Privacy and Legal | Gardeon

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Privacy and Legal

Privacy Policy (GDPR)

Preamble

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

The terms used are not gender-specific.

As of 3 May 2023

Table of contents

  • Preamble
  • Responsible
  • Overview of processing
  • Relevant legal bases
  • Security measures
  • Transfer of personal data
  • Data processing in third countries
  • Deletion of data
  • Use of cookies
  • Business services
  • Providers and services used in the course of business activities
  • Credit checks
  • Provision of online services and web hosting
  • Registration, login and user account
  • Blogs and publication media
  • Contact and enquiry management
  • Newsletters and electronic notifications
  • Advertising communication via e-mail, post, fax or telephone
  • Web analysis, monitoring and optimisation
  • Customer reviews and rating procedures
  • Presence on social networks (social media)
  • Plugins and embedded functions and content
  • Changes and updates to the privacy policy
  • Rights of data subjects
  • Definition of terms

Controller

Gardeon GmbH
Neuer Wall 80
20354 Hamburg

Authorised representatives:

Martin CHOLEVA

Email address:

shop@gardeon.com

Impressum:

www.gardeon.com/impressum

Overview of processing

The following overview summarises the types of data processed and the purposes for which they are processed, and refers to the data subjects.

Types of data processed

  • Inventory data.
  • Payment data.
  • Location data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication and procedural data.
  • Event data (Facebook).

Categories of data subjects

  • Customers.
  • Prospective customers.
  • Communication partners.
  • Users.
  • Business and contractual partners.

Purposes of processing

  • Provision of contractual services and customer service
  • Contact enquiries and communication.
  • Security measures.
  • Direct marketing.
  • Reach measurement.
  • Tracking.
  • Office and organisational procedures.
  • Conversion measurement.
  • Management and response to enquiries.
  • Feedback.
  • Marketing.
  • Provision of our online offering and user-friendliness
  • Assessment of creditworthiness and credit rating.
  • Beurteilung der Bonität und Kreditwürdigkeit.
  • Information technology infrastructure.

Automated decisions in individual cases

  • Credit information.

Relevant legal bases

Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or registered office. If more specific legal bases are relevant in individual cases, we will inform you of this in the privacy policy.

  • Consent (Art. 6(1)(a) GDPR) – The data subject has given consent to the processing of their personal data for one or more specific purposes.
  • Contract performance and pre-contractual enquiries (Art. 6(1)(b) GDPR)  – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract..
  • Legal obligation (Art. 6(1)(c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6(1)(f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

In addition to the data protection provisions of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains, in particular, special provisions 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 transfer, as well as automated decision-making in individual cases, including profiling. It also regulates data processing for employment purposes (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Austria. These include, in particular, the Federal Act on the Protection of Individuals with regard to the Processing of Personal Data (Data Protection Act – DSG). The Data Protection Act contains, in particular, special regulations on the right to information, the right to rectification or erasure, the processing of special categories of personal data, processing for other purposes and transfer, and automated decision-making in individual cases.

In addition to the data protection provisions of the GDPR, the respective national data protection provisions may also apply to national reference points, which we also comply with.

Security measures

In accordance with legal requirements, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons.

These measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, transfer, availability and separation relating to it. Furthermore, we have established procedures to ensure that the rights of data subjects are exercised, data is deleted and responses are made to data threats. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and procedures in accordance with the principle of data protection, through technology design and data protection-friendly default settings.

TLS encryption (https): We use TLS encryption to protect your data transmitted via our online offering. You can recognise such encrypted connections by the prefix https:// in the address bar of your browser.

Transfer of personal data

In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. The recipients of this data may include, for example, 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 to protect your data.

Data transfer within the organisation: We may transfer personal data to other departments within our organisation or grant them access to this data. If this transfer is for administrative purposes, the transfer of data is based on our legitimate business and economic interests or is necessary to fulfil our contractual obligations or if the consent of the data subjects or legal permission has been obtained.

Data processing in third countries

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

Subject to express consent or contractually or legally required transfer, we only process or have the data processed in third countries with a recognised level of data protection, contractual obligations through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations. (Articles 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).

