Last updated on May 5th, 2018
Note: This privacy policy only has informal character, the acutal policy is the one in
German, found at https://www.digineo.de/datenschutz. If this policy and the one in German
differ, the corresponding section in the English version becomes null and void, and the German
version becomes legally binding.
We are very delighted that you have shown interest in our enterprise. Data protection is of a
particularly high priority for the management of the Digineo GmbH. The use of the Internet pages of
the Digineo GmbH is possible without any indication of personal data; however, if a data subject
wants to use special enterprise services via our website, processing of personal data could become
necessary. If the processing of personal data is necessary and there is no statutory basis for such
processing, we generally obtain consent from the data subject.
The processing of personal data, such as the name, address, e-mail address, or telephone number of
a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in
accordance with the country-specific data protection regulations applicable to the Digineo GmbH. By
means of this data protection declaration, our enterprise would like to inform the general public
of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore,
data subjects are informed, by means of this data protection declaration, of the rights to which
they are entitled.
As the controller, the Digineo GmbH has implemented numerous technical and organizational measures
to ensure the most complete protection of personal data processed through this website. However,
Internet-based data transmissions may in principle have security gaps, so absolute protection may
not be guaranteed. For this reason, every data subject is free to transfer personal data to us via
alternative means, e.g. by telephone.
1. Definitions
The data protection declaration of the Digineo GmbH is based on the terms used by the European
legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection
declaration should be legible and understandable for the general public, as well as our customers
and business partners. To ensure this, we would like to first explain the terminology used.
In this data protection declaration, we use, inter alia, the following terms:
- Personal data
Personal data means any information relating to an identified or identifiable natural person
(“data subject”). An identifiable natural person is one who can be identified, directly or
indirectly, in particular by reference to an identifier such as a name, an identification
number, location data, an online identifier or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural or social identity of that natural person. - Data subject
Data subject is any identified or identifiable natural person, whose personal data is processed
by the controller responsible for the processing. - Processing
Processing is any operation or set of operations which is performed on personal data or on sets
of personal data, whether or not by automated means, such as collection, recording,
organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use,
disclosure by transmission, dissemination or otherwise making available, alignment or
combination, restriction, erasure or destruction. - Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their
processing in the future. - Profiling
Profiling means any form of automated processing of personal data consisting of the use of
personal data to evaluate certain personal aspects relating to a natural person, in particular
to analyse or predict aspects concerning that natural person’s performance at work, economic
situation, health, personal preferences, interests, reliability, behaviour, location or
movements. - Pseudonymisation
Pseudonymisation is the processing of personal data in such a manner that the personal data can
no longer be attributed to a specific data subject without the use of additional information,
provided that such additional information is kept separately and is subject to technical and
organisational measures to ensure that the personal data are not attributed to an identified or
identifiable natural person. - Controller or controller responsible for the processing
Controller or controller responsible for the processing 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; where the purposes and means of such processing
are determined by Union or Member State law, the controller or the specific criteria for its
nomination may be provided for by Union or Member State law. - Processor
Processor is a natural or legal person, public authority, agency or other body which processes
personal data on behalf of the controller. - Recipient
Recipient is a natural or legal person, public authority, agency or another body, to which the
personal data are disclosed, whether a third party or not. However, public authorities which
may receive personal data in the framework of a particular inquiry in accordance with Union or
Member State law shall not be regarded as recipients; the processing of those data by those
public authorities shall be in compliance with the applicable data protection rules according
to the purposes of the processing. - Third party
Third party is a natural or legal person, public authority, agency or body other than the data
subject, controller, processor and persons who, under the direct authority of the controller or
processor, are authorised to process personal data. - Consent
Consent of the data subject is any freely given, specific, informed and unambiguous indication
of the data subject’s wishes by which he or she, by a statement or by a clear affirmative
action, signifies agreement to the processing of personal data relating to him or her.
2. Name and Address of the controller
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection
laws applicable in Member states of the European Union and other provisions related to data
protection is:
Fahrenheitstr. 15
28359 Bremen
Phone: 0421 167 66 090
Fax: 0421 167 66 099
Email: datenschutz@digineo.de
Website: https://www.digineo.de
3. Name und Address of the Data Protection Officer
Appointed to the role of (internal) Data Protection Officer is Mr. Sebastian Siede (address
identical to the address of the controller).
4. Cookies
The Internet pages of the Digineo GmbH use cookies. Cookies are text files that are stored in a
computer system via an Internet browser.
Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie
ID is a unique identifier of the cookie. It consists of a character string through which Internet
pages and servers can be assigned to the specific Internet browser in which the cookie was stored.
