PRIVACY POLICY
This privacy policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offering and the associated websites, functions and content as well as external online presences, such as our social media profile. (hereinafter jointly referred to as the “Online Offering”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Controller:
Exxcility Business Solutions GmbH & Co. KG
Zur Steinkuhle 4
48341 Altenberge
Management: Bernhard Schmitz and Naomi Schmitz
info@exxcility.com
+49 (0)2505 939 10 11
Types of processed data:
– Inventory data (e.g. names, addresses).
– Contact data (e.g. e-mail, telephone numbers).
– Content data (e.g. text entries, photographs, videos).
– Contract data (e.g. subject matter of the contract, term, customer category).
– Payment data (e.g. bank details, payment history).
– Usage data (e.g. websites visited, interest in content, access times).
– Meta/communication data (e.g. device information, IP addresses).
Processing of special categories of data (Art. 9 para. 1 GDPR):
No special categories of data are processed.
Categories of data subjects affected by the processing:
Visitors and users of the online offering. In the following, we also refer to the data subjects collectively as “users”.
Purpose of the processing:
– Provision of the online offering, its contents and shop functions.
– Provision of contractual services, service and customer care.
– Answering contact enquiries and communicating with users.
– Marketing, advertising and market research.
– Security measures.
As at: August / 2021
Terms used
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as the “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” means any operation or set of operations which is performed on personal data either with or without automated means. The term is broad and encompasses practically any handling of data.
The “controller” is 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.
Relevant legal bases
In accordance with Art. 13 GDPR, we inform you of the legal basis of our data processing. If the legal basis is not stated in the privacy policy, the following applies: The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for processing to fulfil our services and implement contractual measures and respond to enquiries is Art. 6 para. 1 lit. b GDPR, the legal basis for processing to fulfil our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.
Changes and updates to the privacy policy
We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require an act of co-operation on your part (e.g. consent) or other individual notification.
Security measures
We take appropriate technical and organisational measures in accordance with Art. 32 GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk; the measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as to its access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures to ensure that the rights of data subjects are exercised, data is deleted and we respond to data threats. Furthermore, we already take the protection of personal data into account at the stage of development and selection of hardware, software and processes, in accordance with the principle of data protection through technology design and data protection-friendly default settings (Art. 25 GDPR).
The security measures include in particular the encrypted transmission of data between your browser and our server.
Disclosure and transmission of data
If we disclose data to other persons and companies (processors or third parties) as part of our processing, transfer it to them or otherwise grant them access to the data, this will only be done on the basis of a legal authorisation (e.g. if a transfer of the data to third parties, such as payment service providers, is necessary for the fulfilment of the contract pursuant to Art. 6 para. 1 lit. b GDPR), you have given your consent, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, hosting providers, tax, business and legal advisers, customer care, accounting, billing and similar services that allow us to efficiently and effectively fulfil our contractual obligations, administrative tasks and duties).
If we commission third parties with the processing of data on the basis of what is known as a “processing contract”, this is done on the basis of Art. 28 GDPR.
Transmissions to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this will only take place if it is done to fulfil our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual authorisations, we process or have the data processed in a third country only if the special requirements of Art. 44 et seq. GDPR are met. This means that processing takes place, for example, on the basis of special guarantees, such as the officially recognised determination of a level of data protection corresponding to the EU (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognised special contractual obligations (what are known as “standard contractual clauses”).
Rights of the data subjects
You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR.
In accordance with Art. 16 GDPR, you have the right to request that data concerning you is completed or that inaccurate data concerning you is rectified.
In accordance with Art. 17 GDPR, you have the right to demand that the data in question is deleted immediately or, alternatively, to demand that the processing of the data is restricted in accordance with Art. 18 GDPR.
You have the right to request to receive the data concerning you that you have provided to us in accordance with Art. 20 GDPR and to request that it be transferred to other controllers.
In accordance with Art. 77 GDPR, you also have the right to lodge a complaint with the responsible supervisory authority.
Right of withdrawal
You have the right to withdraw your consent in accordance with Art. 7 (3) GDPR with effect for the future.
Right of objection
You can object to the future processing of data concerning you at any time in accordance with Art. 21 GDPR. The objection can be made in particular against processing for direct marketing purposes.
Cookies and right to object to direct advertising
“Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit to an online offering. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offering and closes their browser. For example, the content of a shopping basket in an online shop or a login status can be stored in such a cookie. The term “permanent” or “persistent” refers to cookies that remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. The interests of users can also be stored in such a cookie and used for reach measurement or marketing purposes. “Third-party cookies” are cookies from providers other than the controller who operates the online offering (otherwise, if they are only the controller’s cookies, they are referred to as “first-party cookies”).
