whether we are processing data about you. If this is the case, you have the right to receive a copy of the data and to know the following information:
    • for what purpose we are processing;
    • the categories, i.e. the types of data that are processed;
    • who receives this data and if the data is transferred to third countries, how security can be guaranteed;
    • how long the data will be stored;
    • the existence of the right to rectification, erasure or restriction of processing and the right to object to processing;
    • that you can lodge a complaint with a supervisory authority (links to these authorities can be found below);
    • the origin of the data if we have not collected it from you;
    • Whether profiling is carried out, i.e. whether data is automatically evaluated to arrive at a personal profile of you.
  • You have a right to rectification of data according to Article 16 GDPR, which means that we must correct data if you find errors.
  • You have the right to erasure (“right to be forgotten”) according to Article 17 GDPR, which specifically means that you may request the deletion of your data.
  • According to Article 18 of the GDPR, you have the right to restriction of processing, which means that we may only store the data but not use it further.
  • According to Article 20 of the GDPR, you have the right to data portability, which means that we will provide you with your data in a standard format upon request.
  • According to Article 21 DSGVO, you have the right to object, which entails a change in processing after enforcement.
    • If the processing of your data is based on Article 6(1)(e) (public interest, exercise of official authority) or Article 6(1)(f) (legitimate interest), you may object to the processing. We will then check as soon as possible whether we can legally comply with this objection.
    • If data is used to conduct direct advertising, you may object to this type of data processing at any time. We may then no longer use your data for direct marketing.
    • If data is used to conduct profiling, you may object to this type of data processing at any time. We may no longer use your data for profiling thereafter.
  • According to Article 22 of the GDPR, you may have the right not to be subject to a decision based solely on automated processing (for example, profiling).
  • You have the right to lodge a complaint under Article 77 of the GDPR. This means that you can complain to the data protection authority at any time if you believe that the data processing of personal data violates the GDPR.

In short: you have rights – do not hesitate to contact the responsible party listed above with us!

If you believe that the processing of your data violates data protection law or your data protection rights have been violated in any other way, you can complain to the supervisory authority. For Austria, this is the data protection authority, whose website can be found at https://www.dsb.gv.at/. In Germany, there is a data protection officer for each federal state. For more information, you can contact the Federal Commissioner for Data Protection and Freedom of Information (BfDI). The following local data protection authority is responsible for our company:

Austria Data protection authority

Manager: Mag. Dr. Andrea Jelinek

Address: Barichgasse 40-42, 1030 Wien

Phone number.: +43 1 52 152-0

E-mail address:
[email protected]

Website:
https://www.dsb.gv.at/

Data transfer to third countries

We only transfer or process data to countries outside the EU (third countries) if you consent to this processing, if this is required by law or if it is contractually necessary. In any case, we generally only do so to the permitted extent. In most cases, your consent is the most important reason for data being processed in third countries. When personal data is being processed in third countries such as the USA, where many software manufacturers offer their services and have their servers located, your personal data may be processed and stored in unexpected ways.

We want to expressly point out, that according to the European Court of Justice, there is currently no adequate level of protection for data transfer to the USA. Data processing by US services (such as Google Analytics) may result in data processing and retention without the data having undergone anonymisation processes. Furthermore, US government authorities may be able to access individual data. The collected data may also get linked to data from other services of the same provider, should you have a user account with the respective provider. We try to use server locations within the EU, whenever this is offered and possible.

We will provide you with more details about data transfer to third countries in the appropriate sections of this privacy policy, whenever applicable.

Security of data processing operations

In order to protect personal data, we have implemented both technical and organisational measures. We encrypt or pseudonymise personal data wherever this is possible. Thus, we make it as difficult as we can for third parties to extract personal information from our data.

Article 25 of the GDPR refers to “data protection by technical design and by data protection-friendly default” which means that both software (e.g. forms) and hardware (e.g. access to server rooms) appropriate safeguards and security measures shall always be placed. If applicable, we will outline the specific measures below.

TLS encryption with https

The terms TLS, encryption and https sound very technical, which they are indeed. We use HTTPS (Hypertext Transfer Protocol Secure) to securely transfer data on the Internet.
This means that the entire transmission of all data from your browser to our web server is secured – nobody can “listen in”.

We have thus introduced an additional layer of security and meet privacy requirements through technology design Article 25 Section 1 GDPR). With the use of TLS (Transport Layer Security), which is an encryption protocol for safe data transfer on the internet, we can ensure the protection of confidential information.
You can recognise the use of this safeguarding tool by the little lock-symbol , which is situated in your browser’s top left corner in the left of the internet address (e.g. examplepage.uk), as well as by the display of the letters https (instead of http) as a part of our web address.
If you want to know more about encryption, we recommend you to do a Google search for “Hypertext Transfer Protocol Secure wiki” to find good links to further information.

Communications

Communications Overview

👥 Affected parties: Anyone who communicates with us via phone, email or online form
📓 Processed data: e. g. telephone number, name, email address or data entered in forms. You can find more details on this under the respective form of contact
🤝 Purpose: handling communication with customers, business partners, etc.
📅 Storage duration: for the duration of the business case and the legal requirements
⚖️ Legal basis: Article 6 (1) (a) GDPR (consent), Article 6 (1) (b) GDPR (contract), Article 6 (1) (f) GDPR (legitimate interests)

If you contact us and communicate with us via phone, email or online form, your personal data may be processed.

The data will be processed for handling and processing your request and for the related business transaction. The data is stored for this period of time or for as long as is legally required.

Affected persons

The above-mentioned processes affect all those who seek contact with us via the communication channels we provide.

Telephone

When you call us, the call data is stored in a pseudonymised form on the respective terminal device, as well as by the telecommunications provider that is being used. In addition, data such as your name and telephone number may be sent via email and stored for answering your inquiries. The data will be erased as soon as the business case has ended and the legal requirements allow for its erasure.

Email

If you communicate with us via email, your data is stored on the respective terminal device (computer, laptop, smartphone, …) as well as on the email server. The data will be deleted as soon as the business case has ended and the legal requirements allow for its erasure.

Online forms

If you communicate with us using an online form, your data is stored on our web server and, if necessary, forwarded to our email address. The data will be erased as soon as the business case has ended and the legal requirements allow for its erasure.

Legal bases

Data processing is based on the following legal bases:

  • Art. 6 para. 1 lit. a GDPR (consent): You give us your consent to store your data and to continue to use it for the purposes of the business case;
  • Art. 6 para. 1 lit. b GDPR (contract): For the performance of a contract with you or a processor such as a telephone provider, or if we have to process the data for pre-contractual activities, such as preparing an offer;
  • Art. 6 para. 1 lit. f GDPR (legitimate interests): We want to conduct our customer inquiries and business communication in a professional manner. Thus, certain technical facilities such email programs, Exchange servers and mobile network operators are necessary to efficiently operate our communications.

Data Processing Agreement (DPA)

In this section, we would like to explain what a Data Processing Agreement is and why it is needed. As the term “Data Processing Agreement” is quite lengthy, we will often only use the acronym DPA here in this text. Like most companies, we do not work alone, but also use the services of other companies or individuals. By involving different companies or service providers, we may pass on personal data for processing. These partners then act as processors with whom we conclude a contract, the so-called Data Processing Agreement (DPA). Most importantly for you to know is that any processing of your personal data takes place exclusively according to our instructions and must be regulated by the DPA.

Who are the processors?

As a company and website owner, we are responsible for any of your data that is processed by us. In addition to the controller, there may also be so-called processors involved. This includes any company or person who processes your personal data. More precisely and according to the GDPR’s definition, this means: Any natural or legal person, authority, institution or other entity that processes your personal data is considered a processor. Processors can therefore be service providers such as hosting or cloud providers, payment or newsletter providers or large companies such as Google or Microsoft.

To make the terminology easier to comprehend, here is an overview of the GDPR’s three roles:

Data subject (you as a customer or interested party) → Controller (we as a company and contracting entity) → Processors (service providers such as web hosts or cloud providers)

Contents of a Data Processing Agreement

As mentioned above, we have concluded a DPA with our partners who act as processors. First and foremost, it states that the processor processes the data exclusively in accordance with the GDPR. The contract must be concluded in writing, although an electronic contract completion is also considered a “written contract”. Any processing of personal data only takes place after this contract is concluded. The contract must contain the following:

  • indication to us as the controller
  • obligations and rights of the controller
  • categories of data subjects
  • type of personal data
  • type and purpose of data processing
  • subject and duration of data processing
  • location of data processing

Furthermore, the contract contains all obligations of the processor. The most important obligations are:

  • ensuring data security measures
  • taking possible technical and organisational measures to protect the rights of the data subject
  • maintaining a data processing record
  • cooperation with the data protection authority upon request
  • performing a risk analysis for any received personal data
  • subprocessors may only be appointed with the written consent of the controller

You can see an example of what a DPA looks like at https://gdpr.eu/data-processing-agreement/. This link shows a sample contract.

Cookies

Cookies Overview

👥 Affected parties: visitors to the website
🤝 Purpose: depending on the respective cookie. You can find out more details below or from the software manufacturer that sets the cookie.
📓 Processed data: depends on the cookie used. More details can be found below or from the manufacturer of the software that sets the cookie.
📅 Storage duration: can vary from hours to years, depending on the respective cookie
⚖️ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What are cookies?

Our website uses HTTP-cookies to store user-specific data.
In the following we explain what cookies are and why they are used, so that you can better understand the following privacy policy.

Whenever you surf the Internet, you are using a browser. Common browsers are for example, Chrome, Safari, Firefox, Internet Explorer and Microsoft Edge. Most websites store small text-files in your browser. These files are called cookies.

It is important to note that cookies are very useful little helpers. Almost every website uses cookies. More precisely, these are HTTP cookies, as there are also other cookies for other uses. HTTP cookies are small files that our website stores on your computer. These cookie files are automatically placed into the cookie-folder, which is the “brain” of your browser. A cookie consists of a name and a value. Moreover, to define a cookie, one or multiple attributes must be specified.

