политика конфиденциальности

Information about the processing of your data

In accordance with Art. 12 of the General Data Protection Regulation (hereinafter: GDPR), we are obliged to inform you about the processing of your data when using our website. We take the protection of your personal data very seriously and this data protection declaration informs you about the details of the processing of your data and about your legal rights in this regard.

We reserve the right to adapt the data protection declaration with effect for the future, in particular in the event of further development of the website, the use of new technologies or changes to the legal basis or the corresponding jurisdiction.

We recommend that you read the data protection statement from time to time and keep a printout or a copy for your files.

Definitions

  • Website” or “internet presence” means hereinafter all pages of the person responsible on www. clicks.de
  • “Personal data” means all information relating to an identified or identifiable natural person. Identifiable is a person who can be identified directly or indirectly, in particular by assignment to an identifier such as a name, an identification number, location data, an online identifier or one or more special characteristics which express the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person. Personal data is therefore, for example, a person’s name, e-mail address and telephone number, but may also include information about preferences, hobbies and memberships.
  • Processing” means operations or sets of operations carried out with or without the aid of automated procedures in connection with personal data, such as the collection, recording, organisation, sorting, storage, adaptation, modification, reading, retrieval, use, disclosure by transmission, dissemination or any other form of provision, reconciliation, linking, restriction, erasure or destruction.
  • Pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that this additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.
  • Consent” means hereinafter any voluntary declaration of intent in the form of a declaration or other clear affirmative act by which the data subject indicates his or her consent to the processing of personal data concerning him or her, in an informed and unambiguous manner, for the particular case.
  • Google” means Google, LLC 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; available in the European Union at: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001.

Scope of application

This data protection declaration applies to all pages of www.clicks.de. It does not extend to any linked websites or internet presences of other providers.

Responsible supplier/representative of the supplier in the European Union (EU)

Responsible for the processing of personal data within the scope of this data protection declaration is:

Clicks Online Business e.K.
An der Mauer 1, 01067 Dresden
Phone: +49 (0) 351 / 65 31 20 10; Fax: 0351 / 65 31 20 11

represented by:
Herbert Buchhorn

Questions about data protection

If you have any questions about data protection with regard to our company or our website, you can contact our data protection officer:

Mandatory information on the data protection officer pursuant to Art. 37 para. 7 of the General Data Protection Regulation (GDPR):

Spirit Legal LLP Rechtsanwälte
Lawyer and Data Protection Officer
Peter Hense
Postal address:
Data Protection Officer
c/o Clicks Online Business e.K., An der Mauer 1, 01067 Dresden
Contact via encrypted online form: Contact data protection officer

Security

We have taken comprehensive technical and organisational precautions to protect your personal data from unauthorised access, misuse, loss and other external disturbances. To this end, we regularly review our security measures and adapt them to the state of the art.

Your rights

You have the following rights with regard to the personal data concerning you that you can assert against us:

You can assert your rights by notifying the contact specified in the “Responsible Provider” section or the data protection officer appointed by us.

You also have the right to complain to a data protection supervisory authority about our processing of your personal data (Art. 77 GDPR).

Use of the website, access data

You can use our website for purely informational purposes without disclosing your identity. When calling up the individual pages of the website in this sense, access data is merely transmitted to our web space provider so that the website can be displayed to you. This is the following data:

Temporary processing of the IP address by the system is necessary to technically enable the website to be delivered to your computer. Processing your IP address for the duration of the session is required. The legal basis for such processing is Art. 6 para. 1 sentence 1 lit. f) GDPR.

The access data is not used to identify individual users and is not merged with other data sources. The access data is deleted when it is no longer required to achieve the purpose of its processing. In the case of collecting the data to provide the website, this is the case when you end your visit to the website.

IP addresses are stored in log files to ensure the functionality of the website. In addition, the data serves us to optimize the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context. The data will be deleted after seven days at the latest, further processing is possible in individual cases. In this case, the IP address is deleted or so alienated that an assignment to the calling client is no longer possible.

The collection of data for the provision of the website and the processing of data in log files is absolutely necessary for the operation of the website. You may object to the processing. In the event of your justified objection, we will examine the situation and either stop or adjust data processing, or point out to you our compelling reasons worthy of protection, on the basis of which we will continue processing.

Cookies

In addition to the aforementioned access data, so-called cookies are stored in the internet browser of the device you are using when using the website. These are small text files with a sequence of numbers that are stored locally in the cache of the browser used. Cookies do not become part of the PC system and cannot execute programmes. They serve to make our website user-friendly. The use of cookies may be technically necessary or may be used for other purposes (e.g. analysis/evaluation of website use).

a) Technically necessary cookies

Some elements of our website require that the calling browser can be identified even after a page change. The following data is processed in the cookies:

The user data collected by technically necessary cookies is not processed to create user profiles. We also use “session cookies”, which store a session ID that can be used to assign various requests from your browser to the shared session. Session cookies are necessary for using the website. In particular, it enables us to recognise the device used when you return to the website. We use this cookie to recognise you on subsequent visits to the website if you have an account with us; otherwise you would have to log in again each time you visit. The legal basis for this processing is Art. 6 para. 1 sentence 1 lit. f) GDPR. We use session cookies to make the use of the website more attractive and effective. Session cookies are deleted as soon as you log out or close your browser.

Most browsers are pre-set to automatically accept cookies. You can object to the processing of your data by cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website in full.

b) Technically unnecessary cookies
We also use cookies on the website which enable an analysis of the user’s surfing behaviour. For example, the following data is stored and processed in the cookies:

These cookies are used to make the use of the website more efficient and attractive. The legal basis for this processing is Art. 6 para. 1 sentence 1 lit. f) GDPR. The technically unnecessary cookies are automatically deleted after a specified period, which may vary depending on the cookie.

