Privacy Policy
Understand, how we process your data.
Privacy Policy Introduction and Overview
We have written this privacy policy (version 08.09.2022-311946593) in order to explain to you, in accordance with the provisions of the General Data Protection Regulation (EU) 2016/679 and applicable national laws, which personal data (data for short) we as the controller – and the processors commissioned by us (e.g. providers) – process, will process in the future and what legal options you have. The terms used are to be considered gender-neutral.
In short: We provide you with comprehensive information about any of your personal data we process.
Privacy policies usually sound very technical and use legal terminology. However, this privacy policy is intended to describe the most important things to you as simply and transparently as possible. So long as it aids transparency, technical terms are explained in a reader-friendly manner, links to further information are provided and graphics are used. We are thus informing in clear and simple language that we only process personal data in the context of our business activities if there is a legal basis for it. This is certainly not possible with brief, unclear and legal-technical statements, as is often standard on the internet when it comes to data protection. I hope you find the following explanations interesting and informative. Maybe you will also find some information that you have not been familiar with.
If you still have questions, we kindly ask you to contact the responsible body named below or in the imprint, follow the existing links and look at further information on third-party sites. You can of course also find our contact details in the imprint.
Scope
This privacy policy applies to all personal data processed by our company and to all personal data processed by companies commissioned by us (processors). With the term personal data, we refer to information within the meaning of Article 4 No. 1 GDPR, such as the name, email address and postal address of a person. The processing of personal data ensures that we can offer and invoice our services and products, be it online or offline. The scope of this privacy policy includes:
all online presences (websites, online shops) that we operate Social media presences and email communication
mobile apps for smartphones and other devices
In short: This privacy policy applies to all areas in which personal data is processed in a structured manner by the company via the channels mentioned. Should we enter into legal relations with you outside of these channels, we will inform you separately if necessary.
Legal bases
In the following privacy policy, we provide you with transparent information on the legal principles and regulations, i.e. the legal bases of the General Data Protection Regulation, which enable us to process personal data.
Whenever EU law is concerned, we refer to REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016. You can of course access the General Data Protection Regulation of the EU online at EUR-Lex, the gateway to EU law, at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679.
We only process your data if at least one of the following conditions applies:
- Consent (Article 6 Paragraph 1 lit. a GDPR): You have given us your consent to process data for a specific purpose. An example would be the storage of data you entered into a contact form.
- Contract (Article 6 Paragraph 1 lit. b GDPR): We process your data in order to fulfill a contract or pre-contractual obligations with you. For example, if we conclude a sales contract with you, we need personal information in advance.
- Legal obligation (Article 6 Paragraph 1 lit. c GDPR): If we are subject to a legal obligation, we will process your data. For example, we are legally required to keep invoices for our bookkeeping. These usually contain personal data.
- Legitimate interests (Article 6 Paragraph 1 lit. f GDPR): In the case of legitimate interests that do not restrict your basic rights, we reserve the right to process personal data. For example, we have to process certain data in order to be able to operate our website securely and economically. Therefore, the processing is a legitimate interest.
Other conditions such as making recordings in the interest of the public, the exercise of official authority as well as the protection of vital interests do not usually occur with us. Should such a legal basis be relevant, it will be disclosed in the appropriate place.
In addition to the EU regulation, national laws also apply:
In Austria this is the Austrian Data Protection Act (Datenschutzgesetz), in short DSG.
In Germany this is the Federal Data Protection Act (Bundesdatenschutzgesetz), in short BDSG.
Should other regional or national laws apply, we will inform you about them in the following sections.
Contact details of our data protection officer
You can find the contact details of our data protection officer below: E-Mail: datenschutzbeauftragter@datenschutzexperte.de
Phone: +49 89250 039 220
Storage Period
It is a general criterion for us to store personal data only for as long as is absolutely necessary for the provision of our services and products. This means that we delete personal data as soon as any reason for the data processing no longer exists. In some cases, we are legally obliged to keep certain data stored even after the original purpose no longer exists, such as for accounting purposes.
If you want your data to be deleted or if you want to revoke your consent to data processing, the data will be deleted as soon as possible, provided there is no obligation to continue its storage.
We will inform you below about the specific duration of the respective data processing, provided we have further information.
Rights in accordance with the General Data Protection Regulation
In accordance with Articles 13, 14 of the GDPR, we inform you about the following rights you have to ensure fair and transparent processing of data:
According to Article 15 DSGVO, you have the right to information about whether we are processing data about you. If this is the case, you have the right to receive a copy of the data and to know the following information:
for what purpose we are processing; the categories, i.e. the types of data that are processed; who receives this data and if the data is transferred to third countries, how security can be guaranteed; how long the data will be stored;
the existence of the right to rectification, erasure or restriction of processing and the right to object to processing;
that you can lodge a complaint with a supervisory authority (links to these authorities can be found below);
the origin of the data if we have not collected it from you; Whether profiling is carried out, i.e. whether data is automatically evaluated to arrive at a personal profile of you.
You have a right to rectification of data according to Article 16 GDPR, which means that we must correct data if you find errors.
You have the right to erasure (“right to be forgotten”) according to Article 17 GDPR, which specifically means that you may request the deletion of your data.
According to Article 18 of the GDPR, you have the right to restriction of processing, which means that we may only store the data but not use it further.
According to Article 20 of the GDPR, you have the right to data portability, which means that we will provide you with your data in a standard format upon request.
According to Article 21 DSGVO, you have the right to object, which entails a change in processing after enforcement.
If the processing of your data is based on Article 6(1)(e) (public interest, exercise of official authority) or Article 6(1)(f) (legitimate interest), you may object to the processing. We will then check as soon as possible whether we can legally comply with this objection.
If data is used to conduct direct advertising, you may object to this type of data processing at any time. We may then no longer use your data for direct marketing.
If data is used to conduct profiling, you may object to this type of data processing at any time. We may no longer use your data for profiling thereafter.
According to Article 22 of the GDPR, you may have the right not to be subject to a decision based solely on automated processing (for example, profiling).
You have the right to lodge a complaint under Article 77 of the GDPR. This means that you can complain to the data protection authority at any time if you believe that the data processing of personal data violates the GDPR.
In short: you have rights – do not hesitate to contact the responsible party listed above with us!
If you believe that the processing of your data violates data protection law or your data protection rights have been violated in any other way, you can complain to the supervisory authority. For Austria, this is the data protection authority, whose website can be found at https://www.dsb.gv.at/. In Germany, there is a data protection officer for each federal state. For more information, you can contact the Federal Commissioner for Data Protection and Freedom of Information (BfDI). The following local data protection authority is responsible for our company:
Security of data processing operations
In order to protect personal data, we have implemented both technical and organisational
measures. We encrypt or pseudonymise personal data wherever this is possible. Thus, we make it as difficult as we can for third parties to extract personal information from our data.
Article 25 of the GDPR refers to “data protection by technical design and by data protection-friendly default” which means that both software (e.g. forms) and hardware (e.g. access to server rooms) appropriate safeguards and security measures shall always be placed. If applicable, we will outline the specific measures below.
TLS encryption with https
The terms TLS, encryption and https sound very technical, which they are indeed. We use HTTPS (Hypertext Transfer Protocol Secure) to securely transfer data on the Internet.
This means that the entire transmission of all data from your browser to our web server is secured – nobody can “listen in”.
We have thus introduced an additional layer of security and meet privacy requirements through technology design Article 25 Section 1 GDPR). With the use of TLS (Transport Layer Security), which is an encryption protocol for safe data transfer on the internet, we can ensure the protection of confidential information.
You can recognise the use of this safeguarding tool by the little lock-symbol , which is situated in your browser’s top left corner in the left of the internet address (e.g. examplepage.uk), as well as by the display of the letters https (instead of http) as a part of our web address.
If you want to know more about encryption, we recommend you to do a Google search for “Hypertext Transfer Protocol Secure wiki” to find good links to further information.
Communications
Communications Overview
Affected parties: Anyone who communicates with us via phone, email or online form Processed data: e. g. telephone number, name, email address or data entered in forms. You can find more details on this under the respective form of contact
Purpose: handling communication with customers, business partners, etc.
Storage duration: for the duration of the business case and the legal requirements
Legal basis: Article 6 (1) (a) GDPR (consent), Article 6 (1) (b) GDPR (contract), Article 6 (1) (f) GDPR (legitimate interests)
If you contact us and communicate with us via phone, email or online form, your personal data may be processed.
The data will be processed for handling and processing your request and for the related business transaction. The data is stored for this period of time or for as long as is legally required.
Affected persons
The above-mentioned processes affect all those who seek contact with us via the communication channels we provide.
Telephone
When you call us, the call data is stored in a pseudonymised form on the respective terminal device, as well as by the telecommunications provider that is being used. In addition, data such as your name and telephone number may be sent via email and stored for answering your inquiries. The data will be erased as soon as the business case has ended and the legal requirements allow for its erasure.
If you communicate with us via email, your data is stored on the respective terminal device (computer, laptop, smartphone, ...) as well as on the email server. The data will be deleted as soon as the business case has ended and the legal requirements allow for its erasure.
Online forms
If you communicate with us using an online form, your data is stored on our web server and, if necessary, forwarded to our email address. The data will be erased as soon as the business case has ended and the legal requirements allow for its erasure.
Legal bases
Data processing is based on the following legal bases:
Art. 6 para. 1 lit. a GDPR (consent): You give us your consent to store your data and to continue to use it for the purposes of the business case;
Art. 6 para. 1 lit. b GDPR (contract): For the performance of a contract with you or a processor such as a telephone provider, or if we have to process the data for pre-contractual activities, such as preparing an offer;
Art. 6 para. 1 lit. f GDPR (legitimate interests): We want to conduct our customer inquiries and business communication in a professional manner. Thus, certain technical facilities such email programs, Exchange servers and mobile network operators are necessary to efficiently operate our communications.
Cookies
Cookies Overview
Affected parties: visitors to the website
Purpose: depending on the respective cookie. You can find out more details below or from the software manufacturer that sets the cookie.
Processed data: depends on the cookie used. More details can be found below or from the manufacturer of the software that sets the cookie.
Storage duration: can vary from hours to years, depending on the respective cookie
Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)
What are cookies?
Our website uses HTTP-cookies to store user-specific data.
In the following we explain what cookies are and why they are used, so that you can better understand the following privacy policy.
Whenever you surf the Internet, you are using a browser. Common browsers are for example, Chrome, Safari, Firefox, Internet Explorer and Microsoft Edge. Most websites store small text-files in your browser. These files are called cookies.
It is important to note that cookies are very useful little helpers. Almost every website uses cookies. More precisely, these are HTTP cookies, as there are also other cookies for other uses. HTTP cookies are small files that our website stores on your computer. These cookie files are automatically placed into the cookie-folder, which is the “brain” of your browser. A cookie consists of a name and a value. Moreover, to define a cookie, one or multiple attributes must be specified.
Cookies store certain user data about you, such as language or personal page settings. When you re-open our website to visit again, your browser submits these “user-related” information back to our site. Thanks to cookies, our website knows who you are and offers you the settings you are familiar to. In some browsers, each cookie has its own file, while in others, such as Firefox, all cookies are stored in one single file.
The following graphic shows a possible interaction between a web browser such as Chrome and the web server. The web browser requests a website and receives a cookie back from the server. The browser then uses this again as soon as another page is requested.
There are both first-party cookies and third-party cookies. First-party cookies are created directly by our site, while third-party cookies are created by partner-websites (e.g. Google Analytics). Each cookie must be evaluated individually, as each cookie stores different data. The expiry time of a cookie also varies from a few minutes to a few years. Cookies are not software programs and do not contain viruses, trojans or other malware. Cookies also cannot access your PC’s information.
This is an example of how cookie-files can look:
Name: _ga
Value: GA1.2.1326744211.152311946593-9 Purpose: Differentiation between website visitors Expiry date: after 2 years
A browser should support these minimum sizes:
At least 4096 bytes per cookie At least 50 cookies per domain At least 3000 cookies in total
Which types of cookies are there?
The exact cookies that we use, depend on the used services, which will be outlined in the following sections of this privacy policy. Firstly, we will briefly focus on the different types of HTTP-cookies.
There are 4 different types of cookies:
Essential cookies
These cookies are necessary to ensure the basic functions of a website. They are needed when a user for example puts a product into their shopping cart, then continues surfing on different websites and comes back later in order to proceed to the checkout. These cookies ensure the shopping cart does not get deleted, even if the user closes their browser window.
Purposive cookies
These cookies collect information about user behaviour and whether the user receives any error messages. Furthermore, these cookies record the website’s loading time as well as its behaviour in different browsers.
Target-orientated cookies
These cookies ensure better user-friendliness. Thus, information such as previously entered locations, fonts sizes or data in forms stay stored.
Advertising cookies
These cookies are also known as targeting cookies. They serve the purpose of delivering customised advertisements to the user. This can be very practical, but also rather annoying.
Upon your first visit to a website you are usually asked which of these cookie-types you want to accept. Furthermore, this decision will of course also be stored in a cookie.
If you want to learn more about cookies and do not mind technical documentation, we recommend https://tools.ietf.org/html/rfc6265, the Request for Comments of the Internet Engineering Task Force (IETF) called “HTTP State Management Mechanism”.
Purpose of processing via cookies
The purpose ultimately depends on the respective cookie. You can find out more details below or from the software manufacturer that sets the cookie.
Which data are processed?
Cookies are little helpers for a wide variety of tasks. Unfortunately, it is not possible to tell which data is generally stored in cookies, but in the privacy policy below we will inform you on what data is processed or stored.
Storage period of cookies
The storage period depends on the respective cookie and is further specified below. Some cookies are erased after less than an hour, while others can remain on a computer for several years.
You can also influence the storage duration yourself. You can manually erase all cookies at any time in your browser (also see “Right of objection” below). Furthermore, the latest instance cookies based on consent will be erased is after you withdraw your consent. The legality of storage will remain unaffected until then.
Right of objection – how can I erase cookies?
You can decide for yourself how and whether you want to use cookies. Regardless of which service or website the cookies originate from, you always have the option of erasing, deactivating or only partially accepting cookies. You can for example block third-party cookies but allow all other cookies.
If you want to find out which cookies have been stored in your browser, or if you want to change or erase cookie settings, you can find this option in your browser settings:
Chrome: Clear, enable and manage cookies in Chrome Safari: Manage cookies and website data in Safari Firefox: Clear cookies and site data in Firefox
Internet Explorer: Delete and manage cookies Microsoft Edge: Delete cookies in Microsoft Edge
If you generally do not want cookies, you can set up your browser in a way to notify you whenever a cookie is about to be set. This gives you the opportunity to manually decide to either permit or deny the placement of every single cookie. This procedure varies depending on the browser. Therefore, it might be best for you to search for the instructions in Google. If you are using Chrome, you could for example put the search term “delete cookies Chrome” or “deactivate cookies Chrome” into Google.
Legal basis
The so-called “cookie directive” has existed since 2009. It states that the storage of cookies requires your consent (Article 6 Paragraph 1 lit. a GDPR). Within countries of the EU, however, the reactions to these guidelines still vary greatly. In Austria, however, this directive was implemented in Section 96 (3) of the Telecommunications Act (TKG). In Germany, the cookie guidelines have not been implemented as national law. Instead, this guideline was largely implemented in Section 15 (3) of the Telemedia Act (TMG).
For absolutely necessary cookies, even if no consent has been given, there are legitimate interests (Article 6 (1) (f) GDPR), which in most cases are of an economic nature. We want to offer our visitors a pleasant user experience on our website. For this, certain cookies often are absolutely necessary.
This is exclusively done with your consent, unless absolutely necessary cookies are used. The legal basis for this is Article 6 (1) (a) of the GDPR.
In the following sections you will find more detail on the use of cookies, provided the used software does use cookies.
Web hosting
Web hosting Overview
Affected parties: visitors to the website
Purpose: professional hosting of the website and security of operations
Processed data: IP address, time of website visit, browser used and other data. You can find more details on this below or at the respective web hosting provider.
Storage period: dependent on the respective provider, but usually 2 weeks
Legal basis: Art. 6 para. 1 lit. f GDPR (legitimate interests)
What is web hosting?
Every time you visit a website nowadays, certain information – including personal data – is automatically created and stored, including on this website. This data should be processed as sparingly as possible, and only with good reason. By website, we mean the entirety of all websites on your domain, i.e. everything from the homepage to the very last subpage (like this one here). By domain we mean example.uk or examplepage.com.
When you want to view a website on a screen, you use a program called a web browser. You probably know the names of some web browsers: Google Chrome, Microsoft Edge, Mozilla Firefox, and Apple Safari.