Cookies store certain user data about you, such as language or personal page settings. When you re-open our website to visit again, your browser submits these “user-related” information back to our site. Thanks to cookies, our website knows who you are and offers you the settings you are familiar to. In some browsers, each cookie has its own file, while in others, such as Firefox, all cookies are stored in one single file.

The following graphic shows a possible interaction between a web browser such as Chrome and the web server. The web browser requests a website and receives a cookie back from the server. The browser then uses this again as soon as another page is requested.

HTTP cookie interaction between browser and web server

There are both first-party cookies and third-party cookies. First-party cookies are created directly by our site, while third-party cookies are created by partner-websites (e.g. Google Analytics). Each cookie must be evaluated individually, as each cookie stores different data. The expiry time of a cookie also varies from a few minutes to a few years. Cookies are not software programs and do not contain viruses, trojans or other malware. Cookies also cannot access your PC’s information.

This is an example of how cookie-files can look:

Name: _ga
Value: GA1.2.1326744211.152112447860-9
Purpose: Differentiation between website visitors
Expiry date: after 2 years

A browser should support these minimum sizes:

  • At least 4096 bytes per cookie
  • At least 50 cookies per domain
  • At least 3000 cookies in total

Which types of cookies are there?

The exact cookies that we use, depend on the used services, which will be outlined in the following sections of this privacy policy. Firstly, we will briefly focus on the different types of HTTP-cookies.

There are 4 different types of cookies:

Essential cookies
These cookies are necessary to ensure the basic functions of a website. They are needed when a user for example puts a product into their shopping cart, then continues surfing on different websites and comes back later in order to proceed to the checkout. These cookies ensure the shopping cart does not get deleted, even if the user closes their browser window.

Purposive cookies
These cookies collect information about user behaviour and whether the user receives any error messages. Furthermore, these cookies record the website’s loading time as well as its behaviour in different browsers.

Target-orientated cookies
These cookies ensure better user-friendliness. Thus, information such as previously entered locations, fonts sizes or data in forms stay stored.

Advertising cookies
These cookies are also known as targeting cookies. They serve the purpose of delivering customised advertisements to the user. This can be very practical, but also rather annoying.

Upon your first visit to a website you are usually asked which of these cookie-types you want to accept. Furthermore, this decision will of course also be stored in a cookie.

If you want to learn more about cookies and do not mind technical documentation, we recommend https://tools.ietf.org/html/rfc6265, the Request for Comments of the Internet Engineering Task Force (IETF) called “HTTP State Management Mechanism”.

Purpose of processing via cookies

The purpose ultimately depends on the respective cookie. You can find out more details below or from the software manufacturer that sets the cookie.

Which data are processed?

Cookies are little helpers for a wide variety of tasks. Unfortunately, it is not possible to tell which data is generally stored in cookies, but in the privacy policy below we will inform you on what data is processed or stored.

Storage period of cookies

The storage period depends on the respective cookie and is further specified below. Some cookies are erased after less than an hour, while others can remain on a computer for several years.

You can also influence the storage duration yourself. You can manually erase all cookies at any time in your browser (also see “Right of objection” below). Furthermore, the latest instance cookies based on consent will be erased is after you withdraw your consent. The legality of storage will remain unaffected until then.

Right of objection – how can I erase cookies?

You can decide for yourself how and whether you want to use cookies. Regardless of which service or website the cookies originate from, you always have the option of erasing, deactivating or only partially accepting cookies. You can for example block third-party cookies but allow all other cookies.

If you want to find out which cookies have been stored in your browser, or if you want to change or erase cookie settings, you can find this option in your browser settings:

Chrome: Clear, enable and manage cookies in Chrome

Safari: Manage cookies and website data in Safari

Firefox: Clear cookies and site data in Firefox

Internet Explorer: Delete and manage cookies

Microsoft Edge: Delete cookies in Microsoft Edge

If you generally do not want cookies, you can set up your browser in a way to notify you whenever a cookie is about to be set. This gives you the opportunity to manually decide to either permit or deny the placement of every single cookie. This procedure varies depending on the browser. Therefore, it might be best for you to search for the instructions in Google. If you are using Chrome, you could for example put the search term “delete cookies Chrome” or “deactivate cookies Chrome” into Google.

Legal basis

The so-called “cookie directive” has existed since 2009. It states that the storage of cookies requires your consent (Article 6 Paragraph 1 lit. a GDPR). Within countries of the EU, however, the reactions to these guidelines still vary greatly. In Austria, however, this directive was implemented in Section 96 (3) of the Telecommunications Act (TKG). In Germany, the cookie guidelines have not been implemented as national law. Instead, this guideline was largely implemented in Section 15 (3) of the Telemedia Act (TMG).

For absolutely necessary cookies, even if no consent has been given, there are legitimate interests (Article 6 (1) (f) GDPR), which in most cases are of an economic nature. We want to offer our visitors a pleasant user experience on our website. For this, certain cookies often are absolutely necessary.

This is exclusively done with your consent, unless absolutely necessary cookies are used. The legal basis for this is Article 6 (1) (a) of the GDPR.

In the following sections you will find more detail on the use of cookies, provided the used software does use cookies.

Registration

Registration Overview

👥 Affected parties: Anyone who registers to create an account with us, and logs in to use the account.
📓 Processed data: Personal data such as email address, name, password and other data that is collected during registration, login and account use.
🤝 Purpose: For the provision of our services, as well as to communicate with clients or customers in the scope of our services.

📅 Storage period: As long as the company account associated with the texts exists, plus a period of usually 3 years.
⚖️ Legal bases: Article 6 paragraph 1 letter b GDPR (contract), Article 6 paragraph 1 letter a GDPR (consent), Article 6 paragraph 1 letter f GDPR (legitimate interests)

If you register with us and provide any personal data, this data may be processed, possibly along with your IP address. Below you can explore what we mean by the rather broad term “personal data”.

Please only enter the data we need for the registration. In case you are registering on behalf of a third party, please only enter data for which you have the approval of the party you are registering for. If possible, use a secure password that you don’t use anywhere else and an email address that you check regularly.

In the following, we will inform you about the exact type of data processing we do. After all, we want you to feel at ease with the services we provide!

What is a registration?

When you register, we retain certain of your data in order to make it easy for you to log in with us online and use your account. An account with us has the advantage that you don’t have to re-enter everything every time. It saves time and effort and ultimately prevents any issues with the provision of our services.

Why do we process personal data?

In short, we process personal data to make account registration and usage possible for you.
If we didn’t do this, you would have to enter all your data each time, wait for our approval and then enter everything again. This strenuous process would probably not only irritate us a little, but also many of our dear clients and customers.

Which data is processed?

Any data that you provided during registration or login and any data that you may enter as part of managing your account data.

During registration, we process the following types of data:

  • First name
  • Last name
  • Email address
  • Company name
  • Street + house number
  • Residence
  • Postcode
  • Country

During your registration, we process any data you enter, such as your username and password, along with data that is collected in the background such as your device information and IP addresses.

When using your account, we process any data you enter while using the account, as well as any data that is created while you use our services.

Storage time

We store the entered data for at least as long as the account associated with the data exists with us and is in use – and as long as there are contractual obligations between you and us. In case the contract ends, we retain the data until the respective claims get time-barred. Moreover, we store your data as long as we are subject to legal storage obligations, if applicable. Following that, we keep any accounting records (invoices, contract documents, account statements, etc.) of the contract for 10 years (§ 147 AO) and other relevant business documents for 6 years (§ 247 HGB) after accrual.

Right to object

You have registered, entered data and want to revoke the data processing? Not a problem. As you can see above, you retain this right under the General Data Protection Regulation also at and after registration, login or account creation with us. Contact the Data Protection Officer above to exercise your rights. If you already have an account with us, you can easily view and manage your data and texts in your account.

Legal Basis

By completing the registration process, you enter into a pre-contractual agreement with us, with the intention to conclude a contract of use for our platform (although there is no automatic payment obligation). You invest time to enter data and register and in return, we offer you our services after you log on to our system and view your customer account. We also meet our contractual obligations. Finally, we need to be able to email registered users about important changes. Article 6(1)(b) GDPR (implementation of pre-contractual measures, fulfilment of a contract) applies.

Where applicable, we will ask for your consent, e.g. in case you voluntarily provide more data than is absolutely necessary, or in case we may ask you if we may send you advertising. Article 6 paragraph 1 lit. a GDPR (consent) applies in this matter.

We also have a legitimate interest in knowing who who our clients or customers are, in order to get in touch if required. We also need to know who is using our services and whether they are being used in accordance with our terms of use, i.e. Article 6(1)(f) GDPR (legitimate interests) applies in this matter.

Note: the following sections are to be ticked by users (as required):

Registration with real names

Since business operations require us to know who our clients or customers are, registration is only possible with your real name (full name) and not with a pseudonym.

Registration with pseudonyms

You can use a pseudonym for the registration, which means you don’t have to register with your real name. This ensures that your real name cannot be processed by us.

Storage of the IP address

During registration, login and account use, we store your IP address for security reasons in order to be able to determine legitimate use.

Public Profile

User profiles are publicly visible, i.e. parts of the profiles can also be viewed on the Internet without the need to enter a username and password.

Two Factor Authentication (2FA)

Two Factor Authentication (2FA) offers additional security when logging in, as it prevents you from logging in without a smartphone, for example. This technical measure to secure your account protects you against the loss of data or unauthorised access, even if your username and password were leaked. During your registration process, login or within the account itself y
ou can find out which 2FA is used.

Web Analytics

Web Analytics Privacy Policy Overview

👥 Affected parties: visitors to the website
🤝 Purpose: Evaluation of visitor information to optimise the website.
📓 Processed data: Access statistics that contain data such as access location, device data, access duration and time, navigation behaviour, click behaviour and IP addresses. You can find more details on this from the respective web analytics tool directly.
📅 Storage period: depending on the respective web analytics tool used
⚖️ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is Web Analytics?