This allows visited Internet sites and servers to differentiate the individual browser of the dats
subject from other Internet browsers that contain other cookies. A specific Internet browser can be
recognized and identified using the unique cookie ID.
Through the use of cookies, the Digineo GmbH can provide the users of this website with more
user-friendly services that would not be possible without the cookie setting.
By means of a cookie, the information and offers on our website can be optimized with the user in
mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of
this recognition is to make it easier for users to utilize our website. The website user that uses
cookies, e.g. does not have to enter access data each time the website is accessed, because this is
taken over by the website, and the cookie is thus stored on the user’s computer system. Another
example is the cookie of a shopping cart in an online shop. The online store remembers the articles
that a customer has placed in the virtual shopping cart via a cookie.
The data subject may, at any time, prevent the setting of cookies through our website by means of a
corresponding setting of the Internet browser used, and may thus permanently deny the setting of
cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or
other software programs. This is possible in all popular Internet browsers. If the data subject
deactivates the setting of cookies in the Internet browser used, not all functions of our website
may be entirely usable.
5. Collection of general data and information
The website of the Digineo GmbH collects a series of general data and information when a data
subject or automated system calls up the website. This general data and information are stored in
the server log files. Collected may be (1) the browser types and versions used, (2) the operating
system used by the accessing system, (3) the website from which an accessing system reaches our
website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the
Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of
the accessing system, and (8) any other similar data and information that may be used in the event
of attacks on our information technology systems.
When using these general data and information, the Digineo GmbH does not draw any conclusions about
the data subject. Rather, this information is needed to (1) deliver the content of our website
correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the
long-term viability of our information technology systems and website technology, and (4) provide
law enforcement authorities with the information necessary for criminal prosecution in case of a
cyber-attack. Therefore, the Digineo GmbH analyzes anonymously collected data and information
statistically, with the aim of increasing the data protection and data security of our enterprise,
and to ensure an optimal level of protection for the personal data we process. The anonymous data
of the server log files are stored separately from all personal data provided by a data subject.
6. Registration on our website
The data subject has the possibility to register on the website of the controller with the
indication of personal data. Which personal data are transmitted to the controller is determined by
the respective input mask used for the registration. The personal data entered by the data subject
are collected and stored exclusively for internal use by the controller, and for his own purposes.
The controller may request transfer to one or more processors (e.g. a parcel service) that also
uses personal data for an internal purpose which is attributable to the controller.
By registering on the website of the controller, the IP address—assigned by the Internet service
provider (ISP) and used by the data subject—date, and time of the registration are also stored. The
storage of this data takes place against the background that this is the only way to prevent the
misuse of our services, and, if necessary, to make it possible to investigate committed offenses.
Insofar, the storage of this data is necessary to secure the controller. This data is not passed on
to third parties unless there is a statutory obligation to pass on the data, or if the transfer
serves the aim of criminal prosecution.
The registration of the data subject, with the voluntary indication of personal data, is intended
to enable the controller to offer the data subject contents or services that may only be offered to
registered users due to the nature of the matter in question. Registered persons are free to change
the personal data specified during the registration at any time, or to have them completely deleted
from the data stock of the controller.
The data controller shall, at any time, provide information upon request to each data subject as to
what personal data are stored about the data subject. In addition, the data controller shall
correct or erase personal data at the request or indication of the data subject, insofar as there
are no statutory storage obligations. The Data Protection Officer is available to the data subject
in this respect as a contact person (address see above).
7. Subscription to our newsletters
On the website of the Digineo GmbH, users are given the opportunity to subscribe to our
enterprise’s newsletter. The input mask used for this purpose determines what personal data are
transmitted, as well as when the newsletter is ordered from the controller.
The Digineo GmbH informs its customers and business partners regularly by means of a newsletter
about enterprise offers. The enterprise’s newsletter may only be received by the data subject if
(1) the data subject has a valid e-mail address and (2) the data subject registers for the
newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data
subject for the first time for newsletter shipping, for legal reasons, in the double opt-in
procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the
data subject is authorized to receive the newsletter.
During the registration for the newsletter, we also store the IP address of the computer system
assigned by the Internet service provider (ISP) and used by the data subject at the time of the
registration, as well as the date and time of the registration. The collection of this data is
necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a
later date, and it therefore serves the aim of the legal protection of the controller.
The personal data collected as part of a registration for the newsletter will only be used to send
our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as
this is necessary for the operation of the newsletter service or a registration in question, as
this could be the case in the event of modifications to the newsletter offer, or in the event of a
change in technical circumstances. There will be no transfer of personal data collected by the
newsletter service to third parties. The subscription to our newsletter may be terminated by the
data subject at any time. The consent to the storage of personal data, which the data subject has
given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of
consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from
the newsletter at any time directly on the website of the controller, or to communicate this to the
controller in a different way.