The web browser has to connect to another computer which stores the website’s code: the web server. Operating a web server is complicated and time-consuming, which is why this is usually done by professional providers. They offer web hosting and thus ensure the reliable and flawless storage of website data.
Whenever the browser on your computer establishes a connection (desktop, laptop, smartphone)
and whenever data is being transferred to and from the web server, personal data may be processed. After all, your computer stores data, and the web server also has to retain the data for a period of time in order to ensure it can operate properly.
Illustration:
Why do we process personal data?
The purposes of data processing are:
1. Professional hosting of the website and operational security
2. To maintain the operational as well as IT security
3. Anonymous evaluation of access patterns to improve our offer, and if necessary, for
prosecution or the pursuit of claims.li>
Which data are processed?
Even while you are visiting our website, our web server, that is the computer on which this website is saved, usually automatically saves data such as
the full address (URL) of the accessed website (e. g. https://www.examplepage.uk/examplesubpage.html?tid=311946593)
browser and browser version (e.g. Chrome 87)
the operating system used (e.g. Windows 10)
the address (URL) of the previously visited page (referrer URL) (e. g. https://www.examplepage.uk/icamefromhere.html/)
the host name and the IP address of the device from the website is being accessed from (e.g. COMPUTERNAME and 194.23.43.121)
date and time
in so-called web server log files
How long is the data stored?
Generally, the data mentioned above are stored for two weeks and are then automatically deleted. We do not pass these data on to others, but we cannot rule out the possibility that this data may be viewed by the authorities in the event of illegal conduct.
In short: Your visit is logged by our provider (company that runs our website on special computers (servers)), but we do not pass on your data without your consent!
Legal basis
The lawfulness of processing personal data in the context of web hosting is justified in Art. 6 para. 1 lit. f GDPR (safeguarding of legitimate interests), as the use of professional hosting with a provider is necessary to present the company in a safe and user-friendly manner on the internet, as well as to have the ability to track any attacks and claims, if necessary.
Amazon Web Services (AWS) Privacy Policy
We use Amazon Web Services (AWS) for our website, which is a web hosting provider, among other things. The provider of this service is the American company Amazon Web Services, Inc., 410 Terry Avenue North, Seattle WA 98109, USA.
Amazon Web Services (AWS) also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.
Amazon Web Services (AWS) uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Amazon Web Services (AWS) to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847
You can find out more about the data that are processed through the use of Amazon Web Services (AWS) in their Privacy Policy at https://aws.amazon.com/privacy/?nc1=h_ls.
Website Builders Introduction
Website Builders Privacy Policy Overview
Affected parties: website visitors
Purpose: service optimisation
Data processed: The data that is being processed includes but is not limited to technical usage information, browser activity, clickstream activity, session heat maps, contact details, IP addresses or geographic locations. You can find more details in the Privacy Policy below as well as in the providers’ Privacy Policies.
Storage duration: depends on the provider
Legal bases: Art. 6 (1) lit. f GDPR (legitimate interests), Art. 6 (1) lit. a GDPR (consent)
What are website builders?
We use a modular website builder for our website. This is a special form of Content Management System (CMS). Website builders enable website operators to create websites very easily and without any programming knowledge. In many cases, web hosts also offer website builders. Your
personal data may be collected, stored and processed if a website builder is being used. In this Privacy Policy, you will find general information about data that is processed by such modular website builder systems. You can find more information in the respective provider’s Privacy Policy.
Why do we use website builders for our website?
The greatest advantage of modular website builders is their ease of use. We want to offer you a clear, simple and nicely designed website that we can easily operate and maintain by ourselves – without needing any external support. Nowadays website builders offer many helpful functions that we can use even without having any programming knowledge. This enables us to design our website according to our wishes and therefore, to give you an informative and pleasant experience on our website.
Which data are stored by website builders?
First of all, the exact data that is stored depends on the website builder that is being used. Each provider processes and collects different data from website visitors. However, technical usage information such as users’ operating system, browser, screen resolution, language and keyboard settings, hosting provider as well as the date of the website visit are usually collected. Moreover, tracking data (e. g. browser activity, clickstream activities, session heat maps, etc.) may also be processed. The same goes for personal data, since data such as contact information e. g. email address, telephone number (if you have provided it), IP address and geographic location data may also be processed and stored. In the respective provider’s Privacy Policy you can find out exactly which of your data is getting stored.
How long and where are the data stored?
Provided that we have any further information on this, we will inform you below about the duration of the data processing associated with the website builder we use. You can find detailed information on this in the provider’s Privacy Policy. Generally, we only process personal data for as long as is absolutely necessary to provide our services and products. The provider may store your data according to their own specifications, over which we have no influence.
Right to object
You always retain the right to information, rectification and erasure of your personal data. If you have any questions, you can also contact the responsible parties at the respective website builder system at any time. You can find the corresponding contact details either in our Privacy Policy or on the website of the respective provider.
What is more, in your browser you can clear, disable or manage cookies that providers use for their functions. Depending on the browser you use, this can be done in different ways. Please note, that this may lead to not all functions working as usual anymore.
Legal Bases
We have a legitimate interest in using a website builder system to optimise our online service and
present it in an efficient and user-friendly way. The corresponding legal basis for this is Article 6 (1) (f) GDPR (legitimate interests). However, we only use the website builder system if you have consented to it.
If the processing of data is not absolutely necessary for the operation of the website, your data will only be processed on the basis of your consent. This particularly applies to tracking activities. The legal basis for this is Article 6 (1) (a) GDPR.
With this Privacy Policy, we have made you more familiar with the most important general information on data processing. If you want to find out more about this, you will find further information – if available – in the following section or in the Privacy Policy of the provider.
WordPress.com Privacy Policy
We use WordPress.com for our website, which is a modular website system. The provider of this service is the American company Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA.
WordPress.com also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.
WordPress.com uses standard contractual clauses approved by the EU Commission as the basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige WordPress.com to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.
You can find out more about the data that is processed by using WordPress.com in their Privacy Policy at https://automattic.com/privacy/.
Web Analytics
Web Analytics Privacy Policy Overview
Affected parties: visitors to the website
Purpose: Evaluation of visitor information to optimise the website.
Processed data: Access statistics that contain data such as access location, device data, access duration and time, navigation behaviour, click behaviour and IP addresses. You can find more details on this from the respective web analytics tool directly.
Storage period: depending on the respective web analytics tool used
Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)
What is Web Analytics?
We use software on our website, which is known as web analytics, in order to evaluate website visitor behaviour. Thus, data is collected, which the analytic tool provider (also called tracking tool) stores, manages and processes. Analyses of user behaviour on our website are created with this data, which we as the website operator receive. Most tools also offer various testing options. These enable us, to for example test which offers or content our visitors prefer. For this, we may show you two different offers for a limited period of time. After the test (a so-called A/B test) we know which product or content our website visitors find more interesting. For such testing as well as for various other analyses, user profiles are created and the respective data is stored in cookies.
Why do we run Web Analytics?
We have a clear goal in mind when it comes to our website: we want to offer our industry’s best website on the market. Therefore, we want to give you both, the best and most interesting offer as well as comfort when you visit our website. With web analysis tools, we can observe the behaviour of our website visitors, and then improve our website accordingly for you and for us. For example, we can see the average age of our visitors, where they come from, the times our website gets visited the most, and which content or products are particularly popular. All this information helps us to optimise our website and adapt it to your needs, interests and wishes.
Which data are processed?
The exact data that is stored depends on the analysis tools that are being used. But generally, data such as the content you view on our website are stored, as well as e. g. which buttons or links you click, when you open a page, which browser you use, which device (PC, tablet, smartphone, etc.) you visit the website with, or which computer system you use. If you have agreed that location data may also be collected, this data may also be processed by the provider of the web analysis tool.
Moreover, your IP address is also stored. According to the General Data Protection Regulation (GDPR), IP addresses are personal data. However, your IP address is usually stored in a pseudonymised form (i.e. in an unrecognisable and abbreviated form). No directly linkable data such as your name, age, address or email address are stored for testing purposes, web analyses and web optimisations. If this data is collected, it is retained in a pseudonymised form. Therefore, it cannot be used to identify you as a person.
The following example shows Google Analytics’ functionality as an example for client-based web tracking with JavaScript code.
The storage period of the respective data always depends on the provider. Some cookies only retain data for a few minutes or until you leave the website, while other cookies can store data for several years.
Duration of data processing
If we have any further information on the duration of data processing, you will find it below. We generally only process personal data for as long as is absolutely necessary to provide products and services. The storage period may be extended if it is required by law, such as for accounting purposes for example for accounting.
Right to object
You also have the option and the right to revoke your consent to the use of cookies or third-party providers at any time. This works either via our cookie management tool or via other opt-out functions. For example, you can also prevent data processing by cookies by managing, deactivating or erasing cookies in your browser.
Legal basis
The use of Web Analytics requires your consent, which we obtained with our cookie popup. According to Art. 6 para. 1 lit. a of the GDPR (consent), this consent represents the legal basis for the processing of personal data, such as by collection through Web Analytics tools.
In addition to consent, we have a legitimate interest in analysing the behaviour of website visitors, which enables us to technically and economically improve our offer. With Web Analytics, we can recognise website errors, identify attacks and improve profitability. The legal basis for this is Art. 6 para. 1 lit. f of the GDPR (legitimate interests). Nevertheless, we only use these tools if you have given your consent.
Since Web Analytics tools use cookies, we recommend you to read our privacy policy on cookies. If you want to find out which of your data are stored and processed, you should read the privacy policies of the respective tools.
If available, information on special Web Analytics tools can be found in the following sections.
Facebook Pixel Privacy Policy
We use Facebook’s Facebook pixel on our website. For that, we have implemented a code on our website. The Facebook pixel is a segment of a JavaScript code, which, in case you came to our website via Facebook ads, loads an array or functions that enable Facebook to track your user actions. For example, if you buy a product on our website, the Facebook pixel is triggered and stores your actions on our website in one or more cookies. These cookies enable Facebook to match your user data (customer data such as IP address, user ID) with the data of your Facebook account. After that, Facebook deletes your data again. The collected data is anonymous as well as inaccessible and can only be used for ad placement purposes. If you are a Facebook user and you are logged in, your visit to our website is automatically assigned to your Facebook user account.
We exclusively want to show our products or services to persons, who are interested in them. With the aid of the Facebook pixel, our advertising measures can get better adjusted to your wishes and interests. Therefore, Facebook users get to see suitable advertisement (if they allowed personalised advertisement). Moreover, Facebook uses the collected data for analytical purposes and for its own advertisements.
In the following we will show you the cookies, which were set on a test page with the Facebook pixel integrated to it. Please consider that these cookies are only examples. Depending on the interaction that is made on our website, different cookies are set.
Name: _fbp
Value: fb.1.1568287647279.257405483-6311946593-7
Purpose: Facebook uses this cookie to display advertising products. Expiration date: after 3 months
Name: fr
Value: 0aPf312HOS5Pboo2r..Bdeiuf...1.0.Bdeiuf.
Purpose: This cookie is used for Facebook pixels to function properly. Expiration date: after 3 months
Name: comment_author_50ae8267e2bdf1253ec1a5769f48e062311946593-3 Value: Name of the author
Purpose: This cookie saves the text and name of a user who e.g. leaves a comment. Expiration date: after 12 months
Name: comment_author_url_50ae8267e2bdf1253ec1a5769f48e062
Value: https%3A%2F%2Fwww.testseite...%2F (URL of the author)
Purpose: This cookie saved the URL of the website that the user types into a text box on our website.
Expiration date: after 12 months
Name: comment_author_email_50ae8267e2bdf1253ec1a5769f48e062
Value: email address of the author
Purpose: This cookie saves the email address of the user, if they provided it on the website. Expiration date: after 12 months
Note: The above-mentioned cookies relate to an individual user behaviour. Moreover, especially concerning the usage of cookies, changes at Facebook can never be ruled out.
If you are registered on Facebook, you can change the settings for advertisements yourself at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. If you are not a Facebook user, you can manage your user based online advertising at https://www.youronlinechoices.com/uk/your-ad-choices. You have the option to activate or deactivate any providers there.
We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfer to the USA. Data processing is done mainly through Facebook Pixel. This may lead to data not being anonymously processed and stored. Furthermore, US government authorities may get access to individual data. The data may also get linked to data from other Facebook services you have a user account with.
If you want to learn more about Facebook’s data protection, we recommend you the view the company’s in-house data policies at https://www.facebook.com/policy.php.
Privacy Policy for Facebook‘s Automatic Advanced Matching
Along with Facebook’s pixel function, we have also activated Automatic Advanced Matching. This function allows us to send hashed emails, names, genders, cities, states, postcodes and dates of birth or telephone numbers as additional information to Facebook, provided you have made them available to us. This activation gives us the opportunity to customise advertising campaigns even better to persons who are interested in our services or products.
Firebase Privacy Policy
On our website, we use Firebase , a web analysis tool. The provider of this service is the American company Google Inc. The responsible entity for the European region is the Irish company Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Irland).
Firebase also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.
Firebase uses standard contractual clauses approved by the EU Commission as basis for data
processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Firebase to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847
The Google Ads Data Processing Terms, which reference the standard contractual clauses, can be found at https://business.safety.google/intl/en/adsprocessorterms/.
You can find out more about Firebases ́ data processing in their privacy policy at https://policies.google.com/privacy?hl=en-US.
Google Analytics Privacy Policy
Google Analytics Privacy Policy Overview
Affected parties: website visitors
Purpose: Evaluation of visitor information to optimise the website.
Processed data: Access statistics that contain data such as the location of access, device data, access duration and time, navigation behaviour, click behaviour and IP addresses. You can find more details on this in the privacy policy below.
Storage period: depending on the properties used
Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)
What is Google Analytics?
We use the tracking and analysis tool Google Analytics (GA) of the US-American company Google LLC (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). Google Analytics collects data on your actions on our website. Whenever you click a link for example, this action is saved in a cookie and transferred to Google Analytics. With the help of reports which we receive from Google Analytics, we can adapt our website and our services better to your wishes. In the following, we will explain the tracking tool in more detail, and most of all, we will inform you what data is saved and how you can prevent this.
Google Analytics is a tracking tool with the purpose of conducting data traffic analysis of our website. For Google Analytics to work, there is a tracking code integrated to our website. Upon your visit to our website, this code records various actions you perform on your website. As soon as you leave our website, this data is sent to the Google Analytics server, where it is stored.
Google processes this data and we then receive reports on your user behaviour. These reports can be one of the following:
Target audience reports: With the help of target audience reports we can get to know our users better and can therefore better understand who is interested in our service. Advertising reports: Through advertising reports we can analyse our online advertising better and hence improve it.
Acquisition reports: Acquisition reports provide us helpful information on how we can get more people enthusiastic about our service.
Behaviour reports: With these reports, we can find out how you interact with our website. By the means of behaviour reports, we can understand what path you go on our website and what links you click.
Conversion reports: A conversion is the process of leading you to carry out a desired action due to a marketing message. An example of this would be transforming you from a mere website visitor into a buyer or a newsletter subscriber. Hence, with the help of these reports we can see in more detail, if our marketing measures are successful with you. Our aim is to increase our conversion rate.
Real time reports: With the help of these reports we can see in real time, what happens on our website. It makes us for example see, we can see how many users are reading this text right now.
Why do we use Google Analytics on our website?
The objective of our website is clear: We want to offer you the best possible service. Google Analytics’ statistics and data help us with reaching this goal.
Statistically evaluated data give us a clear picture of the strengths and weaknesses of our website. On the one hand, we can optimise our page in a way, that makes it easier to be found by interested people on Google. On the other hand, the data helps us to get a better understanding of you as our visitor. Therefore, we can very accurately find out what we must improve on our website, in order to offer you the best possible service. The analysis of that data also enables us to carry out our advertising and marketing measures in a more individual and more cost-effective way. After all, it only makes sense to show our products and services exclusively to people who are interested in them.
What data is stored by Google Analytics?
With the aid of a tracking code, Google Analytics creates a random, unique ID which is connected to your browser cookie. That way, Google Analytics recognises you as a new user. The next time you visit our site, you will be recognised as a “recurring” user. All data that is collected gets saved together with this very user ID. Only this is how it is made possible for us to evaluate and analyse pseudonymous user profiles.
To analyse our website with Google Analytics, a property ID must be inserted into the tracking code. The data is then stored in the corresponding property. Google Analytics 4-property is standard for every newly created property. An alternative however, is the Universal Analytics Property. Depending on the property that is being used, data are stored for different periods of time.
