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Privacy policy


Introduction

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

The terms used are not gender-specific.

    Last updated: 21 November 2019

    Table of contents

    Controller

    HALM Straws GmbH
    Danziger Str. 6
    10435 Berlin

    Authorised representatives: Sebastian Müller

    Email address: contact@halm.co

    Legal notice: https://gastronomie.halm.co

      Overview of processing operations

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

      Types of data processed

      • Inventory data (e.g. names, addresses).

      • Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained in them, such as cover letter, CV, certificates and other information about the applicant's person or qualifications provided with regard to a specific position or voluntarily by applicants).

      • Content data (e.g. text entries, photographs, videos).

      • Contact data (e.g. email, telephone numbers).

      • Meta/communication data (e.g. device information, IP addresses).

      • Usage data (e.g. websites visited, interest in content, access times).

      • Social data (data that is subject to social secrecy (Section 35 of the German Social Code, Book I) and is processed, for example, by social insurance institutions, social welfare agencies or pension authorities).

      • Location data (data indicating the location of an end user's device).

      • Contract data (e.g. subject matter of the contract, term, customer category).

      • Payment data (e.g. bank details, invoices, payment history).

      Categories of data subjects

      • Employees (e.g. staff, applicants, former employees).

      • Applicants.

      • Business and contractual partners.

      • Prospective customers.

      • Communication partners.

      • Customers.

      • Users (e.g. website visitors, users of online services).

      • Participants in prize draws and competitions.

      Purposes of processing

      • Affiliate tracking.

      • Provision of our online offering and user-friendliness.

      • Conversion tracking.

      • Application process (establishment and any later performance as well as possible later termination of the employment relationship).

      • Office and organisational procedures.

      • Click tracking.

      • Cross-device tracking (processing of user data across devices for marketing purposes).

      • Direct marketing (e.g. by email or post).

      • Running prize draws and competitions.

      • Feedback (e.g. collecting feedback via online form).

      • Interest-based and behavioural marketing.

      • Contact enquiries and communication.

      • Conversion measurement (measuring the effectiveness of marketing measures).

      • Profiling (creating user profiles).

      • Remarketing.

      • Reach measurement (e.g. access statistics, recognition of returning visitors).

      • Security measures.

      • Tracking (e.g. interest-based/behavioural profiling, use of cookies).

      • Contractual services and support.

      • Managing and responding to enquiries.

      • Target group formation (determining target groups relevant for marketing purposes or other delivery of content).


      Relevant legal bases

      Below we set out the legal bases of the General Data Protection Regulation (GDPR) on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection requirements in your or our country of residence or domicile may apply.

      • Consent (Art. 6 (1) sentence 1 (a) GDPR) - The data subject has given consent to the processing of personal data relating to them for one specific purpose or several specific purposes.

      • Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 (b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

      • Legal obligation (Art. 6 (1) sentence 1 (c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.

      • Protection of vital interests (Art. 6 (1) sentence 1 (d) GDPR) - Processing is necessary in order to protect the vital interests of the data subject or of another natural person.

      • Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

      • Art. 9 (1) sentence 1 (b) GDPR (application process as a pre-contractual or contractual relationship) (Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR (e.g. health data, such as severe disability status, or ethnic origin) are requested from applicants in the course of the application process so that the controller or the data subject can exercise the rights arising from employment law and from social security and social protection law and fulfil the related obligations, they are processed in accordance with Art. 9 (2) (b) GDPR; in the case of the protection of vital interests of applicants or other persons, in accordance with Art. 9 (2) (c) GDPR; or for the purposes of preventive health care or occupational medicine, for the assessment of the working capacity of the employee, for medical diagnosis, for the provision of care or treatment in the health or social sector or for the management of systems and services in the health or social sector, in accordance with Art. 9 (2) (h) GDPR. Where special categories of data are communicated on the basis of voluntary consent, they are processed on the basis of Art. 9 (2) (a) GDPR.) - .

      National data protection provisions in Germany: In addition to the data protection provisions of the General Data Protection Regulation, national data protection provisions apply in Germany. These include in particular the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act, BDSG). The BDSG contains in particular special provisions on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transfer, as well as automated individual decision-making, including profiling. It also governs data processing for the purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, performance or termination of employment relationships and the consent of employees. In addition, the data protection laws of the individual German federal states may apply.

        Transfer and disclosure of personal data

        In the course of our processing of personal data, the data may be transferred to other bodies, companies, legally independent organisational units or persons, or disclosed to them. The recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks, or providers of services and content that are embedded in a website. In such cases we comply with the legal requirements and in particular conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

        Data transfer within the organisation: We may transfer personal data to other bodies within our organisation or grant them access to this data. Where this transfer takes place for administrative purposes, it is based on our legitimate business and commercial interests, or takes place where it is necessary to fulfil our contract-related obligations, or where the data subjects have given their consent or a statutory permission exists.

        Data processing in third countries

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

        Subject to express consent or a transfer required by contract or by law, we process the data, or have the data processed, only in third countries with a recognised level of data protection, which include US processors certified under the "Privacy Shield", or on the basis of special safeguards, such as a contractual obligation through the so-called standard contractual clauses of the EU Commission, the existence of certifications or binding internal data protection rules (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

        Use of cookies

        Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user's computer. A cookie serves primarily to store information about a user during or after their visit to an online offering. The information stored may include, for example, the language settings on a website, the login status, a shopping basket or the point at which a video was watched. We also include under the term cookies other technologies that fulfil the same functions as cookies (e.g. where user information is stored using pseudonymous online identifiers, also referred to as "user IDs")

        The following types of cookies and functions are distinguished:

        • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their browser.
        • Permanent cookies: Permanent cookies remain stored even after the browser has been closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The interests of users, which are used for reach measurement or marketing purposes, can also be stored in such a cookie.
        • First-party cookies: First-party cookies are set by us.
        • Third-party cookies: Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
        • Necessary (also: essential or strictly necessary) cookies: Cookies may be strictly necessary for the operation of a website (e.g. to save logins or other user input, or for security reasons).
        • Statistics, marketing and personalisation cookies: Cookies are also generally used for reach measurement and when the interests of a user or their behaviour (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that matches their potential interests. This procedure is also referred to as "tracking", i.e. following the potential interests of users. . Where we use cookies or "tracking" technologies, we inform you separately in our privacy policy or when obtaining consent.

        Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for the processing of your data is the consent given. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and its improvement) or, where the use of cookies is necessary, in order to fulfil our contractual obligations.

        General information on withdrawal and objection (opt-out): Depending on whether the processing is based on consent or on statutory permission, you may at any time withdraw any consent given or object to the processing of your data by cookie technologies (collectively referred to as "opt-out"). You can initially declare your objection by means of your browser settings, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared through a variety of services, especially in the case of tracking, via the websites http://optout.aboutads.info and http://www.youronlinechoices.com/. In addition, you can find further information on objecting in the details on the service providers and cookies used.

        Processing of cookie data on the basis of consent: Before we process data, or have data processed, in the context of the use of cookies, we ask users for consent, which can be withdrawn at any time. Until consent has been given, at most those cookies are used that are necessary for the operation of our online offering. They are used on the basis of our interest and the users' interest in the expected functionality of our online offering.

        • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

        • Data subjects: Users (e.g. website visitors, users of online services).

        • Legal bases: Consent (Art. 6 (1) sentence 1 (a) GDPR), legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

        Commercial and business services

        We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as "contractual partners"), in the context of contractual and comparable legal relationships and related measures, and in the context of communication with the contractual partners (or pre-contractually), e.g. to respond to enquiries.

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

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

        We erase the data after the expiry of statutory warranty and comparable obligations, i.e. in principle after 4 years, unless the data is stored in a customer account, e.g. for as long as it must be retained for statutory archiving reasons (e.g. for tax purposes, generally 10 years). Data disclosed to us by the contractual partner in the context of an assignment is erased in accordance with the specifications of the assignment, in principle after the end of the assignment.

        Where we use third-party providers or platforms to provide our services, the terms and conditions and privacy notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.

        Customer account: Contractual partners can create an account within our online offering (e.g. a customer or user account, "customer account" for short). If registration of a customer account is required, contractual partners are informed of this and of the details required for registration. Customer accounts are not public and cannot be indexed by search engines. In the course of registration and subsequent logins and use of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove the registration and prevent any misuse of the customer account.

        If customers have terminated their customer account, the data relating to the customer account is erased, unless its retention is required for legal reasons. It is the customers' responsibility to back up their data when the customer account is terminated.

        Business analyses and market research: For business reasons and in order to identify market trends and the wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc.; the group of data subjects may include contractual partners, prospective customers, customers, visitors and users of our online offering.

        The analyses are carried out for the purposes of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so we may, where available, take into account the profiles of registered users together with their details, e.g. on services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with aggregated, i.e. anonymised, values. We also respect the privacy of users and process the data for analysis purposes in pseudonymised form wherever possible and, where feasible, anonymously (e.g. as aggregated data).

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

        The required details are marked as such in the course of the order or comparable purchasing process and comprise the details needed for delivery or provision and invoicing, as well as contact information so that we can consult with you if necessary.

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

        • Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. email, telephone numbers), contract data (e.g. subject matter of the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

        • Data subjects: Prospective customers, business and contractual partners, customers.

        • Purposes of processing: Contractual services and support, contact enquiries and communication, office and organisational procedures, managing and responding to enquiries, security measures, conversion tracking, interest-based and behavioural marketing, profiling (creating user profiles).

        • Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 (b) GDPR), legal obligation (Art. 6 (1) sentence 1 (c) GDPR), legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

        Use of online marketplaces for e-commerce

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

        • Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. email, telephone numbers), contract data (e.g. subject matter of the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

        • Data subjects: Customers.

        • Purposes of processing: Contractual services and support.

        • Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 (b) GDPR), legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

        Services used and service providers:

        Payment service providers

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

        The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, amount and recipient-related details. This information is required in order to carry out the transactions. However, the data entered is processed only by the payment service providers and stored with them. This means that we do not receive any account or credit card-related information, but only information confirming or declining the payment. Under certain circumstances, the payment service providers transmit the data to credit agencies. The purpose of this transmission is to verify identity and creditworthiness. In this regard we refer to the terms and conditions and the privacy notices of the payment service providers.

        Payment transactions are subject to the terms and conditions and the privacy notices of the respective payment service providers, which are available on the respective websites or in the transaction applications. We also refer to these for further information and for the assertion of rights of withdrawal, access and other data subject rights.

        • Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), contact data (e.g. email, telephone numbers).

        • Data subjects: Customers, prospective customers.

        • Purposes of processing: Contractual services and support, contact enquiries and communication, affiliate tracking.

        • Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 (b) GDPR), legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

        Services used and service providers:

        Registration and login

        Users can create a user account. In the course of registration, users are informed of the mandatory details required, which are processed for the purpose of providing the user account on the basis of the fulfilment of contractual obligations. The data processed includes in particular the login information (name, password and an email address). The data entered during registration is used for the purposes of using the user account and its purpose.

        Users may be informed by email about matters relevant to their user account, such as technical changes. If users have terminated their user account, their data relating to the user account is erased, subject to any statutory retention obligation. It is the users' responsibility to back up their data before the end of the contract when they terminate. We are entitled to irretrievably erase all of the user's data stored during the term of the contract.

        In the context of the use of our registration and login functions and the use of the user account, we store the IP address and the time of the respective user action. This storage is based on our legitimate interests and those of the users in protection against misuse and other unauthorised use. This data is not passed on to third parties as a matter of principle, unless this is necessary to pursue our claims or there is a legal obligation to do so.

        Online forum: Participation in the forum requires registration, for which, unless otherwise stated in the registration form, a name or your name, a password and the email address to which the access data is sent must be provided. For security reasons, the password should correspond to the state of the art, i.e. be complex (users are informed of this during registration if necessary), and should not be used elsewhere. Posts in the forum are visible to the public, unless their visibility is restricted to certain members or groups of members. The authors' posts are stored with their names, where registered or provided, the time and the content of the entry. When users log in and write entries, their IP addresses are also stored in case the entries contain inadmissible content and the IP addresses could serve the purpose of legal action. The controller reserves the right to delete registrations and entries on the basis of an appropriate weighing of interests.

        • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. text entries, photographs, videos), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).

        • Data subjects: Users (e.g. website visitors, users of online services).