Deletion of data

The data we process will be deleted in accordance with legal requirements as soon as the consents permitting its processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data no longer applies or it is not necessary for the purpose). If the data is not deleted because it is required for other, legally permissible purposes, its 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 must be retained for commercial or tax law reasons or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.

Our data protection information may also contain further details on the storage and deletion of data that take precedence for the respective processing operations.

Use of cookies

Cookies are small text files or other storage notes that store information on end devices and read information from end devices. For example, to store the login status in a user account, the contents of a shopping basket in an e-shop, the content accessed or the functions used in an online offer. Cookies can also be used for various purposes, e.g. for the functionality, security and convenience of online offers and for analysing visitor flows.

Information on consent: We use cookies in accordance with legal requirements. We therefore obtain prior consent from users, unless this is not required by law. In particular, consent is not necessary if the storage and retrieval of information, including cookies, is absolutely necessary to provide users with a telemedia service (i.e. our online service) that they have expressly requested. Absolutely necessary cookies usually include cookies with functions that serve the display and operability of the online offer, load balancing, security, storage of user preferences and selections, or similar purposes related to the provision of the main and secondary functions of the online offer requested by users. The revocable consent is clearly communicated to users and contains information about the respective use of cookies.

Information on the legal basis for data protection: The legal basis on which we process users' personal data with the help of cookies depends on whether we ask users for their consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the economic operation of our online offering and improvement of its usability) or, if this is done in the context of fulfilling our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. We explain the purposes for which we process cookies in this privacy policy or as part of our consent and processing procedures.

Storage period: With regard to the storage period, a distinction is made between the following types of cookies:

  • Temporary cookies (also known as session cookies):Temporary cookies are deleted at the latest after a user has left an online offer and closed their device (e.g. browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the device is closed. This allows, for example, the login status to be stored or preferred content to be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.

General information on revocation and objection (opt-out): Users can revoke their consent at any time and also object to the processing in accordance with the legal requirements in Art. 21 GDPR. Users can also declare their objection via their browser settings, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/

  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); consent (Art. 6(1)(a) GDPR).

Further information on processing procedures, processes and services:

  • Customer account: Contractual partners can create an account within our online offering (e.g. customer or user account, or "customer account" for short). If registration of a customer account is required, contractual partners will be informed of this and of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. During registration and subsequent logins and use of the customer account, we store the IP addresses of customers along with the access times in order to verify registration and prevent any misuse of the customer account. When customers cancel their customer accounts, the data relating to the customer account is deleted, unless its retention is required for legal reasons. It is the responsibility of customers to back up their data when they cancel their customer accounts; legal basis: contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR).
  • Economic analyses and market research: For business reasons and in order to identify market trends and the wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., whereby the group of data subjects may include contractual partners, interested parties, customers, visitors and users of our online offering. The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we may take into account the profiles of registered users, including their details, e.g. on services used, if available. The analyses are for our own use only and are not disclosed externally, unless they are anonymous analyses with summarised, i.e. anonymised, values. Furthermore, we respect the privacy of users and process the data for analysis purposes pseudonymously and, where feasible, anonymously (e.g. as aggregated data); legal basis: legitimate interests (Art. 6(1)(f) GDPR).
  • Shop and e-commerce: We process our customers' data to enable them to select, purchase or order the selected products, goods and related services, as well as to pay for and deliver or execute them. If necessary for the execution of an order, we use service providers, in particular postal, freight forwarding and shipping companies, to carry out the delivery or execution for our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such in the context of the order or comparable purchase process and includes the information required for delivery or provision and billing, as well as contact information for the purpose of consultation; legal basis: contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR).
  • Craft services: We process the data of our customers and clients (hereinafter referred to uniformly as "customers") in order to enable them to select, purchase or commission the selected services or works and related activities, as well as to pay for and deliver or perform or provide them. The required information is marked as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for delivery and billing, as well as contact information for any necessary consultations; legal basis: contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR).

Providers and services used in the course of business activities

In the course of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers (hereinafter referred to as "services") in compliance with legal requirements. Their use is based on our interests in proper, lawful and permanent control.