You can object to the processing of your data by cookies. If you do not wish cookies to be used, you have the option of generally or selectively blocking the storage of cookies or removing cookies that have already been stored by changing your browser settings. You can also have the corresponding information displayed before a cookie is set. If you change the browser settings for the use of cookies or deactivate cookies, the functional scope of this website may be limited.

If we integrate third-party cookies into our website, we will point this out to you separately below.

c) Cookie Banner Notice
When you visit the website, an information banner informs you about the use of cookies for analytical purposes and refers you to this data protection declaration. In this context, there is also a note on how the storage of cookies can be prevented in the browser settings.

Contacting our company

When contacting our company, e.g. by e-mail or via the contact form on the website, the personal data provided by you will be processed by us in order to answer your enquiry.

For the processing of enquiries via the contact form on the website, a name or pseudonym, telephone number and a valid e-mail address are absolutely necessary. The company or domain can be entered voluntarily. At the time as the message is sent to us, the following data will also be processed:

The legal basis for processing is Art. 6 para. 1 sentence 1 lit. f) GDPR or Art. 6 para. 1 sentence 1 lit. b) GDPR, if the establishment of contact is aimed at the conclusion of a contract.

The processing of the personal data from the input mask serves us purely for the processing of the establishment of contact. In the event of contact by e-mail, this also constitutes the necessary legitimate interest in the processing of the data. The other personal data processed during the sending process serves to prevent misuse of the contact form and to ensure the security of our information technology systems.

In this context, the data will not be forwarded to third parties. The data is processed exclusively for processing the conversation. We delete the data disclosed in this context after the processing is no longer necessary, or limit the processing to compliance with the existing legally mandatory storage obligations.

You have the possibility to object to the processing of your personal data for contact enquiries at any time. This is the case if processing is not necessary to fulfil a contract with you, which is described by us in the previous description of the functions. In such a case, processing of the request may not be continued. In the event of your justified objection, we will examine the situation and either stop or adjust data processing, or point out to you our compelling reasons worthy of protection, on the basis of which we will continue processing.

Processing and forwarding of personal data for contractual purposes

We process your personal data, if and as far as this is necessary for the initiation, justification, execution and/or termination of a legal transaction with our company. The legal basis for this results from Art. 6 para. 1 sentence 1 lit. b) GDPR.

After the purpose has been achieved (e.g. contract processing), the personal data will be blocked or deleted for further processing, unless we are entitled to further storage and processing required in the respective context on the basis of a consent given by you (e.g. consent to the processing of the e-mail address for sending electronic advertising mail), a contractual agreement, a statutory authorisation (e.g. authorisation to send direct advertising) or on the basis of justified interests (e.g. storage for asserting claims).

Your personal data will be forwarded if

  • it is necessary for the establishment, execution or termination of legal transactions with our company (e.g. when passing on data to a payment service provider / a mail order company to process a contract with you), (Art. 6 para. 1 sentence 1 lit. b) GDPR) or
  • a subcontractor or vicarious agent whom we use exclusively in the context of the provision of the offers or services requested by you, requires this data (such vicarious agents are only entitled to process the data insofar as this is necessary for the provision of the offer or service, unless you are expressly informed otherwise) or
  • an enforceable official order (Art. 6 para. 1 sentence 1 lit. c) GDPR) has been issued or
  • an enforceable court order (Art. 6 para. 1 sentence 1 lit. c) GDPR) exists or
  • we are legally obliged to do so (Art. 6 para. 1 sentence 1 lit. c) GDPR) or
  • the processing is necessary in order to protect the vital interests of the data subject or another natural person (Art. 6 para. 1 sentence 1 lit. d) GDPR) or
  • we are authorised, or even obliged, to forward the data in order to pursue overriding legitimate interests (Art. 6 para. 1 sentence 1 letter f) GDPR).

Your personal data will not be forwarded to other persons, companies or bodies unless you have effectively consented to such a transfer. The legal basis for processing is then Art. 6 para. 1 sentence 1 lit. a) GDPR.

Registration for events

You can register on the website to be a guest or speaker at events organised by our company or events at which our company is represented. The basis for processing your data for participation in events is Art. 6 Par. 1 S. 1 lit b) GDPR. The processing is necessary for the establishment, execution or termination of legal transactions with our company (e.g. also when forwarding data to a payment service provider / a mail order company to process a contract with you).

In the registration form you must include your name, your company and your e-mail address. The purpose of the processing is to maintain contacts in the IT sector and to improve our external image and our public relations work. If you have expressed your interest in a personal appointment, your data will also be processed for the preparation and execution of the appointment.

Your data will be forwarded to third parties (e.g. payment service provider, mail order company and the organiser) for the purpose of payment processing, dispatch of event documents and registration of the event with the organizer. A targeted transfer of your personal data to a so-called third country is not planned.

We delete the data disclosed in this context after the storage is no longer necessary, or limit the processing if statutory retention obligations exist.

Commenting function

You can leave a comment on the website.

When making the entry, we process the following personal data:

You do not have to enter a real name, you are free to use the function pseudonymously.

Furthermore, at the time the entry is made, the following data is also processed:

When your entry is published, the e-mail address you provided will not be published, only the name / pseudonym you provided and optionally the website. Your entry will not be checked by us before publication. We reserve the right to remove entries at any time if they are found to be unlawful.

We process your e-mail address and your name/pseudonym if necessary, in order to be able to determine if the entry is a real experience report. Furthermore, we would like to be able to contact you if your entry on the website is reported to us as being unlawful and to defend ourselves against complaints or claims that may be brought against us as a result of your entry.

For this purpose, we also process your IP address. We delete the IP address after 1 week. We will process your e-mail address as long as the entry remains on the website or we are involved with the entry in the context of a legal dispute.

If you, or we, delete your entry, we process the e-mail address, the names provided and other voluntary information up to the expiry of the statutory limitation periods for the aforementioned reasons of prevention and defence, but limit the processing of this data after 6 months.

We do not forward the data to third parties, unless we are obliged to do so by law or by official or judicial order, or the passing on is necessary for the enforcement of our legitimate interests. The legal basis for the processing is Art. 6 para. 1 sentence 1 lit. f) GDPR.