We use temporary and permanent cookies and explain this in our privacy policy.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Saved cookies can be deleted in the system settings of the browser. Excluding cookies can result in functional restrictions of this online offering.
A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by switching them off in the browser settings. Please note that you may then not be able to use all the functions of this online offering.
Deletion of data
The data processed by us will be erased or restricted in its processing in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
Germany: In accordance with legal requirements, storage is carried out in particular for 6 years in accordance with Section 257 (1) of the German Commercial Code (trading books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting documents, etc.) and for 10 years in accordance with Section 147 (1) of the German Fiscal Code (books, records, management reports, accounting documents, commercial and business letters, documents relevant for taxation, etc.)
Order processing in the online shop and customer account
We process our customers’ data as part of the ordering process in our online shop in order to enable them to select and order the selected products and services, as well as their payment and delivery or fulfilment.
The processed data includes inventory data, communication data, contract data, payment data and the data subjects include our customers, interested parties and other business partners. The processing is carried out for the purpose of providing contractual services in the context of operating an online shop, billing, delivery and customer services. We use session cookies to store the contents of the shopping basket and permanent cookies to store the login status.
The processing is carried out on the basis of Art. 6 para. 1 lit. b (execution of order processes) and c (legally required archiving) GDPR. The information marked as required is necessary for the establishment and fulfilment of the contract. We only disclose the data to third parties within the scope of delivery, payment or within the scope of legal authorisations and obligations towards legal advisers and authorities. The data will only be processed in third countries if this is necessary for the fulfilment of the contract (e.g. at the customer’s request for delivery or payment).
Users can optionally create a user account in which they can view their orders in particular. As part of the registration process, users are informed of the required mandatory information. The user accounts are not public and cannot be indexed by search engines. If users have cancelled their user account, their data will be deleted with regard to the user account, subject to their retention for commercial or tax law reasons in accordance with Art. 6 para. 1 lit. c GDPR. Information in the customer account remains there until its deletion with subsequent archiving in the event of a legal obligation. Users are responsible for backing up their data before the end of the contract in the event of cancellation.
We store the IP address and the time of the respective user action as part of the registration process and during renewed logins and utilisation of our online services. The storage is based on our legitimate interests as well as those of the user in protection against misuse and other unauthorised use. This data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so pursuant to Art. 6 para. 1 lit. c GDPR.
The deletion takes place after the expiry of statutory warranty and comparable obligations, the necessity of storing the data is reviewed every three years; in the case of statutory archiving obligations, the deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) retention obligation); information in the customer account remains there until its deletion.
Business analyses and market research
In order to operate our business economically and identify market trends, customer and user requirements, we analyse the data we have on business transactions, contracts, enquiries, etc. Here we process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. GDPR where the data subjects include customers, interested parties, business partners, visitors and users of the online offering. The analyses are carried out for the purpose of business management evaluations, marketing and market research. In doing so, we can take into account the profiles of registered users with details of their purchase transactions, for example. We use the analyses to increase user-friendliness, optimise our offering and improve business efficiency. The analyses are solely for our purposes and are not published externally, unless they are anonymous analyses with summarised values.
If these analyses or profiles are personal, they will be deleted or anonymised upon termination by the user, otherwise after two years from the conclusion of the contract. In addition, the macroeconomic analyses and general trend analyses are created anonymously wherever possible.
Contacting us and customer service
When contacting us (via the contact form or e-mail), the user’s details are processed to process the contact enquiry and its handling in accordance with Art. 6 para. 1 lit. b) GDPR.
User data may be stored in our customer relationship management system (“CRM system”) or a similar enquiry organisation system.
We delete the enquiries if they are no longer required. We review the necessity every two years; we store enquiries from customers who have a customer account permanently and refer to the details of the customer account for deletion. Furthermore, the statutory archiving obligations apply.
Collection of access data and log files
On the basis of our legitimate interests as defined by Art. 6 para. 1 lit. f. GDPR, we collect data about every access to the server on which this service is located (what are known as server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the page visited previously), IP address and the requesting provider.
Log file information is stored for a maximum of seven days for security reasons (e.g. to investigate misuse or fraud) and then deleted. Data the further retention of which is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
Online presences in social media
On the basis of our legitimate interests as defined by Art. 6 para. 1 lit. f. GDPR, we maintain online presences within social networks and platforms in order to communicate with the customers, interested parties and users active there and to inform them there about our services. When accessing the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.
Unless otherwise stated in our privacy policy, we process users’ data if they communicate with us within social networks and platforms, e.g. write posts on our online presences or send us messages.