  • Types of data processed:  Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact details (e.g. email, telephone numbers); content data (e.g. entries in online forms); contract data (e.g. subject matter of the contract, term, customer category).
  • Data subjects: Customers; interested parties; users (e.g. website visitors, users); business and contractual partners.
  • Purposes of processing: Provision of contractual services and customer service; office and organisational procedures.
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Credit check

If we make advance payments or take on comparable economic risks (e.g. for orders on account), we reserve the right to obtain identity and credit information for the purpose of assessing the credit risk on the basis of mathematical-statistical procedures from specialised service companies (credit agencies) in order to protect our legitimate interests.

We process the information received from the credit agencies about the statistical probability of a payment default as part of an appropriate discretionary decision on the establishment, implementation and termination of the contractual relationship. We reserve the right to refuse payment on account or other advance payments in the event of a negative credit check result.

The decision on whether we make advance payments is made in accordance with Art. 22 GDPR solely on the basis of an automated decision in each individual case, which our software makes on the basis of the information provided by the credit agency.

  • Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact details (e.g. email, telephone numbers); contract data (e.g. subject matter of the contract, term, customer category).
  • Data subjects: Customers.
  • Purposes of processing: Assessment of creditworthiness and credit rating.
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
  • Automated decisions in individual cases: credit rating information.

Provision of online services and web hosting

We process users' data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or end device.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status); content data (e.g. entries in online forms).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and user-friendliness; IT infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)); security measures.
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing procedures, processes and services:

  • Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also known as a "web host"); Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
  • Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files". Server log files may 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 prevent server overload (especially in the case of malicious attacks, known as DDoS attacks) and to ensure server utilisation and stability. Legal basis: legitimate interests (Art. 6(1)(f) GDPR); deletion of data: log file information is stored for a maximum of 30 days and then deleted or anonymised. Data that must be retained for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
  • Email dispatch and hosting: The web hosting services we use also include the sending, receiving and storage of emails. For these purposes, the addresses of the recipients and senders, as well as further information relating to the sending of emails (e.g. the providers involved) and the content of the respective emails, are processed. The aforementioned data may also be processed for the purpose of detecting spam. Please note that emails are generally not sent in encrypted form on the internet. As a rule, emails are encrypted during transmission, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We therefore cannot accept any responsibility for the transmission of emails between the sender and the recipient on our server; legal basis: legitimate interests (Art. 6(1)(f) GDPR).

Registration, login and user account

Users can create a user account. During registration, users are informed of the required mandatory information, which is processed for the purpose of providing the user account on the basis of contractual obligation fulfillment. The data processed includes, in particular, login information (user name, password and email address).

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

Users can be informed by email about processes relevant to their user account, such as technical changes.

  • Types of data processed: Inventory data (e.g. names, addresses); contact details (e.g. email, telephone numbers); content data (e.g. entries in online forms); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and customer service; security measures; administration and response to enquiries; provision of our online services and user-friendliness.
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR); legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing procedures, processes and services:

  • Registrierung mit Klarnamen: Aufgrund der Natur unserer Community bitten wir die Nutzer unser Angebot nur unter Verwendung von Klarnamen zu nutzen. D.h. die Nutzung von Pseudonymen ist nicht zulässig; Rechtsgrundlagen: Vertragserfüllung und vorvertragliche Anfragen (Art. 6 Abs. 1 S. 1 lit. b) DSGVO).
  • Profile der Nutzer sind nicht öffentlich: Die Profile der Nutzer sind öffentlich nicht sichtbar und nicht zugänglich.
  • Einstellung der Sichtbarkeit von Profilen: Die Nutzer können mittels Einstellungen bestimmen, in welchem Umfang ihre Profile für die Öffentlichkeit oder nur für bestimmte Personengruppen sichtbar, bzw. zugänglich sind; Rechtsgrundlagen: Vertragserfüllung und vorvertragliche Anfragen (Art. 6 Abs. 1 S. 1 lit. b) DSGVO).

Blogs and publication media

We use blogs or similar means of online communication and publication (hereinafter referred to as "publication media"). Readers' data is only processed for the purposes of the publication media to the extent necessary for its presentation and communication between authors and readers or for security reasons. For further information, please refer to the information on the processing of visitors to our publication media in this privacy policy.