You can object to the processing of your given data. You can delete your entry yourself at any time. You are free to take measures in accordance with the “Your Rights” section, and if you have any complaints, please contact our company as a first step.

Application process

We are pleased that you are interested in us and have applied or are applying for a position in our company. Hereinafter we would like to provide you with information on the processing of your personal data in connection with your application. We process the data necessary for the online application process (name, e-mail address and location), as well as data that you have sent us in connection with your application in order to check your suitability for the position (or any other open positions in our company) and to carry out the application process.

The legal basis for the processing of your personal data in this application procedure is primarily § 26 BDSG in the version valid from 25.05.2018. It allows the processing of data required in connection with the decision to establish an employment relationship. Should the data be necessary for legal prosecution after completion of the application procedure, data may be processed on the basis of the requirements of Art. 6 GDPR, in particular to safeguard legitimate interests pursuant to Art. 6 para. 1 lit. f) GDPR. We are then interested in asserting or defending claims.

Candidate data will be deleted after 6 months in the event of rejection. In the event that you have agreed to further storage of your personal data, we will add your data to our applicant pool. There the data will be deleted after two years. If your application process is successful, the data from the applicant data system will be transferred to our personnel information system.

We use a specialised software provider for the application process. They will act as a service provider for us and may also gain knowledge of your personal data in connection with the maintenance and care of the systems. We have concluded a so-called order processing contract with this provider, which ensures that data processing is carried out in a permissible manner.

Your application data will be reviewed by the personnel department on receipt of your application. Suitable applications are then forwarded internally to the department heads for the respective open position. The further procedure is then coordinated. In the company, only those persons have access to your data who need this for the proper course of our application procedure.

You have the possibility of objecting to the processing of your data at any time. This is the case if processing is not necessary in particular to fulfil a contract with you, which is described by us in the previous description of the functions. In the event of your justified objection, we will examine the situation and either stop or adjust data processing, or point out to you our compelling reasons worthy of protection, on the basis of which we will continue processing.

E-Mail-Marketing

Existing customer acquisition

We reserve the right to process the e-mail address provided by you within the framework of the registration/order/booking in accordance with the statutory provisions in order to send you the following content by e-mail during or after the contract has been processed, unless you have already objected to this processing of your e-mail address:

The legal basis for processing is Art. 6 para. 1 sentence 1 lit. f) GDPR. We carry out this processing for customer care and to increase our services. We delete your data when you cancel your newsletter subscription, but no later than two years after termination of the contract.

We would like to point out that you can object to receiving direct advertising at any time without incurring any costs other than the transmission costs according to the basic rates. Click on the unsubscribe link in the newsletter or send us your objection to the contact given in the section “Responsible provider”.

Newsletter

You have the possibility of subscribing to our e-mail newsletter on the website, with which we inform you regularly about the following content:

  • Offers from our portfolio,
  • Events organised by our company,
  • Offers (including events) from third parties if you have given your consent,
  • New articles / collections,
  • Special offers / limited offers

In order to receive the newsletter, the following personal data is required.

  • Recipient (name or pseudonym)
  • Valid e-mail address

To subscribe to our e-mail newsletter, please use the double opt-in procedure. After entering the data marked as mandatory, we will send you an e-mail to the e-mail address you have provided, in which we ask you to explicitly confirm your subscription to the newsletter (by clicking on a confirm link). This is how we ensure that you really want to receive our e-mail newsletter. If the confirmation does not take place within 24 hours, we block the information transmitted to us and delete it automatically after one month at the latest.

Furthermore, the following data is processed at the time of the subscription:

  • IP address
  • Date/time of registration for the newsletter,
  • The time of your confirmation link confirmation,

We process your IP address, the time of registration for the newsletter and the time of your confirmation in order to document your newsletter registration and to prevent misuse of your personal data. The legal basis for the processing is Art. 6 para. 1 sentence 1 lit. f) GDPR. We process this data until two years after termination of the contract. If the newsletter registration takes place outside a contract conclusion, we process this data up to the expiration of two years after termination of the usage. We delete this data when the newsletter subscription ends.

After your confirmation, we will process the e-mail address and name/pseudonym of the recipient concerned for the purpose of sending you our e-mail newsletter. The legal basis for processing is Art. 6 para. 1 sentence 1 lit. a) GDPR. We delete this data when you cancel your newsletter subscription.

You can revoke your consent to the processing of your e-mail address to receive the newsletter at any time, either by sending us a message (see the contact details in the section “Responsible provider/representative of the provider in the European Union”) or by clicking directly on the unsubscribe link contained in the newsletter.

We would like to point out that we evaluate your user behaviour when sending the newsletter. For this analysis, the e-mails sent contain so-called web beacons or tracking pixels, which represent single-pixel image files that are integrated in our website. For evaluation purposes, we link the data mentioned in the “Access Data” section and the web beacons with your e-mail address and an individual ID. Links included in the newsletter also contain this ID.

With the collected data, we create a user profile to tailor the newsletter to your individual interests. When you read our newsletters, we record which links you click on in them and deduce your personal interests. We link this data to actions taken by you on our website. The information is processed as long as you have subscribed to the newsletter. After a cancellation, we process the data purely statistically and anonymously.

The purpose of this is to evaluate the use and for optimisation of the e-mail advertising we send you. The legal basis for the processing is Art. 6 para. 1 sentence 1 lit. f) GDPR.

You can object to this tracking at any time by clicking on the separate unsubscribe link provided in each newsletter or by informing us via the contact data specified in the “Responsible provider” section.

You can also prevent tracking by disabling the display of images in your e-mail programme by default. In this case the newsletter will not be displayed completely and you may not be able to use all functions. If you display the images manually, the above tracking takes place.

