Introduction
With the following data protection declaration, we would like to inform you about which types of your personal data (hereinafter also referred to as “data”) we process for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).
The terms used are not gender-specific.
As of: May 6, 2024
Table of contents
- Introduction
- Responsible person
- Overview of processing
- Relevant legal bases
- Security measures
- Transfer and disclosure of personal data
- Data processing in third countries
- Use of cookies
- Provision of the online offer and web hosting
- Blogs and publication media
- Contacting us
- Newsletter and broad communication
- Advertising communication via email, post, fax or telephone
- Web analysis and optimization
- Online marketing
- Affiliate programs and affiliate links
- Presences in social networks
- Plugins and embedded functions and content
- Deletion of data
- Change and update of the data protection declaration
- Rights of the data subjects
- Definitions
Person responsible
Lucas De Melo, Am Dorfgarten 17, 60435 Frankfurt am Main, Germany
E-mail address: contact (at) academiasquare (dot) com.
Legal info: academiasquare.com/legal
Overview of processing
The following overview summarises the types of data processed and the purposes of their processing and refers to the persons concerned.
Types of data processed
- Inventory data (e.g. names).
- Content data (e.g. text entries).
- Contact data (e.g. e-mail).
- Meta/communication data (e.g. device information).
- Usage data (e.g. websites visited, interest in content, access times).
- Location data (data that indicates the location of an end user’s device).
Categories of data subjects
- Employees (e.g. employees, applicants, former employees).
- Interested parties.
- Communication partners.
- Customers.
- Users (e.g. website visitors, users of online services).
Purposes of processing
- Affiliate tracking.
- Provision of our online offer and User-friendliness.
- Visit action evaluation.
- Cross-device tracking (cross-device processing of user data for marketing purposes).
- Direct marketing (e.g. by email or post).
- Feedback (e.g. collecting feedback via an online form).
- Interest-based and behavior-related marketing.
- Contact requests and communication.
- Conversion measurement (measurement of the effectiveness of marketing measures).
- Profiling (creation of user profiles).
- Remarketing.
- Reach measurement (e.g. Access statistics, recognition of returning visitors).
- Security measures.
- Tracking (e.g. interest/behavior-related profiling, use of cookies).
- Contractual services and service.
- Administration and response to inquiries.
- Target group formation (determination of target groups relevant for marketing purposes or other output of content).
Relevant legal bases
Below we divide the legal bases of the General Data Protection Regulation (GDPR),on the basis of which we process the personal data. Please note that in addition to the provisions of the GDPR, the national data protection regulations in your or our country of residence and domicile may apply. If more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.
- Consent (Art. 6 Para. 1 S. 1 lit. a GDPR) – The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
- Performance of a contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR) – The processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.
- Protection of vital interests (Art. 6 Para. 1 S. 1 lit. d. GDPR) – The processing is necessary to protect the vital interests of the data subject or of another natural person.
- Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR) – The processing is necessary to protect the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data prevail.
National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. This includes in particular the law to protect against misuse of personal data in data processing (Federal Data Protection Act – BDSG). The BDSG contains in particular special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Furthermore, the state data protection laws of the individual federal states may apply.
Security measures
In accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.
The measures include in particular ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, transmission, securing the availability and separation of the data. Furthermore, we have set up procedures that ensure the exercise of the rights of those affected, the deletion of data and reactions to threats to the data. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
Transmission and disclosure of personal data
As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons or that it is disclosed to them. The recipients of this data may include, for example, payment institutions as part of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.
Data processing in third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements.
Subject to express consent orr contractually or legally required transmission, we process or have the data processed only in third countries with a recognized level of data protection, which include the US processors certified under the “Privacy Shield”, or on the basis of special guarantees, such as contractual obligations through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).
Use of cookies
Cookies are text files that store data from websites visited or domains and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after their visit to an online service. The information stored can include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was watched. The term cookies also includes other technologies that perform the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also known as “user IDs”).