        • Purposes of processing: Contractual services and support, security measures, managing and responding to enquiries.

        • Legal bases: Consent (Art. 6 (1) sentence 1 (a) GDPR), performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 (b) GDPR), legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

        Blogs and publication media

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

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

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

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

        The personal information provided in comments and posts, any contact and website information, and the content details are stored by us permanently until the users object.

        • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

        • Data subjects: Users (e.g. website visitors, users of online services).

        • Purposes of processing: Contractual services and support, feedback (e.g. collecting feedback via online form), security measures, managing and responding to enquiries.

        • Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 (b) GDPR), legitimate interests (Art. 6 (1) sentence 1 (f) GDPR), consent (Art. 6 (1) sentence 1 (a) GDPR), protection of vital interests (Art. 6 (1) sentence 1 (d) GDPR).

        Contacting us

        When you contact us (e.g. by contact form, email, telephone or via social media), the details of the enquiring persons are processed insofar as this is necessary to respond to the contact enquiries and any requested measures.

        Contact enquiries in the context of contractual or pre-contractual relationships are answered in order to fulfil our contractual obligations or to respond to (pre-)contractual enquiries, and otherwise on the basis of the legitimate interests in responding to the enquiries.

        Chat function: For the purposes of communication and responding to enquiries, we offer a chat function within our online offering. The users' entries in the chat are processed for the purpose of responding to their enquiries.

        • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

        • Data subjects: Communication partners, prospective customers.

        • Purposes of processing: Contact enquiries and communication, managing and responding to enquiries.

        • Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 (b) GDPR), legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

        Communication via messenger

        We use messenger services for communication purposes and therefore ask you to note the following information on how the messengers work, on encryption, on the use of the metadata of the communication and on your options to object.

        You can also contact us by alternative means, e.g. by telephone or email. Please use the contact options communicated to you or the contact options stated within our online offering.

        In the case of end-to-end encryption of content (i.e. the content of your message and attachments), we point out that the communication content (i.e. the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messenger with encryption enabled so that the encryption of the message content is ensured.

        However, we additionally point out to our communication partners that, although the messenger providers cannot view the content, they can find out that and when communication partners communicate with us, and that technical information on the device used by the communication partners and, depending on the settings of their device, also location information (so-called metadata) is processed.

        Notes on legal bases: Where we ask communication partners for permission before communicating with them via messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and they contact us on their own initiative, for example, we use messengers in relation to our contractual partners and in the context of initiating a contract as a contractual measure, and in the case of other prospective customers and communication partners on the basis of our legitimate interests in fast and efficient communication and in meeting the needs of our communication partners for communication via messengers. We also point out that we do not transmit the contact data provided to us to the messengers for the first time without your consent.

        Withdrawal, objection and erasure: You may withdraw any consent given at any time and object to communication with us via messenger at any time. In the case of communication via messenger, we delete the messages in accordance with our general deletion policies (i.e., for example, as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any enquiries from the communication partners, if no reference to a previous conversation is to be expected and no statutory retention obligations prevent deletion.

        Reservation of the right to refer to other means of communication: Finally, we would like to point out that, for reasons of your security, we reserve the right not to answer enquiries via messenger. This is the case, for example, if internal contractual matters require special confidentiality or if a reply via messenger does not meet the formal requirements. In such cases we refer you to more appropriate means of communication.

        • Types of data processed: Contact data (e.g. email, telephone numbers), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), content data (e.g. text entries, photographs, videos).

        • Data subjects: Communication partners.

        • Purposes of processing: Contact enquiries and communication, direct marketing (e.g. by email or post).

        • Legal bases: Consent (Art. 6 (1) sentence 1 (a) GDPR), legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

        Services used and service providers:

        Online conferences, meetings and webinars

        We use platforms and applications of other providers (hereinafter referred to as "third-party providers") for the purpose of holding video and audio conferences, webinars and other types of video and audio meetings. When selecting the third-party providers and their services, we comply with the legal requirements.

        In this context, data of the communication participants is processed and stored on the servers of the third-party providers, insofar as it forms part of communication processes with us. This data may include in particular login and contact data, visual and voice contributions, as well as entries in chats and shared screen content.

        Where users are referred to the third-party providers or their software or platforms in the context of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimisation or marketing purposes. We therefore ask you to note the privacy notices of the respective third-party providers.

        Notes on legal bases: Where we ask users for their consent to the use of the third-party providers, the legal basis for the processing is consent. Furthermore, their use may be a component of our (pre-)contractual services, provided that the use of the third-party providers has been agreed in this context. Otherwise, the users' data is processed on the basis of our legitimate interests. In this context we would also like to refer you to the information on the use of cookies in this privacy policy.

        • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

        • Data subjects: Communication partners, users (e.g. website visitors, users of online services).

        • Purposes of processing: Contractual services and support, contact enquiries and communication, office and organisational procedures.

        • Legal bases: Consent (Art. 6 (1) sentence 1 (a) GDPR), performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 (b) GDPR), legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

        Services used and service providers:

        Chatbots

        We offer a so-called "chatbot" as a means of communication. A chatbot is software that answers users' questions or informs them about news. When you converse with our chatbot, we may process your personal data.

        If you communicate with the chatbot within an online platform, your identification number within the respective platform is also stored. We may also collect information about which users interact with our chatbot and when. Furthermore, we store the content of your conversations with the chatbot and log registration and consent processes in order to be able to prove them in accordance with legal requirements.

        We point out that the respective platform provider can find out that and when users communicate with our chatbot and may collect technical information on the device used by the users and, depending on the settings of their device, also location information (so-called metadata) for the purposes of optimising the respective services and for security purposes. The metadata of the communication via chatbot (i.e., for example, the information about who has communicated with whom) could also be used by the respective platform providers, in accordance with their terms, to which we refer for further information, for marketing purposes or to display advertising tailored to users.

        Where users agree with the chatbot to activate information with regular messages, they may unsubscribe from the information at any time with effect for the future. The chatbot informs users how and with which terms they can unsubscribe from the messages. When users unsubscribe from the chatbot messages, their data is deleted from the list of message recipients.

        We use the aforementioned information to operate our chatbot, e.g. to address users personally, to respond to their enquiries to the chatbot, to transmit any requested content and also to improve our chatbot (e.g. to "teach" it answers to frequently asked questions or to identify unanswered enquiries).