E-Mail Marketing Service “CleverReach”

We use CleverReach for sending newsletters. The provider is CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede. CleverReach is a service with which the newsletter dispatch can be organised and analysed. The data you enter for newsletter subscription (e.g. e-mail address) will be stored on CleverReach’s servers in Germany and Ireland.

Our newsletters that are sent out with CleverReach enable us to analyse the behaviour of newsletter recipients. Among other things, it is possible to analyse how many recipients have opened the newsletter message and how often which link was clicked in the newsletter. With the help of the so-called conversion tracking we can also analyse whether a pre-defined action (e.g. purchase of a product on our website) has taken place after clicking on the link in the newsletter. For more information on data analysis via CleverReach newsletters, please visit: https://www.cleverreach.com/en/features/reporting-und-tracking/.

The evaluation of the information mentioned serves to recognise the reading habits of the recipients in order to be able to adapt and spread our newsletter contents better. The legal basis for the processing is Art. 6 para. 1 sentence 1 lit. f) GDPR. We process this data until two years after termination of the contract. If the newsletter registration takes place outside a contract conclusion, we process this data up to the expiration of two years after termination of the usage. We delete this data when the newsletter subscription ends. We have no knowledge of the storage duration at CleverReach and have no influence upon this. For more information, please see CleverReach’s privacy policy at: https://www.cleverreach.com/en/privacy-policy/.

You can object to the processing at any time with effect for the future by clicking on the unsubscribe link at the end of the newsletter. This terminates the processing for receiving the newsletter and for statistical analysis at the same time. A separate objection to the dispatch via CleverReach or the statistical evaluation is not possible.

Alternatively, you can object at http://www.aboutads.info/choices/ and http://www.youronlinechoices.com/ (for the European Union region).

Payment Service Provider (PSP)

Disclosure of personal data in the case of “purchase on account”

In the case of payment on account, we reserve the right to forward your data, which you provide when ordering / booking, to external companies (e.g. Verband der Vereine Creditreform e.V., Hellersbergstraße 12, D-41460 Neuss) in order to carry out a credit assessment.

This data is forwarded on the basis of Art. 6 Par. 1 S. 1 lit. f) GDPR, since in the case of payment on account, we make advance payment and bear the credit risk. We delete the data disclosed in this context after the storage is no longer necessary, or limit the processing if statutory retention obligations exist.

You can object to this processing at any time, but it is possible that you can no longer use the “purchase on account” payment method.

Disclosure of personal data for the purposes of law enforcement / of address determination / for collection purposes

In the event of non-payment, we reserve the right to forward the disclosed data at the time of order / booking to a lawyer and/or to external companies (e.g. Verband der Vereine Creditreform e.V., Hellersbergstraße 12, D-41460 Neuss) if there is a legitimate interest pursuant to Art. 6 para. 1 sentence 1 lit. f) GDPR for purposes of address determination and/or law enforcement.

In addition, we may disclose your information when necessary to exercise our rights, as well as the rights of our affiliates, our cooperation partners, our employees and/or users of our website. Under no circumstances will we sell or rent your data to third parties. This data is forwarded on the basis of Art. 6 Par. 1 S. 1 lit. f) GDPR.

We delete the data disclosed in this context after the storage is no longer necessary, or limit the processing if statutory retention obligations exist.

You have the possibility to object to the processing of your data at any time. This is the case if processing is not necessary in particular to fulfil a contract with you, which is described by us in the previous description of the functions. In the event of your justified objection, we will examine the situation and either stop or adjust data processing, or point out to you our compelling reasons worthy of protection, on the basis of which we will continue processing.

Hosting

We use external hosting services to provide the following services: Infrastructure and platform services, computing capacity, storage resources and database services, security and technical maintenance services. All data necessary for the operation and use of our website will be processed.

We use external hosting services for the operation of this website. By using external hosting services, we aim to make our website available efficiently and securely. The legal basis for processing is Art. 6 para. 1 sentence 1 lit. f) GDPR.

The collection of data for the provision and use of the website and the processing of data via external web hosts is absolutely essential for the operation of the website. You may object to the processing. In the event of your justified objection, we will examine the situation and either stop or adjust data processing, or point out to you our compelling reasons worthy of protection, on the basis of which we will continue processing.

Integration of third-party content

The website includes third-party content such as videos, maps, RSS feeds or graphics from other websites. This integration always requires that the providers of this content (“third party providers”) have access to the Users’ IP addresses. Without the IP address, they are not able to send the content to the browser of the respective user. The IP address is, therefore, required in order for the content to be displayed.

We make every effort to only use content from third parties who process the IP address solely for the purpose of delivering the content. However, we have no influence if the third-party providers process the IP addresses, e.g. for statistical purposes. As far as we are aware of this, we will inform you hereinafter accordingly.

Some of these third parties may process data outside the European Union.

You can object by installing a JavaScript blocker such as the browser plugin ‘NoScript’ (http://www.noscript.net) or deactivating JavaScript in your browser.

However, this can lead to functional restrictions on the website.

AddThis Bookmarking

The website includes plugins from AddThis, a service of AddThis Inc. (1595 Spring Hill Rd, Suite 300, Vienna, VA 22182; hereinafter “AddThis”).

These plugins allow you to bookmark or share interesting content with other users. With the plugins, we offer you the possibility to interact with social networks and other users, so that we can improve our offer and make it more interesting for you as a user.

When using these plugins, your internet browser establishes a direct connection to the AddThis servers and the selected social networking or bookmarking service, if applicable. Recipients are informed that they have accessed the relevant website of our online offer and the data specified in the section “Use of the website, access data” is processed on AddThis servers in the USA. [We have concluded standard data protection clauses with AddThis.]. When you send content on our website to social networks or bookmarking services, a link can be established between visiting our website and your user profile on the relevant network. We have no influence on the data collected and processing procedures, nor are we aware of the full scope, the purposes of the processing and the storage periods. We also have no information on the deletion of the processed data by the plugin provider.