We use Google Analytics to display adverts placed by Google and its partners within advertising services only to those users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Google (what is known as “remarketing” or “Google Analytics audiences”). With the help of the remarketing audiences, we also want to ensure that our adverts correspond to the potential interest of users and are not annoying.
Google Analytics
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offering as defined by Art. 6 para. 1 lit. f. GDPR), we use Google Analytics, a web analysis service provided by Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offering by the users is usually transmitted to a Google server in the USA and stored there.
Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to analyse the use of our online offering by users, to compile reports on the activities within this online offering and to provide us with further services associated with the use of this online offering and the use of the Internet. Pseudonymised user profiles can be created from the processed data.
We only use Google Analytics with activated IP anonymisation. This means that the IP address of the user is truncated by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there.
The IP address transmitted by the user’s browser is not merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of data generated by the cookie and related to their use of the online offering being sent to Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
Users’ personal data is deleted or anonymised after 14 months.
Further information on the use of data by Google, setting and objection options can be found on the Google websites: https://www.google.com/intl/de/policies/privacy/partners (“Data use by Google when you use our partners’ websites or apps“), https://policies.google.com/technologies/ads (“Data use for advertising purposes”), https://adssettings.google.com/authenticated(“Manage information that Google uses to show you adverts”).
As an alternative to the browser add-on or within browsers on mobile devices, please click this link to prevent Google Analytics from collecting data within this website in the future:
Here an opt-out cookie is stored on your device. If you delete your cookies, you must click this link again.
Google Re-/Marketing Services
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offering as defined by Art. 6 para. 1 lit. f. GDPR) we use the marketing and remarketing services (in short “Google Marketing Services”) of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).
Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google marketing services allow us to display adverts for and on our website in a more targeted manner in order to present users only with adverts that potentially match their interests. If, for example, a user is shown adverts for products that they were interested in on other websites, this is referred to as “remarketing”. For these purposes, when our and other websites on which Google marketing services are active are called up, a code from Google is executed directly by Google and what are known as (re)marketing tags (invisible graphics or code, also known as “web beacons”) are integrated in the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). The cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file records which websites the user has visited, what content they are interested in and which offerings they have clicked on, as well as technical information about the browser and operating system, referring websites, visiting time and other information about the use of the online offering. The IP address of users is also recorded, whereby we communicate within the framework of Google Analytics that the IP address is truncated within member states of the European Union or in other contracting states of the Agreement on the European Economic Area and only in exceptional cases is it transmitted in full to a Google server in the USA and truncated there. The IP address is not merged with the user’s data within other Google offerings. Google may also combine the aforementioned information with such information from other sources. If the user subsequently visits other websites, he can be shown adverts tailored to his interests.
User data is processed pseudonymously as part of Google marketing services. This means that Google does not store and process the user’s name or email address, for example, but processes the relevant data in relation to cookies within pseudonymous user profiles. This means that, from Google’s point of view, the adverts are not managed and displayed for a specifically identified person, but for the cookie owner, regardless of who this cookie owner is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymisation. The information collected by Google marketing services about users is transmitted to Google and stored on Google’s servers in the USA.
The Google marketing services we use include the online advertising programme “Google AdWords”. In the case of Google AdWords, each AdWords customer is given a different “conversion cookie”. Cookies can therefore not be tracked via the websites of AdWords customers. The information collected with the help of the cookie is used to create conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers find out the total number of users who clicked on their advert and were redirected to a page provided with a conversion tracking tag. However, they are not given any information with which users can be personally identified.
We can integrate third-party adverts on the basis of the Google marketing service “DoubleClick”. DoubleClick uses cookies to enable Google and its partner websites to display adverts based on users’ visits to this website or other websites on the Internet.
We can also use the “Google Optimizer” service. Google Optimizer allows us to track the effects of various changes to a website (e.g. changes to input fields, design, etc.) as part of what is known as “A/B testing”. Cookies are stored on users’ devices for these test purposes. Here only pseudonymised user data is processed.
We may also use the “Google Tag Manager” to integrate and manage Google analytics and marketing services on our website.
Further information on the use of data for marketing purposes by Google can be found on the overview page: https://policies.google.com/technologies/ads, Google’s privacy policy can be found at https://adssettings.google.com/authenticated.
Furthermore, when using the Facebook pixel, we use the additional function “Advanced Matching” (this is where data such as telephone numbers, e-mail addresses or Facebook IDs of users are transmitted to Facebook (encrypted) to form target groups (“Custom Audiences” or “Look Alike Audiences”). Further information on “advanced matching” is available at: https://www.facebook.com/business/help/611774685654668).