  • Types of data processed: Inventory data (e.g. names, addresses); Contact data (e.g. email, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and customer service; feedback (e.g. collection of feedback via online form); provision of our online offering and user-friendliness; security measures; management and response to enquiries.
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing procedures, processes and services:

  • Comments and posts: When users leave comments or other posts, their IP addresses may be stored on the basis of our legitimate interests. This is for our security in case someone leaves illegal content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves may be prosecuted for the comment or post and are therefore interested in the identity of the author. Furthermore, we reserve the right to process user information for the purpose of spam detection on the basis of our legitimate interests. On the same legal basis, we reserve the right to store users' IP addresses for the duration of surveys and to use cookies to prevent multiple voting. The personal information provided in the context of comments and posts, any contact and website information, as well as the content information, will be stored by us permanently until the user objects; legal basis: legitimate interests (Art. 6(1)(f) GDPR).

Contact and enquiry management

When contacting us (e.g. by post, contact form, email, telephone or via social media) and within the framework of existing user and business relationships, the details of the persons making the enquiry are processed to the extent necessary to respond to the contact enquiries and any requested measures.

  • Types of data processed: Contact details (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
  • Data subjects: Communication partners.
  • Purposes of processing: Contact enquiries and communication; management and response to enquiries; feedback (e.g. collection of feedback via online form); provision of our online offering and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR).

Further information on processing procedures, processes and services:

  • Contact form: When users contact us via our contact form, email or other communication channels, we process the data provided in this context in order to deal with the matter raised. Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Newsletters and electronic notifications

We send newsletters, emails and other electronic notifications (hereinafter referred to as "newsletters") only with the consent of the recipients or with legal permission. If the content of the newsletter is specifically described when registering for it, this content is decisive for the consent of the users. Otherwise, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to provide your email address. However, we may ask you to provide a name for personalised communication in the newsletter or other information if this is necessary for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter is always carried out using a double opt-in procedure. This means that after registering, you will receive an email asking you to confirm your registration. This confirmation is necessary to prevent anyone from registering with someone else's email address. Newsletter registrations are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the mailing service provider are also logged.

Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting 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 defence against claims. An individual request for deletion is possible at any time, provided that the former 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 block list for this purpose alone.

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

Contents:

Information about us, our services, promotions and offers.

  • Types of data processed: Inventory data (e.g. names, addresses); contact details (e.g. email, telephone numbers); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status); usage data (e.g. websites visited, interest in content, access times).
  • Data subjects: Communication partners; users (e.g. website visitors, users of online services).
  • Purposes of processing: Direct marketing (e.g. by email or post); provision of contractual services and customer service.
  • Legal basis: Consent (Art. 6(1)(a) GDPR).
  • Right to object (opt-out): You can unsubscribe from 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 at the end of each newsletter or you can use one of the contact options listed above, preferably email.

Further information on processing procedures, methods and services:

  • Measurement of opening and click rates: The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from our server or, if we use a mailing service provider, from their server when the newsletter is opened. During this retrieval, technical information such as information about your browser and your system, as well as your IP address and the time of retrieval, is initially collected. This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behaviour based on their retrieval location (which can be determined using the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. The evaluations serve to help us recognise the reading habits of our users and adapt our content to them or send different content according to the interests of our users. Legal basis: consent (Art. 6(1)(a) GDPR)..
  • Prerequisite for the use of free services: Consent to the sending of mailings may be made a prerequisite for the use of free services (e.g. access to certain content or participation in certain promotions). If users wish to use the free service without subscribing to the newsletter, we ask them to contact us.

Advertising communication via email, post, fax or telephone

We process personal data for the purposes of advertising communication, which may take place via various channels, such as email, telephone, post or fax, in accordance with legal requirements.

Recipients have the right to revoke their consent at any time or to object to advertising communications at any time.

After revocation or objection, we store the data necessary to prove previous authorisation for contact or sending up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defence against claims. On the basis of the legitimate interest in permanently observing the revocation or objection of users, we also store the data necessary to avoid renewed contact (e.g. depending on the communication channel, the email address, telephone number, name).

  • Types of data processed: Inventory data (e.g. names, addresses); contact details (e.g. email, telephone numbers).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g. by email or post).
  • Legal basis: Consent (Art. 6(1)(a) GDPR); legitimate interests (Art. 6(1)(f) GDPR).