Your interactions on our website are measured by tags such as cookies and app instance IDs. Interactions are all kinds of actions that you perform on our website. If you are also using other Google systems (such as a Google Account), data generated by Google Analytics can be linked with third-party cookies. Google does not pass on any Google Analytics data, unless we as the website owners authorise it. In case it is required by law, exceptions can occur.
The following cookies are used by Google Analytics:
Name: _ga
Value:2.1326744211.152311946593-5
Purpose: By deafault, analytics.js uses the cookie _ga, to save the user ID. It generally serves the purpose of differentiating between website visitors.
Expiration date: After 2 years
Name: _gid
Value:2.1687193234.152311946593-1
Purpose: This cookie also serves the purpose of differentiating between website users Expiration date: After 24 hours
Name: _gat_gtag_UA_<property-id>
Value: 1
Verwendungszweck: It is used for decreasing the demand rate. If Google Analytics is provided via Google Tag Manager, this cookie gets the name _dc_gtm_ <property-id>.
Expiration date: After 1 minute
Name: AMP_TOKEN
Value: No information
Purpose: This cookie has a token which is used to retrieve the user ID by the AMP Client ID Service. Other possible values suggest a logoff, a request or an error.
Expiration date: After 30 seconds up to one year
Name: __utma
Value:1564498958.1564498958.1564498958.1
Purpose: With this cookie your behaviour on the website can be tracked and the site performance can be measured. The cookie is updated every time the information is sent to Google Analytics. Expiration date: After 2 years
Name: __utmt
Value: 1
Purpose: Just like _gat_gtag_UA_<property-id> this cookie is used for keeping the requirement rate in check.
Expiration date: Afer 10 minutes
Name: __utmb
Value:3.10.1564498958
Purpose: This cookie is used to determine new sessions. It is updated every time new data or information gets sent to Google Analytics.
Expiration date: After 30 minutes
Name: __utmc
Value: 167421564
Purpose: This cookie is used to determine new sessions for recurring visitors. It is therefore a session cookie, and only stays stored until you close the browser again.
Expiration date: After closing the browser
Name: __utmz
Value: m|utmccn=(referral)|utmcmd=referral|utmcct=/
Purpose: This cookie is used to identify the source of the number of visitors to our website. This means, that the cookie stored information on where you came to our website from. This could be another site or an advertisement.
Expiration date: After 6 months
Name: __utmv
Value: No information
Purpose: The cookie is used to store custom user data. It gets updated whenever information is sent to Google Analytics.
Expiration date: After 2 years
Note: This list is by no means exhaustive, since Google are repeatedly changing the use of their cookies.
Below we will give you an overview of the most important data that can be evaluated by Google Analytics:
Heatmaps: Google creates so-called Heatmaps an. These Heatmaps make it possible to see the exact areas you click on, so we can get information on what routes you make on our website.
Session duration: Google calls the time you spend on our website without leaving it session duration. Whenever you are inactive for 20 minutes, the session ends automatically.
Bounce rate If you only look at one page of our website and then leave our website again, it is called a bounce.
Account creation: If you create an account or make an order on our website, Google Analytics collects this data.
IP-Address: The IP address is only shown in a shortened form, to make it impossible to clearly allocate it.
Location: Your approximate location and the country you are in can be defined by the IP address. This process is called IP location determination.
Technical information: Information about your browser type, your internet provider and your screen resolution are called technical information.
Source: Both, Google Analytics as well as ourselves, are interested what website or what advertisement led you to our site.
Further possibly stored data include contact data, potential reviews, playing media (e.g. when you play a video on our site), sharing of contents via social media or adding our site to your favourites.
This list is not exhaustive and only serves as general guidance on Google Analytics’ data retention.
How long and where is the data stored?
Google has servers across the globe. Most of them are in America and therefore your data is mainly saved on American servers. Here you can read detailed information on where Google’s data centres are located: https://www.google.com/about/datacenters/locations/?hl=en
Your data is allocated to various physical data mediums. This has the advantage of allowing to retrieve the data faster, and of protecting it better from manipulation. Every Google data centre has respective emergency programs for your data. Hence, in case of a hardware failure at Google or a server error due to natural disasters, the risk for a service interruption stays relatively low.
The data retention period depends on the properties used. When using the newer Google Analytics 4-properties, the retention period of your user data is set to 14 months. For so-called event data, we have the option of choosing a retention period of either 2 months or 14 months.
Google Analytics has a 26 months standardised period of retaining your user data. After this time, your user data is deleted. However, we have the possibility to choose the retention period of user data ourselves. There are the following five options:
Deletion after 14 months Deletion after 26 months Deletion after 38 months Deletion after 50 months No automatical deletion
Additionally, there is the option for data to be deleted only if you no longer visit our website within a period determined by us. In this case, the retention period will be reset every time you revisit our website within the specified period.
As soon as the chosen period is expired, the data is deleted once a month. This retention period applies to any of your data which is linked to cookies, user identification and advertisement IDs (e.g. cookies of the DoubleClick domain). Any report results are based on aggregated information and are stored independently of any user data. Aggregated information is a merge of individual data into a single and bigger unit.
How can I delete my data or prevent data retention?
Under the provisions of the European Union’s data protection law, you have the right to obtain information on your data and to update, delete or restrict it. With the help of a browser add on that can deactivate Google Analytics’ JavaScript (ga.js, analytics.js, dc.js), you can prevent Google Analytics from using your data. You can download this add on at https://tools.google.com/dlpage/gaoptout?hl=en-GB. Please consider that this add on can only deactivate any data collection by Google Analytics.
If you generally want to deactivate, delete or manage all cookies (independently of Google
Analytics), you can use one of the guides that are available for any browser:
Chrome: Clear, enable and manage cookies in Chrome Safari: Manage cookies and website data in Safari Firefox: Clear cookies and site data in Firefox
Internet Explorer: Delete and manage cookies Microsoft Edge: Delete cookies in Microsoft Edge
Legal basis
The use of Google Analytics requires your consent, which we obtained via our cookie popup. According to Art. 6 para. 1 lit. a of the GDPR (consent) , this is the legal basis for the processing of personal data when collected via web analytics tools.
In addition to consent, we have legitimate interest in analysing the behaviour of website visitors, in order to technically and economically improve our offer. With Google Analytics, we can recognise website errors, identify attacks and improve profitability. The legal basis for this is Art. 6 para. 1 lit. f of the GDPR (legitimate interests) . Nevertheless, we only use Google Analytics if you have given your consent.
Google also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.
Google uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Google to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847
The Google Ads Data Processing Terms, which reference the standard contractual clauses, can be found at https://business.safety.google/intl/en/adsprocessorterms/.
We hope we could provide you with the most important information about data processing by Google Analytics. If you want to find out more on the tracking service, we recommend these two links: https://marketingplatform.google.com/about/analytics/terms/gb/ and https://support.google.com/analytics/answer/6004245?hl=en.
Google Analytics Reports on demographic characteristics and interests
We have turned on Google Analytics’ functions for advertising reports. These reports on demographic characteristics and interests contain details about age, gender and interests. Through them we can get a better picture of our users – without being able to allocate any data to individual persons. You can learn more about advertising functions at auf https://support.google.com/analytics/answer/3450482?hl=en&%3Butm_id=ad.
You can terminate the use of your Google Account’s activities and information in “Ads Settings” at https://adssettings.google.com/authenticated via a checkbox.
Google Analytics IP Anonymisation
We implemented Google Analytics’ IP address anonymisation to this website. Google developed this function, so this website can comply with the applicable privacy laws and the local data protection authorities’ recommendations, should they prohibit the retention of any full IP addresses.
The anonymisation or masking of IP addresses takes place, as soon as they reach Google Analytics’ data collection network, but before the data would be saved or processed.
You can find more information on IP anonymisation at https://support.google.com/analytics/answer/2763052?hl=en.
Google Tag Manager Privacy Policy
Google Tag Manager Privacy Policy Overview
Affected parties: website visitors
Purpose: Organisation of individual tracking tools
Processed data: Google Tag Manager itself does not store any data. The data record tags of the web analytics tools used.
Storage period: depending on the web analytics tool used
Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)
What is Google Tag Manager?
We use Google Tag Manager by the company Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA) for our website.
This Tag Manager is one of Google’s many helpful marketing products. With it, we can centrally integrate and manage code sections of various tracking tools, that we use on our website.
In this privacy statement we will explain in more detail, what Google Tag Manager does, why we use it and to what extent your data is processed.
Google Tag Manager is an organising tool with which we can integrate and manage website tags centrally and via a user interface. Tags are little code sections which e.g. track your activities on our
website. For this, segments of JavaScript code are integrated to our site’s source text. The tags often come from Google’s intern products, such as Google Ads or Google Analytics, but tags from other companies can also be integrated and managed via the manager. Since the tags have different tasks, they can collect browser data, feed marketing tools with data, embed buttons, set cookies and track users across several websites.
Why do we use Google Tag Manager for our website?
Everybody knows: Being organised is important! Of course, this also applies to maintenance of our website. In order to organise and design our website as well as possible for you and anyone who is interested in our products and services, we rely on various tracking tools, such as Google Analytics. The collected data shows us what interests you most, which of our services we should improve, and which other persons we should also display our services to. Furthermore, for this tracking to work, we must implement relevant JavaScript Codes to our website. While we could theoretically integrate every code section of every tracking tool separately into our source text, this would take too much time and we would lose overview. This is the reason why we use Google Tag Manager. We can easily integrate the necessary scripts and manage them from one place. Additionally, Google Tag Manager’s user interface is easy to operate, and requires no programming skills. Therefore, we can easily keep order in our jungle of tags.
What data is stored by Google Tag Manager?
Tag Manager itself is a domain that neither uses cookies nor stores data. It merely functions as an “administrator“ of implemented tags. Data is collected by the individual tags of the different web analysis tools. Therefore, in Google Tag Manager the data is sent to the individual tracking tools and does not get saved.
However, with the integrated tags of different web analysis tools such as Google Analytics, this is quite different. Depending on the analysis tool used, various data on your internet behaviour is collected, stored and processed with the help of cookies. Please read our texts on data protection for more information on the articular analysis and tracking tools we use on our website.
We allowed Google via the account settings for the Tag Manager to receive anonymised data from us. However, this exclusively refers to the use of our Tag Manager and not to your data, which are saved via code sections. We allow Google and others, to receive selected data in anonymous form. Therefore, we agree to the anonymised transfer of our website data. However, even after extensive research we could not find out what summarised and anonymous data it is exactly that gets transmitted. What we do know is that Google deleted any info that could identify our website. Google combines the data with hundreds of other anonymous website data and creates user trends as part of benchmarking measures. Benchmarking is a process of comparing a company’s results with the ones of competitors. As a result, processes can be optimised based on the collected information.
How long and where is the data stored?
When Google stores data, this is done on Google’s own servers. These servers are located all over
the world, with most of them being in America. At
https://www.google.com/about/datacenters/inside/locations/?hl=en you can read in detail where Google’s servers are.
In our individual data protection texts on the different tools you can find out how long the respective tracking tools store your data.
How can I delete my data or prevent data retention?
Google Tag Manager itself does not set any cookies but manages different tracking websites’ tags. In our data protection texts on the different tracking tools you can find detailed information on how you can delete or manage your data.
Please note that when using this tool, your data may also be stored and processed outside the EU. Most third countries (including the USA) are not considered secure under current European data protection law. Data must not be transferred, stored and processed to insecure third countries, unless there are suitable guarantees (such as EU standard contractual clauses) between us and the non-European service provider.
Legal basis
The use of the Google Tag Manager requires your consent, which we obtained via our cookie popup. According to Art. 6 para. 1 lit. a GDPR (consent), this consent is the legal basis for personal data processing, such as when it is collected by web analytics tools.
In addition to consent, we have a legitimate interest in analysing the behaviour of website visitors and thus technically and economically improving our offer. With the help of Google Tag Managers we can also improve profitability. The legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests). We only use Google Tag Manager if you have given us your consent.
Google also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.
Google uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Google to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847
The Google Ads Data Processing Terms, which reference the standard contractual clauses, can be found at https://business.safety.google/intl/en/adsprocessorterms/
If you want to learn more about Google Tag Manager, we recommend their FAQs at
https://support.google.com/tagmanager/?hl=en#topic=3441530. Hotjar Privacy Policy
Hotjar Privacy Policy Overview
Affected parties: website visitors
Purpose: To evaluate visitor information for optimising user experience.
Processed data: Access statistics that contain data such as access location, device data, access duration and time, navigation behaviour, click behaviour and IP addresses.
Storage period: the data will be deleted after one year
Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)
What is Hotjar?
We use Hotjar of the company Hotjar Limited (Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta) on our website, to statistically evaluate visitor data. Hotjar is a service which analyses the behaviour and feedback of you as a user of our website by combining analysis and feedback tools. We receive reports as well as visual displays from Hotjar, which show us how you move on our site. Personal data is anonymised automatically and never reaches Hotjar’s servers. This means you as the website user are not personally identified, while we can still learn much about your user behaviour.
As mentioned in the above paragraph, Hotjar helps us analyse the behaviour of our site visitors. Some of the tools Hotjar offers are e.g. heatmaps, conversion funnels, visitor recording, incoming feedback, feedback polls and surveys (you can find more information about it at https://www.hotjar.com/). Therewith, Hotjar helps us to provide you a better user experience as well as an improved service. On the one hand it offers good analysis of online behaviour and on the other hand it gives us good feedback on our website’s quality. Besides the analytical aspects we of course also want to know your opinion about our website. This is possible thanks to the feedback tool.
Why do we use Hotjar on our website?
Within the last years the importance of websites’ user experience has gained in importance. And justifiably so – a website should be structured in a way that makes the user feel comfortable and is easy to navigate. Thanks to Hotjar’s analysis and the feedback tools, we can make our website and our offer more attractive. To us, Hotjar’s Heatmaps has proven particularly valuable, as it helps with presenting and visualising data. In that sense, Hotjar’s Heatmaps e.g. helps us see what you like to click on and where you scroll to.
What data is stored by Hotjar?
Hotjar automatically collects information on your user behaviour while you surf our website. In order to be able to collect this information, we implemented a tracking code. We integrated a tracking code, to be able to collect this information. The following data can be gathered via your computer or your browser:
Your computer’s IP address (is collected and saved in an anonymous format) Screen size
Browser information (which browser and version etc.)
Your location (but only the country)
Your language preference
Visited websites (subpages)
Date and time of access to one of our subpages (websites)
Moreover, cookies also save data that have been placed on your computer (mostly your browser), although no personal data is collected. Generally, Hotjar does not pass collected data to third parties. However, Hotjar explicitly emphasises that it is sometimes necessary to share data with Amazon Web Services. _ parts of your information is saved on its servers. Nonetheless, Amazon is bound to a confidentiality obligation and cannot disclose these data.
Only a limited number of people (employees of Hotjar) have access to the stored information. Furthermore, Hotjar’s servers are protected by firewalls and IP restrictions (only authorised IP addresses have access). Firewalls are security systems which protect computers from unwanted network accesses. They serve as barriers between Hotjar’s secure internal network and the internet. Moreover, Hotjar also uses third-party companies for their services, such as Google Analytics or Optimizely. These firms can also save information that your browser sends to our website.
The following cookies are used by Hotjar. Since we refer to the cookie list in Hotjar’s privacy statement at https://www.hotjar.com/legal/policies/cookie-information, not every cookie has a sample value. The list shows examples of utilised Hotjar cookies and does not claim to be exhaustive.
Name: ajs_anonymous_id
Value: %2258832463-7cee-48ee-b346-a195f18b06c3%22311946593-5
Purpose: This cookie is generally used for analysis purposes and helps with counting our website’s visitors by tracking whether they have been to the website before.
Expiry date: after one year
Name: ajs_group_id
Value: 0
Purpose: This cookie collects data on user behaviour. Based on the similarities between website visitors, the data can then be assigned to a specific visitor group.
Expiry date: after one year
Name: _hjid
Value: 699ffb1c-4bfb-483f-bde1-22cfa0b59c6c
Purpose: This cookie is used to maintain a Hotjar user ID, which is unique for the website in the browser. That way, upon the next website visits, the user behaviour can be assigned to the same user ID.
Expiry date: after one year
Name: _hjMinimizedPolls
Value: 462568311946593-8
Verwendungszweck: Every time you minimise a feedback poll widget, Hotjar sets this cookie. It ensures that the widget stays minimised when you surf our sites.
Expiry date: after one year
Name: _hjIncludedInSample
Value: 1
Purpose: This session cookie is used to inform Hotjar if you are part of the selected individuals (sample), who are used for the creation of funnels.