The following cookie types and functions are distinguished:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their browser.
- Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users that are used for reach measurement or marketing purposes can be stored in such a cookie.
- First-party cookies: First-party cookies are set by us ourselves.
- Third-party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
- Necessary (also: essential or absolutely necessary) cookies: Cookies can be absolutely necessary for the operation of a website (e.g. to save logins or other user inputs or for security reasons).
- Statistical, marketing and personalization cookies: Cookies are also usually used as part of reach measurement and when the interests of a user or their behavior (e.g. viewing certain content, using functions, etc.) on individual websites are saved in a user profile. Such profiles are used to show users, for example, content that corresponds to their potential interests. This process is also known as “tracking”, i.e. tracking the potential interests of users. If we use cookies or “tracking” technologies, we will inform you separately in our privacy policy or when obtaining your consent.
Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is your declared consent. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and its improvement) or, if the use of cookies is necessary to fulfil our contractual obligations.
General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke a given consent or to object to the processing of your data using cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection using the settings in your browser, e.g. by deactivating the use of cookies (although this may also limit the functionality of our online offering). An objection to the use of cookies for onlineemarketing can also be explained using a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further objection notices in the information on the service providers and cookies used.
Processing of cookie data based on consent: Before we process data as part of the use of cookies or have it processed, we ask users for consent that can be revoked at any time. Before consent has been given, only cookies that are necessary for the operation of our online offer will be used. Their use is based on our interest and the interest of the users in the expected functionality of our online offer.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Affected persons: Users (e.g. website visitors, users of online services).
- Legal basis: Consent (Art. 6 Para. 1 Clause 1 lit. a GDPR), Legitimate interests (Art. 6 Para. 1 Clause 1 lit. f. GDPR).
Provision of the online offer and web hosting
In order to be able to provide our online offer securely and efficiently, we use the services of one or more web hosting providers, whose Servers (or servers managed by them) the online offer can be accessed. For these purposes, we can use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.
The data processed as part of the provision of the hosting offer can include all information concerning the users of our online offer that arises in the context of use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or on websites.
Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files can include the address and name of the websites and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.
The server log files can be used for security purposes, e.g. to avoid overloading the servers (particularly in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability.
- Types of data processed: Content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Affected parties People: Users (e.g. website visitors, users of online services).
- Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 lit. f. GDPR).
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data is only processed for the purposes of the publication medium to the extent that it is necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium in the context of this data protection notice.
Comments and contributions: When users leave comments or other contributions, their IP addresses can be stored on the basis of our legitimate interests. This is done for our security in case someone leaves illegal content in comments and contributions (insults, prohibited political propaganda, etc.). In this case, we ourselves can be held liable for the comment or contribution and are therefore interested in the identity of the author.
We also reserve the right to process user information for the purpose of spam detection based on our legitimate interests.
On the same legal basis, we reserve the right to store the IP addresses of users for the duration of surveys and to use cookies to avoid multiple voting.
The personal information provided in the comments and contributions, any contact and website information as well as the content information will be stored by us permanently until the user objects.
- Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Affected persons: users (e.g. website visitors, users of online services).
- Purposes of Processing: Contractual services and service, feedback (e.g. Collecting feedback via online form), security measures, administration and answering of inquiries.
- Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 Clause 1 lit. f. GDPR), consent (Art. 6 Para. 1 Clause 1 lit. a GDPR), protection of vital interests (Art. 6 Para. 1 Clause 1 lit. d. GDPR).
Contacting us
When you contact us (e.g. via contact form, email, telephone or via social media), the details of the inquiring persons are processed insofar as this is necessary to answer the contact inquiries and any requested measures.
The answer to contact inquiries within the framework of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of the legitimate interests in answering the inquiries.
- Types of data processed: Inventory data (e.g. Names, addresses), contact details (e.g. email, telephone numbers), content data (e.g. text entries, photographs, videos).
- Affected persons: communication partners.