Web analysis, monitoring and optimisation

Web analysis (also known as "reach measurement") is used to evaluate visitor traffic to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at what time our online offering or its functions or content are used most frequently or invite reuse. We can also identify which areas need 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.

Unless otherwise stated below, profiles, i.e. data summarised for a usage process, may be created for these purposes and information may be stored in a browser or on a terminal device and read from it. The information collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used and information on usage times. If users have agreed to the collection of their location data by us or by the providers of the services we use, location data may also be processed.

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

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles); tracking (e.g. interest/behaviour-based profiling, use of cookies); provision of our online offering and user-friendliness.
  • Security measures: IP masking (pseudonymisation of the IP address).
  • Legal basis: Consent (Art. 6(1)(a) GDPR).

Further information on processing procedures, methods and services:

Customer reviews and rating procedures

We participate in review and rating procedures in order to evaluate, optimise and promote our services. If users rate us or otherwise provide feedback via the participating rating platforms or procedures, the general terms and conditions or terms of use and privacy policies of the providers also apply. As a rule, the rating also requires registration with the respective providers.

To ensure that the persons providing reviews have actually used our services, we transmit the necessary data relating to the customer and the service used to the respective review platform (including name, email address and order number or item number) with the customer's consent. This data is used solely to verify the authenticity of the user.

  • 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 and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
  • Data subjects: Customers; users (e.g. website visitors, users of online services).
  • Purposes of processing: Feedback (e.g. collecting feedback via online form); marketing.
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing procedures, processes and services:

  • Review widget: We integrate so-called "review widgets" into our online offering. A widget is a functional and content element integrated into our online offering that displays variable information. It can be displayed, for example, in the form of a seal or similar element, sometimes also referred to as a "badge". The corresponding content of the widget is displayed within our online offering, but is retrieved from the servers of the respective widget provider at that moment. This is the only way to ensure that the current content is always displayed, especially the current rating. To do this, a data connection must be established from the website accessed within our online offering to the widget provider's server, and the widget provider receives certain technical data (access data, including IP address) that is necessary to deliver the content of the widget to the user's browser. Furthermore, the widget provider receives information that users have visited our online offering. This information may be stored in a cookie and used by the widget provider to identify which online offerings participating in the rating process have been visited by the user. The information may be stored in a user profile and used for advertising or market research purposes; legal basis: legitimate interests (Art. 6(1)(f) GDPR).

Presence on social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to provide 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, as it could, for example, make it more difficult to enforce user rights.

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

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

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

  • Types of data processed: Contact details (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Contact enquiries and communication; feedback (e.g. collecting feedback via online form); marketing..
  • Legal basis: legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures and services:

Plugins and embedded functions and content

We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may be, for example, graphics, videos or city maps (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, as they would not be able to send the content to their browsers without the IP address. The IP address is therefore necessary for the display of this content or these functions. We endeavour to use only content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. Pixel tags can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may include technical information about the browser and operating system, referring websites, visit time and other information about the use of our online offering, and may be linked to such information from other sources.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time stamps, identification numbers, consent status); inventory data (e.g. names, addresses); contact details (e.g. email, telephone numbers); Content data (e.g. entries in online forms); Location data (information about the geographical position of a device or person); Event data (Facebook) ("Event data" is data that can be transmitted by us to Facebook, e.g. via Facebook pixels (via apps or other means), and relates to persons or their actions; The data includes, for example, information about visits to websites, interactions with content, functions, app installations, product purchases, etc.; the event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); Event data does not include the actual content (such as comments posted), login information or contact information (i.e. no names, email addresses or telephone numbers). Event data is deleted by Facebook after a maximum of two years, and the target groups formed from it are deleted when our Facebook account is deleted.
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and user-friendliness; marketing; profiles with user-related information (creation of user profiles).
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); consent (Art. 6(1)(a) GDPR).