We use software on our website, which is known as web analytics, in order to evaluate website visitor behaviour. Thus, data is collected, which the analytic tool provider (also called tracking tool) stores, manages and processes. Analyses of user behaviour on our website are created with this data, which we as the website operator receive. Most tools also offer various testing options. These enable us, to for example test which offers or content our visitors prefer. For this, we may show you two different offers for a limited period of time. After the test (a so-called A/B test) we know which product or content our website visitors find more interesting. For such testing as well as for various other analyses, user profiles are created and the respective data is stored in cookies.

Why do we run Web Analytics?

We have a clear goal in mind when it comes to our website: we want to offer our industry’s best website on the market. Therefore, we want to give you both, the best and most interesting offer as well as comfort when you visit our website. With web analysis tools, we can observe the behaviour of our website visitors, and then improve our website accordingly for you and for us. For example, we can see the average age of our visitors, where they come from, the times our website gets visited the most, and which content or products are particularly popular. All this information helps us to optimise our website and adapt it to your needs, interests and wishes.

Which data are processed?

The exact data that is stored depends on the analysis tools that are being used. But generally, data such as the content you view on our website are stored, as well as e. g. which buttons or links you click, when you open a page, which browser you use, which device (PC, tablet, smartphone, etc.) you visit the website with, or which computer system you use. If you have agreed that location data may also be collected, this data may also be processed by the provider of the web analysis tool.

Moreover, your IP address is also stored. According to the General Data Protection Regulation (GDPR), IP addresses are personal data. However, your IP address is usually stored in a pseudonymised form (i.e. in an unrecognisable and abbreviated form). No directly linkable data such as your name, age, address or email address are stored for testing purposes, web analyses and web optimisations. If this data is collected, it is retained in a pseudonymised form. Therefore, it cannot be used to identify you as a person.

The following example shows Google Analytics’ functionality as an example for client-based web tracking with JavaScript code.

Schematic data flow in Google Analytics

The storage period of the respective data always depends on the provider. Some cookies only retain data for a few minutes or until you leave the website, while other cookies can store data for several years.

Duration of data processing

If we have any further information on the duration of data processing, you will find it below. We generally only process personal data for as long as is absolutely necessary to provide products and services. The storage period may be extended if it is required by law, such as for accounting purposes for example for accounting.

Right to object

You also have the option and the right to revoke your consent to the use of cookies or third-party providers at any time. This works either via our cookie management tool or via other opt-out functions. For example, you can also prevent data processing by cookies by managing, deactivating or erasing cookies in your browser.

Legal basis

The use of Web Analytics requires your consent, which we obtained with our cookie popup. According to Art. 6 para. 1 lit. a of the GDPR (consent), this consent represents the legal basis for the processing of personal data, such as by collection through Web Analytics tools.

In addition to consent, we have a legitimate interest in analysing the behaviour of website visitors, which enables us to technically and economically improve our offer. With Web Analytics, we can recognise website errors, identify attacks and improve profitability. The legal basis for this is Art. 6 para. 1 lit. f of the GDPR (legitimate interests). Nevertheless, we only use these tools if you have given your consent.

Since Web Analytics tools use cookies, we recommend you to read our privacy policy on cookies. If you want to find out which of your data are stored and processed, you should read the privacy policies of the respective tools.

If available, information on special Web Analytics tools can be found in the following sections.

Facebook Pixel Privacy Policy

We use Facebook’s Facebook pixel on our website. For that, we have implemented a code on our website. The Facebook pixel is a segment of a JavaScript code, which, in case you came to our website via Facebook ads, loads an array or functions that enable Facebook to track your user actions. For example, if you buy a product on our website, the Facebook pixel is triggered and stores your actions on our website in one or more cookies. These cookies enable Facebook to match your user data (customer data such as IP address, user ID) with the data of your Facebook account. After that, Facebook deletes your data again. The collected data is anonymous as well as inaccessible and can only be used for ad placement purposes. If you are a Facebook user and you are logged in, your visit to our website is automatically assigned to your Facebook user account.

We exclusively want to show our products or services to persons, who are interested in them. With the aid of the Facebook pixel, our advertising measures can get better adjusted to your wishes and interests. Therefore, Facebook users get to see suitable advertisement (if they allowed personalised advertisement). Moreover, Facebook uses the collected data for analytical purposes and for its own advertisements.

In the following we will show you the cookies, which were set on a test page with the Facebook pixel integrated to it. Please consider that these cookies are only examples. Depending on the interaction that is made on our website, different cookies are set.

Name: _fbp
Value: fb.1.1568287647279.257405483-6112447860-7
Purpose: Facebook uses this cookie to display advertising products.
Expiration date: after 3 months

Name: fr
Value: 0aPf312HOS5Pboo2r..Bdeiuf…1.0.Bdeiuf.
Purpose: This cookie is used for Facebook pixels to function properly.
Expiration date: after 3 months

Name: comment_author_50ae8267e2bdf1253ec1a5769f48e062112447860-3
Value: Name of the author
Purpose: This cookie saves the text and name of a user who e.g. leaves a comment.
Expiration date: after 12 months

Name: comment_author_url_50ae8267e2bdf1253ec1a5769f48e062
Value: https%3A%2F%2Fwww.testseite…%2F (URL of the author)
Purpose: This cookie saved the URL of the website that the user types into a text box on our website.
Expiration date: after 12 months

Name: comment_author_email_50ae8267e2bdf1253ec1a5769f48e062
Value: email address of the author
Purpose: This cookie saves the email address of the user, if they provided it on the website.
Expiration date: after 12 months

Note: The above-mentioned cookies relate to an individual user behaviour. Moreover, especially concerning the usage of cookies, changes at Facebook can never be ruled out.

If you are registered on Facebook, you can change the settings for advertisements yourself at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. If you are not a Facebook user, you can manage your user based online advertising at https://www.youronlinechoices.com/uk/your-ad-choices. You have the option to activate or deactivate any providers there.

We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfer to the USA. Data processing is done mainly through Facebook Pixel. This may lead to data not being anonymously processed and stored. Furthermore, US government authorities may get access to individual data. The data may also get linked to data from other Facebook services you have a user account with.

If you want to learn more about Facebook’s data protection, we recommend you the view the company’s in-house data policies at https://www.facebook.com/policy.php.

Google Analytics Privacy Policy

Google Analytics Privacy Policy Overview

👥 Affected parties: website visitors
🤝 Purpose: Evaluation of visitor information to optimise the website.
📓 Processed data: Access statistics that contain data such as the location of access, device data, access duration and time, navigation behaviour, click behaviour and IP addresses. You can find more details on this in the privacy policy below.
📅 Storage period: depending on the properties used
⚖️ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is Google Analytics?

We use the tracking and analysis tool Google Analytics (GA) of the US-American company Google LLC (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). Google Analytics collects data on your actions on our website. Whenever you click a link for example, this action is saved in a cookie and transferred to Google Analytics. With the help of reports which we receive from Google Analytics, we can adapt our website and our services better to your wishes. In the following, we will explain the tracking tool in more detail, and most of all, we will inform you what data is saved and how you can prevent this.

Google Analytics is a tracking tool with the purpose of conducting data traffic analysis of our website. For Google Analytics to work, there is a tracking code integrated to our website. Upon your visit to our website, this code records various actions you perform on your website. As soon as you leave our website, this data is sent to the Google Analytics server, where it is stored.

Google processes this data and we then receive reports on your user behaviour. These reports can be one of the following:

  • Target audience reports: With the help of target audience reports we can get to know our users better and can therefore better understand who is interested in our service.
  • Advertising reports: Through advertising reports we can analyse our online advertising better and hence improve it.
  • Acquisition reports: Acquisition reports provide us helpful information on how we can get more people enthusiastic about our service.
  • Behaviour reports: With these reports, we can find out how you interact with our website. By the means of behaviour reports, we can understand what path you go on our website and what links you click.
  • Conversion reports: A conversion is the process of leading you to carry out a desired action due to a marketing message. An example of this would be transforming you from a mere website visitor into a buyer or a newsletter subscriber. Hence, with the help of these reports we can see in more detail, if our marketing measures are successful with you. Our aim is to increase our conversion rate.
  • Real time reports: With the help of these reports we can see in real time, what happens on our website. It makes us for example see, we can see how many users are reading this text right now.

Why do we use Google Analytics on our website?

The objective of our website is clear: We want to offer you the best possible service. Google Analytics’ statistics and data help us with reaching this goal.

Statistically evaluated data give us a clear picture of the strengths and weaknesses of our website. On the one hand, we can optimise our page in a way, that makes it easier to be found by interested people on Google. On the other hand, the data helps us to get a better understanding of you as our visitor. Therefore, we can very accurately find out what we must improve on our website, in order to offer you the best possible service. The analysis of that data also enables us to carry out our advertising and marketing measures in a more individual and more cost-effective way. After all, it only makes sense to show our products and services exclusively to people who are interested in them.

What data is stored by Google Analytics?

With the aid of a tracking code, Google Analytics creates a random, unique ID which is connected to your browser cookie. That way, Google Analytics recognises you as a new user. The next time you visit our site, you will be recognised as a “recurring” user. All data that is collected gets saved together with this very user ID. Only this is how it is made possible for us to evaluate and analyse pseudonymous user profiles.

To analyse our website with Google Analytics, a property ID must be inserted into the tracking code. The data is then stored in the corresponding property. Google Analytics 4-property is standard for every newly created property. An alternative however, is the Universal Analytics Property. Depending on the property that is being used, data are stored for different periods of time.

Your interactions on our website are measured by tags such as cookies and app instance IDs. Interactions are all kinds of actions that you perform on our website. If you are also using other Google systems (such as a Google Account), data generated by Google Analytics can be linked with third-party cookies. Google does not pass on any Google Analytics data, unless we as the website owners authorise it. In case it is required by law, exceptions can occur.