The plugin provider stores this data as user profiles and processes it for purposes of advertising, market research and/or demand-oriented design of its website. Such evaluation takes place in particular (even for users that are not logged in) to provide demand-oriented advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact the respective plugin provider to exercise this right.

The legal basis for the use of the plugins is Art. 6 para. 1 sentence 1 lit. f) GDPR. We have no knowledge of the storage duration at AddThis and have no influence upon this.

If you do not wish to participate in this process, you can object to the data processing at any time by setting an opt-out cookie with effect for the future: http://www.addthis.com/privacy/opt-out.

The opt-out cookie is set for the domain in the browser used. If you use different devices, change your browser after the opt-out or delete all cookies, you must set the opt-out cookie again using the above activation link.

Alternatively, you can set your browser to prevent the setting of a cookie.

For more information about the purpose and scope of processing by the plugin provider and to learn more about your rights and privacy settings, please visit www.addthis.com/privacy.

Google Tag Manager

We use the Google Tag Manager on our website. Google Tag Manager is a solution that allows marketers to manage website tags via a single interface. The Tool Tag Manager itself, (which implements the tags), is a cookieless domain and does not collect any personal data. The tool triggers other tags, which in turn may collect data. Google Tag Manager does not access this data. If deactivation has been made at the domain or cookie level, it will remain in effect for all tracking tags implemented with Google Tag Manager.

YouTube videos

We use plugins from the video platform YouTube.de or YouTube.com on the website, a service operated – represented by Google – by YouTube LLC (headquarters at 901 Cherry Avenue, San Bruno, CA 94066, USA; “YouTube”). When using the plugins, we can also include visual content (“videos”) that we have published on Youtube.de and Youtube.com on this website.

The videos are all in “extended privacy mode”, which means that no data about you as a user will be transmitted to YouTube if you do not play the videos. Only when you play the videos, will the below-mentioned data be transmitted. We have no influence on this data transmission.

When you visit the website, YouTube receives the information that you have accessed the corresponding subpage of our website. In addition, the data specified in the “Access data” section is transmitted. This is independent of whether YouTube provides a user account via which you are logged in or whether no user account exists. If you are logged in to Google, your information will be directly associated with your account. If you do not wish to be associated with your profile on YouTube, you must log out before activating the button.

YouTube stores your data as user profiles and processes them for purposes of advertising, market research and/or demand-oriented design of its website. Such evaluation takes place in particular (even for users that are not logged in) to provide demand-oriented advertising and to inform other users of the social network about your activities on our website.

The legal basis for processing is Art. 6 para. 1 sentence 1 lit. f) GDPR. The processing serves to make our website more attractive and to offer you additional services. We have no knowledge of the storage duration on YouTube and have no influence upon this.

You have the right to object to the processing and must contact YouTube to exercise this right. You can deactivate or restrict the transmission of cookies by changing the settings in your internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website in full.

For more information about the purpose and scope of processing by YouTube, please see the privacy policy on https://policies.google.com/privacy?hl=en. Google also processes your personal data in the USA and has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

Integration of Google Maps

This website also uses the “Google Maps” service from Google to display maps or map sections and thus enables you to conveniently use the map function on the website.

By visiting the website, Google receives the information that you have accessed the corresponding subpage of our website. In addition, the data specified in the “Access data” section will be transmitted to Google. This is regardless of whether Google provides a user account via which you are logged in with or whether no user account exists. If you are logged in to Google, your information will be directly associated with your account. If you do not wish to be associated with your profile on Google, you must log out before activating the button.

Google stores your data as user profiles and processes them for purposes of advertising, market research and/or demand-oriented design of its website. Such evaluation takes place in particular (even for users that are not logged in) to provide demand-oriented advertising and to inform other users of the social network about your activities on our website.

The legal basis for processing is Art. 6 para. 1 sentence 1 lit. f) GDPR. The processing serves to make our website more attractive and to offer you additional services. We have no knowledge of the storage duration at Google and have no influence upon this.

You have the right to object to the processing and you must contact Google to exercise this right. You can deactivate or restrict the transmission of cookies by changing the settings in your internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website in full.

For more information about the purpose and scope of processing by the plugin provider, please refer to the provider’s privacy policy. There you will also find further information about your rights in this regard and setting options for the protection of your privacy: https://policies.google.com/privacy?hl=en. Google also processes your personal data in the USA and has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. For more information on the Google Maps Terms of Use, please visit https://www.google.com/intl/en-us/help/terms_maps.html.

Integration of Vimeo

We use the plugins of Vimeo for the integration of videos on our website. Vimeo is operated by Vimeo LLC, 555 West 18th Street, New York, New York 10011, USA. When using the plugins, we can also include visual content (“videos”) that we have published on www.vimeo.com on this website.

When you access one of our websites with the Vimeo plugin, a connection to the Vimeo servers is established. This informs Vimeo server which website you have visited. If you are logged in as a member of Vimeo, Vimeo will assign this information to your personal user account. When using the plugin, e.g. playing a video by activating the play button, this information is also assigned to your user account. Vimeo stores your data as user profiles and processes it for the purposes of advertising, market research and/or the design of its website according to your needs. Such evaluation takes place in particular (even for users that are not logged in) to provide demand-oriented advertising and to inform other users of the social network about your activities on our website.

The legal basis for processing is Art. 6 para. 1 sentence 1 lit. f) GDPR. The processing serves to make our website more attractive and to offer you additional services. We have no knowledge of the storage duration at Vimeo and have no influence upon this. We have entered into “standard contractual clauses” with Vimeo to require Vimeo to maintain an adequate level of data protection.

You have the right to object to the processing and you must contact Vimeo to exercise this right. You can deactivate or restrict the transmission of cookies by changing the settings in your internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website in full.

For more information on Vimeo’s data processing and privacy policy, please visit https://vimeo.com/privacy.

Integration of Getty Images

On our website, we use plugins from the image agency Getty Images, which offers pictures and other image material. The supplier of Getty-Images components is Getty Images International, 1st Floor, The Herbert Building, The Park, Carrickmines, Dublin 18, Ireland (“Getty Images).