Expiry date: after one year
Name: _hjClosedSurveyInvites
Purpose: This cookie is set when you see an invitation to a feedback poll in a popup window. It is used to ensure that this invitation appears to you only once.
Expiry date: after one year
Name: _hjDonePolls
Purpose: This cookie is set in your browser whenever you finish a round of questions for feedback in a poll widget. Therewith, Hotjar prevents you from receiving the same polls in the future.
Expiry date: after one year
Name: _hjDoneTestersWidgets
Purpose: This cookie is used when you enter your data in the “recruit user tester” widget. With this widget we want to engage you as a tester. The cookie is used to prevent the form from reappearing repeatedly.
Expiry date: after one year
Name: _hjMinimizedTestersWidgets
Purpose: This cookie is set to keep the “recruit user tester“ widget minimised accross all our pages. The cookie is set upon you minimising this widget once.
Expiry date: after one year
Name: _hjShownFeedbackMessage
Purpose: This cookie is set if you minimise or amend the given feedback. This is done so the feedback is instantly loaded as minimised when you navigate to another page, on which it is displayed.
Expiry date: after one year
How long and where is the data stored?
We integrated a tracking code to our website, which is transmitted to Hotjar’s servers in Ireland (EU). This tracking code contacts Hotjar’s servers and sends a script to your computer or any terminal device with which you are accessing our website. The script collects certain data concerning your interaction with our website. Then, the data is sent to Hotjar’s servers for processing. Moreover, Hotjar imposed a limit of retaining data for up to 365 days on itself. This
means that all data collected by Hotjar which is over one year old are deleted automatically.
How can I erase my data or prevent data retention?
Hotjar saves none of your personal data for its analysis. The company even advertises with the slogan “We track behaviour, not individuals“. In addition, it is always possible for you to prevent the collection of your data. For this you simply need to visit Hotjar’s “Opt-out page“ and click on “deactivate Hotjar”. Please note that deleting cookies, using your browser’s private mode or utilising a different browser will result in the collection of data again. Furthermore, you can activate the “Do Not Track” button in your browser. To do this in Chrome for example, you must click on the three bars and select “Settings”. In the section “Data Protection“ you will find the option “Send a ‘Do Not Track’ request with your browsing traffic”. Finally, you must click on this button and no data will be collected by Hotjar.
Legal basis
The use of Hotjar requires your consent, which we obtained via our cookie popup. According to Art. 6 para. 1 lit. a GDPR (consent) , this consent represents the legal basis for personal data processing , such as when it is collected by web analytics tools.
In addition to consent, we have legitimate interest in analysing the behaviour of website visitors, and thus technically and economically improving our offer. With the help of Hotjar, we can recognise website errors, identify attacks and improve profitability. The legal basis for this is Art. 6 para. 1 lit.f GDPR (legitimate interests). Nevertheless, we only use Hotjar if you have given us your consent.
You can find more details on the privacy policy and on what data Hotjar uses and how it is utilised at https://www.hotjar.com/legal/policies/privacy?tid=311946593.
Mixpanel Privacy Policy
On our website, we use Mixpanel a tool for product analysis. The provider of this service provider is the American company Mixpanel Inc., One Front Street, Floor 28, San Francisco, CA 94111, USA.
Mixpanel also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.
Mixpanel uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Mixpanel to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847
You can find out more on data processing by Mixpanel in their privacy policy at
https://mixpanel.com/legal/privacy-policy/. Email-Marketing
Email Marketing Overview
Affected parties: newsletter subscribers
Purpose: direct marketing via email, notification of events that are relevant to the system Processed data: data entered during registration, but at least the email address. You can find more details on this in the respective email marketing tool used.
Storage duration: for the duration of the subscription
Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)
What is Email-Marketing?
We use email marketing to keep you up to date. If you have agreed to receive our emails or newsletters, your data will be processed and stored. Email marketing is a part of online marketing. In this type of marketing, news or general information about a company, product or service are emailed to a specific group of people who are interested in it.
If you want to participate in our email marketing (usually via newsletter), you usually just have to register with your email address. To do this, you have to fill in and submit an online form. However, we may also ask you for your title and name, so we can address you personally in our emails.
The registration for newsletters generally works with the help of the so-called “double opt-in procedure”. After you have registered for our newsletter on our website, you will receive an email, via which you can confirm the newsletter registration. This ensures that you own the email address you signed up with, and prevents anyone to register with a third-party email address. We or a notification tool we use, will log every single registration. This is necessary so we can ensure and prove, that registration processes are done legally and correctly. In general, the time of registration and registration confirmation are stored, as well as your IP address. Moreover, any change you make to your data that we have on file is also logged.
Why do we use Email-Marketing?
Of course, we want to stay in contact with you and keep you in the loop of the most important news about our company. For this, we use email marketing – often just referred to as “newsletters” – as an essential part of our online marketing. If you agree to this or if it is permitted by law, we will send you newsletters, system emails or other notifications via email. Whenever the term “newsletter” is used in the following text, it mainly refers to emails that are sent regularly. We of course don’t want to bother you with our newsletter in any way. Thus, we genuinely strive to offer only relevant and interesting content. In our emails you can e.g. find out more about our company and our services or products. Since we are continuously improving our offer, our newsletter will always give you the latest news, or special, lucrative promotions. Should we commission a service provider for our email marketing, who offers a professional mailing tool, we do this in order to offer you fast and secure newsletters. The purpose of our email marketing is to inform you about new
offers and also to get closer to our business goals.
Which data are processed?
If you subscribe to our newsletter via our website, you then have to confirm your membership in our email list via an email that we will send to you. In addition to your IP and email address, your name, address and telephone number may also be stored. However, this will only be done if you agree to this data retention. Any data marked as such are necessary so you can participate in the offered service. Giving this information is voluntary, but failure to provide it will prevent you from using this service. Moreover, information about your device or the type of content you prefer on our website may also be stored. In the section “Automatic data storage” you can find out more about how your data is stored when you visit a website. We record your informed consent, so we can always prove that it complies with our laws.
Duration of data processing
If you unsubscribe from our e-mail/newsletter distribution list, we may store your address for up to three years on the basis of our legitimate interests, so we can keep proof your consent at the time. We are only allowed to process this data if we have to defend ourselves against any claims.
However, if you confirm that you have given us your consent to subscribe to the newsletter, you can submit an individual request for erasure at any time. Furthermore, if you permanently object to your consent, we reserve the right to store your email address in a blacklist. But as long as you have voluntarily subscribed to our newsletter, we will of course keep your email address on file.
Withdrawal – how can I cancel my subscription?
You have the option to cancel your newsletter subscription at any time. All you have to do is revoke your consent to the newsletter subscription. This usually only takes a few seconds or a few clicks. Most of the time you will find a link at the end of every email, via which you will be able to cancel the subscription. Should you not be able to find the link in the newsletter, you can contact us by email and we will immediately cancel your newsletter subscription for you.
Legal basis
Our newsletter is sent on the basis of your consent (Article 6 (1) (a) GDPR). This means that we are only allowed to send you a newsletter if you have actively registered for it beforehand. Moreover, we may also send you advertising messages on the basis of Section 7 (3) UWG (Unfair Competition Act), provided you have become our customer and have not objected to the use of your email address for direct mail.
If available – you can find information on special email marketing services and how they process personal data, in the following sections.
MailChimp Privacy Policy
MailChimp Privacy Policy Overview
Affected parties: newsletter subscribers
Purpose: direct marketing via email, notification of events that are relevant to the system Processed data: data entered during registration, but at least the email address.
Storage duration: for the subscription period
Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)
What is MailChimp?
Like many other websites, we use the services of the newsletter company MailChimp on our website. The operator of MailChimp is the company The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA. With the aid of MailChimp we can easily send you interesting news via newsletter. For the use of the service we do not have to install anything but can still access a pool of very efficient features. In the following we will give more details on this email marketing service and will inform you about the most important data protection aspects.
MailChimp is a cloud-based newsletter management service. “Cloud-based“ means that we do not need to install MailChimp on our own computer or server. Instead, we use the service on an external server, or more specifically via an IT infrastructure, which is available via the internet. Using a software this way is also called SaaS (software as a service).
MailChimp allows us to chose from a wide range of different email types. Depending on what goal we want to reach with our newsletter, we can run individual campaigns, regular campaigns, auto responders (automated emails), A/B tests, RSS campaigns (mailings at pre-set times and frequencies) and follow-up campaigns.
Why do we use MailChimp on our website?
The reason we would use any newsletter service is so we can stay in contact with you. We want to
keep you on the loop about what news or attractive offers we have for you at the time. As we constantly seek out the easiest and best solutions for our marketing measures, we have decided on MailChimp as our newsletter management service. While the software is very easy to use, it offers many helpful features. For example, it allows us to create interesting and attractive newsletters in only a short time. With integrated design templates we can create every newsletter in an individual way. Due to the “responsive design” feature, our contents are also presented in a readable and pleasant way on your smartphone (or any other mobile device).
With tools such as A/B testing or the extensive analysis options, we can swiftly tell how you like our newsletters. This means that we can react if necessary and improve our offer or our services.
Another advantage is MailChimp’s “cloud system”. The data is not stored and processed directly on our server. We can retrieve the data from external servers and therefore save our memory space and also decrease maintenance effort.
What data is stored by MailChimp?
Rocket Science Group LLC (MailChimp) operate online platforms which enable us to get in contact with you, provided you subscribed to our newsletter. If you become a subscriber of our newsletter via our website, by email you agree to become a member of a MailChimp email list. Then, MailChimp saves your subscription data and your IP address, so it can verify your entry into the list provider. Moreover, MailChimp stores your email address, your name, your physical address and demographic information, such as language or location.
This information is used to send emails to you and to allow certain other MailChimp functions (e.g. the evaluation of newsletters).
MailChimp also shares information with third parties to improve its services. Moreover, MailChimp shares certain data with advertising partners of third parties to get a better understanding of its clients’ interests, in order to provide relevant contents and target-oriented advertising.
With so-called “web beacons” (small graphics in HTML emails), MailChimp can determine if an email has arrived, has been opened or if links have been clicked. This information is then stored on MailChimp’s servers. That way we receive statistical evaluations and can see how you liked our newsletter. Therefore, we can tailor our offer better to your wishes and improve our service.
Moreover, MailChimp are allowed to use this data for improving their own service. Thus, they can for example technically optimise the distribution or determine the location (or the country) of the recipient.
The following cookies can be set by MailChimp. This list is not exhaustive and is merely an exemplary selection:
Name: AVESTA_ENVIRONMENT
Value: Prod
Purpose: This cookie is necessary to provide the services of MailChimp. It is always set when a user registers for a newsletter mailing list.
Expiry date: at the end of the session
Name: ak_bmsc
Value: F1766FA98C9BB9DE4A39F70A9E5EEAB55F6517348A7000001311946593-3
Purpose: The cookie is used to differentiate a human from a bot. That way secure reports on the use of a website can be created.
Expiry date: after 2 hours
Name: bm_sv
Value: A5A322305B4401C2451FC22FFF547486~FEsKGvX8eovCwTeFTzb8//I3ak2Au...
Purpose: This cookie comes from MasterPass Digital Wallet (a MasterCard service) and is used to offer a secure and easy virtual payment process to visitors. For this purpose, the user is anonymously identified on the website.
Expiry date: after 2 hours
Name: _abck
Value: 8D545C8CCA4C3A50579014C449B045311946593-9
Purpose: We could not find any further information about the purpose of this cookie. Expiry date: after one year
For better display you might sometimes open our newsletter via a specified link. This can be the case if your email program does not work or if the newsletter is not displayed correctly. The newsletter will then be shown via a MailChimp website. MailChimp also uses cookies on its websites (small text files which save data on your browser).
Personal data can be processed by MailChimp and their partners (e.g. Google Analytics). MailChimp is responsible for the collection of this data and we have no influence on it. MailChimp’s “Cookie Statement” (at: https://mailchimp.com/legal/cookies/) tells you exactly how and why the company uses cookies.
How long and where is the data stored?
Since MailChimp is an American company, all retained data is stored on American servers.
Generally, the data stays permanently stored on MailChimp’s servers and is deleted only when you request it. You can have your contact information with us deleted. This permanently removes all your personal data for us and anonymises you in MailChimp’s reports. However, you can also request the erasure of your data permanently at MailChimp. Then all your data are removed from there and we receive a notification from MailChimp. After we receive the email we have 30 days to delete your contact details from all integrations.
How can I erase my data or prevent data retention?
You can withdraw your approval for the receipt of our newsletters anytime, by clicking the link in the lower area of the received newsletter email. When you click on the unsubscribe link, your data with MailChimp gets deleted.
When you land on a MailChimp website via a link in our newsletter and cookies are consequently
set in your browser, you can delete or deactivate these cookies anytime.
Depending on the browser, the deactivation or deletion differs slightly. The following instructions show how to manage cookies in your browser:
Chrome: Clear, enable and manage cookies in Chrome Safari: Manage cookies and website data in Safari Firefox: Clear cookies and site data in Firefox
Internet Explorer: Delete and manage cookies Microsoft Edge: Delete cookies in Microsoft Edge
If you generally do not want to allow any cookies, you can set up your browser in a way so it would notify you whenever a potential cookie is about to be set. This lets you decide upon the placement of every single cookie.
Legal basis
MailChimp sends our newsletter on the basis of your consent (Article 6 (1) (a) GDPR). This means that we are only allowed to mail you a newsletter if you have actively registered for it beforehand. If consent is not required, the newsletter is sent on the basis of legitimate interest in direct marketing (Article 6 (1) (f)), provided this is legally permitted. We record your registration process so we can keep proof of compliance with our laws.
MailChimp also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.
MailChimp uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige MailChimp to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847
You can find out more on MailChimp’s use of cookies at https://mailchimp.com/legal/cookies/. Furthermore, at https://mailchimp.com/legal/privacy/ you can find more information on data protection at MailChimp (Privacy).
SendGrid Privacy Policy
On our website we use SendGrid, which is a service for email-delivery. The provider of this service is the American company Twilio Inc., 889 Winslow St, Redwood City, California 94063, US.
SendGrid also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.
SendGrid uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway, and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige SendGrid to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847
In SendGrid’s privacy policy at https://www.twilio.com/legal/privacy, you can find out more about the data that are being processed by using SendGrid.
Chatbots Overview
Chatbots Privacy Policy Overview
Affected parties: website visitors
Purpose: for contact requests and general communications between you and ourselves Processed data: Data such as name, address, email address, telephone number, general content data, IP address if applicable
You can find more details on this under the respective tools used.
Storage duration: depending on the chatbots & chat functions used
Legal basis: Article 6 paragraph 1 letter a GDPR (consent), Article 6 paragraph 1 letter f GDPR (legitimate interests), Article 6 paragraph 1 sentence 1 letter b. GDPR (contractual or pre- contractual obligations)
What are chatbots?
You can communicate with us also via chatbots or similar chat functions. A chat offers the possibility to write or talk to one another with only a very small time delay. A chatbot is software that tries to answer your question and, if necessary, informs you about any news. By using these means of communication, your personal data may also be processed and stored.
Why do we use chatbots?
Our ability to communicate with you is important to us. After all, we want to talk to you and answer any questions about our service in the best possible way. Thus, well-functioning communication is an important part of our service. Chatbots have the great advantage that they can automatically answer frequently asked questions. This saves us time and you will still receive detailed and helpful answers. If the chatbot cannot help, you can of course contact us directly at any time.
Please note that when using our built-in elements, your data may also be processed outside the European Union, since many providers are American companies. As a result, you may not be able to claim or enforce your rights in relation to your personal data as easily.
What data is processed?
You may also use the chat services on other websites/platforms. In this case, your user ID will also be stored on the servers of this website. We may also be informed about which user used the chat at what time. The chat content is also stored. Exactly which data is stored depends on the respective service. As a rule, however, it is contact data such as your email address or telephone number, IP address and various usage data.
If you have consented to the use of the chat function, this consent will also be stored or retained along with any registration. We do this so that we can also show your registration or consent if required by law.
The provider of a chat platform can also find out when you are chatting and also receive technical information about the device you are using. Exactly what information is stored and processed also depends on your PC settings. In many cases, data about your approximate location may be collected. This is done to optimise the chat services and to ensure more security. Furthermore, the information may also be used to set personalised advertising and marketing measures.
If you agree that a chatbot can send you messages, you can deactivate this activation at any time. The chatbot also serves as a help for this and shows you how to unsubscribe from this function. All your relevant data will then be deleted from the recipient directory.
We use the above data to be able to address you personally via the chat, to be able to answer your questions and inquiries or to send you any content. It also allows us to fundamentally improve our chat services.
How long is data stored?