The following cookies are used by Google Analytics:

Name: _ga
Value:2.1326744211.152112447860-5
Purpose: By deafault, analytics.js uses the cookie _ga, to save the user ID. It generally serves the purpose of differentiating between website visitors.
Expiration date: After 2 years

Name: _gid
Value:2.1687193234.152112447860-1
Purpose: This cookie also serves the purpose of differentiating between website users
Expiration date: After 24 hours

Name: _gat_gtag_UA_<property-id>
Value: 1
Verwendungszweck: It is used for decreasing the demand rate. If Google Analytics is provided via Google Tag Manager, this cookie gets the name _dc_gtm_ <property-id>.
Expiration date: After 1 minute

Name: AMP_TOKEN
Value: No information
Purpose: This cookie has a token which is used to retrieve the user ID by the AMP Client ID Service. Other possible values suggest a logoff, a request or an error.
Expiration date: After 30 seconds up to one year

Name: __utma
Value:1564498958.1564498958.1564498958.1
Purpose: With this cookie your behaviour on the website can be tracked and the site performance can be measured. The cookie is updated every time the information is sent to Google Analytics.
Expiration date: After 2 years

Name: __utmt
Value: 1
Purpose: Just like _gat_gtag_UA_<property-id> this cookie is used for keeping the requirement rate in check.
Expiration date: Afer 10 minutes

Name: __utmb
Value:3.10.1564498958
Purpose: This cookie is used to determine new sessions. It is updated every time new data or information gets sent to Google Analytics.
Expiration date: After 30 minutes

Name: __utmc
Value: 167421564
Purpose: This cookie is used to determine new sessions for recurring visitors. It is therefore a session cookie, and only stays stored until you close the browser again.
Expiration date: After closing the browser

Name: __utmz
Value: m|utmccn=(referral)|utmcmd=referral|utmcct=/
Purpose: This cookie is used to identify the source of the number of visitors to our website. This means, that the cookie stored information on where you came to our website from. This could be another site or an advertisement.
Expiration date: After 6 months

Name: __utmv
Value: No information
Purpose: The cookie is used to store custom user data. It gets updated whenever information is sent to Google Analytics.
Expiration date: After 2 years

Note: This list is by no means exhaustive, since Google are repeatedly changing the use of their cookies.

Below we will give you an overview of the most important data that can be evaluated by Google Analytics:

Heatmaps: Google creates so-called Heatmaps an. These Heatmaps make it possible to see the exact areas you click on, so we can get information on what routes you make on our website.

Session duration: Google calls the time you spend on our website without leaving it session duration. Whenever you are inactive for 20 minutes, the session ends automatically.

Bounce rate If you only look at one page of our website and then leave our website again, it is called a bounce.

Account creation: If you create an account or make an order on our website, Google Analytics collects this data.

IP-Address: The IP address is only shown in a shortened form, to make it impossible to clearly allocate it.

Location: Your approximate location and the country you are in can be defined by the IP address. This process is called IP location determination.

Technical information: Information about your browser type, your internet provider and your screen resolution are called technical information.

Source: Both, Google Analytics as well as ourselves, are interested what website or what advertisement led you to our site.

Further possibly stored data include contact data, potential reviews, playing media (e.g. when you play a video on our site), sharing of contents via social media or adding our site to your favourites. This list is not exhaustive and only serves as general guidance on Google Analytics’ data retention.

How long and where is the data stored?

Google has servers across the globe. Most of them are in America and therefore your data is mainly saved on American servers. Here you can read detailed information on where Google’s data centres are located: https://www.google.com/about/datacenters/locations/?hl=en

Your data is allocated to various physical data mediums. This has the advantage of allowing to retrieve the data faster, and of protecting it better from manipulation. Every Google data centre has respective emergency programs for your data. Hence, in case of a hardware failure at Google or a server error due to natural disasters, the risk for a service interruption stays relatively low.

The data retention period depends on the properties used. When using the newer Google Analytics 4-properties, the retention period of your user data is set to 14 months. For so-called event data, we have the option of choosing a retention period of either 2 months or 14 months.

Google Analytics has a 26 months standardised period of retaining your user data. After this time, your user data is deleted. However, we have the possibility to choose the retention period of user data ourselves. There are the following five options:

  • Deletion after 14 months
  • Deletion after 26 months
  • Deletion after 38 months
  • Deletion after 50 months
  • No automatical deletion

Additionally, there is the option for data to be deleted only if you no longer visit our website within a period determined by us. In this case, the retention period will be reset every time you revisit our website within the specified period.

As soon as the chosen period is expired, the data is deleted once a month. This retention period applies to any of your data which is linked to cookies, user identification and advertisement IDs (e.g. cookies of the DoubleClick domain). Any report results are based on aggregated information and are stored independently of any user data. Aggregated information is a merge of individual data into a single and bigger unit.

How can I delete my data or prevent data retention?

Under the provisions of the European Union’s data protection law, you have the right to obtain information on your data and to update, delete or restrict it. With the help of a browser add on that can deactivate Google Analytics’ JavaScript (ga.js, analytics.js, dc.js), you can prevent Google Analytics from using your data. You can download this add on at https://tools.google.com/dlpage/gaoptout?hl=en-GB. Please consider that this add on can only deactivate any data collection by Google Analytics.

If you generally want to deactivate, delete or manage all cookies (independently of Google Analytics), you can use one of the guides that are available for any browser:

Chrome: Clear, enable and manage cookies in Chrome

Safari: Manage cookies and website data in Safari

Firefox: Clear cookies and site data in Firefox

Internet Explorer: Delete and manage cookies

Microsoft Edge: Delete cookies in Microsoft Edge

Legal basis

The use of Google Analytics requires your consent, which we obtained via our cookie popup. According to Art. 6 para. 1 lit. a of the GDPR (consent) , this is the legal basis for the processing of personal data when collected via web analytics tools.

In addition to consent, we have legitimate interest in analysing the behaviour of website visitors, in order to technically and economically improve our offer. With Google Analytics, we can recognise website errors, identify attacks and improve profitability. The legal basis for this is Art. 6 para. 1 lit. f of the GDPR (legitimate interests) . Nevertheless, we only use Google Analytics if you have given your consent.

Google also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.

Google uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Google to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847

The Google Ads Data Processing Terms, which reference the standard contractual clauses, can be found at https://business.safety.google/intl/en/adsprocessorterms/.

We hope we could provide you with the most important information about data processing by Google Analytics. If you want to find out more on the tracking service, we recommend these two links: https://marketingplatform.google.com/about/analytics/terms/gb/ and https://support.google.com/analytics/answer/6004245?hl=en.

Data Processing Agreement (DPA) Google Analytics

In accordance with Article 28 of the General Data Protection Regulation (GDPR), we have entered into a Data Processing Agreement (DPA) with Google Analytics. What exactly a DPA is and especially what must be included in a DPA, you can read in our general section “Data Processing Agreement (DPA)”.

This contract is required by law because Google Analytics processes personal data on our behalf. It clarifies that Google Analytics may only process data they receive from us according to our instructions and must comply with the GDPR. You can find the link to the Data Processing Terms under https://business.safety.google/intl/en/adsprocessorterms/.

Google Analytics IP Anonymisation

We implemented Google Analytics’ IP address anonymisation to this website. Google developed this function, so this website can comply with the applicable privacy laws and the local data protection authorities’ recommendations, should they prohibit the retention of any full IP addresses.
The anonymisation or masking of IP addresses takes place, as soon as they reach Google Analytics’ data collection network, but before the data would be saved or processed.

You can find more information on IP anonymisation at https://support.google.com/analytics/answer/2763052?hl=en.

Google Tag Manager Privacy Policy

Google Tag Manager Privacy Policy Overview

👥 Affected parties: website visitors
🤝 Purpose: Organisation of individual tracking tools
📓 Processed data: Google Tag Manager itself does not store any data. The data record tags of the web analytics tools used.
📅 Storage period: depending on the web analytics tool used
⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is Google Tag Manager?

We use Google Tag Manager by the company Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA) for our website.
This Tag Manager is one of Google’s many helpful marketing products. With it, we can centrally integrate and manage code sections of various tracking tools, that we use on our website.

In this privacy statement we will explain in more detail, what Google Tag Manager does, why we use it and to what extent your data is processed.

Google Tag Manager is an organising tool with which we can integrate and manage website tags centrally and via a user interface. Tags are little code sections which e.g. track your activities on our website. For this, segments of JavaScript code are integrated to our site’s source text. The tags often come from Google’s intern products, such as Google Ads or Google Analytics, but tags from other companies can also be integrated and managed via the manager. Since the tags have different tasks, they can collect browser data, feed marketing tools with data, embed buttons, set cookies and track users across several websites.

Why do we use Google Tag Manager for our website?

Everybody knows: Being organised is important! Of course, this also applies to maintenance of our website. In order to organise and design our website as well as possible for you and anyone who is interested in our products and services, we rely on various tracking tools, such as Google Analytics.
The collected data shows us what interests you most, which of our services we should improve, and which other persons we should also display our services to. Furthermore, for this tracking to work, we must implement relevant JavaScript Codes to our website. While we could theoretically integrate every code section of every tracking tool separately into our source text, this would take too much time and we would lose overview. This is the reason why we use Google Tag Manager. We can easily integrate the necessary scripts and manage them from one place. Additionally, Google Tag Manager’s user interface is easy to operate, and requires no programming skills. Therefore, we can easily keep order in our jungle of tags.

What data is stored by Google Tag Manager?

Tag Manager itself is a domain that neither uses cookies nor stores data. It merely functions as an “administrator“ of implemented tags. Data is collected by the individual tags of the different web analysis tools. Therefore, in Google Tag Manager the data is sent to the individual tracking tools and does not get saved.

However, with the integrated tags of different web analysis tools such as Google Analytics, this is quite different. Depending on the analysis tool used, various data on your internet behaviour is collected, stored and processed with the help of cookies. Please read our texts on data protection for more information on the articular analysis and tracking tools we use on our website.