- Purposes of processing: contact requests and communication.
- Legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 Clause 1 lit. f. GDPR).
Newsletter and broad communication
We only send newsletters, emails and other electronic notifications (hereinafter “newsletters”) with the consent of the recipient or legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the consent of the user. In addition, our newsletters contain information about our services and us.
To subscribe to our newsletters To register, it is generally sufficient to provide your email address. However, we may ask you to provide a name so that we can address you personally in the newsletter, or other information if this is required for the purposes of the newsletter.
Double opt-in procedure: Registration for our newsletter is generally carried out using a so-called double opt-in procedure. This means that after registering, you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register with someone else’s email address. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Likewise, changes to your data stored by the shipping service provider are logged.
Deletion and restriction of processing: We can store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address in a blocking list (so-called “blacklist”) for this purpose alone.
The registration process is logged on the basis of our legitimate interests for the purpose of proving that it is carried out properly. If we commission a service provider to send emails, this is done on the basis ofage of our legitimate interests in an efficient and secure shipping system.
Notes on legal bases: The newsletter is sent based on the consent of the recipient or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of advertising to existing customers. If we commission a service provider to send emails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests in order to demonstrate that it was carried out in accordance with the law.
Content: Information about us, our services, promotions and offers.
Analysis and success measurement: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from its server. As part of this retrieval, technical information is initially collected, such as information about the browser and your system, as well as your IP address and the time of retrieval.
This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor that of the shipping service provider, if used, to monitor individual users. Rather, the evaluations serve to identify the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
The evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purposes of using a user-friendly and secure newsletter system that serves both our business interests and meets the expectations of the users.
Unfortunately, a separate revocation of the success measurement is not possible; in this case, the entire newsletter subscription must be canceled or revoked.
- Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
- Affected persons: communication partners.
- Purposes of processing: direct marketing (e.g. by email or post).
- Legal basis: consent (Art. 6 Para. 1 Clause 1 Letter a of GDPR), legitimate interests (Art. 6 Para. 1 Clause 1 Letter f of GDPR).
- Opt-out option: You can cancel your subscription to our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email.
Advertising communication via email, post, fax or telephone
We process personal data for the purposes of advertising communication, which can take place via various channels, such as email, telephone, post or fax, in accordance with legal requirements.
The recipients have the right to revoke consent given at any time or to object to advertising communication at any time.
After revocation or objection, we can store the data required to prove consent for up to three years on the basis of our legitimate interests before we delete it. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time.
- Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
- Affected persons: Communication partners.
- Purposes of processing: Direct marketing (e.g. by e-mail or post).
- Legal basis: Consent (Art. 6 Para. 1 Clause 1 lit. aGDPR), legitimate interests (Art. 6 Para. 1 Clause 1 lit. f. GDPR).
Web analysis and optimization
Web analysis (also known as “reach measurement”) is used to evaluate the flow of visitors to our online offering and can include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online offering or its functions or content are used most frequently or invite reuse. We can also understand which areas require optimization.
In addition to web analysis, we can also use test procedures to test and optimize different versions of our online offering or its components, for example.
For these purposes, so-called user profiles can be created and saved in a file (so-called “cookie”) or similar procedures can be used for the same purpose. This information may include, for example, content viewed, websites visited and elements used there and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, these may also be processed depending on the provider.
The IP addresses of users are also stored. However, we use an IP masking process (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored as part of web analysis, A/B testing and optimization, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, only the information stored in their profiles for the purposes of the respective processes.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times).
- Affected persons: Users (e.g. website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behavior-related profiling, use of cookies), visit action evaluation, profiling (creation of user profiles), interest-based and behavior-related marketing.