We also use the “Custom Audiences from File” procedure of the social network Facebook, Inc. In this case, the e-mail addresses of the newsletter recipients are uploaded to Facebook. The upload process is encrypted. The upload is used solely to determine the recipients of our Facebook adverts. We want to ensure that the adverts are only shown to users who are interested in our information and services.
This page is based on the opt-in for the Facebook pixel. You can change your settings here:
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Facebook, Custom Audiences and Facebook Marketing Services
Within our online offering, what is known as the “Facebook pixel” of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are resident in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), is used based on our legitimate interests in the analysis, optimisation and economic operation of our online offering and for these purposes.
Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
With the help of the Facebook pixel, it is possible for Facebook to determine the visitors of our online offering as a target group for the display of adverts (what are known as “Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Facebook (what are known as “custom audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of users and are not annoying. With the help of the Facebook pixel, we can also track the effectiveness of Facebook adverts for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook advert (what is known as “conversion”).
The processing of data by Facebook takes place within the framework of Facebook’s data usage policy. Accordingly, general information on the display of Facebook Ads can be found in the Facebook Data Usage Policy: https://www.facebook.com/policy.php. Specific information and details about the Facebook pixel and how it works can be found in the Facebook help section: https://www.facebook.com/business/help/651294705016616.
You can object to the collection by the Facebook pixel and use of your data to display Facebook ads. To set which types of adverts are displayed to you within Facebook, you can call up the page set up by Facebook and follow the instructions there on the settings for usage-based advertising: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e. they are adopted for all devices, such as desktop computers or mobile devices.
You can also object to the use of cookies for reach measurement and advertising purposes via the deactivation page of the network advertising initiative (http://optout.networkadvertising.org/) and additionally the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).
Facebook Social Plugins
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offering as defined by Art. 6 para. 1 lit. f. GDPR), we use social plugins (“plugins”) of the social network facebook.com which is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The plugins can display interaction elements or content (e.g. videos, graphics or text contributions) and can be recognised by one of the Facebook logos (white “f” on a blue tile, the terms “Like” or a “thumbs up” sign) or are marked with the addition “Facebook Social Plugin”. The list and appearance of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
When a user calls up a function of this online offering that contains such a plugin, their device establishes a direct connection with the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated by it in the online offering. User profiles can be created from the processed data. We therefore have no influence on the extent of the data that Facebook collects using this plugin and therefore inform users according to our level of knowledge.
By integrating the plugins, Facebook receives the information that a user has called up the corresponding page of the online offering. If the user is logged in to Facebook, Facebook can assign the visit to their Facebook account. When users interact with the plugins, for example by clicking the Like button or by leaving a comment, the corresponding information is transmitted directly from your device to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to find out and store their IP address. According to Facebook, only an anonymised IP address is stored in Germany.
The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the relevant rights and setting options for protecting the privacy of users, can be found in Facebook’s data protection information: https://www.facebook.com/about/privacy/.
If a user is a Facebook member and does not want Facebook to collect data about them via this online offering and link it to their membership data stored on Facebook, they must log out of Facebook and delete their cookies before using our online offering. Further settings and objections to the use of data for advertising purposes can be made within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are adopted for all devices, such as desktop computers or mobile devices.
Communication by post, e-mail, fax or telephone
We use remote means of communication, such as post, telephone or e-mail, for business transactions and marketing purposes. In doing so, we process inventory data, address and contact data as well as contract data of customers, participants, interested parties and communication partners.
The processing is carried out on the basis of Art. 6 para. 1 lit. a, Art. 7 GDPR, Art. 6 para. 1 lit. f GDPR in conjunction with legal requirements for advertising communications. Contact will only be made with the consent of the contact partners or within the framework of the legal permissions and the processed data will be deleted as soon as it is no longer required and in all other cases if there is an objection to or revocation or discontinuation of the authorisation basis or legal archiving obligations.
Dispatch service provider: The newsletter is sent by CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede, hereinafter referred to as the “dispatch service provider”. You can view the data protection provisions of the dispatch service provider here: https://www.cleverreach.com/de/datenschutz/.
Newsletter
With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.
Content of the newsletter: We only send newsletters, e-mails and other electronic notifications with advertising information (hereinafter “newsletter”) with the consent of the recipient or with legal authorisation. If the content of the newsletter is specifically described when registering for the newsletter, it is decisive for the user’s consent. Our newsletters also contain information about our products, offers, promotions and our company.
Double opt-in and logging: Registration for our newsletter takes place in a so-called double opt-in procedure. This means that you will receive an e-mail after registration asking you to confirm your registration. This confirmation is necessary so that no-one can log in with other people’s e-mail addresses. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored with the shipping service provider are also logged.