We allowed Google via the account settings for the Tag Manager to receive anonymised data from us. However, this exclusively refers to the use of our Tag Manager and not to your data, which are saved via code sections. We allow Google and others, to receive selected data in anonymous form. Therefore, we agree to the anonymised transfer of our website data. However, even after extensive research we could not find out what summarised and anonymous data it is exactly that gets transmitted. What we do know is that Google deleted any info that could identify our website. Google combines the data with hundreds of other anonymous website data and creates user trends as part of benchmarking measures. Benchmarking is a process of comparing a company’s results with the ones of competitors. As a result, processes can be optimised based on the collected information.

How long and where is the data stored?

When Google stores data, this is done on Google’s own servers. These servers are located all over the world, with most of them being in America. At https://www.google.com/about/datacenters/inside/locations/?hl=en you can read in detail where Google’s servers are.

In our individual data protection texts on the different tools you can find out how long the respective tracking tools store your data.

How can I delete my data or prevent data retention?

Google Tag Manager itself does not set any cookies but manages different tracking websites’ tags. In our data protection texts on the different tracking tools you can find detailed information on how you can delete or manage your data.

Please note that when using this tool, your data may also be stored and processed outside the EU. Most third countries (including the USA) are not considered secure under current European data protection law. Data must not be transferred, stored and processed to insecure third countries, unless there are suitable guarantees (such as EU standard contractual clauses) between us and the non-European service provider.

Legal basis

The use of the Google Tag Manager requires your consent, which we obtained via our cookie popup. According to Art. 6 para. 1 lit. a GDPR (consent), this consent is the legal basis for personal data processing, such as when it is collected by web analytics tools.

In addition to consent, we have a legitimate interest in analysing the behaviour of website visitors and thus technically and economically improving our offer. With the help of Google Tag Managers we can also improve profitability. The legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests). We only use Google Tag Manager if you have given us your consent.

Google also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.

Google uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Google to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847

The Google Ads Data Processing Terms, which reference the standard contractual clauses, can be found at https://business.safety.google/intl/en/adsprocessorterms/

If you want to learn more about Google Tag Manager, we recommend their FAQs at https://support.google.com/tagmanager/?hl=en#topic=3441530.

Email-Marketing

Email Marketing Overview

👥 Affected parties: newsletter subscribers
🤝 Purpose: direct marketing via email, notification of events that are relevant to the system
📓 Processed data: data entered during registration, but at least the email address. You can find more details on this in the respective email marketing tool used.
📅 Storage duration: for the duration of the subscription
⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is Email-Marketing?

We use email marketing to keep you up to date. If you have agreed to receive our emails or newsletters, your data will be processed and stored. Email marketing is a part of online marketing. In this type of marketing, news or general information about a company, product or service are emailed to a specific group of people who are interested in it.

If you want to participate in our email marketing (usually via newsletter), you usually just have to register with your email address. To do this, you have to fill in and submit an online form. However, we may also ask you for your title and name, so we can address you personally in our emails.

The registration for newsletters generally works with the help of the so-called “double opt-in procedure”. After you have registered for our newsletter on our website, you will receive an email, via which you can confirm the newsletter registration. This ensures that you own the email address you signed up with, and prevents anyone to register with a third-party email address. We or a notification tool we use, will log every single registration. This is necessary so we can ensure and prove, that registration processes are done legally and correctly. In general, the time of registration and registration confirmation are stored, as well as your IP address. Moreover, any change you make to your data that we have on file is also logged.

Why do we use Email-Marketing?

Of course, we want to stay in contact with you and keep you in the loop of the most important news about our company. For this, we use email marketing – often just referred to as “newsletters” – as an essential part of our online marketing. If you agree to this or if it is permitted by law, we will send you newsletters, system emails or other notifications via email. Whenever the term “newsletter” is used in the following text, it mainly refers to emails that are sent regularly. We of course don’t want to bother you with our newsletter in any way. Thus, we genuinely strive to offer only relevant and interesting content. In our emails you can e.g. find out more about our company and our services or products. Since we are continuously improving our offer, our newsletter will always give you the latest news, or special, lucrative promotions. Should we commission a service provider for our email marketing, who offers a professional mailing tool, we do this in order to offer you fast and secure newsletters. The purpose of our email marketing is to inform you about new offers and also to get closer to our business goals.

Which data are processed?

If you subscribe to our newsletter via our website, you then have to confirm your membership in our email list via an email that we will send to you. In addition to your IP and email address, your name, address and telephone number may also be stored. However, this will only be done if you agree to this data retention. Any data marked as such are necessary so you can participate in the offered service. Giving this information is voluntary, but failure to provide it will prevent you from using this service. Moreover, information about your device or the type of content you prefer on our website may also be stored. In the section “Automatic data storage” you can find out more about how your data is stored when you visit a website. We record your informed consent, so we can always prove that it complies with our laws.

Duration of data processing

If you unsubscribe from our e-mail/newsletter distribution list, we may store your address for up to three years on the basis of our legitimate interests, so we can keep proof your consent at the time. We are only allowed to process this data if we have to defend ourselves against any claims.

However, if you confirm that you have given us your consent to subscribe to the newsletter, you can submit an individual request for erasure at any time. Furthermore, if you permanently object to your consent, we reserve the right to store your email address in a blacklist. But as long as you have voluntarily subscribed to our newsletter, we will of course keep your email address on file.

Withdrawal – how can I cancel my subscription?

You have the option to cancel your newsletter subscription at any time. All you have to do is revoke your consent to the newsletter subscription. This usually only takes a few seconds or a few clicks. Most of the time you will find a link at the end of every email, via which you will be able to cancel the subscription. Should you not be able to find the link in the newsletter, you can contact us by email and we will immediately cancel your newsletter subscription for you.

Legal basis

Our newsletter is sent on the basis of your consent (Article 6 (1) (a) GDPR). This means that we are only allowed to send you a newsletter if you have actively registered for it beforehand. Moreover, we may also send you advertising messages on the basis of Section 7 (3) UWG (Unfair Competition Act), provided you have become our customer and have not objected to the use of your email address for direct mail.

If available – you can find information on special email marketing services and how they process personal data, in the following sections.

Sendinblue Privacy Policy

Sendinblue Privacy Policy Overview

👥 Affected parties: newsletter subscribers
🤝 Purpose: direct marketing via email, notification of relevant events to the system
📓 Processed data: data that was entered during registration, but at least email addresses.
📅 Storage duration: for subscription duration
⚖️ Legal bases: Art. 6 paragraph 1 lit. a GDPR (consent), Art. 6 paragraph 1 lit. f GDPR (legitimate interests)

What is Sendinblue?

On our website you can subscribe to our newsletter for free. For this to work, we use the Sendinblue email service for our newsletter. This is a service of the German company Sendinblue GmbH, Köpenicker street 126, 10179 Berlin. Sendinblue is an email marketing tool, among other things, that we can use to send you customised newsletters. With Sendinblue there is no need for us to install anything, all while we can still draw on a pool of really useful functions. In the following we will go into more detail about this email marketing service and inform you on the most important aspects that are relevant to data protection and privacy.

Why do we use Sendinblue?

The newsletter service also offers us helpful options for analysis purposes. This means that if we send a newsletter, we can for example find out whether and when you opened the newsletter. The software also detects and records which link you click in the newsletter. This information helps us enormously to adapt and optimise our service to your wishes and concerns. After all, we naturally want to offer you the best possible service. In addition to the data already mentioned above, data about your user behaviour is also stored.

Which data is processed by Sendinblue?

We are of course very pleased if you register for our newsletter. That way we can always let you know first-handedly what is going on in our company, so you can stay up to date. However, you should know that when you sign up for the newsletter, all data you enter (such as your email address or your first and last name) will be retained and managed on our server as well as at Sendinblue. This also applies to personal data. For example, in addition to the time and date of registration, your IP address is also stored. During registration, you also consent to being sent our newsletter. There will also be a reference to this Privacy Policy. Furthermore, data such as your click behaviour within the newsletter may also be processed.

How long and where are the data retained?

The data for the newsletter tool are stored on servers in Germany. Any retained data that could be used to identify you personally (i.e. personal data), are generally erased at Sendinblue no later than two years after our contractual relationship ends. You can also request the erasure of your data individually and at any time. Requests are processed within 30 days. Data that we collect and transmit to Sendinblue will be erased by us as soon as you unsubscribe from our newsletter.

Right to object

You have the option to cancel your newsletter subscription at any time. All you have to do is revoke your consent to your newsletter subscription. This normally only takes a few seconds or one or two clicks. Usually you will find a link at the end of every email to unsubscribe from the newsletter. If you genuinely cannot find the link in the newsletter, please email us and we will cancel your newsletter subscription immediately. After you unsubscribe, your personal data will be erased from our server as well as from Sendinblue’s servers located in Germany. You have the right to receive free information about your stored data and, where applicable, a right to erasure, restrict processing or rectification.

Legal basis

Our newsletter is sent by Sendinblue on the basis of your consent (Article 6 paragraph 1 lit. a GDPR). Thus, we are only authorised to send you a newsletter if you have actively registered for it beforehand. If your consent is not required, the newsletter is sent to you on the basis of our  legitimate interest in direct marketing (Article 6 paragraph 1 lit. f), provided this is legally permitted. We record your registration process so we can prove compliance with the law at any time.

If you would like more information about data processing, we recommend the company’s Privacy Policy at https://www.sendinblue.com/legal/privacypolicy/ along with the following information page at https://www.sendinblue.com/information-for-email-recipients/.

Content Delivery Networks

Content Delivery Networks Privacy Policy Overview

👥 Affected parties: website visitors
🤝 Purpose: Service performance optimisation (to increase website loading speeds)
📓 Processed data: data such as your IP address
You can find more details on this below as well as in the individual Privacy Policies.
📅 Storage period: most data is stored until it is no longer needed for the provision of the service.
⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is a Content Delivery Network?

On our website we use a so-called content delivery network or CDN. This helps to load our website quickly and easily, regardless of your location. Moreover, your personal data will also be stored, managed and processed on the respective CDN provider’s servers. In the following, we will go into more general detail on this service and the data processing associated with it. You can find detailed information on how your data is handled in the provider’s Privacy Policy.