How long the data is processed and stored depends primarily on the tools we use. Below you can find out more about the data processing of individual tools. The privacy policies of the providers usually state exactly which data is stored and processed for how long. Generally, personal data is only processed for as long as is necessary to provide our services. When data is stored in cookies, the storage period varies greatly. Data can be erased immediately after leaving a website, but it may also be stored for several years. You should therefore research every single cookie in detail if you want to know more about data retention. In most cases, you will also find helpful information about the individual cookies in the privacy policies of the individual providers.
Right to object
You also have the right and the option to revoke your consent to the use of cookies or third-party providers at any time. This works either via our cookie management tool or via other opt-out functions. For example, you can also prevent data collection by cookies by managing, deactivating or erasing the cookies in your browser.
Since cookies can be used for chat services, we also recommend our Privacy Policy on cookies. To find out exactly which of your data is stored and processed, you should read the privacy policies of the respective tools.
Legal Basis
Via a pop-up window, we ask for your permission to process your data within the framework of the chat services. If you consent, this consent is also the legal basis (Art. 6 Para. 1 lit. a GDPR) for data processing. In addition, we process your inquiries and manage your data within the framework of contractual or pre-contractual relationships in order to fulfill our pre-contractual and contractual obligations or to answer inquiries. The basis for this is Art. 6 paragraph 1 sentence 1 letter b. GDPR. In principle, your data will also be stored and processed on the basis of our legitimate interest (Art. 6 Para. 1 lit. f GDPR) in quick and smooth communication with you or other customers and business partners. However, we only use the tools if you have given your consent.
HubSpot (Chatbot) Privacy Policy
We also use the chatbot function HubSpot. The provider of this service is the American company HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA.
HubSpot also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.
HubSpot uses standard contractual clauses approved by the EU Commission as the basis for data processing by recipients based in third countries (i. e. outside the European Union, Iceland, Liechtenstein, Norway, and thus especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). Standard Contractual Clauses (SCC) are legal templates provided by the EU Commission. Their purpose is to ensure that your data complies with European data privacy standards, even if your data is transferred to and stored in third countries (such as the USA). With these clauses, HubSpot commits to comply with the EU‘s level of data protection when processing relevant data, even if it is stored, processed and managed in the USA. These clauses are based on an implementing order by the EU Commission. You can find the order and the standard contractual clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.
You can find HubSpot’s Data Processing Agreement, which corresponds to the standard contractual clauses at https://legal.hubspot.com/dpa.
You can find out more about the data that is processed by using HubSpot in their Privacy Policy at https://legal.hubspot.com/privacy-policy.
Social Media
Social Media Privacy Policy Overview
Affected parties: website visitors
Purpose: Service presentation and optimisation, staying in contact with visitors, interested parties, etc. as well as advertising Processed data: data such as telephone numbers, email addresses, contact data, data on user behaviour, information about your device and your IP address.
You can find more details on this directly at the respective social media tool used.
Storage period: depending on the social media platforms used
Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)
What is Social Media?
In addition to our website, we are also active on various social media platforms. For us to be able to target interested users via social networks, user data may be processed. Additionally, elements of social media platforms may be embedded directly in our website. This is e.g. the case if you click a so-called social button on our website and are forwarded directly to our social media presence. So- called social media are websites and apps on which registered members can produce and exchange content with other members, be it openly or in certain groups and networks.
Why do we use Social Media?
For years, social media platforms have been the place where people communicate and get into contact online. With our social media presence, we can familiarise interested people better with our products and services. The social media elements integrated on our website help you switch to our social media content quickly and hassle free.
The data that is retained and processed when you use a social media channel is primarily used to conduct web analyses. The aim of these analyses is to be able to develop more precise and personal marketing and advertising strategies. The evaluated data on your behaviour on any social media platform can help to draw appropriate conclusions about your interests. Moreover, so-called user profiles can be created. Thus, the platforms may also to present you with customised advertisements. For this, cookies are usually placed in your browser, which store data on your user behaviour.
We generally assume that we will continue to be responsible under Data Protection Law, even when using the services of a social media platform. However, the European Court of Justice has ruled that, within the meaning of Art. 26 GDPR, in certain cases the operator of the social media platform can be jointly responsible with us. Should this be the case, we will point it out separately and work on the basis of a related agreement. You will then find the essence of the agreement for the concerned platform below.
Please note that when you use social media platforms or our built-in elements, your data may also be processed outside the European Union, as many social media channels, such as Facebook or Twitter, are American companies. As a result, you may no longer be able to easily claim or enforce your rights regarding your personal data.
Which data are processed?
Exactly which data are stored and processed depends on the respective provider of the social media platform. But usually it is data such as telephone numbers, email addresses, data you enter in contact forms, user data such as which buttons you click, what you like or who you follow, when you visited which pages, as well as information about your device and IP address. Most of this data is stored in cookies. Should you have a profile on the social media channel you are visiting and are logged in, data may be linked to your profile.
All data that are collected via social media platforms are also stored on the providers’ servers. This means that only the providers have access to the data and can provide you with appropriate information or make changes for you.
If you want to know exactly which data is stored and processed by social media providers and how you can object to the data processing, we recommend you to carefully read the privacy policy of the respective company. We also recommend you to contact the provider directly if you have any questions about data storage and data processing or if you want to assert any corresponding rights.
Duration of data processing
Provided we have any further information on this, we will inform you about the duration of the data processing below. The social media platform Facebook example stores data until they are no longer needed for the company’s own purposes. However, customer data that is synchronised with your own user data is erased within two days. Generally, we only process personal data for as long as is absolutely necessary for the provision of our services and products. This storage period can also be exceeded however, if it is required by law, such as e.g. in the case of accounting.
Right to object
You also retain the right and the option to revoke your consent to the use of cookies or third-party providers such as embedded social media elements at any time. This can be done either via our cookie management tool or via other opt-out functions. You can e.g. also prevent data collection via cookies by managing, deactivating or erasing cookies in your browser.
Since cookies may be used with social media tools, we also recommend you to read our privacy policy on cookies. If you want to find out which of your data is stored and processed, we advise you to read the privacy policies of the respective tools.
Legal basis
If you have consented to the processing and storage of your data by integrated social media elements, this consent serves as the legal basis for data processing (Art. 6 para. 1 lit. a GDPR). Generally, provided you have given your consent, your data will also be stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f GDPR) in maintaining fast and good communication with you and other customers and business partners. Nevertheless, we only use the tools if you have consented. Most social media platforms also set cookies on your browser to store data. We therefore recommend you to read our privacy policy on cookies carefully and to take a look at the privacy policy or cookie policy of the respective service provider.
in the following section you can find information on special social media platforms – provided this information is available.
Facebook Privacy Policy
Facebook Privacy Policy Overview
Affected parties: website visitors
Purpose: service optimisation
Processed data: data such as customer data, data on user behaviour, device information and IP address.
You can find more details in the Privacy Policy below.
Storage period: until the data no longer serves Facebook’s purposes
Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)
What are Facebook tools?
We use selected Facebook tools on our website. Facebook is a social media network of the company Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland. With the aid of this tool we can provide the best possible offers to you and anyone interested in our products and services.
If your data is collected and forwarded via our embedded Facebook elements or via our Facebook page (fanpage), both we and Facebook Ireland Ltd. are responsible for this. However, should any further processing occur, then Facebook is solely responsible for this data. Our joint commitments were also set out in a publicly available agreement at https://www.facebook. com / legal / controller_addendum . It e.g. states that we must clearly inform you about the use of Facebook tools on our website. We are also responsible for ensuring that the tools are securely integrated into our website and are in accordance with the applicable privacy laws. Facebook, on the other hand, is e.g. responsible for the data security of Facebook’s products. If you have any questions about Facebook’s data collection and processing, you can contact the company directly. Should you direct the question to us, we are obliged to forward it to Facebook.
In the following we will give you an overview on the different Facebook tools, as well as on what data is sent to Facebook and how you can erase this data.
Along with many other products, Facebook also offers so called “Facebook Business Tools”. This is Facebook’s official name for its tools, but it is not very common. Therefore, we decided to merely call them “Facebook tools”. They include the following:
Facebook-Pixel
Social Plugins (e.g. the “Like” or “Share“ button) Facebook Login
Account Kit
APIs (application programming interface)
SDKs (Softwart developmept kits) Plattform-integrations
Plugins
Codes
Specifications
Documentations
Technologies and Services
With these tools Facebook can extend its services and is able to receive information on user activities outside of Facebook.
Why do we use Facebook tools on our website?
We only want to show our services and products to people who are genuinely interested in them. With the help of advertisements (Facebook Ads) we can reach exactly these people. However, to be able to show suitable adverts to users, Facebook requires additional information on people’s needs and wishes. Therefore, information on the user behaviour (and contact details) on our website, are provided to Facebook. Consequently, Facebook can collect better user data and is able to display suitable adverts for our products or services. Thanks to the tools it is possible to create targeted, customised ad campaigns of Facebook.
Facebook calls data about your behaviour on our website “event data” and uses them for analytics services. That way, Facebook can create “campaign reports” about our ad campaigns’ effectiveness on our behalf. Moreover, by analyses we can get a better insight in how you use our services, our website or our products. Therefore, some of these tools help us optimise your user experience on our website. With the social plugins for instance, you can share our site’s contents directly on Facebook.
What data is stored by Facebook tools?
With the use of Facebook tools, personal data (customer data) may be sent to Facebook. Depending on the tools used, customer data such as name, address, telephone number and IP address may be transmitted.
Facebook uses this information to match the data with the data it has on you (if you are a Facebook member). However, before the customer data is transferred to Facebook, a so called “Hashing” takes place. This means, that a data record of any size is transformed into a string of characters, which also has the purpose of encrypting data.
Moreover, not only contact data, but also “event data“ is transferred. These data are the information we receive about you on our website. To give an example, it allows us to see what subpages you visit or what products you buy from us. Facebook does not disclose the obtained information to third parties (such as advertisers), unless the company has an explicit permission or is legally obliged to do so. Also, “event data“ can be linked to contact information, which helps Facebook to offer improved, customised adverts. Finally, after the previously mentioned matching process, Facebook deletes the contact data.
To deliver optimised advertisements, Facebook only uses event data, if they have been combined with other data (that have been collected by Facebook in other ways). Facebook also uses event data for the purposes of security, protection, development and research. Many of these data are transmitted to Facebook via cookies. Cookies are little text files, that are used for storing data or information in browsers. Depending on the tools used, and on whether you are a Facebook member, a different number of cookies are placed in your browser. In the descriptions of the individual Facebook tools we will go into more detail on Facebook cookies. You can also find general information about the use of Facebook cookies at
https://www.facebook.com/policies/cookies.
How long and where are the data stored?
Facebook fundamentally stores data, until they are no longer of use for their own services and products. Facebook has servers for storing their data all around the world. However, customer data is cleared within 48 hours after they have been matched with their own user data.
How can I erase my data or prevent data retention?
In accordance with the General Data Protection Regulation (GDPR) you have the right of information, rectification, transfer and deletion of your data.
The collected data is only fully deleted, when you delete your entire Facebook account. Deleting your Facebook account works as follows:
1) Click on settings in the top right side in Facebook.
2) Then, click “Your Facebook information“ in the left column.
3) Now click on “Deactivation and deletion”.
4) Choose “Permanently delete account“ and then click on “Continue to account deletion“. 5) Enter your password, click on “continue“ and then on “Delete account“.
The retention of data Facebook receives via our site is done via cookies (e.g. with social plugins), among others. You can deactivate, clear or manage both all and individual cookies in your browser. How this can be done differs depending on the browser you use. The following instructions show, how to manage cookies in your browser:
Chrome: Clear, enable and manage cookies in Chrome Safari: Manage cookies and website data in Safari Firefox: Clear cookies and site data in Firefox
Internet Explorer: Delete and manage cookies Microsoft Edge: Delete cookies in Microsoft Edge
If you generally do not want to allow any cookies at all, you can set up your browser to notify you whenever a cookie is about to be set. This gives you the opportunity to decide upon the permission or deletion of every single cookie.
Legal basis
If you have consented to your data being processed and stored by integrated Facebook tools, this consent is the legal basis for data processing (Art. 6 para. 1 lit. a GDPR). Generally, your data is
also stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f GDPR) to maintain fast and good communication with you or other customers and business partners. Nevertheless, we only use these tools if you have given your consent. Most social media platforms also set cookies on your browser to store data. We therefore recommend you to read our privacy policy about cookies carefully and to take a look at the privacy policy or Facebook’s cookie policy.
Facebook also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.
Facebook uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Facebook to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847
We hope we could give you an understanding of the most important information about the use of Facebook tools and data processing. If you want to find out more on how Facebook use your data, we recommend reading the data policies at https://www.facebook.com/about/privacy/update.
Instagram Privacy Policy
Instagram Privacy Policy Overview
Affected parties: website visitors
Purpose: optimising our service
Processed data: includes data on user behaviour, information about your device and IP address.
More details can be found in the privacy policy below.
Storage period: until Instagram no longer needs the data for its purposes
Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)
What is Instagram?
We have integrated functions of Instagram to our website. Instagram is a social media platform of the company Instagram LLC, 1601 Willow Rd, Menlo Park CA 94025, USA. Since 2012, Instagram is a subsidiary company of Facebook Inc. and is a part of Facebook’s products. The inclusion of Instagram’s contents on our website is called embedding. With this, we can show you Instagram contents such as buttons, photos or videos directly on our website. If you open websites of our online presence, that have an integrated Instagram function, data gets transmitted to, as well as stored and processed by Instagram. Instagram uses the same systems and technologies as Facebook. Therefore, your data will be processed across all Facebook firms.
In the following, we want to give you a more detailed insight on why Instagram collects data, what
data these are and how you can control data processing. As Instagram belongs to Facebook Inc., we have, on the one hand received this information from the Instagram guidelines, and on the other hand from Facebook’s Data Policy.
Instagram is one of the most famous social media networks worldwide. Instagram combines the benefits of a blog with the benefits of audio-visual platforms such as YouTube or Vimeo. To “Insta“ (how the platform is casually called by many users) you can upload photos and short videos, edit them with different filters and also share them to other social networks. Also, if you do not want to be active on Instagram yourself, you can just follow other interesting users.
Why do we use Instagram on our website?
Instagram is a social media platform whose success has skyrocketed within recent years. Naturally, we have also reacted to this boom. We want you to feel as comfortable as possible on our website. Therefore, we attach great importance to diversified contents. With the embedded Instagram features we can enrich our content with helpful, funny or exciting Instagram contents. Since Instagram is a subsidiary company of Facebook, the collected data can also serve us for customised advertising on Facebook. Hence, only persons who are genuinely interested in our products or services can see our ads.
Instagram also uses the collected data for tracking and analysis purposes. We receive summarised statistics and therefore more insight to your wishes and interests. It is important to mention that these reports do not identify you personally.
What data is stored by Instagram?
Whenever you land on one of our sites, which have Instagram functions (i.e. Instagram photos or plugins) integrated to them, your browser automatically connects with Instagram’s servers. Thereby, data is sent to, as well as saved and processed by Instagram. This always happens, whether you have an Instagram account or not. Moreover, it includes information on our website, your computer, your purchases, the advertisements you see and on how you use our offer. The date and time of your interaction is also stored. If you have an Instagram account or are logged in, Instagram saves significantly more data on you.
Facebook distinguishes between customer data and event data. We assume this is also the case for Instagram. Customer data are for example names, addresses, phone numbers and IP addresses. These data are only transmitted to Instagram, if they have been “hashed” first. Thereby, a set of data is transformed into a string of characters, which encrypts any contact data. Moreover, the aforementioned “event data“ (data on your user behaviour) is transmitted as well. It is also possible, that contact data may get combined with event data. The collected data data is matched with any data Instagram already has on you.
Furthermore, the gathered data are transferred to Facebook via little text files (cookies) which usually get set in your browser. Depending on the Instagram function used, and whether you have an Instagram account yourself, the amount of data that gets stored varies.
We assume data processing on Instagram works the same way as on Facebook. Therefore, if you
have an account on Instagram or have visited www.instagram.com, Instagram has set at least one cookie. If this is the case, your browser uses the cookie to send information to Instagram, as soon as you come across an Instagram function. No later than 90 days (after matching) the data is deleted or anonymised. Even though we have studied Instagram’s data processing in-depth, we cannot tell for sure what exact data Instagram collects and retains.
In the following we will show you a list of the least cookies placed in your browser when click on an Instagram function (e.g. button or an Insta picture). In our test we assume you do not have an Instagram account, since if you would be logged in to your Instagram account, your browser would place significantly more cookies.