        Notes on legal bases: We use the chatbot on the basis of consent if we have previously obtained the users' permission for the processing of their data by the chatbot (this applies to cases in which users are asked for consent, e.g. so that the chatbot sends them messages regularly). Where we use the chatbot to respond to users' enquiries about our services or our company, this is done for contractual and pre-contractual communication. Otherwise, we use the chatbot on the basis of our legitimate interests in optimising the chatbot, its economic efficiency and enhancing the positive user experience.

        Withdrawal, objection and erasure: You may withdraw any consent given at any time or object to the processing of your data in the context of our use of the chatbot.

        • Types of data processed: Contact data (e.g. email, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

        • Data subjects: Communication partners, users (e.g. website visitors, users of online services).

        • Purposes of processing: Contact enquiries and communication, direct marketing (e.g. by email or post), reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest-based/behavioural profiling, use of cookies), remarketing, conversion tracking, profiling (creating user profiles), conversion measurement (measuring the effectiveness of marketing measures).

        • Legal bases: Consent (Art. 6 (1) sentence 1 (a) GDPR), legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

        Services used and service providers:

        Surveys and polls

        The surveys and polls we conduct (hereinafter "surveys") are evaluated anonymously. Personal data is processed only insofar as this is necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address in order to display the survey in the user's browser or to enable the survey to be resumed by means of a temporary cookie (session cookie)) or where users have given their consent.

        Notes on legal bases: Where we ask participants for consent to the processing of their data, this is the legal basis for the processing; otherwise the participants' data is processed on the basis of our legitimate interests in conducting an objective survey.

        • Types of data processed: Contact data (e.g. email, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

        • Data subjects: Communication partners, users (e.g. website visitors, users of online services).

        • Purposes of processing: Contact enquiries and communication, direct marketing (e.g. by email or post), tracking (e.g. interest-based/behavioural profiling, use of cookies), feedback (e.g. collecting feedback via online form).

        • Legal bases: Consent (Art. 6 (1) sentence 1 (a) GDPR), legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

        Services used and service providers:

        Provision of the online offering and web hosting

        In order to provide our online offering securely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers managed by them) the online offering can be accessed. For these purposes we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services.

        The data processed in the context of providing the hosting service may include all information relating to the users of our online offering that arises in the course of use and communication. This regularly includes the IP address, which is necessary in order to deliver the content of online offerings to browsers, and all entries made within our online offering or on websites.

        Sending and hosting of emails: The web hosting services we use also include the sending, receiving and storage of emails. For these purposes, the addresses of the recipients and senders, as well as further information relating to the sending of emails (e.g. the providers involved) and the content of the respective emails, are processed. The aforementioned data may also be processed for the purpose of detecting spam. Please note that emails are generally not sent in encrypted form on the internet. As a rule, emails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of emails between the sender and receipt on our server.

        Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user's operating system, the referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

        The server log files may be used on the one hand for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and on the other hand to ensure the utilisation of the servers and their stability.

        • Types of data processed: Content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

        • Data subjects: Users (e.g. website visitors, users of online services).

        • Legal bases: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

        Application process

        The application process requires applicants to provide us with the data necessary for their assessment and selection. Which information is required can be found in the job description or, in the case of online forms, in the details given there.

        In principle, the required details include personal information such as name, address, a means of contact and evidence of the qualifications necessary for a position. On request, we will be happy to tell you additionally which details are needed.

        Where made available, applicants may submit their applications to us by means of an online form. The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants may also send us their applications by email. Please note, however, that emails are generally not sent in encrypted form on the internet. As a rule, emails are encrypted in transit, but not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of the application between the sender and receipt on our server.

        For the purposes of searching for applicants, submitting applications and selecting applicants, we may, in compliance with the legal requirements, use applicant management or recruitment software and platforms and services of third-party providers.

        Applicants are welcome to contact us about how to submit their application or to send us the application by post.

        Processing of special categories of data: Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR (e.g. health data, such as severe disability status, or ethnic origin) are requested from applicants in the course of the application process so that the controller or the data subject can exercise the rights arising from employment law and from social security and social protection law and fulfil the related obligations, they are processed in accordance with Art. 9 (2) (b) GDPR; in the case of the protection of vital interests of applicants or other persons, in accordance with Art. 9 (2) (c) GDPR; or for the purposes of preventive health care or occupational medicine, for the assessment of the working capacity of the employee, for medical diagnosis, for the provision of care or treatment in the health or social sector or for the management of systems and services in the health or social sector, in accordance with Art. 9 (2) (h) GDPR. Where the special categories of data are communicated on the basis of voluntary consent, they are processed on the basis of Art. 9 (2) (a) GDPR.

        Erasure of data: In the event of a successful application, the data provided by applicants may be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job vacancy is not successful, the applicants' data is erased. Applicants' data is also erased if an application is withdrawn, which applicants are entitled to do at any time. Subject to a justified withdrawal by the applicants, erasure takes place at the latest after a period of six months, so that we can answer any follow-up questions about the application and meet our obligations to provide evidence under the provisions on equal treatment of applicants. Invoices for any reimbursement of travel expenses are archived in accordance with tax law requirements.

        Inclusion in an applicant pool: Inclusion in an applicant pool, where offered, is based on consent. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the current application process and that they may withdraw their consent at any time with effect for the future.

        • Types of data processed: Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained in them, such as cover letter, CV, certificates and other information about the applicant's person or qualifications provided with regard to a specific position or voluntarily by applicants).

        • Data subjects: Applicants.

        • Purposes of processing: Application process (establishment and any later performance as well as possible later termination of the employment relationship).

        • Legal bases: Art. 9 (1) sentence 1 (b) GDPR (application process as a pre-contractual or contractual relationship) (Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR (e.g. health data, such as severe disability status, or ethnic origin) are requested from applicants in the course of the application process so that the controller or the data subject can exercise the rights arising from employment law and from social security and social protection law and fulfil the related obligations, they are processed in accordance with Art. 9 (2) (b) GDPR; in the case of the protection of vital interests of applicants or other persons, in accordance with Art. 9 (2) (c) GDPR; or for the purposes of preventive health care or occupational medicine, for the assessment of the working capacity of the employee, for medical diagnosis, for the provision of care or treatment in the health or social sector or for the management of systems and services in the health or social sector, in accordance with Art. 9 (2) (h) GDPR. Where special categories of data are communicated on the basis of voluntary consent, they are processed on the basis of Art. 9 (2) (a) GDPR.).