Further information on processing procedures, methods and services:

  • Facebook plugins and content: Facebook social plugins and content – This may include content such as images, videos or text and buttons that allow users to share content from this online offering within Facebook. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/ – Together with Meta Platforms Ireland Limited, we are jointly responsible for the collection or receipt in the context of a transfer (but not the further processing) of "event data" that Facebook collects or receives in the context of a transfer for the following purposes using the Facebook social plugins (and content embedding functions) that are executed on our online offering: a) Displaying content and advertising information that matches the presumed interests of users; b) Delivering commercial and transaction-related messages (e.g. contacting users via Facebook Messenger); c) Improving ad delivery and personalising features and content (e.g. improving the recognition of which content or advertising information is likely to match the interests of users). We have entered into a special agreement with Facebook ("Addendum for Controllers", https://www.facebook.com/legal/controller_addendum), which specifically regulates the security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to comply with data subject rights (i.e. users can, for example, send requests for information or deletion directly to Facebook). Note: When Facebook provides us with metrics, analyses and reports (which are aggregated, i.e. do not contain any information about individual users and are anonymous to us), this processing is not carried out within the framework of joint responsibility, but on the basis of a data processing agreement ("Data Processing Terms ", https://www.facebook.com/legal/terms/dataprocessing) , the "Data Security Terms" (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of standard contractual clauses ("Facebook-EU Data Transfer Addendum",  https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: consent (Art. 6(1)(a) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy.
  • Google Fonts (obtained from Google Server): Obtaining fonts (and symbols) for the purpose of technically secure, maintenance-free and efficient use of fonts and symbols with regard to topicality and loading times, their uniform display and consideration of possible licensing restrictions. The user's IP address is communicated to the font provider so that the fonts can be made available in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) is transmitted, which is necessary for the provision of the fonts depending on the devices used and the technical environment. This data may be processed on a server of the font provider in the USA. When visiting our online offering, users' browsers send their browser HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) from Google Fonts and then the fonts specified in the CCS. These HTTP requests include (1) the IP address used by the respective user to access the internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user agent, which describes the browser and operating system versions of the website visitors, as well as the referrer URL (i.e. the web page on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers, and they are not analysed. The Google Fonts Web API logs details of HTTP requests (requested URL, user agent and referrer URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wishes to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must customise the font that is generated for the respective browser type. The user agent is primarily logged for debugging purposes and used to generate aggregated usage statistics that measure the popularity of font families. These summarised usage statistics are published on the Google Fonts Analytics page. Finally, the referral URL is logged so that the data can be used for production maintenance and an aggregated report on the top integrations can be generated based on the number of font requests. According to its own information, Google does not use any of the information collected by Google Fonts to create profiles of end users or to serve targeted ads; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: legitimate interests (Art. 6(1)(f) GDPR); Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy; further information: https://developers.google.com/fonts/faq/privacy?hl=de.
  • Google Maps: We integrate maps from the Google Maps service provided by Google. The data processed may include, in particular, IP addresses and location data of users; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland; Legal basis: legitimate interests (Art. 6(1)(f) GDPR); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy.
  • Instagram plugins and content: Instagram plugins and content – This may include, for example, content such as images, videos or text and buttons that allow users to share content from this online offering within Instagram. – Together with Meta Platforms Ireland Limited, we are jointly responsible for the collection or receipt in the context of a transfer (but not the further processing) of "event data" that Facebook collects or receives in the context of a transfer for the following purposes using Instagram functions (e.g. embedding functions for content) that are executed on our online offering: a) Displaying content and advertising information that matches the presumed interests of users; b) Delivering commercial and transaction-related messages (e.g. contacting users via Facebook Messenger); c) Improving ad delivery and personalising features and content (e.g. improving the recognition of which content or advertising information is presumed to match the interests of users). We have entered into a special agreement with Facebook ("Addendum for Controllers",  https://www.facebook.com/legal/controller_addendum), which specifically regulates the security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to comply with data subject rights (i.e. users can, for example, send requests for information or deletion directly to Facebook). Please note: When Facebook provides us with metrics, analyses and reports (which are aggregated, i.e. do not contain any information about individual users and are anonymous to us), this processing is not carried out within the framework of joint responsibility, but on the basis of a data processing agreement ("Data Processing Terms ", , https://www.facebook.com/legal/terms/dataprocessing) , the "Data Security Terms" (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of standard contractual clauses ("Facebook-EU Data Transfer Addendum",  https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: legitimate interests (Art. 6(1)(f) GDPR) Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
  • LinkedIn plugins and content: LinkedIn plugins and content – This may include content such as images, videos or text and buttons that allow users to share content from this online offering within LinkedIn;  Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Data processing agreement: : https://legal.linkedin.com/dpa; Standard contractual clauses (guaranteeing data protection level when processing in third countries):  https://legal.linkedin.com/dpa; Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • Pinterest plugins and content: Pinterest plugins and content – This may include content such as images, videos or text and buttons that allow users to share content from this online offering within Pinterest; Service provide: Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.pinterest.com; Privacy policy: https://policy.pinterest.com/de/privacy-policy.
  • Twitter plugins and content: Twitter plugins and buttons – These may include content such as images, videos or text and buttons that allow users to share content from this online offering within Twitter; ; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Irland, Mutterunternehmen: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://twitter.com/de; Privacy policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
  • YouTube Videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland;  Legal basis: Legitimate interests (Art. 6(1)(f) GDPR);  Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; 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.
  • YouTube videos: Video content; YouTube videos are integrated via a special domain (recognisable by the component "youtube-nocookie") in the so-called "extended data protection mode", which means that no cookies are collected on user activities in order to personalise video playback. However, information about user interaction with the video (e.g. remembering the last playback position) may be stored; Dienstanbieter: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy.