The following cookies were used in our test:
Name: csrftoken
Value: “”
Purpose: This cookie is most likely set for security reasons to prevent falsifications of requests. We could not find out more information on it.
Expiry date: after one year
Name: mid
Value: “”
Purpose: Instagram places this cookie to optimise its own offers and services in- and outside of Instagram. The cookie allocates a unique user ID.
Expiry date: after end of session
Name: fbsr_311946593124024
Value: no information
Purpose: This cookie stores the login request of Instagram app users. Expiry date: after end of session
Name: rur
Value: ATN
Purpose: This is an Instagram cookie which guarantees functionality on Instagram. Expiry date: after end of session
Name: urlgen
Value: “{”194.96.75.33”: 1901}:1iEtYv:Y833k2_UjKvXgYe311946593” Purpose: This cookie serves Instagram’s marketing purposes. Expiry date: after end of session
Note: We do not claim this list to be exhaustive. The cookies that are placed in each individual case, depend on the functions embedded as well as on your use of Instagram.
How long and where are these data stored?
Instagram shares the information obtained within the Facebook businesses with external partners and persons you are globally connected with. Data processing is done according to Facebook’s internal data policy. Your data is distributed to Facebook’s servers across the world, partially for security reasons. Most of these servers are in the USA.
How can I erase my data or prevent data retention?
Thanks to the General Data Protection Regulation (GDPR), you have the right of information, rectification, transfer and deletion of your data. Furthermore, you can manage your data in Instagram’s settings. If you want to delete your data on Instagram completely, you will have to delete your Instagram account permanently.
And this is how an Instagram account can be deleted:
First, open the Instagram app. Then, navigate to your profile page, select the three bars in the top right, choose “Settings” and then click “Help”. Now, you will be redirected to the company’s website, where you must click on “Managing Your Account” and then “Delete Your Account”.
When you delete your account completely, Instagram deletes posts such as your photos and status updates. Any information other people shared about you are not a part of your account and do therefore not get deleted.
As mentioned before, Instagram primarily stores your data via cookies. You can manage, deactivate or delete these cookies in your browser. Depending on your browser, managing them varies a bit. We will show you the instructions of the most relevant browsers here.
Chrome: Clear, enable and manage cookies in Chrome
Safari: Manage cookies and website data in Safari
Firefox: Clear cookies and site data in Firefox
Internet Explorer: Delete and manage cookies
Microsoft Edge: Delete cookies in Microsoft Edge
Generally, you can set your browser to notify you whenever a cookie is about to be set. Then you can individually decide upon the permission of every cookie.
Legal basis
If you have consented to the processing and storage of your data by integrated social media elements, this consent is the legal basis for data processing (Art. 6 para. 1 lit. a GDPR) . Generally, your data is also stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f GDPR) to maintain fast and good communication with you or other customers and business partners. We only use the integrated social media elements if you have given your consent. Most social media platforms also place cookies in your browser to store data. We therefore recommend you to read our privacy policy about cookies carefully and to take a look at the privacy policy or the cookie policy of the respective service provider.
Instagram and Facebook also process data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfer to the USA. This can be associated with various risks to the legality and security of data processing.
As a basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfers there, Facebook uses standard contractual clauses approved by the EU Commission (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Facebook to comply with the EU’s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847
We have tried to give you the most important information about data processing by Instagram. On
https://help.instagram.com/519522125107875
you can take a closer look at Instagram’s data guidelines.
LinkedIn Privacy Policy
LinkedIn Privacy Policy Overview
Affected parties: website visitors
Purpose: optimisation of our service
Processed data: includes data on user behaviour, information about your device and IP address.
More details can be found in the privacy policy below.
Storage period: the data is generally deleted within 30 days
Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)
What is LinkedIn?
On our website we use social plugins from the social media network LinkedIn, of the LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Social plugins can be feeds, content sharing or a link to our LinkedIn page. Social plugins are clearly marked with the well- known LinkedIn logo and for example allow sharing interesting content directly via our website. Moreover, LinkedIn Ireland Unlimited Company Wilton Place in Dublin is responsible for data processing in the European Economic Area and Switzerland.
By embedding these plugins, data can be sent to, as well as stored and processed by LinkedIn. In this privacy policy we want to inform you what data this is, how the network uses this data and how you can manage or prevent data retention.
LinkedIn is the largest social network for business contacts. In contrast to e.g. Facebook, LinkedIn focuses exclusively on establishing business connections. Therefore, companies can present services and products on the platform and establish business relationships. Many people also use LinkedIn to find a job or to find suitable employees for their own company. In Germany alone, the network has over 11 million members. In Austria there are about 1.3 million.
Why do we use LinkedIn on our website?
We know how busy you are. You just cannot keep up with following every single social media channel. Even if it would really be worth it, as it is with our channels, since we keep posting interesting news and articles worth spreading. Therefore, on our website we have created the opportunity to share interesting content directly on LinkedIn, or to refer directly to our LinkedIn page. We consider built-in social plugins as an extended service on our website. The data LinkedIn collects also help us to display potential advertising measures only to people who are interested in our offer.
What data are stored by LinkedIn?
LinkedIn stores no personal data due to the mere integration of social plugins. LinkedIn calls the data generated by plugins passive impressions. However, if you click on a social plugin to e.g. share our content, the platform stores personal data as so-called “active impressions”. This happens regardless of whether you have a LinkedIn account or not. If you are logged in, the collected data will be assigned to your account.
When you interact with our plugins, your browser establishes a direct connection to LinkedIn’s servers. Through that, the company logs various usage data. These may include your IP address, login data, device information or information about your internet or cellular provider. If you use LinkedIn services via your smartphone, your location may also be identified (after you have given permission). Moreover, LinkedIn can share these data with third-party advertisers in “hashed” form. Hashing means that a data set is transformed into a character string. This allows data to be encrypted, which prevents persons from getting identified.
Most data on of your user behaviour is stored in cookies. These are small text files that usually get placed in your browser. Furthermore, LinkedIn can also use web beacons, pixel tags, display tags and other device recognitions.
Various tests also show which cookies are set when a user interacts with a social plug-in. We do not claim for the information we found to be exhaustive, as it only serves as an example. The following cookies were set without being logged in to LinkedIn:
Name: bcookie
Value: =2&34aab2aa-2ae1-4d2a-8baf-c2e2d7235c16311946593-
Purpose: This cookie is a so-called “browser ID cookie” and stores your identification number (ID). Expiry date: after 2 years
Name: lang
Value: v=2&lang=en-gb
Purpose:This cookie saves your default or preferred language. Expiry date: after end of session
Name: lidc
Value: 1818367:t=1571904767:s=AQF6KNnJ0G311946593...
Purpose:This cookie is used for routing. Routing records how you found your way to LinkedIn and how you navigate through the website.
Expiry date: after 24 hours
Name: rtc
Value: kt0lrv3NF3x3t6xvDgGrZGDKkX
Purpose:No further information could be found about this cookie. Expiry date: after 2 minutes
Name: JSESSIONID
Value: ajax:3119465932900777718326218137
Purpose: This is a session cookie that LinkedIn uses to maintain anonymous user sessions through the server.
Expiry date: after end of session
Name: bscookie
Value: “v=1&201910230812...
Purpose: This cookie is a security cookie. LinkedIn describes it as a secure browser ID cookie. Expiry date: after 2 years
Name: fid
Value: AQHj7Ii23ZBcqAAAA...
Purpose: We could not find any further information about this cookie. Expiry date: after 7 days
Note: LinkedIn also works with third parties. That is why we identified the Google Analytics cookies _ga and _gat in our test.
How long and where are the data stored?
In general, LinkedIn retains your personal data for as long as the company considers it necessary for providing its services. However, LinkedIn deletes your personal data when you delete your account. In some exceptional cases, LinkedIn keeps some summarised and anonymised data, even account deletions. As soon as you delete your account, it may take up to a day until other people can no longer see your data. LinkedIn generally deletes the data within 30 days. However, LinkedIn retains data if it is necessary for legal reasons. Also, data that can no longer be assigned to any person remains stored even after the account is closed. The data are stored on various servers in America and presumably also in Europe.
How can I delete my data or prevent data retention?
You have the right to access and delete your personal data at any time. In your LinkedIn account you can manage, change and delete your data. Moreover, you can request a copy of your personal data from LinkedIn.
How to access account data in your LinkedIn profile:
In LinkedIn, click on your profile icon and select the “Settings & Privacy” section. Now click on “Privacy” and then on the section “How LinkedIn uses your data on”. Then, click “Change” in the row with “Manage your data and activity”. There you can instantly view selected data on your web activity and your account history.
In your browser you also have the option of preventing data processing by LinkedIn. As mentioned above, LinkedIn stores most data via cookies that are placed in your browser. You can manage, deactivate or delete these cookies. Depending on which browser you have, these settings work a little different. You can find the instructions for the most common browsers here:
Chrome: Clear, enable and manage cookies in Chrome Safari: Manage cookies and website data in Safari Firefox: Clear cookies and site data in Firefox
Internet Explorer: Delete and manage cookies Microsoft Edge: Delete cookies in Microsoft Edge
You can generally set your browser to always notify you when a cookie is about to be set. Then you can always decide individually whether you want to allow the cookie or not.
Legal basis
If you have consented to the processing and storage of your data by integrated social media elements, your consent is the legal basis for data processing (Art. 6 para. 1 lit. a GDPR). Generally, your data is also stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f GDPR) to maintain fast and good communication with you or other customers and business partners. We only use the integrated social media elements if you have given your consent. Most social media platforms also place cookies in your browser to store data. We therefore recommend you to read our privacy policy about cookies carefully and take a look at the privacy policy or the cookie policy of the respective service provider.
LinkedIn also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.
LinkedIn uses standard contractual clauses approved by the EU Commission as the basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway, and especially in the USA) or data transfer there (= Art. 46, paragraph 2 and 3 of the GDPR). These clauses oblige LinkedIn to comply with the EU’s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847
We have tried to provide you with the most important information about data processing by
LinkedIn. On https://www.linkedin.com/legal/privacy-policy you can find out more on data processing by the social media network LinkedIn.
Online Marketing
Online Marketing Privacy Policy Overview
Affected parties: visitors to the website
Purpose: Evaluation of visitor information for website optimisation
Processed data: Access statistics containing data such as access location, device data, access duration and time, navigation behaviour, click behaviour and IP addresses. Personal data such as name or email address may also be processed. You can find more details on this from the respective Online Marketing tool.
Storage period: depending on the Online Marketing tools used
Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)
What is Online Marketing?
Online Marketing refers to all measures that are carried out online to achieve marketing goals, such as increasing brand awareness or doing business transactions. Furthermore, our Online Marketing measures aim to draw people’s attention to our website. In order to be able to show our offer to many interested people, we do Online Marketing. It mostly is about online advertising, content marketing or search engine optimisation. For this, personal data is also stored and processed, to enable us to use Online Marketing efficiently and targeted. On the one hand, the data help us to only show our content to people who are interested in it. On the other hand, it helps us to measure the advertising success of our Online Marketing measures.
Why do we use Online Marketing tools?
We want to show our website to everyone who is interested in our offer. We are aware that this is not possible without conscious measures being taken. That is why we do Online Marketing. There are various tools that make working on our Online Marketing measures easier for us. These also provide suggestions for improvement via data. Thus, we can target our campaigns more precisely to our target group. The ultimate purpose of these Online Marketing tools is to optimise our offer.
Which data are processed?
For our Online Marketing to work and to measure its success, user profiles are created and data are e.g. stored in cookies (small text files). With the help of this data, we can not only advertise in the traditional way, but also present our content directly on our website in the way you prefer. There are various third-party tools that offer these functions and thus collect and store your data accordingly. The aforementioned cookies e.g. store the pages you visit on our website, how long you view these pages, which links or buttons you click or which website you came from. What is more, technical information may also be stored. This may include e.g. your IP address, the browser and device you use to visit our website or the time you accessed our website as well as the time you left. If you have agreed for us to determine your location, we can also store and process it.
Your IP address is stored in pseudonymised form (i.e. shortened). What is more, distinct data that directly identify you as a person, such as your name, address or email address, are only stored in pseudonymised for advertising and Online Marketing purposes. With this data we cannot identify you as a person and only retain the pseudonymised information that is stored in your user profile.
Under certain circumstances, cookies may also be utilised, analysed and used for advertising purposes on other websites that use the same advertising tools. Thus, your data may then also be stored on the servers of the respective provider of the advertising tool.
In rare exceptions, unique data (name, email address, etc.) may also be stored in the user profiles. This can happen, if you are for example a member of a social media channel that we use for our Online Marketing measures and if the network connects previously received data with the user profile.
We only ever receive summarised information from the advertising tools we use that do store data on their servers. We never receive data that can be used to identify you as an individual. What is more, the data only shows how well-placed advertising measures have worked. For example, we can see what measures have caused you or other users to visit our website and purchase a service or product. Based on these analyses we can improve our advertising offer in the future and adapt it more precisely to the needs and wishes of people who are interested.
Duration of data processing
Below we will inform you on the duration of data processing, provided we have this information. In general, we only process personal data for as long as is absolutely necessary to provide our services and products. Data stored in cookies are retained for different lengths of time. Some cookies are deleted after you leave a website, while others may be stored in your browser for a number of years. However, in the respective privacy policies of the respective provider, you will usually find detailed information on the individual cookies this provider uses.
Right of withdrawal
You also retain the right and the option to revoke your consent to the use of cookies or third-party providers at any time. This can be done either via our cookie management tool or via other opt-out functions. You can for example also prevent data collection by cookies if you manage, deactivate or erase cookies in your browser. The legality of the processing remains unaffected to the point of revocation.
Since Online Marketing tools usually use cookies, we also recommend you to read our privacy policy on cookies. If you want to find out which of your data is stored and processed, you should read the privacy policies of the respective tools.
Legal basis
If you have consented to the use of third-party providers, then this consent is the legal basis for the corresponding data processing. According to Art. 6 para. 1 lit. a GDPR (consent) , this consent is the legal basis for personal data processing, as may be done when data is collected by online marketing tools.
Moreover, we have a legitimate interest in measuring our online marketing activities in anonymised form, in order to use this data for optimising our offer and our Marketing. The corresponding legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests) . Nevertheless, we only use these tools if you have given your consent.
Information on special online marketing tools can be found in the following sections, provided this information is available.
Google Ads (Google AdWords) Conversion Tracking Privacy Policy
Google Ads (Google AdWords) Conversion Tracking Privacy Policy Overview
Affected parties: visitors to the website
Purpose: economic success and service optimisation.
Processed data: Access statistics that contain data such as access location, device data, access duration and time, navigation behaviour, click behaviour and IP addresses. Personal data such as name or email address may also be processed.
Storage period: Conversion cookies usually expire after 30 days and do not transmit any personal data
Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit.f GDPR (legitimate interests)
What is Google Ads conversion tracking?
We use Google Ads (previously Google AdWords) as an online marketing measure, to advertise our products and services. Thus, we want to draw more people’s attention on the internet to the high quality of our offers. As part of our advertising measures with Google Ads, we use the conversion tracking of Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”) on our website. With the aid of this free tracking tool we can tailor our advertising offer better to your interests and needs. In the following article we will explain, why we use conversion tracking, what data gets saved and how you can prevent this data retention.
Google Ads (previously Google AdWords) is the internal online advertising sxstem of the company Google LLC. We are convinced of our offer‘s quality and would like as many people as possible to discover our website. For this, Google Ads offers the best platform within the online environment. Of course, we also want to get an overview of the cost-benefit factor of our advertising campaigns. Thence, we use Google Ads’ conversion tracking tool.
But what is a conversion actually? A conversion occurs, when you turn from an interested visitor into an acting website visitor. This happens every time you click on our ad and then make another action, such as paying a visit to our website. With Google’s conversion tracking tool, we can understand what happens after a user clicks our Google ad. It shows us for instance if products get bought, services are used or whether users have subscribed to our newsletter.
Why do we use Google Ads conversion tracking on our website?
We use Google Ads to show our offer also across other websites. Our aim is for our advertising campaigns to reach only those people, who are interested in our offers. With the conversion tracking tool, we see what keywords, ads, ad groups and campaigns lead to the desired customer actions. We see how many customers interact with our ads on a device, to then convert. With this data we can calculate our cost-benefit-factor, measure the success of individual ad campaigns and therefore optimise our online marketing measures. With the help of the obtained data we can give our website a more interesting design and customise our advertising offer better to your needs.
What data is stored with Google Ads conversion tracking?
For a better analysis of certain user actions, we have integrated a conversion tracking tag, or code snippet to our website. Therefore, if you click one of our Google ads, a Google domain stores the cookie “conversion” on your computer (usually in the browser) or on your mobile device. Cookies are little text files that save information on your computer.