        Cloud services

        We use software services that are accessible via the internet and run on the servers of their providers (so-called "cloud services", also referred to as "software as a service") for the following purposes: document storage and management, calendar management, sending emails, spreadsheets and presentations, exchanging documents, content and information with certain recipients or publishing web pages, forms or other content and information, as well as chats and participation in audio and video conferences.

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

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

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

        • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

        • Data subjects: Customers, employees (e.g. staff, applicants, former employees), prospective customers, communication partners.

        • Purposes of processing: Office and organisational procedures.

        • Legal bases: Consent (Art. 6 (1) sentence 1 (a) GDPR), performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 (b) GDPR), legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

        Services used and service providers:

        Newsletters and mass communication

        We send newsletters, emails and other electronic notifications (hereinafter "newsletter") only with the consent of the recipients or on the basis of statutory permission. Where the content of the newsletter is specifically described when subscribing, it is decisive for the users' consent. Otherwise, our newsletters contain information about our services and about us.

        To subscribe to our newsletters, it is in principle sufficient to provide your email address. However, we may ask you to provide a name, so that we can address you personally in the newsletter, or further details where these are necessary for the purposes of the newsletter.

        Double opt-in procedure: Subscription to our newsletter generally takes place in a so-called double opt-in procedure. This means that after subscribing you will receive an email asking you to confirm your subscription. This confirmation is necessary so that nobody can subscribe with someone else's email address. Subscriptions to the newsletter are logged in order to be able to prove the subscription process in accordance with legal requirements. This includes storing the time of subscription and of confirmation as well as the IP address. Changes to your data stored with the mailing service provider are also logged.

        Erasure and restriction of processing: We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before erasing them, in order to be able to prove consent previously given. The processing of this data is restricted to the purpose of a possible defence against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to observe objections permanently, we reserve the right to store the email address in a blocklist (so-called "blacklist") for this purpose alone.

        The subscription procedure is logged on the basis of our legitimate interests for the purpose of proving that it was carried out properly. Where we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure mailing system.

        Notes on legal bases: The newsletter is sent on the basis of the recipients' consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and insofar as this is permitted by law, e.g. in the case of advertising to existing customers. Where we commission a service provider to send emails, this is done on the basis of our legitimate interests. The registration procedure is recorded on the basis of our legitimate interests in order to prove that it was carried out in accordance with the law.

        Content: Information about us, our services, promotions and offers.

        Performance measurement: The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a mailing service provider, from that provider's server. In the course of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, is initially collected.

        This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined using the IP address) or access times. This analysis also includes 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, it is neither our aim nor, where used, that of the mailing service provider to observe individual users. Rather, the evaluations serve to help us recognise the reading habits of our users and to adapt our content to them or to send different content in line with the interests of our users.

        The evaluation of the newsletter and the performance measurement take place, subject to the express consent of the users, on the basis of our legitimate interests for the purposes of using a user-friendly and secure newsletter system that serves both our business interests and the expectations of users.

        Unfortunately, it is not possible to withdraw from performance measurement separately; in this case the entire newsletter subscription must be cancelled or objected to.

        Prerequisite for the use of free services: Consent to the sending of mailings may be made a prerequisite for the use of free services (e.g. access to certain content or participation in certain promotions). If users wish to use the free service without subscribing to the newsletter, we ask you to contact us.

        Sending via SMS: Our communications are (also) sent via SMS text messages.

        • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).

        • Data subjects: Communication partners, users (e.g. website visitors, users of online services).

        • Purposes of processing: Direct marketing (e.g. by email or post), contractual services and support, contact enquiries and communication.

        • Legal bases: Consent (Art. 6 (1) sentence 1 (a) GDPR), legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

        • Opt-out: You can cancel receipt of our newsletter at any time, i.e. withdraw your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter, or you can otherwise use one of the contact options stated above, preferably email, for this purpose.

        Services used and service providers:

        Promotional communication by post, fax or telephone

        We process personal data for the purposes of promotional communication, which may take place via various channels such as email, telephone, post or fax. In this context we comply with the legal requirements and obtain the necessary consent, unless the communication is permitted by law.

        Recipients have the right to withdraw any consent given at any time or to object to promotional communication at any time.

        After withdrawal or objection, we may store the data required to prove consent for up to three years on the basis of our legitimate interests before erasing it. The processing of this data is restricted to the purpose of a possible defence against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time.

        • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers).

        • Data subjects: Communication partners.

        • Purposes of processing: Direct marketing (e.g. by email or post).

        • Legal bases: Consent (Art. 6 (1) sentence 1 (a) GDPR), legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

        Prize draws and competitions

        We process the personal data of participants in prize draws and competitions only in compliance with the relevant data protection provisions, insofar as the processing is contractually necessary for the provision, running and handling of the prize draw, the participants have consented to the processing or the processing serves our legitimate interests (e.g. in the security of the prize draw or the protection of our interests against misuse by possibly recording IP addresses when entries are submitted).

        If entries by participants are published as part of the prize draws (e.g. in the context of a vote or presentation of the entries or the winners, or reporting on the prize draw), we point out that the names of the participants may also be published in this context. Participants may object to this at any time.

        If the prize draw takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as the "online platform"), the terms of use and privacy provisions of the respective platforms also apply. In these cases we point out that we are responsible for the information provided by participants in the context of the prize draw and that enquiries regarding the prize draw should be addressed to us.

        The participants' data is erased as soon as the prize draw or competition has ended and the data is no longer required to inform the winners or because queries about the prize draw are no longer to be expected. In principle, the participants' data is erased no later than 6 months after the end of the prize draw. Winners' data may be retained for longer, e.g. in order to answer queries about the prizes or to provide the prizes; in this case the retention period depends on the type of prize and is, for example, up to three years in the case of goods or services, e.g. in order to handle warranty cases. Furthermore, the participants' data may be stored for longer, e.g. in the form of reporting on the prize draw in online and offline media.