Changes and updates to the privacy policy

We ask you to regularly review the content of our privacy policy. We will amend the privacy policy as soon as changes to our data processing practices make 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 for companies and organisations in this privacy policy, please note that the addresses may change over time and please check the information before contacting them.

Rights of data subjects

As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing..
  • Right to withdraw consent: You have the right to withdraw your consent at any time.
  • Right to information: You have the right to request confirmation as to whether data concerning you is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with the statutory provisions.
  • Right to rectification: In accordance with legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased immediately or, alternatively, in accordance with legal requirements, to request a restriction on the processing of the data.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with legal requirements, or to request that it be transferred to another controller.
  • Complaint to supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the provisions of the GDPR.

Supervisory authority responsible for us:

The Hamburg Commissioner for Data Protection and Freedom of Information
Ludwig-Erhard-Straße 22
20459 Hamburg

Tel.: 040 / 428 54 – 4040
Fax: 040 / 428 54 – 4000
E-Mail: mailbox@datenschutz.hamburg.de

Definition of terms

This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined in particular in Art. 4 GDPR. The legal definitions are binding. The following explanations are intended primarily to aid understanding. The terms are listed in alphabetical order.

  • Credit information: Automated decisions are based on automatic data processing without human intervention (e.g. in the case of automatic rejection of a purchase on account, an online credit application or an online application process without any human intervention). Such automated decisions are only permissible under Art. 22 GDPR if the data subjects consent, if they are necessary for the performance of a contract or if national laws permit such decisions.
  • Conversion measurement: Conversion measurement (also known as "visit action evaluation") is a method used to determine the effectiveness of marketing measures. To do this, a cookie is usually stored on the user's device within the websites where the marketing measures are carried out and then retrieved again on the target website. This allows us to track whether the advertisements we place on other websites have been successful.
  • Personal data: "Personal data" is any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); A natural person is considered identifiable if they can be identified directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special characteristics that express the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, comprises any type of automated processing of personal data that consists of using this personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information relating to demographics, behaviour and interests, such as interaction with websites and their content, etc.). Cookies and web beacons are often used for profiling purposes.
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate visitor flows to an online offering and may include the behaviour or interests of visitors in certain information, such as website content. With the help of reach analysis, website owners can, for example, identify at what time visitors visit their website and what content they are interested in. This enables them, for example, to better tailor the content of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis purposes to recognise returning visitors and thus obtain more accurate analyses of the use of an online offering.
  • Location data: Location data is generated when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, WLAN or similar technical intermediaries and location determination functions. Location data is used to indicate the geographically determinable position of the respective device on Earth. Location data can be used, for example, to display map functions or other location-dependent information.
  • Tracking:  "Tracking" refers to the ability to track the behaviour of users across multiple online services. As a rule, information about behaviour and interests is stored in cookies or on the servers of the providers of tracking technologies (known as profiling) with regard to the online services used. This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
  • Controller: The "controller" is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: "Processing" means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers virtually any handling of data, whether it is collection, evaluation, storage, transmission or deletion.
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