Each content delivery network (CDN) is a network of regionally distributed servers that are connected to each other via the internet. Through this network, website content (especially very large files) can be delivered quickly and smoothly, even when large loading peaks occur. To make this possible, CDNs create a copy of our website on their servers. The website can be delivered quickly because these servers are distributed all around the world. Any data transfer to your browser is therefore significantly shortened by the CDN.

Why do we use a Content Delivery Network for our website?

A fast loading website is part of our service. Of course, we know how annoying it is when a website loads at a snail’s pace. Most of the time, you lose your patience and click away before the website is fully loaded. But of course we want to avoid that. Therefore, to us a fast loading website is an obligatory part of our website offer. With the use of a content delivery network, our website loads significantly faster in your browser. Furthermore, CDNs are particularly helpful when you are abroad, as the website is always delivered from a server in your area.

Which data are processed?

If you access a website or its content and it gets cached in a CDN, the CDN forwards the request to the server closest to you which then delivers the content. Content delivery networks are built in a way that JavaScript libraries can be downloaded and hosted on npm and Github servers. Alternatively, WordPress plugins can also be loaded on most CDNs, provided they are hosted on WordPress.org. Moreover, your browser can send personal data to the content delivery network we use. This includes data such as IP addresses, browser type, browser version, the accessed website or the time and date of the page visit. This data is collected and stored by the CDN. Whether cookies are used for data storage depends on the network that is being used. For more information on this, please read the Privacy Policy of the respective service.

Right to object

If you want to prevent this data transfer altogether, you can use a JavaScript blocker (see for example https://noscript.net/) on your computer. However, our website can then of course no longer offer its usual service (such as a fast loading speeds).

Legal basis

If you have consented to the use of a content delivery network, your consent represents the the legal basis for the corresponding data processing. According to Art. 6 paragraph 1 lit. a (consent) your consent represents the legal basis for the processing of personal data, as it can occur when collected by a content delivery network.

We also have a legitimate interest in using a content delivery network to optimise our online service and make it more secure. The corresponding legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests). Nevertheless, we only use the tool if you have consented to it.

Provided this information is available, you can find out more about the particular content delivery networks in the following sections.

Cloudflare Privacy Policy

Cloudflare Privacy Policy Overview

👥 Affected parties: website visitors
🤝 Purpose: service performance optimisation (to accelerate website loading times)
📓 Processed data: data such as IP address, contact and protocol information, security fingerprints and website performance data
You can find more details on this in the Privacy Policy below.
📅 Storage duration: most of the data is stored for less than 24 hours
⚖️ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is Cloudflare?

We use Cloudflare by the company Cloudflare, Inc. (101 Townsend St., San Francisco, CA 94107, USA) on our website to enhance its speed and security. For this, Cloudflare uses cookies and processes user data. Cloudflare, Inc. is an American company that offers a content delivery network and various security services. These services take place between the user and our hosting provider. In the following, we will try to explain in detail what all this means.

A content delivery network (CDN), as provided by Cloudflare, is nothing more than a network of servers that are connected to each other. Cloudflare has deployed servers around the world, which ensure websites can appear on your screen faster. Simply put, Cloudflare makes copies of our website and places them on its own servers. Thus, when you visit our website, a load distribution system ensures that the main part of our website is delivered by a server that can display our website to you as quickly as possible. The CDN significantly shortens the route of the transmitted data to your browser. Thus, Cloudflare does not only deliver our website’s content from our hosting server, but from servers from all over the world. Cloudflare is particularly helpful for users from abroad, since pages can be delivered from a nearby server. In addition to the fast delivery of websites, Cloudflare also offers various security services, such as DDoS protection, or the web application firewall.

Why do we use Cloudflare on our website?

Of course, we want our website to offer you the best possible service. Cloudflare helps us make our website faster and more secure. Cloudflare offers us web optimisations as well as security services such as DDoS protection and a web firewall. Moreover, this includes a Reverse-Proxy and the content distribution network (CDN). Cloudflare blocks threats and limits abusive bots as well as crawlers that waste our bandwidth and server resources. By storing our website in local data centres and blocking spam software, Cloudflare enables us to reduce our bandwidth usage by about 60%. Furthermore, the provision of content through a data centre near you and certain web optimizations carried out there, cut the average loading time of a website in about half. According to Cloudflare, the setting “I’m Under Attack Mode” can be used to mitigate further attacks by displaying a JavaScript calculation task that must be solved before a user can access a website. Overall, this makes our website significantly more powerful and less susceptible to spam or other attacks.

What data is stored by Cloudflare?

Cloudflare generally only transmits data that is controlled by website operators. Therefore, Cloudflare does not determine the content, but the website operator themselves does. Additionally, Cloudflare may collect certain information about the use of our website and may process data we send or data which Cloudflare has received certain instructions for. Mostly, Cloudflare receives data such as IP addresses, contacts and protocol information, security fingerprints and websites’ performance data. Log data for example helps Cloudflare identify new threats. That way, Cloudflare can ensure a high level of security for our website. As part of their services, Cloudflare process this data in compliance with the applicable laws. Of course, this also includes the compliance with the General Data Protection Regulation (GDPR).

Furthermore, Cloudflare uses a cookie for security reasons. The cookie (__cfduid) is used to identify individual users behind a shared IP address, and to apply security settings for each individual user. The cookie is very useful, if you e.g. use our website from a restaurant where several infected computers are located. However, if your computer is trustworthy, we can recognise that with the cookie. Hence, you will be able to freely and carelessly surf our website, despite the infected PCs in your area. Another point that is important to know, is that this cookie does not store any personal data. The cookie is essential for Cloudflare’s security functions and cannot be deactivated.

Cookies by Cloudflare

Name: __cfduid
Value: d798bf7df9c1ad5b7583eda5cc5e78112447860-3
Purpose: Security settings for each individual visitor
Expiry date: after one year

Cloudflare also works with third party providers. They may however only process personal data after the instruction of Cloudflare and in accordance with the data protection guidelines and other confidentiality and security measures. Without explicit consent from us, Cloudflare will not pass on any personal data.

How long and where is the data stored?

Cloudflare stores your information primarily in the United States and the European Economic Area. Cloudflare can transfer and access the information described above, from all over the world. In general, Cloudflare stores domains’ user-level data with the Free, Pro and Business versions for less than 24 hours. For enterprise domains that have activated Cloudflare Logs (previously called Enterprise LogShare or ELS), data can be stored for up to 7 days. However, if IP addresses trigger security warnings in Cloudflare, there may be exceptions to the storage period mentioned above.

How can I erase my data or prevent data retention?

Cloudflare only keeps data logs for as long as necessary and in most cases deletes the data within 24 hours. Cloudflare also does not store any personal data, such as your IP address. However, there is information that Cloudflare store indefinitely as part of their permanent logs. This is done to improve the overall performance of Cloudflare Resolver and to identify potential security risks. You can find out exactly which permanent logs are saved at https://developers.cloudflare.com/1.1.1.1/commitment-to-privacy/privacy-policy/privacy-policy/. All data Cloudflare collects (temporarily or permanently) is cleared of all personal data. Cloudflare also anonymise all permanent logs.

In their privacy policy, Cloudflare state that they are not responsible for the content you receive. For example, if you ask Cloudflare whether you can update or delete content, Cloudflare will always refer to us as the website operator. You can also completely prevent the collection and processing of your data by Cloudflare, when you deactivate the execution of script-code in your browser, or if you integrate a script blocker to your browser.

Legal basis

If you have consented to the use of Cloudflare, your consent is the legal basis for the corresponding data processing. According to Art. 6 paragraph 1 lit. a (Consent) your consent is the legal basis for the processing of personal data, as can occur when it is collected by Cloudflare.

We also have a legitimate interest in using Cloudflare to optimise our online service and make it more secure. The corresponding legal basis for this is Art. 6 para. 1 lit.f GDPR (legitimate interests). Nevertheless, we only use Cloudflare if you have given your consent to it.

Cloudflare also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.

Cloudflare uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Cloudflare to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.

You can find more information about data protection at Cloudflare at https://www.cloudflare.com/en-gb/privacypolicy/.

Cookie Consent Management Platform Overview

👥 Affected parties: Website visitors
🤝 Purpose: Obtaining and managing consent to certain cookies and thus the use of certain tools
📓 Processed data: data for managing cookie settings such as IP address, time of consent, type of consent and individual consent. You can find more details on this directly with the tool that is being used.
📅 Storage period: depends on the tool used, periods of several years can be assumed
⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is a cookie consent management platform?

We use a Consent Management Platform (CMP) software on our website that makes it easier for us and you to handle the scripts and cookies used correctly and securely. The software automatically creates a cookie pop-up, scans and controls all scripts and cookies, provides you with the cookie consent required under data protection law and helps you and us to keep track of all cookies. Most cookie consent management tools identify and categorize all existing cookies. As a website visitor, you then decide for yourself whether and which scripts and cookies you allow or not. The following graphic shows the relationship between browser, web server and CMP.

Consent Management Platform overview

Why do we use a cookie management tool?

Our goal is to offer you the best possible transparency in the area of ​​data protection. We are also legally obliged to do so. We want to inform you as well as possible about all tools and all cookies that can save and process your data. It is also your right to decide for yourself which cookies you accept and which you do not. In order to grant you this right, we first need to know exactly which cookies actually landed on our website. Thanks to a cookie management tool, which regularly scans the website for all cookies present, we know about all cookies and can provide you with GDPR-compliant information. You can then use the consent system to accept or reject cookies.

Which data are processed?

As part of our cookie management tool, you can manage each individual cookie yourself and have complete control over the storage and processing of your data. The declaration of your consent is stored so that we do not have to ask you every time you visit our website and we can also prove your consent if required by law. This is saved either in an opt-in cookie or on a server. The storage time of your cookie consent varies depending on the provider of the cookie management tool. Usually this data (e.g. pseudonymous user ID, time of consent, detailed information on the cookie categories or tools, browser, device information) is stored for up to two years.