        Where data was also collected for other purposes in the context of the prize draw, its processing and the retention period are governed by the privacy notices relating to that use (e.g. in the case of subscribing to the newsletter as part of a prize draw).

        • Types of data processed: Inventory data (e.g. names, addresses), content data (e.g. text entries, photographs, videos).

        • Data subjects: Participants in prize draws and competitions.

        • Purposes of processing: Running prize draws and competitions.

        • Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 (b) GDPR).

        Web analytics and optimisation

        Web analytics (also referred to as "reach measurement") serves to evaluate the flows of visitors to our online offering and may include behaviour, interests or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of reach analysis we can, for example, recognise at what time our online offering or its functions or content are used most frequently or invite repeat use. We can also understand which areas need optimising.

        In addition to web analytics, we may also use test procedures, e.g. to test and optimise different versions of our online offering or its components.

        For these purposes, so-called user profiles may be created and stored in a file (a so-called "cookie"), or similar procedures with the same purpose may be used. This information may include, for example, content viewed, websites visited and elements used there, and technical details such as the browser used, the computer system used and information on times of use. Where users have consented to the collection of their location data, this may also be processed, depending on the provider.

        The IP addresses of users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by truncating the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored in the context of web analytics, A/B testing and optimisation, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

        Notes on legal bases: Where we ask users for their consent to the use of the third-party providers, the legal basis for the processing of data is consent. Otherwise, the users' data is processed on the basis of our legitimate interests (i.e. an interest in efficient, economical and recipient-friendly services). In this context we would also like to draw your attention to the information on the use of cookies in this privacy policy.

        • Types of data processed: Usage data (e.g. websites visited, interest in content, access times).

        • Data subjects: Users (e.g. website visitors, users of online services).

        • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest-based/behavioural profiling, use of cookies), conversion tracking, profiling (creating user profiles), interest-based and behavioural marketing.

        • Security measures: IP masking (pseudonymisation of the IP address).

        • Legal bases: Consent (Art. 6 (1) sentence 1 (a) GDPR), legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

        Services used and service providers:

        Online marketing

        We process personal data for the purposes of online marketing, which may include in particular the marketing of advertising space or the display of advertising and other content (collectively referred to as "content") based on the potential interests of users, as well as measuring its effectiveness.

        For these purposes, so-called user profiles are created and stored in a file (a so-called "cookie"), or similar procedures are used, by means of which the information about the user that is relevant for the display of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical details such as the browser used, the computer system used and information on times of use. Where users have consented to the collection of their location data, this may also be processed.

        The IP addresses of users are also stored. However, we use available IP masking procedures (i.e. pseudonymisation by truncating the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored in the context of the online marketing procedure, but pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual identity of the users, but only the information stored in their profiles.

        The information in the profiles is generally stored in the cookies or by means of similar procedures. These cookies can generally also be read later on other websites that use the same online marketing procedure, analysed for the purposes of displaying content, supplemented with further data and stored on the server of the provider of the online marketing procedure.

        By way of exception, clear data may be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing procedure we use and the network links the users' profiles with the aforementioned information. Please note that users may make additional agreements with the providers, e.g. by giving consent during registration.

        In principle, we only receive access to summarised information about the success of our advertisements. However, in the context of so-called conversion measurement, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. Conversion measurement is used solely to analyse the success of our marketing measures.

        Unless otherwise stated, please assume that the cookies used are stored for a period of two years.

        Notes on legal bases: Where we ask users for their consent to the use of the third-party providers, the legal basis for the processing of data is consent. Otherwise, the users' data is processed on the basis of our legitimate interests (i.e. an interest in efficient, economical and recipient-friendly services). In this context we would also like to draw your attention to the information on the use of cookies in this privacy policy.

        Target group formation with Google Analytics: We use Google Analytics in order to display the advertisements placed within the advertising services of Google and its partners 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) which we transmit to Google (so-called "remarketing audiences" or "Google Analytics audiences"). With the help of remarketing audiences we also want to ensure that our advertisements match the potential interest of the users

        Google Universal Analytics: We use Google Analytics in the form of Universal Analytics (https://support.google.com/analytics/answer/2790010?hl=de&ref_topic=6010376). "Universal Analytics" refers to a Google Analytics procedure in which the user analysis is carried out on the basis of a pseudonymous user ID, thereby creating a pseudonymous profile of the user with information from the use of different devices (so-called "cross-device tracking").

        Facebook pixel: With the help of the Facebook pixel, Facebook is able, on the one hand, to determine the visitors to our online offering as a target group for the display of advertisements (so-called "Facebook ads"). Accordingly, we use the Facebook pixel in order to display the Facebook ads placed by us only to those users on Facebook and within the services of the partners cooperating with Facebook (the so-called "Audience Network" https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offering or who have certain characteristics (e.g. interest in certain topics or products apparent from the websites visited) which we transmit to Facebook (so-called "custom audiences"). With the help of the Facebook pixel we also want to ensure that our Facebook ads match the potential interest of the users and are not a nuisance. With the help of the Facebook pixel we can also track the effectiveness of the Facebook advertisements for statistical and market research purposes by seeing whether users were forwarded to our website after clicking on a Facebook advertisement (so-called "conversion measurement").

        Advanced matching for the Facebook pixel: When the Facebook pixel is used, the additional function "advanced matching" is used. In this context, data such as email addresses or Facebook IDs of users is transmitted to Facebook (in encrypted form) in order to form target groups.

        Facebook - target group formation via data upload: Uploading of data, such as telephone numbers, email addresses or Facebook IDs, to the Facebook platform. The data is encrypted in the process. The upload serves only to display advertisements to the owners of the data or to persons whose user profiles correspond to any user profiles of the owners of the data on Facebook. In this way we want to ensure that the advertisements are displayed only to users who have an interest in our information and services.

        • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (data indicating the location of an end user's device), social data (data that is subject to social secrecy (Section 35 of the German Social Code, Book I) and is processed, for example, by social insurance institutions, social welfare agencies or pension authorities).

        • Data subjects: Users (e.g. website visitors, users of online services), prospective customers, customers, employees (e.g. staff, applicants, former employees), communication partners.