Getty Images allows us to embed stock images using an embed code, such as text, video or image data provided by an external website. The technical implementation of the embed code transfers your IP address to Getty Images. Getty Images also processes information about our website, the type of browser used, the browser language, the time and length of access. In addition, Getty Images may collect information about your use of our website (e.g. access to subpages and clicking on links) and other interactions you may have made while visiting our website. Getty Images also processes your personal data in the USA and is subject to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. Further information and Getty Images’ current privacy policy can be found on https://www.gettyimages.com/company/privacy-policy

The legal basis for processing is Art. 6 para. 1 sentence 1 lit. f) GDPR. The processing serves to make our website more attractive and to offer you additional services. We have no knowledge of, and no control over, the storage duration at Getty Images.

You have the right to object to the processing and must contact Getty Images to exercise this right. You can deactivate or restrict the transmission of cookies by changing the settings in your internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website in full.

Services for statistical, analytical and marketing purposes

We use third-party services for statistical, analytical and marketing purposes. This enables us to provide you with a user-friendly, optimised use of the website. The third-party providers use cookies to control their services (see the “Cookies” section above). Personal data will not be processed, unless otherwise explained below.

Some of the third-party providers offer the possibility to directly object to the use of the respective service, e.g. by setting an opt-out cookie.

If you activate a corresponding opt-out cookie, the external provider will no longer process any data about your usage behaviour. A mere selective objection to an individual selection of external services is also possible. If you change the browser or the terminal device used or delete all cookies, you must set the opt-out cookie again.

Furthermore, you can also opt-out of the use of cookies via the opt-out platform of the Bundesverband Digitale Wirtschaft e.V. (German Digital Industry Association). (BVDW) on http://www.meine-cookies.org/cookies_verwalten/praeferenzmanager.html or directly via the deactivation page of the Network Advertising Initiative on http://www.networkadvertising.org/choices/. Further information on usage-based advertising and opt-out options can also be found using the following link: http://www.youronlinechoices.com/de/.

We inform you below about the services of external providers currently used on our website, as well as about the purpose and scope of the respective processing in individual cases, and about your possibilities to object.

Google Analytics

In order to tailor our website optimally to your interests, we use Google Analytics, a web analysis service from Google. Google Analytics uses so-called “cookies” (see the “Cookies” section above), which are stored on your computer and enable an analysis of your use of the website. The information generated about your use of this website is transmitted to a Google server in the USA and processed there.

If IP anonymisation is activated on this website, your IP address will be shortened by Google within Member States of the European Union or in other countries party to 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 shortened there. On our behalf, Google will use this information to evaluate your use of the website, to compile reports for us on website activity and to provide us with further services relating to website and internet use.

The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.

This website uses Google Analytics with the extension “_anonymizeIp()”. As a result, IP addresses are further processed in abbreviated form, so that a personal relationship can be ruled out. Should the data collected about you be personal, it will be excluded immediately and the personal data will be deleted immediately.

We use Google Analytics to analyse and regularly improve the use of our website. The statistics help us to improve our offer and make it more interesting for you as a user. For the exceptional cases in which personal data is transferred to the USA, Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The legal basis for the processing of Google Analytics is Art. 6 Par. 1 S. 1 lit. f) GDPR. The Google Analytics cookies will be deleted on request.

You have the right to object. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plugin available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

For more information from Google, a third-party provider, please visit:

https://www.google.com/analytics/terms/us.html
https://support.google.com/analytics/answer/6004245?hl=en
https://policies.google.com/privacy?hl=en

Hotjar

We also use the Hotjar analysis service to make our website better and more user-friendly. Provider of the analysis service is Hotjar Ltd, Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta, Europe, +1 (855) 464-6788, david@hotjar.com)

This tool records movements on the observed web pages in so-called heat maps. All data is collected without us being able to assign it to specific users. We can only track how the mouse moves, where it was clicked and how far it was scrolled. This allows us to make our website better and more customer-friendly. Furthermore, the screen size of the device, the device type, information about the browser, the country from which it was accessed and the preferred language are recorded. If personal data is displayed on a website, it is automatically hidden by Hotjar. It is, therefore, incomprehensible to us.

To analyse your usage behaviour, so-called “cookies” (see the “Cookies” section above) are used, which are stored on your computer and enable an analysis of your use of the website. The information generated by the “tracking code” and “cookie” about your visit to our website is transmitted to and stored on the Hotjar servers. The tracking code collects the following information about your device such as IP address, device type and browser information, geographic location (country only), the language preferred to display our website, pages visited, date and time when the website was accessed. Hotjar shortens your IP address before it is processed. Should the data collected about you be personal, it will be excluded immediately and the personal data will be deleted immediately.

Hotjar will use this information to evaluate your use of our website, generate usage reports and other services relating to website usage and internet analysis of the website. Hotjar also uses third-party services such as Google Analytics and Optimizely. These third parties may store information that your browser sends when you visit the site, such as cookies or IP requests. For more information on how Google Analytics and Optimizely store and use data, please refer to their respective privacy statements.

The legal basis for processing is Art. 6 para. 1 sentence 1 lit. f) GDPR. The cookies Hotjar uses have different retention periods. some remain valid for up to 365 days, some only remain valid during the current visit. An overview of the storage duration can be found on: https://www.hotjar.com/legal/policies/cookie-information. Further information about Hotjar Ltd. and about the tool Hotjar can be found on: https://www.hotjar.com/legal/policies/privacy.

You can object to the processing in various ways:

  • by activating the Do-Not-Track function in your browser software, which is supported by Hotjar. Instructions for activating the Do-Not-Track function are available on: https://www.hotjar.com/legal/compliance/opt-out
  • by adjusting your browser software accordingly, in particular the suppression of third-party cookies means that you will not receive any ads from third parties or
  • by deactivating the provider’s interest-based ads that are part of the “About Ads” self-regulation campaign via the link http://www.aboutads.info/choices. This setting is deleted if you delete your cookies.