Here are data of the most significant cookies for Google’s conversion tracking:
Name: Conversion
Value: EhMI_aySuoyv4gIVled3Ch0llweVGAEgt-mr6aXd7dYlSAGQ311946593-3
Purpose: This cookie saves every conversion you make on our website after you came to us via a Google ad.
Expiry date: after 3 months
Name: _gac
Value: 1.1558695989.EAIaIQobChMIiOmEgYO04gIVj5AYCh2CBAPrEAAYASAAEgIYQfD_BwE Purpose: This is a classic Google Analytics Cookie that records various actions on our website. Expiry date: after 3 months
Note: The cookie _gac only appears in connection with Google Analytics. The above list does not claim to be exhaustive, as Google repeatedly change the cookies they use for analytical evaluation.
As soon as you complete an action on our website, Google identifies the cookie and saves your action as a so-called conversion. For as long as you surf our website, provided the cookie has not expired, both Google and us can determine that you found your way to us via a Google ad. Then, the cookie is read and sent back to Google Ads, together with the conversion data. Moreover, other cookies may also be used for measuring conversions. Google Ads‘ conversion tracking can be fine- tuned and improved with the aid of Google Analytics. Furthermore, ads which Google displays in various places across the web, might be placed under our domain with the name “__gads” or “_gac”. Since September 2017, analytics.js retains various campaign information with the _gac cookie. This cookie stores data, as soon as you open one of our sites that has been set up for Google Ads’ auto- tagging. In contrast to cookies that are placed for Google domains, Google can only read these conversion cookies when you are on our website. We do neither collect nor receive any personal data. We do obtain a report with statistical evaluations by Google. With the help thereof, we can not only see the total number of users who clicked our ad, but also what advertising measures were well received.
How long and where is the data stored?
At this point we want to reiterate, that we have no influence on how Google use the collected data. According to Google, the data are encrypted and stored on a secure server. In most cases, conversion cookies expire after 30 days, and do not transmit any personalised data. The cookies named “conversion“ and “_gac“ (which is used with Google Analytics) have an expiry date of 3 months.
How can I erase my data or prevent data retention?
You have the possibility to opt out of Google Ads’ conversion tracking. The conversion tracking can be blocked by deactivating the conversion tracking cookie via your browser. If you do this, you will not be considered for the statistic of the tracking tool. You can change the cookie settings in your browser anytime. Doing so, works a little different in every browser. Hence, in the following you will find an instruction on how to manage cookies in your browser:
Chrome: Clear, enable and manage cookies in Chrome Safari: Manage cookies and website data in Safari Firefox: Clear cookies and site data in Firefox
Internet Explorer: Delete and manage cookies Microsoft Edge: Delete cookies in Microsoft Edge
If you generally do not want to allow any cookies at all, you can set up your browser to notify you whenever a potential cookie is about to be set. This lets you decide upon permitting or denying the cookie’s placement. By downloading and installing the browser plugin at https://support.google.com/ads/answer/7395996 you can also deactivate all “advertising cookies”. Please consider that by deactivating these cookies, you cannot prevent all advertisements, only personalised ads.
Legal basis
If you have consented to the use of Google Ads Conversion Tracking, your consent is the legal basis for the corresponding data processing. According to Art. 6 para. 1 lit. a GDPR (consent), this consent is the legal basis for personal data processing, as may be done when collected by Google Ads Conversion Tracking.
We also have legitimate interest in using Google Ads Conversion Tracking to optimise our online service and marketing measures. The corresponding legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests). Nevertheless, we only use Google Ads Conversion Tracking if you have consented to it.
Google also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.
Google uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Google to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847
The Google Ads Data Processing Terms, which reference the standard contractual clauses, can be found at https://business.safety.google/intl/en/adsprocessorterms/
If you would like to find out more about data protection at Google, we recommend Google’s privacy policy at: https://policies.google.com/privacy?hl=en-GB.
HubSpot privacy policy
On our website, we use HubSpot, which is a tool for digital marketing. The provider of this service is the American company HubSpot Inc.. The responsible entity for the European region is the Irish company HubSpot (1 Sir John Rogerson’s Quay, Dublin 2, Ireland).
HubSpot also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.
HubSpot uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway, and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige HubSpot to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847
You can find out more about HubSpot’s data processing in their privacy policy at https://legal.hubspot.com/de/privacy-policy.
Lead Forensics Privacy Policy
On our website we use Lead Forensics, a lead generation software. The provider of this service is the British company Lead Forensics 4 Old Park Lane, Mayfair, London, Great Britain. You can find out more on the data processed by using Lead Forensics in their Privacy Policy at https://www.leadforensics.com/privacy-and-cookies/.
Cookie Consent Management Platform
Cookie Consent Management Platform Overview
Affected parties: Website visitors
Purpose: Obtaining and managing consent to certain cookies and thus the use of certain tools Processed data: data for managing cookie settings such as IP address, time of consent, type of consent and individual consent. You can find more details on this directly with the tool that is being used.
Storage period: depends on the tool used, periods of several years can be assumed
Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)
What is a cookie consent management platform?
We use a Consent Management Platform (CMP) software on our website that makes it easier for us and you to handle the scripts and cookies used correctly and securely. The software automatically creates a cookie pop-up, scans and controls all scripts and cookies, provides you with the cookie consent required under data protection law and helps you and us to keep track of all cookies. Most cookie consent management tools identify and categorize all existing cookies. As a website visitor, you then decide for yourself whether and which scripts and cookies you allow or not. The following graphic shows the relationship between browser, web server and CMP.
Why do we use a cookie management tool?
Our goal is to offer you the best possible transparency in the area of data protection. We are also legally obliged to do so. We want to inform you as well as possible about all tools and all cookies that can save and process your data. It is also your right to decide for yourself which cookies you accept and which you do not. In order to grant you this right, we first need to know exactly which cookies actually landed on our website. Thanks to a cookie management tool, which regularly scans the website for all cookies present, we know about all cookies and can provide you with GDPR- compliant information. You can then use the consent system to accept or reject cookies.
Which data are processed?
As part of our cookie management tool, you can manage each individual cookie yourself and have complete control over the storage and processing of your data. The declaration of your consent is stored so that we do not have to ask you every time you visit our website and we can also prove your consent if required by law. This is saved either in an opt-in cookie or on a server. The storage time of your cookie consent varies depending on the provider of the cookie management tool. Usually this data (e.g. pseudonymous user ID, time of consent, detailed information on the cookie categories or tools, browser, device information) is stored for up to two years.
Duration of data processing
We will inform you below about the duration of the data processing if we have further information. In general, we only process personal data for as long as is absolutely necessary for the provision of our services and products. Data stored in cookies are stored for different lengths of time. Some cookies are deleted after you leave the website, others may be stored in your browser for a few years. The exact duration of the data processing depends on the tool used, in most cases you should be prepared for a storage period of several years. In the respective data protection declarations of the individual providers, you will usually receive precise information about the duration of the data processing.
Right of objection
You also have the right and the option to revoke your consent to the use of cookies at any time. This works either via our cookie management tool or via other opt-out functions. For example, you can also prevent data collection by cookies by managing, deactivating or deleting cookies in your browser.
Information on special cookie management tools can be found – if available – in the following sections.
Legal basis
If you agree to cookies, your personal data will be processed and stored via these cookies. If we are allowed to use cookies with your consent (Article 6 paragraph 1 lit. a GDPR), this consent is also the legal basis for the use of cookies and the processing of your data. In order to be able to manage the consent to cookies and to enable you to give your consent, a cookie consent management platform software is used. The use of this software enables us to operate the website in an efficient and legally compliant manner, which is a legitimate interest (Article 6 paragraph 1 lit. f GDPR).
Usercentrics Privacy Policy
On our website we use Usercentrics, which is a cookie consent management plattform (CMP). The service provider is the German company Usercentrics GmbH, Sendlinger Straße 7, 80331 München, Germany. You can find out more about the data that is processed by using Usercentrics in their Privacy Policy at https://usercentrics.com/privacy-policy.
Payment providers
Payment Providers Privacy Policy Overview
Affected parties: visitors to the website
Purpose: To enable and optimise the payment process on our website
Processed data: data such as name, address, bank details (account number, credit card number, passwords, TANs, etc.), IP address and contract data
You can find more details on this directly from the payment provider tool that is being used. Storage period: depending on the payment provider that is being used
Legal basis: Art. 6 paragraph 1 lit. b GDPR (performance of a contract)
What is a payment provider?
On our website we use online payment systems, which enable us as well as you to have a secure and smooth payment process available. Among other things, personal data may also be sent to the respective payment provider, where it may also be stored and processed. Payment providers are online payment systems that enable you to place an order via online banking. The payment processing is carried out by the payment provider of your choice. We will then receive information about the payment. This method can be used by any user who has an active online banking account with a PIN and TAN. There are hardly any banks that do not offer or accept such payment methods.
Why do we use payment providers on our website?
With both our website and our embedded online shop, we of course want to offer you the best possible service, so you can feel comfortable on our site and take advantage of our offers. We know that your time is valuable and that payment processing in particular has to work quickly and smoothly. Thus, we offer various payment providers. You can choose your preferred payment provider and pay in the usual way.
Which data are processed?
What exact data that is processed of course depends on the respective payment provider. However, generally data such as name, address, bank details (account number, credit card number, passwords, TANs, etc.) do get stored. This data is necessary for carrying out any transactions. In addition, any contract data and user data, such as when you have visited our website, what content you are interested in or which sub-pages you have clicked, may also be stored. Most payment providers also store your IP address and information about the computer you are using.
Your data is usually stored and processed on the payment providers’ servers. We, so the website operator, do not receive this data. We only get information on whether the payment has gone through or not. For identity and credit checks, it may happen for payment providers to forward data to the appropriate body. The business and privacy policy principles of the respective provider always apply to all payment transactions. Therefore, please always take a look at the general terms and conditions and the privacy policy of the payment provider. You e.g. also have the right to have data erased or rectified at any time. Please contact the respective service provider regarding your rights (right to withdraw, right of access and individual rights).
Duration of data processing
Provided we have further information on this, we will inform you below about the duration of the processing of your data. In general, we only process personal data for as long as is absolutely necessary for providing our services and products. This storage period may be exceeded however, if it is required by law, for example for accounting purposes. We keep any accounting documents of contracts (invoices, contract documents, account statements, etc.) for 10 years (Section 147 AO) and other relevant business documents for 6 years (Section 247 HGB).
Right to object
You always have the right to information, rectification and erasure of your personal data. If you have any questions, you can always contact the person that is responsible for the respective payment provider. You can find contact details for them either in our respective privacy policy or on the relevant payment provider’s website.
You can erase, deactivate or manage cookies in your browser, that payment providers use for their functions. How this works differs a little depending on which browser you are using. Please note, however, that the payment process may then no longer work.
Legal basis
For the processing of contractual or legal relationships (Art. 6 para. 1 lit. b GDPR), we offer other payment service providers in addition to the conventional banking/credit institutions. In the privacy policy of the individual payment providers (such as Amazon Payments, Apple Pay or Discover) you will find a detailed overview of data processing and data storage. In addition, you can always contact the responsible parties should you have any questions about data protection issues.
Provided it is available, you can find information on the special payment providers in the following sections.
Stripe Privacy Policy
Stripe Privacy Policy Overview
Affected parties: website visitors
Purpose: optimising the payment process on our website
Processed data: data such as name, address, bank details (account number, credit card number, passwords, TANs, etc.), IP address and contract data
You can find more details on this in the privacy policy below
Storage period: data is stored until the collaboration with Stripe is terminated
Legal basis: Art. 6 para. 1 lit. b GDPR (contract processing), Art. 6 para. 1 lit. a GDPR (consent)
What is Stripe?
On our website we use a payment tool by Stripe, an American technology company and online payment service. Stripe Payments Europe (Europe Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland) is responsible for customers within the EU. Therefore, if you choose Stripe as your payment method, your payment will be processed via Stripe Payments. Hence, the data required for the payment process is forwarded to Stripe where it is then stored. In this privacy policy we will give you an overview of Stripe’s data processing and retention. Moreover, we will explain why we use Stripe on our website.
The technology company Stripe offers payment solutions for online payments. Stripe enables us to accept credit and debit card payments in our webshop while it handles the entire payment process. A major advantage of Stripe is that you never have to leave our website or shop during the payment process. Moreover, payments are processed very quickly via Stripe.
Why do we use Stripe on our website?
We of course want to offer the best possible service with both our website and our integrated online shop. After all, we would like you to feel comfortable on our site and take advantage of our offers. We know that your time is valuable and therefore, payment processing in particular must work quickly and smoothly. In addition to our other payment providers, with Stripe we have found a partner that guarantees secure and fast payment processing.
What data are stored by Stripe?
If you choose Stripe as your payment method, your personal data (transaction data) will be transmitted to Stripe where it will be stored. These data include the payment method (i.e. credit card, debit card or account number), bank sort code, currency, as well as the amount and the payment date. During a transaction, your name, email address, billing or shipping address and sometimes your transaction history may also be transmitted. These data are necessary for authentication. Furthermore, Stripe may also collect relevant data for the purpose of fraud prevention, financial reporting and for providing its services in full. These data may include your name, address, telephone number as well as your country in addition to technical data about your device (such as your IP address).
Stripe does not sell any of your data to independent third parties, such as marketing agencies or other companies that have nothing to do with Stripe. However, data may be forwarded to internal departments, a limited number of Stripe’s external partners or for legal compliance reasons. What is more, Stripe uses cookies to collect data. Here is a selection of cookies that Stripe may set during the payment process:
Name: m
Value: edd716e9-d28b-46f7-8a55-e05f1779e84e040456311946593-5
Purpose: This cookie appears when you select your payment method. It saves and recognises whether you are accessing our website via a PC, tablet or smartphone.
Expiry date: after 2 years
Name: __stripe_mid
Value: fc30f52c-b006-4722-af61-a7419a5b8819875de9311946593-1
Purpose: This cookie is required for carrying out credit card transactions. For this purpose, the cookie stores your session ID.
Expiry date: after one year
Name: __stripe_sid
Value: 6fee719a-c67c-4ed2-b583-6a9a50895b122753fe
Purpose: This cookie also stores your ID. Stripe uses it for the payment process on our website. Expiry date: after end of the session
How long and where are the data stored?
Generally, personal data are stored for the duration of the provided service. This means that the data will be stored until we terminate our cooperation with Stripe. However, in order to meet legal and official obligations, Stripe may also store personal data for longer than the duration of the provided service. Furthermore, since Stripe is a global company, your data may be stored in any of the countries Stripe offers its services in. Therefore, your data may be stored outside your country, such as in the USA for example.
How can I erase my data or prevent data retention?
Please note that when you use this tool, your data may also be stored and processed outside the EU. Most third countries (including the USA) are not considered secure under current European data protection law. Data must not simply be transferred to, as well as stored and processed in insecure third countries, unless there are suitable guarantees (such as EU standard contractual clauses) between us and the respective non-European service provider.
You always reserve the right to information, correction and deletion of your personal data. Should you have any questions, you can contact the Stripe team at https://support.stripe.com/contact/email.
You can erase, deactivate or manage cookies in your browser that Stripe uses for its functions. This works differently depending on which browser you are using. Please note, however, that if you do so the payment process may no longer work. The following instructions will show you how to manage cookies in your browser:
Chrome: Clear, enable and manage cookies in Chrome Safari: Manage cookies and website data in Safari Firefox: Clear cookies and site data in Firefox
Internet Explorer: Delete and manage cookies Microsoft Edge: Delete cookies in Microsoft Edge
Legal basis
For the processing of contractual or legal relationships (Art. 6 para. 1 lit. b GDPR), we offer the payment service provider Sofortüberweisung in addition to the conventional bank/credit institutions. Successful use of the service also requires your consent (Art. 6 para. 1 lit. a GDPR), provided the use of cookies is necessary for it.
Stripe also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.
Stripe uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Stripe to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847
We have now given you a general overview of Stripe’s data processing and retention. If you want more information, Stripe’s detailed privacy policy at https://stripe.com/at/privacy is a good source.
Audio & Video
Audio & Video Privacy Policy Overview
Affected parties: website visitors
Purpose: service optimisation
Processed data: Data such as contact details, user behaviour, device information and IP addresses can be stored.
You can find more details in the Privacy Policy below.
Storage period: data are retained for as long as necessary for the provision of the service Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)
What are audio and video elements?
We have integrated audio and video elements to our website. Therefore, you can watch videos or listen to music/podcasts directly via our website. This content is delivered by service providers and is obtained from the respective providers’ servers.