        • Purposes of processing: Tracking (e.g. interest-based/behavioural profiling, use of cookies), remarketing, conversion tracking, interest-based and behavioural marketing, profiling (creating user profiles), conversion measurement (measuring the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors), cross-device tracking (processing of user data across devices for marketing purposes), target group formation (determining target groups relevant for marketing purposes or other delivery of content), click tracking, direct marketing (e.g. by email or post).

        • Security measures: IP masking (pseudonymisation of the IP address).

        • Legal bases: Consent (Art. 6 (1) sentence 1 (a) GDPR), legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

        • Opt-out: We refer to the privacy notices of the respective providers and the opt-out options stated for the providers. Where no explicit opt-out option has been stated, you can, on the one hand, switch off cookies in your browser settings. However, this may restrict functions of our online offering. We therefore additionally recommend the following opt-out options, which are offered collectively for the respective regions: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-regional: http://optout.aboutads.info.

        Services used and service providers:

        Affiliate programme

        We offer an affiliate programme, i.e. commissions or other benefits (collectively referred to as "commission") for users (referred to as "affiliates") who refer to our offers and services. The referral is made by means of a link assigned to the respective affiliate or other methods (e.g. discount codes) that allow us to recognise that the use of our services was based on the referral (collectively referred to as "affiliate links").

        In order to be able to track whether users have made use of our services on the basis of the affiliate links used by the affiliates, it is necessary for us to learn that the users followed an affiliate link. The assignment of the affiliate links to the respective business transactions or to other use of our services serves solely the purpose of commission accounting and is cancelled as soon as it is no longer required for that purpose.

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

        Notes on legal bases: Where we ask users for their consent to the use of the third-party providers, the legal basis for the processing of data is consent. Furthermore, their use may be a component of our (pre-)contractual services, provided that the use of the third-party providers has been agreed in this context. Otherwise, the users' data is processed on the basis of our legitimate interests (i.e. an interest in efficient, economical and recipient-friendly services). In this context we would also like to draw your attention to the information on the use of cookies in this privacy policy.

        • Types of data processed: Contract data (e.g. subject matter of the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times).

        • Data subjects: Users (e.g. website visitors, users of online services), business and contractual partners.

        • Purposes of processing: Contractual services and support, affiliate tracking.

        • Legal bases: Consent (Art. 6 (1) sentence 1 (a) GDPR), performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 (b) GDPR), legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

        Review platforms

        We take part in review procedures in order to evaluate, optimise and advertise our services. If users rate us via the participating review platforms or procedures or otherwise give feedback, the general terms and conditions or terms of use and the privacy notices of the providers also apply. As a rule, a review also requires registration with the respective provider.

        In order to ensure that the persons submitting reviews have actually used our services, we transmit, with the customers' consent, the data required for this purpose regarding the customer and the service used to the respective review platform (including name, email address and order number or item number). This data is used solely to verify the authenticity of the user.

        Review widget: We integrate so-called "review widgets" into our online offering. A widget is a functional and content element integrated into our online offering that displays variable information. It may, for example, be displayed in the form of a seal or comparable element, sometimes also called a "badge". Although the corresponding content of the widget is displayed within our online offering, it is retrieved at that moment from the servers of the respective widget provider. Only in this way can the current content always be shown, above all the current rating. For this purpose, a data connection must be established from the web page accessed within our online offering to the server of the widget provider, and the widget provider receives certain technical data (access data, including IP address) that is necessary for the content of the widget to be delivered to the user's browser.

        Furthermore, the widget provider receives information that users have visited our online offering. This information may be stored in a cookie and used by the widget provider to recognise which online offerings participating in the review procedure have been visited by the user. The information may be stored in a user profile and used for advertising or market research purposes.

        • Types of data processed: Contract data (e.g. subject matter of the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

        • Data subjects: Customers, users (e.g. website visitors, users of online services).

        • Purposes of processing: Feedback (e.g. collecting feedback via online form), reach measurement (e.g. access statistics, recognition of returning visitors), conversion tracking, interest-based and behavioural marketing, profiling (creating user profiles).

        • Legal bases: Consent (Art. 6 (1) sentence 1 (a) GDPR), legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

        Presences on social networks

        We maintain online presences within social networks in order to communicate with the users active there or to offer information about us there.

        We point out that user data may be processed outside the European Union in this context. This may result in risks for users, for example because it could make it more difficult to enforce users' rights. With regard to US providers that are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we point out that they thereby undertake to comply with EU data protection standards.

        Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles may be created on the basis of user behaviour and the resulting interests of users. The usage profiles may in turn be used, for example, to place advertisements inside and outside the networks that presumably match the interests of the users. For these purposes, cookies are generally stored on the users' computers, in which the usage behaviour and interests of the users are stored. Furthermore, data may also be stored in the usage profiles independently of the devices used by the users (in particular if the users are members of the respective platforms and are logged in to them).

        For a detailed description of the respective forms of processing and the opt-out options, we refer to the privacy policies and information provided by the operators of the respective networks.

        In the case of requests for information and the assertion of data subject rights, we also point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can take appropriate measures and provide information directly. Should you nevertheless need help, you can contact us.

        • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

        • Data subjects: Users (e.g. website visitors, users of online services).

        • Purposes of processing: Contact enquiries and communication, tracking (e.g. interest-based/behavioural profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).

        • Legal bases: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

        Services used and service providers:

        Plugins and embedded functions and content

        We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may be, for example, graphics, videos or social media buttons as well as posts (hereinafter uniformly referred to as "content").

        The integration always requires that the third-party providers of this content process the IP address of the users, since without the IP address they could not send the content to their browsers. The IP address is therefore required for the display of this content or these functions. We endeavour to use only content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the users' device and may contain, among other things, technical information on the browser and operating system, referring websites, the time of the visit and other details on the use of our online offering, and may also be combined with such information from other sources.

        Notes on legal bases: Where we ask users for their consent to the use of the third-party providers, the legal basis for the processing of data is consent. Otherwise, the users' data is processed on the basis of our legitimate interests (i.e. an interest in efficient, economical and recipient-friendly services). In this context we would also like to draw your attention to the information on the use of cookies in this privacy policy.

        • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), contact data (e.g. email, telephone numbers), content data (e.g. text entries, photographs, videos), inventory data (e.g. names, addresses).