Usage-based online advertising.

The website also uses the “Website Custom Audiences” function via the so-called “Facebook Pixel” of Facebook Inc. (provider is Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland, e-mail: impressum-support@support.facebook.com, data protection information on: https://www.facebook.com/privacy/explanation; hereinafter: “Facebook”).

This allows users of the website to see interest-based advertisements (“Facebook ads”) when visiting the social network Facebook or other websites that also use the process. We are interested in showing you advertisements that are of interest to you in order to make our website more attractive to you.

Due to the marketing tools used, your browser automatically establishes a direct connection to the Facebook server. We have no influence on the extent and further processing of the data collected by Facebook by using this tool and, therefore, inform you according to our level of knowledge: By integrating Facebook Custom Audiences, Facebook receives the information that you have accessed the corresponding website of our internet presence, or that you have clicked on one of our advertisements. If you are registered with a Facebook service, Facebook can associate your visit with your account. Even if you are not registered with Facebook or have not logged in, it is possible that the provider may obtain and store your IP address and other identifying information.

The legal basis for the processing of your data is Art. 6 para. 1 sentence 1 lit. f) GDPR. In this case, we do not store any personal data about you. We have no knowledge of and no influence over the storage duration on Facebook.

Logged-in users can deactivate the “Facebook Custom Audiences” function at https://www.facebook.com/settings/?tab=ads# to exercise their right of objection.

You can prevent the “Facebook Custom Audiences” function in various ways and thus make use of your right of objection:

  • By setting your browser software accordingly, in particular the suppression of third-party cookies means that you will not receive any ads from third-party providers;
  • By deactivating the provider’s interest-based ads that are part of the “About Ads” self-regulation campaign via the link http://www.aboutads.info/choices. This setting is deleted if you delete your cookies.

For more information about Facebook processing, please visit https://www.facebook.com/about/privacy.

Facebook Analytics

For the use of Facebook Analytics we use the so-called “tracking pixel” of Facebook Inc. (provider is Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland, e-mail: impressum-support@support.facebook.com, privacy statement on: https://www.facebook.com/privacy/explanation; hereinafter: “Facebook”) to track your user behaviour. The information obtained through the tracking pixel cookie serves us solely for statistical purposes, is transmitted to us anonymously by Facebook and does not provide any information about the user as an individual. However, Facebook will connect you to your Facebook account, store and use your data for its own promotional purposes in accordance with Facebook’s Privacy Policy and may also transfer your information to Facebook partners. Even if you are not registered with Facebook or have not logged in, it is possible that the provider may obtain and store your IP address and other identifying information.

Your data will be processed in accordance with Art. 6 Par. 1 letter f) GDPR. By using Facebook Analytics, we are pursuing the interest of being able to better evaluate our website and improve our services offered. In this case, we do not store any personal data about you. We have no knowledge of and no influence over the storage duration on Facebook.

Logged-in users can deactivate the “Facebook Analytics” function at https://www.facebook.com/settings/?tab=ads# to exercise their right of objection.

You can prevent the “Facebook Analytics” function in various ways and thus make use of your right of objection:

  • By setting your browser software accordingly, in particular the suppression of third-party cookies means that you will not receive any ads from third-party providers;
  • By deactivating the interest-based ads of the providers that are part of the “About Ads” self-regulation campaign via the link http://www.aboutads.info/choices. This setting is deleted if you delete your cookies.

For more information about Facebook’s privacy policy, please see their privacy policy at https://www.facebook.com/about/privacy/.

Google AdWords/Google Ads Conversion

We use the Google AdWords/Google Ads service from Google to draw attention to our attractive offers with the help of advertising material (so-called Google AdWords/Google Ads) on external websites. We can determine in relation to the data of the advertising campaigns how successful the individual advertising measures are. We are interested in showing you advertisements that are of interest to you, to make our website more attractive to you and to achieve a fair calculation of advertising costs.

This advertising media is delivered by Google via so-called “Ad Servers”. For this purpose, we use ad server cookies, with which certain parameters for measuring success, such as the insertion of ads or clicks by users, can be measured. If you access our website via a Google ad, Google AdWords/Google Ads stores a cookie on your PC. These cookies usually expire after 30 days and are not intended to identify you personally. For this cookie, the unique cookie ID, number of ad impressions per placement (frequency), last impression (relevant for post-view conversions) and opt-out information (mark that the user no longer wishes to be addressed) are usually stored as analysis values.

These cookies enable Google to recognise your internet browser. If a user visits certain pages of an AdWords customer’s website and the cookie stored on their computer has not expired, Google and the customer may recognise that the user has clicked on the ad and has been redirected to this page. Each AdWords customer is assigned a different cookie. Cookies can, therefore, not be traced via the AdWords customers’ websites. We do not process any personal data ourselves in the aforementioned advertising measures. We only receive statistical evaluations from Google. On the basis of these evaluations we can recognise which of the used advertising measures are particularly effective. We do not receive any further data from the use of advertising material; in particular, we cannot identify users on the basis of this information.

Due to the marketing tools used, your browser automatically establishes a direct connection to the Google server. We have no influence on the extent and the further processing of the data collected by Google by using of this tool and therefore inform you according to our level of knowledge: By integrating AdWords Conversion, Google receives the information that you have called the corresponding part of our internet presence or clicked on one of our advertisements. If you are registered with a Google service, Google may associate your visit with your account. Even if you are not registered with Google or have not logged in, it is possible that the provider may obtain and store your IP address.

The legal basis for the processing of your data is Art. 6 para. 1 sentence 1 lit. f) GDPR. We have no knowledge of the storage duration at Google and have no influence upon this.