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Art. 6 Para. 1 Clause 1 lit. a GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Services and service providers used:
- Google Optimize: Use of Google Analytics data for the purposes of improving areas of our online offering and better aligning our marketing measures with the potential interests of users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://optimize.google.com; Data protection declaration: https://policies.google.com/privacy; Privacy Shield (guaranteeing data protection standards when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; Opt-out option: Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
Online marketing
We process personal data for the purposes of online marketing, which includes in particular the marketing of advertising space or the display ofn advertising and other content (collectively referred to as “content”) based on the potential interests of users and measuring their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used by means of which the information about the user relevant to the presentation of the aforementioned content is stored. This information can include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, these can also be processed.
The IP addresses of the users are also stored. However, we use available IP masking procedures (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear data of the users (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that neither we nor the providers of the online marketing processes know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is usually stored in cookies or using similar processes. These cookies can generally be read later on other websites that use the same online marketing process and analyzed for the purposes of displaying content, as well as supplemented with further data and stored on the server of the online marketing process provider.
In exceptional cases, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing process we use and the network links the users’ profiles with the aforementioned information. Please note that users can make additional agreements with the providers, e.g. by consenting during registration.
We generally only receive access to summarized information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. Conversion measurements are used solely to analyze the success of our marketing measures.
Unless otherwise stated, we ask you to assume that cookies used are stored for a period of two years.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
Target group formation with Google Analytics: We use Google Analytics to display the ads placed within advertising services of Google and its partners only to users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products determined based on the websites visited) that we transmit to Google (so-called “remarketing” or “Google Analytics audiences”). With the help of remarketing audiences, we also want to ensure that our ads correspond to the potential interests of users.
Facebook pixel: With the help of the Facebook pixel, Facebook is able to determine the visitors to our online offering as a target group for the display of ads (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads we place only to those users on Facebook and within the services of partners cooperating with Facebook (so-called “Audience Network” https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offering or who have certain characteristics (e.g. interest in certain topics or products that can be seen from the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interests of users and do not appear annoying. With the help of the Facebook pixel, we cann we also track the effectiveness of Facebook advertisements for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook advertisement (so-called “conversion measurement”).
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (data that indicates the location of an end user’s device), social data (data that is subject to social secrecy (Section 35 SGB I) and is processed, for example, by social insurance providers, social welfare providers or welfare authorities).
- Affected persons: Users (e.g. website visitors, users of online services), interested parties, customers, employees (e.g. employees, applicants, former employees), communication partners.
- Purposes of processing: Tracking (e.g. interest/behavior-related profiling, use of cookies), remarketing, visit action analysis, interest-based and behavior-related marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors), target group formation (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes).
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a GDPR), Legitimate Interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
- Opt-out option: We refer to the data protection information of the respective providers and the objection options specified for the providers (so-called “Opt-Out”). If no explicit opt-out option has been specified, you have the option of deactivating cookies in your browser settings. However, this may restrict the functions of our online offering. We therefore also recommend the following opt-out options, which are offered in summary for the respective regions:
a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://www.youradchoices.ca/choices.
c) USA: https://www.aboutads.info/choices.
d) Cross-regional: https://optout.aboutads.info.
Services and service providers used:
- Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface (and thus integrate, for example, Google Analytics and other Google marketing services into our online offering). The Tag Manager itself (which implements the tags) does not process any personal data of users. With regard to the processing of users’ personal data, reference is made to the following information on Google services. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing data protection standards when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- Google Analytics: online marketing and web analysis; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing data protection level when processing data inn the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; Opt-out option: Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
- Google Ads and conversion measurement: We use the online marketing process “Google Ads” to place advertisements in the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who are likely to be interested in the advertisements. We also measure the conversion of the advertisements. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page with a so-called “conversion tracking tag”. We ourselves do not receive any information with which users can be identified. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing data protection standards when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- Google Ad Manager: We use the “Google Marketing Platform” (and services such as “Google Ad Manager”) to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.). The Google Marketing Platform is characterized by the fact that ads are displayed in real time based on users’ presumed interests. This allows us to display ads for and within our online offering in a more targeted manner in order to only present users with ads that potentially correspond to their interests. If, for example, a user is shown advertisements for products in which he was interested on other online offers, this is referred to as “remarketing”. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing data protection level when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- Google Adsense with personalized ads: We use the Google Adsense service with personalized ads, with the help of which ads are displayed within our online offering and we receive remuneration for their display or other use. ; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing data protection standards when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- Google Adsense with non-personalized ads: We use the Google Adsense service with non-personalized ads, which is used to display ads within our online offering and for which we receive remuneration for displaying them or for other use. ; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (ensuring data protection standards when processing data in the USA): https ://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- Facebook Pixel: Service provider: https://www.facebook.com, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland , Parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Privacy Shield (ensuring data protection level for Processing of data in the USA): https://www.privacyshield .gov/participant?id=a2zt0000000GnywAAC&status=Active; Opt-out option: https://www.facebook.com/ settings?tab=ads.