Audio and video elements are integrated functional elements of platforms such as YouTube, Vimeo or Spotify. It is usually free of charge to use these portals, but they can also contain paid content. With the integrated elements, you can listen to or view any of their content on our website.
If you use audio or video elements on our website, your personal data may get transmitted to as well as processed and retained by service providers.
Why do we use audio & video elements on our website?
We of course want to provide you with the best offer on our website. And we are aware that content is no longer just conveyed in text and static images. Instead of just giving you a link to a video, we offer you audio and video formats directly on our website. These are entertaining or informative, but ideally they are both. Our service therefore gets expanded and it gets easier for you to access interesting content. In addition to our texts and images, we thus also offer video and/or audio content.
Which data are retained by audio & video elements?
When you visit a page on our website with e.g. an embedded video, your server connects to the service provider’s server. Thus, your data will also be transferred to the third-party provider, where it will be stored. Certain data is collected and stored regardless of whether you have an account with the third party provider or not. This usually includes your IP address, browser type, operating system and other general information about your device. Most providers also collect information on your web activity. This e.g. includes the session duration, bounce rate, the buttons you clicked or information about the website you are using the service on. This data is mostly stored via cookies or pixel tags (also known as web beacons). Any data that is pseudonymised usually gets stored in your browser via cookies. In the respective provider’s Privacy Policy, you can always find more information on the data that is stored and processed.
Duration of data processing
You can find out exactly how long the data is stored on the third-party provider’s servers either in a lower point of the respective tool’s Privacy Policy or in the provider’s Privacy Policy. Generally, personal data is only processed for as long as is absolutely necessary for the provision of our services or products. This usually also applies to third-party providers. In most cases, you can assume that certain data will be stored on third-party providers’ servers for several years. Data can be retained for different amounts of time, especially when stored in cookies. Some cookies are deleted after you leave a website, while others may be stored in your browser for a few years.
Right to object
You also retain the right and the option to revoke your consent to the use of cookies or third-party providers at any time. This can be done either via our cookie management tool or via other opt-out functions. You can e.g. also prevent data retention via cookies by managing, deactivating or erasing cookies in your browser. The legality of the processing up to the point of revocation remains unaffected.
Since the integrated audio and video functions on our site usually also use cookies, we recommend you to also read our general Privacy Policy on cookies. You can find out more about the handling and storage of your data in the Privacy Policies of the respective third party providers.
Legal basis
If you have consented to the processing and storage of your data by integrated audio and video elements, your consent is considered the legal basis for data processing (Art. 6 Para. 1 lit. a GDPR). Generally, your data is also stored and processed on the basis of our legitimate interest (Art. 6 Para. 1 lit. f GDPR) in maintaining fast and good communication with you or other customers and business partners. We only use the integrated audio and video elements if you have consented to it.
YouTube Privacy Policy
YouTube Privacy Policy Overview
Affected parties: website visitors
Purpose: optimising our service
Processed data: Data such as contact details, data on user behaviour, information about your device and IP address may be stored.
You can find more details on this in the privacy policy below.
Storage period: data are generally stored for as long as is necessary for the purpose of the service
Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)
What is YouTube?
We have integrated YouTube videos to our website. Therefore, we can show you interesting videos directly on our site. YouTube is a video portal, which has been a subsidiary company of Google LLC since 2006. The video portal is operated by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. When you visit a page on our website that contains an embedded YouTube video, your browser automatically connects to the servers of YouTube or Google. Thereby, certain data are transferred (depending on the settings). Google is responsible for YouTube’s data processing and therefore Google’s data protection applies.
In the following we will explain in more detail which data is processed, why we have integrated YouTube videos and how you can manage or clear your data.
On YouTube, users can watch, rate, comment or upload videos for free. Over the past few years, YouTube has become one of the most important social media channels worldwide. For us to be able to display videos on our website, YouTube provides a code snippet that we have integrated to our website.
Why do we use YouTube videos on our website?
YouTube is the video platform with the most visitors and best content. We strive to offer you the best possible user experience on our website, which of course includes interesting videos. With the help of our embedded videos, we can provide you other helpful content in addition to our texts and images. Additionally, embedded videos make it easier for our website to be found on the Google search engine. Moreover, if we place ads via Google Ads, Google only shows these ads to people who are interested in our offers, thanks to the collected data.
What data is stored by YouTube?
As soon as you visit one of our pages with an integrated YouTube, YouTube places at least one cookie that stores your IP address and our URL. If you are logged into your YouTube account, by using cookies YouTube can usually associate your interactions on our website with your profile. This includes data such as session duration, bounce rate, approximate location, technical information such as browser type, screen resolution or your Internet provider. Additional data can include contact details, potential ratings, shared content via social media or YouTube videos you added to your favourites.
If you are not logged in to a Google or YouTube account, Google stores data with a unique identifier linked to your device, browser or app. Thereby, e.g. your preferred language setting is maintained. However, many interaction data cannot be saved since less cookies are set.
In the following list we show you cookies that were placed in the browser during a test. On the one hand, we show cookies that were set without being logged into a YouTube account. On the other hand, we show you what cookies were placed while being logged in. We do not claim for this list to be exhaustive, as user data always depend on how you interact with YouTube.
Name: YSC
Value: b9-CV6ojI5Y311946593-1
Purpose: This cookie registers a unique ID to store statistics of the video that was viewed. Expiry date: after end of session
Name: PREF
Value: f1=50000000
Purpose: This cookie also registers your unique ID. Google receives statistics via PREF on how you use YouTube videos on our website.
Expiry date: after 8 months
Name: GPS
Value: 1
Purpose: This cookie registers your unique ID on mobile devices to track GPS locations. Expiry date: after 30 minutes
Name: VISITOR_INFO1_LIVE
Value: 95Chz8bagyU
Purpose: This cookie tries to estimate the user’s internet bandwith on our sites (that have built-in YouTube videos).
Expiry date: after 8 months
Further cookies that are placed when you are logged into your YouTube account:
Name: APISID
Value: zILlvClZSkqGsSwI/AU1aZI6HY7311946593-
Purpose: This cookie is used to create a profile on your interests. This data is then used for personalised advertisements.
Expiry date: after 2 years
Name: CONSENT
Value: YES+AT.de+20150628-20-0
Purpose: The cookie stores the status of a user’s consent to the use of various Google services. CONSENT also provides safety measures to protect users from unauthorised attacks.
Expiry date: after 19 years
Name: HSID
Value: AcRwpgUik9Dveht0I
Purpose: This cookie is used to create a profile on your interests. This data helps to display customised ads.
Expiry date: after 2 years
Name: LOGIN_INFO
Value: AFmmF2swRQIhALl6aL...
Purpose: This cookie stores information on your login data. Expiry date: after 2 years
Name: SAPISID
Value: 7oaPxoG-pZsJuuF5/AnUdDUIsJ9iJz2vdM
Purpose: This cookie identifies your browser and device. It is used to create a profile on your interests.
Expiry date: after 2 years
Name: SID
Value: oQfNKjAsI311946593-
Purpose: This cookie stores your Google Account ID and your last login time, in a digitally signed and encrypted form.
Expiry date: after 2 years
Name: SIDCC
Value: AN0-TYuqub2JOcDTyL
Purpose: This cookie stores information on how you use the website and on what advertisements you may have seen before visiting our website.
Expiry date: after 3 months
How long and where is the data stored?
The data YouTube receive and process on you are stored on Google’s servers. Most of these servers are in America. At https://www.google.com/about/datacenters/locations/?hl=en you can see where Google’s data centres are located. Your data is distributed across the servers. Therefore, the data can be retrieved quicker and is better protected against manipulation.
Google stores collected data for different periods of time. You can delete some data anytime, while other data are automatically deleted after a certain time, and still other data are stored by Google for a long time. Some data (such as elements on “My activity”, photos, documents or products) that are saved in your Google account are stored until you delete them. Moreover, you can delete some data associated with your device, browser, or app, even if you are not signed into a Google Account.
How can I erase my data or prevent data retention?
Generally, you can delete data manually in your Google account. Furthermore, in 2019 an automatic deletion of location and activity data was introduced. Depending on what you decide on, it deletes stored information either after 3 or 18 months.
Regardless of whether you have a Google account or not, you can set your browser to delete or deactivate cookies placed by Google. These settings vary depending on the browser you use. The following instructions will show how to manage cookies in your browser:
Chrome: Clear, enable and manage cookies in Chrome Safari: Manage cookies and website data in Safari Firefox: Clear cookies and site data in Firefox
Internet Explorer: Delete and manage cookies Microsoft Edge: Delete cookies in Microsoft Edge
If you generally do not want to allow any cookies, you can set your browser to always notify you when a cookie is about to be set. This will enable you to decide to either allow or permit each individual cookie.
Legal basis
If you have consented processing and storage of your data by integrated YouTube elements, this consent is the legal basis for data processing (Art. 6 para. 1 lit. a GDPR). Generally, your data is also stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f GDPR) to maintain fast and good communication with you or other customers and business partners. Nevertheless, we only use integrated YouTube elements if you have given your consent. YouTube also sets cookies in your browser to store data. We therefore recommend you to read our privacy policy on cookies carefully and to take a look at the privacy policy or the cookie policy of the respective service provider.
YouTube also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of the data processing.
YouTube uses standard contractual clauses approved by the EU Commission (= Art. 46, paragraphs 2 and 3 of the GDPR) as basis for data processing by recipients based in third countries (which are
outside the European Union, Iceland, Liechtenstein and Norway) or for data transfer there. These
clauses oblige YouTube to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847
Since YouTube is a subsidiary company of Google, Google’s privacy statement applies to both. If you want to learn more about how your data is handled, we recommend the privacy policy at https://policies.google.com/privacy?hl=en.
Video Conferencing & Streaming
Video Conferencing & Streaming Privacy Policy Overview
Affected parties: users of our video conferencing or streaming tools
Purpose: communication and presentation of content
Processed data: Access statistics such as your name, address, contact details, email address, telephone number or IP address. You can find more details on this directly at the video conference or streaming tool that is being used.
Storage duration: depending on the video conferencing or streaming tool
Legal bases: Article 6 (1) (a) GDPR (consent), Article 6 (1) (f) GDPR (legitimate interests), Article 6 (1) (b) GDPR (contract)
What are video conferences & streamings?
We use software programs that enable us to hold video conferences, online meetings, webinars and to utilise display sharing and/or streaming. In a video conference or a streaming, information is transmitted simultaneously via sound and moving images. With such video conference or streaming tools, we can communicate quickly and easily with customers, business partners, clients and employees via the Internet. Of course, when selecting the service provider, we consider the given legal framework.
Generally, third-party providers can process data as soon as you interact with the software program. Third-party video conference providers or streaming solutions use your data and metadata for different purposes. The data helps to e.g. make the tool more secure and to improve the service. Most of the time, the data may also be used for the respective third-party provider’s own marketing purposes.
Why do we use video conferencing & streaming on our website?
We want to communicate digitally, quickly, easily and securely with you, our customers and our business partners. This works best with video conferencing solutions that are very easy to use. Most tools also work directly in your browser and with just a few clicks you can get right to your video meeting. The tools also offer helpful additional features such as chat and screen sharing functions or the possibility of sharing content between meeting participants.
Which data are processed?
If you join our video conference or streaming, your data will also be processed and stored on the servers of the respective service provider.
The exact data that gets stored depends on the respective software. Each provider stores and processes data differently. Generally, however, most providers store your name, address, contact details such as your email address or telephone number and your IP address. Information about the device you are using may also get stored, along with usage data, such as which websites you visit, when you visit a website or which buttons you click. Data that is shared within the video conference (photos, videos, texts) may also be retained.
Duration of data processing
Below we will inform you about the duration of the data processing of the service that is being used, provided we have further information on this. In general, we only process personal data for as long as is absolutely necessary to provide our services and products. Moreover, it is possible that the provider may store your data according to their own requirements, which we have no influence on.
Right to object
You always have the right to information, rectification and erasure of your personal data. If you have any questions, you can always contact the person responsible for the respective video conferencing or streaming tool. You can find contact details either in our specific privacy policy or on the website of the relevant provider.
In your browser you can erase, deactivate or manage cookies that providers use for their functions. This works slightly different, depending on which browser you are using. Please note, however, that functions may not keep working as usual after doing so.
Legal basis
If you have consented to the processing and storage of your data by the respective video or streaming solution, this consent is the legal basis for data processing (Art. 6 para. 1 lit. a GDPR). We may also offer a video conference as part of our services, if there has been a contractual agreement with you in advance (Art. 6 para. 1 lit. b GDPR). Generally, your data is also stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f GDPR) to maintain fast and good communication with you or other customers and business partners, provided you have priorly given consent. Most video or streaming solutions also place cookies in your browser to store data. We therefore recommend you to read our privacy policy about cookies carefully and to take a look at the privacy policy or the cookie policy of the respective service provider.
Provided it is available, you can find information on special video conference and streaming solutions in the following sections.
Skype Privacy Policy
On our wevsite we use Skype, which is a service for chat and video conferencing solutions. The provider of this service is the American company Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA.
Skype also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.
Skype uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Skype to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847
You can find out more about the data that is processed by using Skype in their Privacy Policy at https://privacy.microsoft.com/en-GB/privacystatement.
Recruiting Tools Privacy Policy
Recruiting Tools Privacy Policy Overview
Affected parties: Users who conduct a job application process online or use a recruiting tool Purpose: job application process handling
Processed data: data such as name, address, contact details, email address or telephone number. You can find more details about this directly from the respective recruiting tool. Storage period: if the application is successful, data is retained until the end of the employment relationship. Otherwise the data will be erased after the application process. Legal bases: Art. 6 paragraph 1 lit. a GDPR (consent), Art. 6 paragraph 1 lit. b GDPR (contract), Art. 9 paragraph 2 lit. a. GDPR (processing of special categories)
What are recruiting tools?
Various companies offer software programs that can make application processes much easier. Most systems offer options to filter searches through databases of potential candidates. This enables us to quickly and efficiently find employees who are a great fit for our company. When using recruiting tools or online forms, applicants’ personal data is transmitted, retained and managed. In this general Privacy Policy we also refer to the classic application process via email or online form in addition to recruiting tools. You can find more detailed information on recruiting tools in the Privacy Policies of the respective providers.
Why do we use recruiting tools?
To search for suitable applicants and to administer all application documents, we use software programs and platforms that specialize in application management, taking into account all legal guidelines. So-called recruiting tools usually make the application process easier because the software takes on many administrative tasks and optimizes processes in the application process. In some cases, this enables us to find suitable employees for our company more quickly.
For the conditions of the recruiting process, we refer in detail to the respective job advertisements.
Which data are processed?
If you apply with us, you of course also have to provide us with your data so we can assess your application accordingly. The exact details you provide us depends on the job posting or on the information required in the online form.
Generally, this involves data such as name, address, date of birth and proof of the qualifications required for the job. During the application process, however, not only basic personal data such as name or address may be transmitted, but information about applicants’ health or ethnicity may also be requested so both parties can exercise the applicant’s rights in relation to labor law, social security and social protection, while ensuring to meet the corresponding obligations. These data are called “data of special categories”.
Your application’s data are sent to us via the online form in encrypted nature. Alternatively, you can send your application to us by email. If you opt for the latter, your data will be transmitted in encrypted form, but will not be retained in encrypted form by the servers used to send and receive it.
Duration of data processing
If your application is successful, we can process the data you provide for the employment relationship. If the application does not meet the requirements, we will erase the data we received. The data will also be erased if you withdraw your application. If you agree to join our pool of applicants, we will store your data in this context until you leave the pool of applicants. The same rules apply to the withdrawal as well as to the revocation of your consent.
Right to object
You always have the right and the option to withdraw your consent. The data will be deleted after 6 months at the latest, so we can answer any questions you may have about the application and meet our obligations to provide proof. We also archive invoices for possible reimbursement of travel expenses due to tax law requirements.
Legal basis
If we include you in our application pool, this is done on the basis of your consent (Art. 6 para. 1 lit. a GDPR). We would like to note, that your consent to our application pool is voluntary and has no influence on the application process. Moreover, you can revoke your consent at any time.
In the event of the protection of vital interests, data processing takes place in accordance with Article 9 (2) c. GDPR. For the purposes of health care, occupational medicine, medical diagnostics, care or treatment in the health or social sector or for the administration of systems and services in the health or social sector, personal data is processed in accordance with Art. 9 para. 2 lit. h. GDPR. If you voluntarily provide data of special categories, data processing takes place on the basis of Art. 9 Para. 2 lit. a. GDPR.
Provided this information is available, you can find out more about the special recruiting tools in the following sections.
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