You can prevent participation in this tracking procedure in various ways:

  • By setting your browser software accordingly, in particular the suppression of third-party cookies means that you will not receive any ads from third-party providers;
  • By disabling cookies for conversion tracking by setting your browser to block cookies from the “www.googleadservices.com” domain, https://adssettings.google.com, which will be deleted when you delete your cookies;
  • By deactivating the provider’s interest-based ads that are part of the “About Ads” self-regulation campaign via the link http://www.aboutads.info/choices. This setting is deleted if you delete your cookies;
  • By permanent deactivation in your browsers Firefox, Internet Explorer or Google Chrome under the link http://www.google.com/settings/ads/plugin. Please note that in this case it is possible that you are not able to use all functions of this offer in full.

Further information on data protection at Google can be found here: https://policies.google.com/privacy?hl=en and https://services.google.com/sitestats/en.html. Alternatively, you can visit the website of the Network Advertising Initiative (NAI) on http://www.networkadvertising.org

Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

Google Remarketing

Besides Adwords Conversion we use the application Google Remarketing from Google. This is a process we would like to use to contact you again. This application allows you to see our advertisements after visiting our website when you continue to use the internet. This is done by means of cookies stored in your browser, which are used to record and evaluate your usage behaviour when you visit various websites via Google. This is how Google can determine your previous visit to our website. According to its own statements, Google does not merge the data collected in the context of remarketing with your personal data, which may be processed by Google. According to Google, pseudonymisation is used for remarketing.

The legal basis for the processing is Art. 6 para. 1 sentence 1 lit. f) GDPR. We have no knowledge of the storage duration at Google and have no influence upon this.

You can prevent participation in this tracking procedure in various ways and thus exercise your right of objection:

  • By setting your browser software accordingly, in particular the suppression of third-party cookies means that you will not receive any ads from third-party providers;
  • By disabling cookies for conversion tracking by setting your browser to block cookies from the “www.googleadservices.com” domain, https://www.google.com/settings/ads, which will be deleted when you delete your cookies;
  • By deactivating the provider’s interest-based ads that are part of the “About Ads” self-regulation campaign via the link http://www.aboutads.info/choices. This setting is deleted if you delete your cookies;
  • By permanent deactivation in your browsers Firefox, Internet Explorer or Google Chrome under the link http://www.google.com/settings/ads/plugin.

Bing Ads

We use the conversion and tracking tool Bing Ads from Microsoft Corporation (One Microsoft Way, Redmond, WA 98052-6399, “Microsoft”) on our website.

Microsoft stores a cookie on the user’s computer to enable analysis of the use of our online offer. The prerequisite for this is that the user has reached our website via an advertisement from Microsoft Bing Ads. This enables Microsoft and ourselves to see that someone has clicked on an ad, has been redirected to our online offer and has reached a predetermined target page. We only see the total number of users who clicked on a Bing ad and were then forwarded to the target page (conversions). No IP addresses are stored.

Due to the marketing tools used, your browser automatically establishes a direct connection to the Microsoft server. We have no influence on the extent and the further processing of the data that occur with the use of Bing Ads. Microsoft has submitted to the EU-US Privacy Shield (https://www.privacyshield.gov/EU-US-Framework), thereby offering a guarantee to comply with European data protection law.

The legal basis for the processing of your data is Art. 6 para. 1 sentence 1 lit. f) GDPR. We have no knowledge of the storage duration at Microsoft and have no influence upon this. For more information about Microsoft’s privacy statement, please visit: https://privacy.microsoft.com/en-US/privacystatement.

You can object to the processing in various ways:

  • By adjusting your browser software accordingly, in particular the suppression of third-party cookies means that you will not receive any ads from third parties or
  • By deactivating the provider’s interest-based ads that are part of the “About Ads” self-regulation campaign via the link http://www.aboutads.info/choices. This setting is deleted if you delete your cookies.

Plugins for social networks

Our website includes plugins from social networks. These are made available by the following providers:

 

The plugins are indicated on our website by the above-mentioned lettering or by small stylised symbols.

We offer you the possibility to communicate directly with the provider of the plugin via the button. The plugin provider only receives the information that you have accessed the corresponding website of our online offer if you click on the marked field and thereby activate it. In addition, the data specified in the “Access data” section are transmitted.

In the case of Facebook and Xing, the IP address is anonymised immediately after collection, according to the respective provider in Germany. By activating the plugin, personal data is transmitted from you to the respective plugin provider and processed there (for US providers in the USA). Since the plugin provider collects data mainly via cookies, we recommend that you delete all cookies before clicking on the greyed-out box using your browser’s security settings.

We have no influence on the data collected and processing procedures, nor are we aware of the full scope of data processing, the purposes of processing, the storage periods. We also have no information on the deletion of the data collected by the plugin provider.

The plugin provider stores the data collected about you as user profiles and processes this for purposes of advertising, market research and/or demand-oriented design of its website. Such an evaluation takes place in particular (also for users that are not logged in) for the representation of demand-fair advertisement and in order to inform other users of the social network about your activities on our website.

The legal basis for the use of the plugins is Art. 6 para. 1 sentence 1 lit. f) GDPR. By using plugins we offer you the possibility to interact with social networks and other users, so that we can improve our offer and make it more interesting for you as a user.

You have a right of objection to the creation of these user profiles, whereby you must contact the respective plugin provider to exercise this right. You can also prevent the creation of user profiles in various ways and thus make use of your right of objection:

  • By setting your browser software accordingly, in particular the suppression of third-party cookies means that you will not receive any ads from third-party providers;
  • By deactivating the provider’s interest-based ads that are part of the “About Ads” self-regulation campaign via the link http://www.aboutads.info/choices. This setting is deleted if you delete your cookies.

The data is transferred regardless of whether you have an account with the plugin provider and are logged in there. If you are logged in with the plugin provider, the data that we have collected from you will be directly assigned to your existing account with the plugin provider. If you click on the activated button and, for example, link the page, the plugin provider also stores this information in your user account and shares it publicly with your contacts.

We recommend that you log out regularly after using a social network, especially before activating the button, as this way you can avoid being assigned to your profile with the plugin provider.

Copyright by Spirit Legal LLP