- Twitter: Twitter marketing and ads; Service provider: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Website: https://twitter.com/de; Privacy Policy: https://www.facebook.com/about/privacy ; Privacy Shield (ensuring data protection standards when processing data in the USA): https ://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active; Opt-out option: https://twitter.com/personalization. li>
Affiliate programs and affiliate links
We include so-called affiliate links or other references (which may include discount codes, for example) in our online offering. on the offers and services of third parties (collectively referred to as “affiliate links”). If users follow the affiliate links or subsequently take advantage of the offers, we may receive a commission or other benefits from these third parties (collectively referred to as ” Commission”).
In order to be able to track whether users have taken advantage of the offers of an affiliate link used by us, it is necessary for the respective third-party providers to know that the users have -Link followed. The assignment of the affiliate links to the respective business transactions or other actions (e.g. purchases) serves solely for the purpose of commission settlement and is canceled as soon as it is no longer required for this purpose.
For the purposes of the aforementioned Assignment of affiliate links, the affiliate links can be supplemented with certain values that are part of the link or can be stored elsewhere, e.g. in a cookie. The values can include in particular the source website (referrer), the time, an online -Identification of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer and an online identifier of the user.
Notes on legal bases: If we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Furthermore, their use can be a component of our (pre)contractual services, provided the use of third-party providers was agreed within this framework. Otherwise, the user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
- Types of data processed: Contract data(e.g. subject matter of the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Affected persons: users (e.g. website visitors, users of online services).
- Purpose of processing: affiliate tracking.
- Legal basis: consent (Art. 6 Para. 1 Clause 1 lit. a GDPR), contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 Clause 1 lit. f. GDPR).
Services and service providers used:
- Amazon affiliate program: Amazon – affiliate program – Amazon and the Amazon logo are trademarks of Amazon.com, Inc. or one of its affiliates. Service providers: Amazon Europe Core S.à.r.l., Amazon EU S.à.r.l, Amazon Services Europe S.à.r.l. and Amazon Media EU S.à.r.l., all four located at 38, avenue John F. Kennedy, L-1855 Luxembourg, and Amazon Instant Video Germany GmbH, Domagkstr. 28, 80807 Munich (together “Amazon Europe”), parent company: Amazon.com, Inc., 2021 Seventh Ave, Seattle, Washington 98121, USA.; Website: https://www.amazon.de; Privacy Policy: https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010; Privacy Shield (guaranteeing data protection standards when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TOWQAA4&status=Active.
Presences in social networks
We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for users because it could, for example, make it more difficult to enforce users’ rights. With regard to US providers who are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we would like to point out that they are thereby committed to complying with EU data protection standards.
In addition, the data of users within social networks is usually processed for market research and advertising purposes. For example, user profiles can be created based on the user’s usage behavior and the resulting interests. The user profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the user’s interests. For these purposes, cookies are usually stored on the user’s computers in which the user’s usage behavior and interests are stored. Furthermore, data can also be stored in the user profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
For a detailed description of the respective processing methods and the objection options (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
- Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Affected persons: Users (e.g. website visitors, users of online services).