8. Newsletter Tracking
The newsletter of the Digineo GmbH contains so-called tracking pixels. A tracking pixel is a
miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file
recording and analysis. This allows a statistical analysis of the success or failure of online
marketing campaigns. Based on the embedded tracking pixel, the Digineo GmbH may see if and when an
e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.
Such personal data collected in the tracking pixels contained in the newsletters are stored and
analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt
the content of future newsletters even better to the interests of the data subject. These personal
data will not be passed on to third parties. Data subjects are at any time entitled to revoke the
respective separate declaration of consent issued by means of the double-opt-in procedure. After a
revocation, these personal data will be deleted by the controller. The Digineo GmbH automatically
regards a withdrawal from the receipt of the newsletter as a revocation.
9. Contact possibility via the website
The website of the Digineo GmbH contains information that enables a quick electronic contact to our
enterprise, as well as direct communication with us, which also includes a general address of the
so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or
via a contact form, the personal data transmitted by the data subject are automatically stored.
Such personal data transmitted on a voluntary basis by a data subject to the data controller are
stored for the purpose of processing or contacting the data subject. There is no transfer of this
personal data to third parties.
10. Comments function in the blog on the website
The Digineo GmbH offers users the possibility to leave individual comments on individual blog
contributions on a blog, which is on the website of the controller. A blog is a web-based,
publicly-accessible portal, through which one or more people called bloggers or web-bloggers may
post articles or write down thoughts in so-called blogposts. Blogposts may usually be commented by
third parties.
If a data subject leaves a comment on the blog published on this website, the comments made by the
data subject are also stored and published, as well as information on the date of the commentary
and on the user’s (pseudonym) chosen by the data subject. In addition, the IP address assigned by
the Internet service provider (ISP) to the data subject is also logged. This storage of the IP
address takes place for security reasons, and in case the data subject violates the rights of third
parties, or posts illegal content through a given comment. The storage of these personal data is,
therefore, in the own interest of the data controller, so that he can exculpate in the event of an
infringement. This collected personal data will not be passed to third parties, unless such a
transfer is required by law or serves the aim of the defense of the data controller.
11. Subscription to comments in the blog on the website
The comments made in the blog of the Digineo GmbH may be subscribed to by third parties. In
particular, there is the possibility that a commenter subscribes to the comments following his
comments on a particular blog post.
If a data subject decides to subscribe to the option, the controller will send an automatic
confirmation e-mail to check the double opt-in procedure as to whether the owner of the specified
e-mail address decided in favor of this option. The option to subscribe to comments may be
terminated at any time.
12. Routine erasure and blocking of personal data
The data controller shall process and store the personal data of the data subject only for the
period necessary to achieve the purpose of storage, or as far as this is granted by the European
legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European
legislator or another competent legislator expires, the personal data are routinely blocked or
erased in accordance with legal requirements.
13. Rights of the data subject
13.1. Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from the
controller the confirmation as to whether or not personal data concerning him or her are being
processed. If a data subject wishes to avail himself of this right of confirmation, he or she may,
at any time, contact the Data Protection Officer of the controller (address see above).
13.2. Right of access
Each data subject shall have the right granted by the European legislator to obtain from the
controller free information about his or her personal data stored at any time and a copy of this
information. Furthermore, the European directives and regulations grant the data subject access to
the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be
disclosed, in particular recipients in third countries or international organisations; - where possible, the envisaged period for which the personal data will be stored, or, if not
possible, the criteria used to determine that period; - the existence of the right to request from the controller rectification or erasure of personal
data, or restriction of processing of personal data concerning the data subject, or to object to
such processing; - the existence of the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from the data subject, any available information as to
their source; - the existence of automated decision-making, including profiling, referred to in Article 22(1) and
(4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as
well as the significance and envisaged consequences of such processing for the data subject.
Furthermore, the data subject shall have a right to obtain information as to whether personal data
are transferred to a third country or to an international organisation. Where this is the case, the
data subject shall have the right to be informed of the appropriate safeguards relating to the
transfer.
If a data subject wishes to avail himself of this right of access, he or she may, at any time,
contact the Data Protection Officer of the controller (address see above).
13.3. Right to rectification
Each data subject shall have the right granted by the European legislator to obtain from the
controller without undue delay the rectification of inaccurate personal data concerning him or her.
Taking into account the purposes of the processing, the data subject shall have the right to have
incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time,
contact the Data Protection Officer of the controller (address see above).