Duration of data processing

We will inform you below about the duration of the data processing if we have further information. In general, we only process personal data for as long as is absolutely necessary for the provision of our services and products. Data stored in cookies are stored for different lengths of time. Some cookies are deleted after you leave the website, others may be stored in your browser for a few years. The exact duration of the data processing depends on the tool used, in most cases you should be prepared for a storage period of several years. In the respective data protection declarations of the individual providers, you will usually receive precise information about the duration of the data processing.

Right of objection

You also have the right and the option to revoke your consent to the use of cookies at any time. This works either via our cookie management tool or via other opt-out functions. For example, you can also prevent data collection by cookies by managing, deactivating or deleting cookies in your browser.

Information on special cookie management tools can be found – if available – in the following sections.

Legal basis

If you agree to cookies, your personal data will be processed and stored via these cookies. If we are allowed to use cookies with your consent (Article 6 paragraph 1 lit. a GDPR), this consent is also the legal basis for the use of cookies and the processing of your data. In order to be able to manage the consent to cookies and to enable you to give your consent, a cookie consent management platform software is used. The use of this software enables us to operate the website in an efficient and legally compliant manner, which is a legitimate interest (Article 6 paragraph 1 lit. f GDPR).

BorlabsCookie Privacy Policy

On our website we use BorlabsCookie, which is one of the tools that store your consent to cookies. The provider of this service is the German company Borlabs – Benjamin A. Bornschein, Rübenkamp 32, 22305 Hamburg, Germany. You can find out more about the data that is processed by the use of BorlabsCookie in their Privacy Policy at
https://borlabs.io/privacy/.

Audio & Video

Audio & Video Privacy Policy Overview

👥 Affected parties: website visitors
🤝 Purpose: service optimisation
📓 Processed data: Data such as contact details, user behaviour, device information and IP addresses can be stored.
You can find more details in the Privacy Policy below.
📅 Storage period: data are retained for as long as necessary for the provision of the service
⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What are audio and video elements?

We have integrated audio and video elements to our website. Therefore, you can watch videos or listen to music/podcasts directly via our website. This content is delivered by service providers and is obtained from the respective providers’ servers.

Audio and video elements are integrated functional elements of platforms such as YouTube, Vimeo or Spotify. It is usually free of charge to use these portals, but they can also contain paid content. With the integrated elements, you can listen to or view any of their content on our website.

If you use audio or video elements on our website, your personal data may get transmitted to as well as processed and retained by service providers.

Why do we use audio & video elements on our website?

We of course want to provide you with the best offer on our website. And we are aware that content is no longer just conveyed in text and static images. Instead of just giving you a link to a video, we offer you audio and video formats directly on our website. These are entertaining or informative, but ideally they are both. Our service therefore gets expanded and it gets easier for you to access interesting content. In addition to our texts and images, we thus also offer video and/or audio content.

Which data are retained by audio & video elements?

When you visit a page on our website with e.g. an embedded video, your server connects to the service provider’s server. Thus, your data will also be transferred to the third-party provider, where it will be stored. Certain data is collected and stored regardless of whether you have an account with the third party provider or not. This usually includes your IP address, browser type, operating system and other general information about your device. Most providers also collect information on your web activity. This e.g. includes the session duration, bounce rate, the buttons you clicked or information about the website you are using the service on. This data is mostly stored via cookies or pixel tags (also known as web beacons). Any data that is pseudonymised usually gets stored in your browser via cookies. In the respective provider’s Privacy Policy, you can always find more information on the data that is stored and processed.

Duration of data processing

You can find out exactly how long the data is stored on the third-party provider’s servers either in a lower point of the respective tool’s Privacy Policy or in the provider’s Privacy Policy. Generally, personal data is only processed for as long as is absolutely necessary for the provision of our services or products. This usually also applies to third-party providers. In most cases, you can assume that certain data will be stored on third-party providers’ servers for several years. Data can be retained for different amounts of time, especially when stored in cookies. Some cookies are deleted after you leave a website, while others may be stored in your browser for a few years.

Right to object

You also retain the right and the option to revoke your consent to the use of cookies or third-party providers at any time. This can be done either via our cookie management tool or via other opt-out functions. You can e.g. also prevent data retention via cookies by managing, deactivating or erasing cookies in your browser. The legality of the processing up to the point of revocation remains unaffected.

Since the integrated audio and video functions on our site usually also use cookies, we recommend you to also read our general Privacy Policy on cookies. You can find out more about the handling and storage of your data in the Privacy Policies of the respective third party providers.

Legal basis

If you have consented to the processing and storage of your data by integrated audio and video elements, your consent is considered the legal basis for data processing (Art. 6 Para. 1 lit. a GDPR). Generally, your data is also stored and processed on the basis of our legitimate interest (Art. 6 Para. 1 lit. f GDPR) in maintaining fast and good communication with you or other customers and business partners. We only use the integrated audio and video elements if you have consented to it.

YouTube Privacy Policy

YouTube Privacy Policy Overview

👥 Affected parties: website visitors
🤝 Purpose: optimising our service
📓 Processed data: Data such as contact details, data on user behaviour, information about your device and IP address may be stored.
You can find more details on this in the privacy policy below.
📅 Storage period: data are generally stored for as long as is necessary for the purpose of the service
⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is YouTube?

We have integrated YouTube videos to our website. Therefore, we can show you interesting videos directly on our site. YouTube is a video portal, which has been a subsidiary company of Google LLC since 2006. The video portal is operated by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. When you visit a page on our website that contains an embedded YouTube video, your browser automatically connects to the servers of YouTube or Google. Thereby, certain data are transferred (depending on the settings). Google is responsible for YouTube’s data processing and therefore Google’s data protection applies.

In the following we will explain in more detail which data is processed, why we have integrated YouTube videos and how you can manage or clear your data.

On YouTube, users can watch, rate, comment or upload videos for free. Over the past few years, YouTube has become one of the most important social media channels worldwide. For us to be able to display videos on our website, YouTube provides a code snippet that we have integrated to our website.

Why do we use YouTube videos on our website?

YouTube is the video platform with the most visitors and best content. We strive to offer you the best possible user experience on our website, which of course includes interesting videos. With the help of our embedded videos, we can provide you other helpful content in addition to our texts and images. Additionally, embedded videos make it easier for our website to be found on the Google search engine. Moreover, if we place ads via Google Ads, Google only shows these ads to people who are interested in our offers, thanks to the collected data.

What data is stored by YouTube?

As soon as you visit one of our pages with an integrated YouTube, YouTube places at least one cookie that stores your IP address and our URL. If you are logged into your YouTube account, by using cookies YouTube can usually associate your interactions on our website with your profile. This includes data such as session duration, bounce rate, approximate location, technical information such as browser type, screen resolution or your Internet provider. Additional data can include contact details, potential ratings, shared content via social media or YouTube videos you added to your favourites.

If you are not logged in to a Google or YouTube account, Google stores data with a unique identifier linked to your device, browser or app. Thereby, e.g. your preferred language setting is maintained. However, many interaction data cannot be saved since less cookies are set.

In the following list we show you cookies that were placed in the browser during a test. On the one hand, we show cookies that were set without being logged into a YouTube account. On the other hand, we show you what cookies were placed while being logged in. We do not claim for this list to be exhaustive, as user data always depend on how you interact with YouTube.

Name: YSC
Value: b9-CV6ojI5Y112447860-1
Purpose: This cookie registers a unique ID to store statistics of the video that was viewed.
Expiry date: after end of session

Name: PREF
Value: f1=50000000
Purpose: This cookie also registers your unique ID. Google receives statistics via PREF on how you use YouTube videos on our website.
Expiry date: after 8 months

Name: GPS
Value: 1
Purpose: This cookie registers your unique ID on mobile devices to track GPS locations.
Expiry date: after 30 minutes

Name: VISITOR_INFO1_LIVE
Value: 95Chz8bagyU
Purpose: This cookie tries to estimate the user’s internet bandwith on our sites (that have built-in YouTube videos).
Expiry date: after 8 months

Further cookies that are placed when you are logged into your YouTube account:

Name: APISID
Value: zILlvClZSkqGsSwI/AU1aZI6HY7112447860-
Purpose: This cookie is used to create a profile on your interests. This data is then used for personalised advertisements.
Expiry date: after 2 years

Name: CONSENT
Value: YES+AT.de+20150628-20-0
Purpose: The cookie stores the status of a user’s consent to the use of various Google services. CONSENT also provides safety measures to protect users from unauthorised attacks.
Expiry date: after 19 years

Name: HSID
Value: AcRwpgUik9Dveht0I
Purpose: This cookie is used to create a profile on your interests. This data helps to display customised ads.
Expiry date: after 2 years

Name: LOGIN_INFO
Value: AFmmF2swRQIhALl6aL…
Purpose: This cookie stores information on your login data.
Expiry date: after 2 years

Name: SAPISID
Value: 7oaPxoG-pZsJuuF5/AnUdDUIsJ9iJz2vdM
Purpose: This cookie identifies your browser and device. It is used to create a profile on your interests.
Expiry date: after 2 years

Name: SID
Value: oQfNKjAsI112447860-
Purpose: This cookie stores your Google Account ID and your last login time, in a digitally signed and encrypted form.
Expiry date: after 2 years

Name: SIDCC
Value: AN0-TYuqub2JOcDTyL
Purpose: This cookie stores information on how you use the website and on what advertisements you may have seen before visiting our website.
Expiry date: after 3 months

How long and where is the data stored?

The data YouTube receive and process on you are stored on Google’s servers. Most of these servers are in America. At https://www.google.com/about/datacenters/locations/?hl=en you can see where Google’s data centres are located. Your data is distributed across the servers. Therefore, the data can be retrieved quicker and is better protected against manipulation.

Google stores collected data for different periods of time. You can delete some data anytime, while other data are automatically deleted after a certain time, and still other data are stored by Google for a long time. Some data (such as elements on “My activity”, photos, documents or products) that are saved in your Google account are stored until you delete them. Moreover, you can delete some data associated with your device, browser, or app, even if you are not signed into a Google Account.

How can I erase my data or prevent data retention?