- Purposes of processing: Contact requests and communication, tracking (e.g. interest/behavior-related profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
- Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. DSGVO).
Lawte services and service providers:
- Instagram: social network; service provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; website: https://www.instagram.com; privacy policy: https://instagram.com/about/legal/privacy.
- Facebook: social network; service provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Privacy Shield (guaranteeing data protection standards when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Opt-out option: Advertising settings: https://www.facebook.com/settings?tab=ads; Additional information on data protection: Agreement on joint processing of personal data on Facebook pages: https://www.facebook.com/legal/terms/page_controller_addendum, data protection information for Facebook pages: https://www.facebook.com/legal/terms/information_about_page_insights_data.
- LinkedIn: Social network; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Privacy Shield (guaranteeing data protection standards when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active; Possibility of objection (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Twitter: Social network; Service provider: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Privacy Policy: https://twitter.com/de/privacy, (Settings) https://twitter.com/personalization; Privacy Shield (guaranteeing data protection standards when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.
- Xing: Social network; service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; website: https://www.xing.de; Data protection declaration: https://privacy.xing.com/de/datenschutzerklaerung.
Plugins and embedded functions and content
We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These can be, for example, graphics, videos or social media buttons as well as posts (hereinafter uniformly referred to as “content”).
The integration always requires that the third-party providers of this content process the IP address of the users, since without the IP address they would not be able to send the content to their browser. The IP address is therefore required to display this content or functions. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers cann also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user’s device and can contain, among other things, technical information about the browser and operating system, referring websites, the time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, the user’s data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (data that indicates the location of an end user’s device), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos).
- Affected persons: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offer and user-friendliness, contractual services and service, security measures, administration and answering of inquiries.
- Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR), consent (Art. 6 Para. 1 S. 1 lit. a GDPR), contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR).
Services and service providers used:
- Google Fonts: We integrate the fonts (“Google Fonts”) of the provider Google, whereby the user data is used solely for the purpose of displaying the fonts in the user’s browser. The integration is based on our legitimate interests in the technically secure, maintenance-free and efficient use of fonts, their uniform presentation and taking into account possible licensing restrictions for their integration. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing data protection standards when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- Google Maps: We integrate maps from the “Google Maps” service provided by Google. The data processed may include users’ IP addresses and location data, which, however, are not collected without their consent (usually as part of the settings on their mobile devices); service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://cloud.google.com/maps-platform; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing data protection standards when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TRkEAAW&status=Active; Opt-out option: Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
- YouTube Videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (ensuring data protection standards when processing data in the USA): https ://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; Opt-out option: Opt-out plugin: https: //tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
Deletion of data
The The data processed by us will be deleted in accordance with the legal requirements as soon as the consents permitted for processing are revoked or other permissions expire (e.g. if the purpose of processing this data no longer applies or it is no longer required for the purpose).
< p>If the data is not are deleted because they are required for other legally permissible purposes, their processing will be restricted to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that is retained for commercial or tax reasons. or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.
Further information on the deletion of personal data can also be found in the individual data protection notices of this data protection declaration.
Changes and updates to the privacy policy
We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as the changes to the the data processing we carry out makes this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting us.
Rights of the data subjects
As a data subject, you have various rights under the GDPR , which arise in particular from Art. 15 to 18 and 21 GDPR:
- Right of objection: You have the right to object at any time to the processing of your personal data for reasons arising from your particular situation. of personal data concerning you which is based on Art. 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed in order to conduct direct advertising, you have the right to object at any time to the processing of the personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct advertising.
- Right of withdrawal of consent: You have the right to withdraw consent at any time.< /li>
- Right to information: You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with legal requirements.
- Right to rectification: You have the right, in accordance with the statutory provisions, to request that the data concerning you be completed or that inaccurate data concerning you be rectified.
- Right to erasure and restriction of processing: You have the right, in accordance with the statutory provisions, to demand that data concerning you be erased immediately or, alternatively, to request that the processing of the data be restricted in accordance with the statutory provisions. data.