        • Data subjects: Users (e.g. website visitors, users of online services), communication partners.

        • Purposes of processing: Provision of our online offering and user-friendliness, contractual services and support, contact enquiries and communication, direct marketing (e.g. by email or post), tracking (e.g. interest-based/behavioural profiling, use of cookies), interest-based and behavioural marketing, profiling (creating user profiles), security measures, managing and responding to enquiries.

        • Legal bases: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR), consent (Art. 6 (1) sentence 1 (a) GDPR), performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 (b) GDPR).

        Services used and service providers:

        Planning, organisation and tools

        We use services, platforms and software of other providers (hereinafter referred to as "third-party providers") for the purposes of organising, managing, planning and providing our services. When selecting the third-party providers and their services, we comply with the legal requirements.

        In this context, personal data may be processed and stored on the servers of the third-party providers. This may affect various data that we process in accordance with this privacy policy. This data may include in particular master data and contact data of users, data on transactions, contracts, other processes and their content.

        Where users are referred to the third-party providers or their software or platforms in the context of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, for service optimisation or for marketing purposes. We therefore ask you to note the privacy notices of the respective third-party providers.

        Notes on legal bases: Where we ask users for their consent to the use of the third-party providers, the legal basis for the processing of data is consent. Furthermore, their use may be a component of our (pre-)contractual services, provided that the use of the third-party providers has been agreed in this context. Otherwise, the users' data is processed on the basis of our legitimate interests (i.e. an interest in efficient, economical and recipient-friendly services). In this context we would also like to draw your attention to the information on the use of cookies in this privacy policy.

        • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

        • Data subjects: Communication partners, users (e.g. website visitors, users of online services).

        • Legal bases: Consent (Art. 6 (1) sentence 1 (a) GDPR), performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 (b) GDPR), legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

        Erasure of data

        The data processed by us is erased in accordance with the legal requirements as soon as the consent permitting its processing is withdrawn or other permissions cease to apply (e.g. if the purpose of processing this data no longer applies or the data is not required for the purpose).

        Where the data is not erased because it is required for other, legally permissible purposes, its processing is restricted to those purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.

        Further information on the erasure of personal data may also be given in the individual privacy notices of this privacy policy.

          Changes and updates to the privacy policy

          We ask you to inform yourself regularly about the content of our privacy policy. We adapt the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

          Where we provide addresses and contact information of companies and organisations in this privacy policy, please note that the addresses may change over time, and please check the details before contacting them.

          Rights of data subjects

          As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 18 and 21 GDPR:

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

          Definitions of terms

          This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined above all in Art. 4 GDPR. The statutory definitions are binding. The following explanations, by contrast, are intended above all to aid understanding. The terms are sorted alphabetically according to the German original.

          • Affiliate tracking: In affiliate tracking, links with which the linking websites refer users to websites with product or other offers are logged. The operators of the linking websites may receive a commission if users follow these so-called affiliate links and then take up the offers (e.g. buy goods or use services). For this purpose, the providers need to be able to track whether users who are interested in certain offers subsequently take them up at the instigation of the affiliate links. For affiliate links to function, it is therefore necessary that they are supplemented with certain values that become part of the link or are stored elsewhere, e.g. in a cookie. The values include in particular the source website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, and tracking-specific values such as advertising material ID, partner ID and categorisations.
          • Conversion tracking: "Conversion tracking" refers to a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is generally stored on the users' devices within the websites on which the marketing measures take place and then retrieved again on the target website. In this way we can, for example, track whether the advertisements placed by us on other websites were successful).
          • Cross-device tracking: Cross-device tracking is a form of tracking in which behavioural and interest information of users is recorded across devices in so-called profiles by assigning an online identifier to the users. In this way the user information can generally be analysed for marketing purposes regardless of the browsers or devices used (e.g. mobile phones or desktop computers). With most providers, the online identifier is not linked to clear data such as names, postal addresses or email addresses.
          • IP masking: "IP masking" refers to a method in which the last octet, i.e. the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymising processing procedures, particularly in online marketing
          • Interest-based and behavioural marketing: Interest-based and/or behavioural marketing is when the potential interests of users in advertisements and other content are predicted as precisely as possible. This is done on the basis of information on their previous behaviour (e.g. visiting and staying on certain websites, purchasing behaviour or interaction with other users), which is stored in a so-called profile. Cookies are generally used for these purposes.
          • Click tracking: Click tracking makes it possible to keep track of users' movements within an entire online offering. Since the results of these tests are more accurate if the interaction of users can be tracked over a certain period of time (e.g. so that we can find out whether a user likes to return), cookies are generally stored on the users' computers for these test purposes.
          • Conversion measurement: Conversion measurement is a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is generally stored on the users' devices within the websites on which the marketing measures take place and then retrieved again on the target website. In this way we can, for example, track whether the advertisements placed by us on other websites were successful.
          • Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
          • Profiling: "Profiling" means any form of automated processing of personal data consisting of the use of such personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this includes information concerning age, gender, location data and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people), e.g. interests in certain content or products, click behaviour on a website or location. Cookies and web beacons are frequently used for profiling purposes.
          • Reach measurement: Reach measurement (also referred to as web analytics) serves to evaluate the flows of visitors to an online offering and may include the behaviour or interests of visitors in certain information, such as website content. With the help of reach analysis, website owners can, for example, recognise at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. Pseudonymous cookies and web beacons are frequently used for reach analysis purposes in order to recognise returning visitors and thus obtain more precise analyses of the use of an online offering.
          • Remarketing: "Remarketing" or "retargeting" is when, for example, a record is made for advertising purposes of which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
          • Tracking: "Tracking" is when the behaviour of users can be traced across several online offerings. As a rule, behavioural and interest information with regard to the online offerings used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can subsequently be used, for example, to display advertisements to users that are likely to match their interests.
          • Controller: 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.
          • Processing: "Processing" means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it collecting, evaluating, storing, transmitting or erasing.
          • Target group formation: Target group formation (or "custom audiences") is when target groups are determined for advertising purposes, e.g. the display of advertisements. For example, on the basis of a user's interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which they viewed the products. "Lookalike audiences" (or similar target groups), in turn, is when the content considered suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used for the purposes of forming custom audiences and lookalike audiences.