Generally, you can delete data manually in your Google account. Furthermore, in 2019 an automatic deletion of location and activity data was introduced. Depending on what you decide on, it deletes stored information either after 3 or 18 months.

Regardless of whether you have a Google account or not, you can set your browser to delete or deactivate cookies placed by Google. These settings vary depending on the browser you use. The following instructions will show how to manage cookies in your browser:

Chrome: Clear, enable and manage cookies in Chrome

Safari: Manage cookies and website data in Safari

Firefox: Clear cookies and site data in Firefox

Internet Explorer: Delete and manage cookies

Microsoft Edge: Delete cookies in Microsoft Edge

If you generally do not want to allow any cookies, you can set your browser to always notify you when a cookie is about to be set. This will enable you to decide to either allow or permit each individual cookie.

Legal basis

If you have consented processing and storage of your data by integrated YouTube elements, this consent is the legal basis for data processing (Art. 6 para. 1 lit. a GDPR). Generally, your data is also stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f GDPR) to maintain fast and good communication with you or other customers and business partners. Nevertheless, we only use integrated YouTube elements if you have given your consent. YouTube also sets cookies in your browser to store data. We therefore recommend you to read our privacy policy on cookies carefully and to take a look at the privacy policy or the cookie policy of the respective service provider.

YouTube also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of the data processing.

YouTube uses standard contractual clauses approved by the EU Commission (= Art. 46, paragraphs 2 and 3 of the GDPR) as basis for data processing by recipients based in third countries (which are outside the European Union, Iceland, Liechtenstein and Norway) or for data transfer there. These clauses oblige YouTube to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847

Since YouTube is a subsidiary company of Google, Google’s privacy statement applies to both. If you want to learn more about how your data is handled, we recommend the privacy policy at https://policies.google.com/privacy?hl=en.

Web Design Introduction

Web Design Privacy Policy Overview

👥 Affected parties: website visitors
🤝 Purpose: improvement of user experience
📓 Processed data: depends heavily on the services used. Usually, data such as IP address, technical data, language settings, browser version, screen resolution and browser name are processed. You can find more details directly with the respective web design tools.
📅 Storage duration: depends on the tools used
⚖️ Legal bases: Article 6 paragraph 1 lit. a GDPR (consent), Article 6 paragraph 1 lit. f GDPR (legitimate interests)

What is web design?

We use various tools on our website for the purpose of our web design. Contrary to common belief, web design is not just about making our website look nice, but rather also about functionality and performance. But of course, a good-looking website is also a major goal of professional web design. Web design is a part of media design and deals with the visual as well as the structural and functional design of a website. Our aim with our web design is to improve your experience on our site. In web design jargon, this is called User Experience (UX) and usability. User Experience entails all impressions and experiences that website visitors come across on a website. What is more, usability is part of the User Experience, as it determines how user-friendly a website is. This includes the clear structuring of content, subpages or products, along with how quickly and easily the website enables you to find what you are looking for. In order to offer you the best possible experience on our website, we also use so-called third-party web design tools. Therefore, all tools and services that help improve our website’s design are classified under the category “web design”. This may, for example, include fonts, various plugins or other integrated web design functions.

Why do we use web design tools?

The way you absorb information on a website depends very much on its structure, functionality and visual perception. Therefore, good and professional web design has become increasingly important for us. We are constantly working on improving our site as a way of further extending our services for you as a website visitor. Furthermore, a beautiful and functioning website also has economic advantages for us. Needless to say, you will only visit it and take advantage of our offers if you feel completely at ease.

What data is stored by web design tools?

When you visit our website, any web design elements integrated into our pages may process your data. The exact data that is processed depends on the tools used. Below you can see exactly which tools we use for our website. For more information about data processing, we recommend you also read the respective privacy policy of the respective tools. There you can usually find out which data is processed, whether cookies are used and how long the data is stored. Moreover, fonts such as Google Fonts, for example, also automatically transmit information such as your language settings, IP address, browser version, browser screen resolution and browser name to Google’s servers.

Duration of data processing

Data processing times are very individual and depend on the web design elements used. For example, when cookies are used, the retention period can be as little as a minute, but it may also be a few years. Please make yourself familiar with this topic. You may for example read our general section on cookies as well as the Privacy Policies of the tools used. There you can likely find out exactly which cookies are used and what information is stored there. For example, Google Font files are stored for one year, in order to improve the loading speed of a website. In principle, data is only kept for as long as is necessary to provide the service. But legal requirements may require data to be stored for longer.

Right to object

You also retain the right and the option to revoke your consent to the use of cookies or third-party providers at any time. You can do this either via our cookie management tool or via other opt-out functions. You can also prevent cookies from collecting your data by managing, deactivating or deleting the cookies in your browser. However, among web design elements (typically fonts) there is also data that cannot be erased easily. This is the case whenever data is automatically collected as soon as a page is accessed and then directly transmitted to a third party (e.g. Google). In these cases, please contact the support of the respective provider. In the case of Google, you can reach support at https://support.google.com/?hl=de.

Legal Basis

If you have consented to the use of web design tools, this consent serves as the legal basis for the relevant data processing. According to Article 6 (1) (a) GDPR (consent), your consent represents the legal basis for the processing of personal data, as it may occur when it is collected by web design tools. We also have a legitimate interest in web design to improve on our website. After all, only then can we provide you with a beautiful and professional web offer. The corresponding legal basis for this is Article 6 (1) (f) GDPR (legitimate interests). However, we strongly want to emphasise once more that we only use web design tools if you have given your consent.

You can find information on different web design tools – if available – in the following sections.

Google Fonts Local Privacy Policy

On our website we use Google Fonts, by the company Google Inc. The responsible entity for the European area is Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland). We have integrated Google fonts locally, i.e. on our web server and not on Google’s servers. This means that no connection to Google’s servers and therefore no data transfer or retention take place.

What are Google Fonts?

Google Fonts was previously called Google Web Fonts. It is an interactive list with over 800 fonts which Google offer for free use. With the use of Google Fonts, it is possible to utilise fonts without uploading them to your own server. In order to prevent any transfer of information to Google’s servers, we downloaded the fonts to our own server. This way we can comply with data privacy and do not transmit any data to Google Fonts.

Explanation of the terminology used

We always strive to make our privacy policy as clear and comprehensible as possible. However, this is not always easy, especially when it comes to technical and legal matters. It is often sensible to use legal terms (such as ‘personal data)’ or certain technical terms (such as ‘cookies’ or ‘IP address’). But we don’t want to use such terms without any explanation. This is why you will find an alphabetical list of important terms used below. These are terms we may not yet have sufficiently explained in the privacy policy. In case we have adopted any of these terms from the GDPR which are definitions, we will also list the GDPR texts here and add our own further explanations if necessary.

Processor

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:


“processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

Explanation: As a company and a website owner, we are responsible for all your data we process (i. e. the ‘controller’). In addition to the controller, there may also be so-called processors. This includes any company or person who processes personal data on our behalf. In addition to service providers such as tax consultants, processors can also be hosting or cloud providers, payment or newsletter providers or large companies such as Google or Microsoft.

Consent

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:


“consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

Explanation: With websites, such consent is usually given via a cookie consent tool. You’ve most certainly come across these. Whenever you visit a website for the first time, you will usually be asked via a banner whether you agree or consent to the data processing. You can usually also make individual settings and thus decide for yourself which level of data processing you want to allow. If you do not give your consent, no personal data may be processed. Consent can of course also be given in writing, i.e. not via a tool.

Personal Data

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:


“personenal data”

means any information relating to an identified or identifiable natural person (‘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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Explanation: Personal data is all data that can identify you as a person. This is usually data such as:

  • name
  • address
  • email address
  • postal address
  • phone number
  • birthday
  • identification numbers such as social security number, tax identification number, ID card number or matriculation number
  • banking data such as account number, credit information, account balances and more.

According to the European Court of Justice (ECJ), your IP address is also personal data. IT experts can use your IP address to determine at least the approximate location of your device and subsequently your location as the connection owner. Therefore, storing an IP address also requires a legal basis within the scope of the GDPR. There are also so-called “special categories” of personal data, which are particularly worthy of protection. These include:

  • racial and ethnic origin
  • political opinions
  • religious or ideological beliefs
  • Union membership
  • genetic data such as data obtained from blood or saliva samples
  • biometric data (this is information about psychological, physical or behavioural characteristics that can identify an individual).
    health Data
  • Data relating to sexual orientation or sex life

Profiling

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:


“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, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;

Explanation: Profiling collects various personal data about an individual in order to learn more about that individual. On the internet, profiling is often used for advertising purposes or for credit checks. Web and advertising analysis programs e. g. collect data about your behaviour and interests on a website. This results in a special user profile that can be used to target advertising to specific target groups.

 

Controller

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:


“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; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

Explanation: In our example, we are responsible for the processing of your personal data and are therefore the “controller”. If we pass on collected data to other service providers for processing, they are considered “contract processors”. For this, a “Data Processing Agreement (DPA)” must be concluded.

 

Processing

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:


“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, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Note: When we talk about processing in our Privacy Policy, we talk about any type of data processing. As mentioned above in the original GDPR declaration, this includes not only the collection but also the storage and processing of data.

Closing Remarks

Congratulations! If you are reading these lines, you have most likely familiarised yourself with our entire Privacy Policy – or at least scrolled down here. As you can see from the scope of our Privacy Policy, we do not take the protection of your personal data lightly.
We find it important to inform you about the processing of your personal data to the best of our abilities. In doing so, we not only want to tell you which data is processed but also explain to you why we use various software programs. In general, Privacy Policies have very technical and legal jargon. However, since most of you are not web developers or solicitors, we wanted to take a different approach and explain the facts in simple and clear language. Of course, this is not always possible due to the subject matter. Therefore, you can also find a more detailed explanation of the most important terms at the end of the Privacy Policy.
If you have any questions about data protection on our website, please do not hesitate to contact us or the responsible body. We wish you all the best and hope to soon welcome you to our website again.

All texts are copyrighted.