- Right to data portability: You have the right to request data concerning you that you have made available to us in accordance with thelegal requirements in a structured, common and machine-readable format or to request that they be transmitted to another responsible party.
- Complaint to the supervisory authority: You also have the right, in accordance with the legal requirements, to lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, your place of work or the place of the alleged infringement, if you believe that the processing of personal data concerning you violates the GDPR.
Definitions of terms
This section provides you with an overview of the terms used in this data protection declaration. Many of the terms are taken from the law and defined primarily in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended primarily to aid understanding. The terms are sorted alphabetically.
- Affiliate tracking: As part of affiliate tracking, links that the linked websites use to refer users to websites with product or other offers are logged. The operators of the linked websites can receive a commission if users follow these so-called affiliate links and then take advantage of the offers (e.g. buy goods or use services). To do this, it is necessary for the providers to be able to track whether users who are interested in certain offers then take advantage of them at the instigation of the affiliate links. Therefore, in order for affiliate links to function, they must be supplemented with certain values that become part of the link or are stored elsewhere, e.g. in a cookie. The values include in particular the source website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user as well as tracking-specific values, such as advertising material ID, partner ID and categorizations.
- Visit action analysis: “Visit action analysis” (English “conversion tracking”) refers to a process with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the user’s devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, we can use this to see whether the advertisements we placed on other websites were successful).
- Cross-device tracking: Cross-device tracking is a form of tracking in which user behavior and interest information is recorded across devices in so-called profiles by assigning users an online identifier. This means that user information can usually be analyzed for marketing purposes regardless of the browser or device used (e.g. mobile phones or desktop computers). For most providers, the online identifier is not linked to clear data such as names, postal addresses or email addresses.
- IP masking: “IP masking” is a method in which the last octet, i.e. the last two numbers of an IP address, is deleted so that the IP address can no longer be used to clearly identify a person. IP masking is therefore a means of pseudonymizing processing procedures, particularly in online marketing.
- Interest-based and behavior-related marketing: Interest-based and/or behavior-related marketing is when the potential interests of users in advertisements and other content are predetermined as precisely as possible. This is done using information about their previous behavior (e.g. visiting certain websites and staying on them, purchasing behavior or interaction with other users), which is stored in a so-called profile. Cookies are usually used for these purposes.
- Conversion measurement: Conversion measurement is a method with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the user’s device within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, this allows us to see whether the advertisements we have placed on other websites were successful.
- Personal data: “Personal data” is all information relating to an identified or identifiable natural person (hereinafter “data subject”).n”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more special characteristics that express the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Profiling: “Profiling” refers to any type of automated processing of personal data consisting of the use of personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this includes information relating to age, gender, location data and movement data, interaction with websites and their content, shopping behavior, social interactions with other people) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
- Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, website owners can, for example, recognize at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognise returning visitors and thus obtain more precise analyses of the use of an online service.
- Remarketing: “Remarketing” or “retargeting” is when, for example, it is noted for advertising purposes which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
- Tracking: “Tracking” is when the behavior of users can be tracked across multiple online offerings. As a rule, behavior and interest information is stored in cookies or on servers of the tracking technology providers with regard to the online offerings used (so-called profiling). This information can then be used, for example, to show users advertisements that are likely to correspond to their interests.
- Responsible party: The “responsible party” is the natural or legal person, public authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data.
- Processing: “Processing” is any process or series of processes carried out with or without the aid of automated procedures in connection with personal data. The term is broad and covers practically every handling of data, be it collection, evaluation, storage, transmission or deletion.
- Target group formation: Target group formation (or “custom audiences”) is when target groups are determined for advertising purposes, e.g. displaying advertisements. For example, based on a user’s interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which he viewed the products. “Lookalike audiences” (or similar target groups) are, in turn, when the content assessed as suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used to create custom audiences and lookalike audiences.
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