Dispatch service provider: The newsletter is sent by CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede, hereinafter referred to as the “dispatch service provider”. You can view the data protection provisions of the dispatch service provider here: https://www.cleverreach.com/de/datenschutz/.
If we use a dispatch service provider, the dispatch service provider may, according to its own information, use this data in pseudonymous form, i.e. without assigning it to a user, to optimise or improve its own services, e.g. to technically optimise the mailing and display of the newsletter or for statistical purposes to determine which countries the recipients come from. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or forward it to third parties.
Registration data: To subscribe to the newsletter, simply enter your e-mail address. Optionally, we ask you to enter a name so that we can address you personally in the newsletter.
Performance measurement – The newsletters contain what is known as a “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we are using a dispatch service provider, from their server. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval are initially collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined using the IP address) or the access times. The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, we do not strive nor, if used, does the dispatch service provider to observe the behaviour of individual users. The analyses are much more for the purpose of helping us to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
The newsletter is sent and its performance measured on the basis of the recipient’s consent in accordance with Art. 6 para. 1 lit. a, Art. 7 GDPR in conjunction with Section 7 para. 2 no. 3 UWG (Unfair Competition Act) or on the basis of a legal authorisation in accordance with Section 7 para. 3 UWG.
The logging of the registration process is based on our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR and serves as proof of consent to receive the newsletter.
Newsletter recipients can cancel the receipt of our newsletter at any time, i.e. revoke their consent. You will find a link to cancel the newsletter at the end of each newsletter. At the same time, their consent to participate in performance measurement expires. A separate cancellation of the performance measurement unfortunately cannot be made, in this case the entire newsletter subscription must be cancelled. When you unsubscribe from the newsletter, your personal data will be deleted unless its retention is legally required or justified, in which case its processing will be limited to these exceptional purposes. In particular, we may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before we delete them for the purpose of sending the newsletter in order to be able to prove that consent was given in the past. The processing of this data is limited to the purpose of a possible defence against claims. An individual deletion request can be made at any time, provided that the former existence of consent is confirmed at the same time.
Integration of third-party services and content
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offering as defined by Art. 6 para. 1 lit. f. GDPR), we use content or service offerings from third-party providers within our online offering in order to integrate their content and services such as videos or fonts (hereinafter uniformly referred to as “content”). This always presupposes that the third-party providers of this content recognise the IP address of the user as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use what are known as pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to analyse information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offering, as well as being linked to such information from other sources.
The following presentation provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and, in some cases already mentioned here, options for objection (what is known as opt-out)
– If our customers use the payment services of third parties (e.g. PayPal or immediate transfer), the terms and conditions and data protection notices of the respective third-party providers apply, which can be called up within the respective websites or transaction applications.
– Maps of the “Google Maps” service of the third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
– Videos from the “YouTube” platform of the third-party provider Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
– Functions of the Google+ service are integrated within our online offering. These functions are offered by the third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. If you are logged into your Google+ account, you can link the content of our pages to your Google+ profile by clicking the Google+ button. This allows Google to assign your visit to our web pages to your user account. We would like to point out that, as the provider of the pages, we are not given any knowledge of the content of the transmitted data or its use by Google+. Privacy Policy: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated.
– Functions of the Instagram service are integrated within our online offering. These functions are offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA. If you are logged into your Instagram account, you can link the content of our pages to your Instagram profile by clicking the Instagram button. This allows Instagram to assign your visit to our web pages to your user account. We would like to point out that, as the provider of the pages, we are not given any knowledge of the content of the transmitted data or its use by Instagram. Privacy Policy: http://instagram.com/about/legal/privacy/.
– We use social plugins from the social network Pinterest, which is operated by Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA (“Pinterest”). When you call up a page that contains such a plugin, your browser establishes a direct connection to the Pinterest servers. During this process, the plugin transmits log data to the Pinterest server in the USA. This log data may contain your IP address, the address of the websites visited that also contain Pinterest functions, the type and settings of the browser, the date and time of the request, and information regarding how you use Pinterest and cookies. Privacy Policy: https://about.pinterest.com/de/privacy-policy.
– Functions of the Twitter service or platform (hereinafter referred to as “Twitter”) may be integrated within our online offering. Twitter is a service provided by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The functions include the display of our posts within Twitter within our online offering, the link to our profile on Twitter and the possibility to interact with the posts and the functions of Twitter, as well as to measure whether users are reaching our online offering via the adverts placed by us on Twitter (what is known as conversion measurement). Twitter is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active). Privacy Policy: https://twitter.com/de/privacy, Opt-Out: .