13.4. Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by the European legislator to obtain from the
controller the erasure of personal data concerning him or her without undue delay, and the
controller shall have the obligation to erase personal data without undue delay where one of the
following grounds applies, as long as the processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were
collected or otherwise processed. - The data subject withdraws consent to which the processing is based according to point (a) of
Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other
legal ground for the processing. - The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no
overriding legitimate grounds for the processing, or the data subject objects to the processing
pursuant to Article 21(2) of the GDPR. - The personal data have been unlawfully processed.
- The personal data must be erased for compliance with a legal obligation in Union or Member State
law to which the controller is subject. - The personal data have been collected in relation to the offer of information society services
referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of
personal data stored by the Digineo GmbH, he or she may, at any time, contact the Data Protecion
Officer any employee of the controller (address see above). The DPO of Digineo GmbH shall promptly
ensure that the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17(1) to
erase the personal data, the controller, taking account of available technology and the cost of
implementation, shall take reasonable steps, including technical measures, to inform other
controllers processing the personal data that the data subject has requested erasure by such
controllers of any links to, or copy or replication of, those personal data, as far as processing
is not required. The Data Protection Officer of the Digineo GmbH will arrange the necessary
measures in individual cases.
13.5. Right of restriction of processing
Each data subject shall have the right granted by the European legislator to obtain from the
controller restriction of processing where one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the
controller to verify the accuracy of the personal data. - The processing is unlawful and the data subject opposes the erasure of the personal data and
requests instead the restriction of their use instead. - The controller no longer needs the personal data for the purposes of the processing, but they are
required by the data subject for the establishment, exercise or defence of legal claims. - The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the
verification whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the
restriction of the processing of personal data stored by the Digineo GmbH, he or she may at any
time contact the Data Protection Officer of the controller (address see above). The DPO of the
Digineo GmbH will arrange the restriction of the processing.
13.6. Right to data portability
Each data subject shall have the right granted by the European legislator, to receive the personal
data concerning him or her, which was provided to a controller, in a structured, commonly used and
machine-readable format. He or she shall have the right to transmit those data to another
controller without hindrance from the controller to which the personal data have been provided, as
long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or
point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of
the GDPR, and the processing is carried out by automated means, as long as the processing is not
necessary for the performance of a task carried out in the public interest or in the exercise of
official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the
GDPR, the data subject shall have the right to have personal data transmitted directly from one
controller to another, where technically feasible and when doing so does not adversely affect the
rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact the Data
Protection Officer of the Digineo GmbH (address see above).
13.7. Right to object
Each data subject shall have the right granted by the European legislator to object, on grounds
relating to his or her particular situation, at any time, to processing of personal data concerning
him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to
profiling based on these provisions.
The Digineo GmbH shall no longer process the personal data in the event of the objection, unless we
can demonstrate compelling legitimate grounds for the processing which override the interests,
rights and freedoms of the data subject, or for the establishment, exercise or defence of legal
claims.
If the Digineo GmbH processes personal data for direct marketing purposes, the data subject shall
have the right to object at any time to processing of personal data concerning him or her for such
marketing. This applies to profiling to the extent that it is related to such direct marketing. If
the data subject objects to the Digineo GmbH to the processing for direct marketing purposes, the
Digineo GmbH will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular
situation, to object to processing of personal data concerning him or her by the Digineo GmbH for
scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1)
of the GDPR, unless the processing is necessary for the performance of a task carried out for
reasons of public interest.
In order to exercise the right to object, the data subject may contact the Data Protection Officer
of the Digineo GmbH (address see above). In addition, the data subject is free in the context of
the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or
her right to object by automated means using technical specifications.
13.8. Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to a
decision based solely on automated processing, including profiling, which produces legal effects
concerning him or her, or similarly significantly affects him or her, as long as the decision (1)
is not is necessary for entering into, or the performance of, a contract between the data subject
and a data controller, or (2) is not authorised by Union or Member State law to which the
controller is subject and which also lays down suitable measures to safeguard the data subject’s
rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit
consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the
data subject and a data controller, or (2) it is based on the data subject’s explicit consent, the
Digineo GmbH shall implement suitable measures to safeguard the data subject’s rights and freedoms
and legitimate interests, at least the right to obtain human intervention on the part of the
controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making,
he or she may, at any time, contact the Data Protection Officer of the Digineo GmbH (address see
above).
13.9. Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her
consent to processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any
time, contact the Data Protection Officer of the Digineo GmbH (address see above).
14. Data protection for applications and the application procedures
The data controller shall collect and process the personal data of applicants for the purpose of
the processing of the application procedure. The processing may also be carried out electronically.
This is the case, in particular, if an applicant submits corresponding application documents by
e-mail or by means of a web form on the website to the controller. If the data controller concludes
an employment contract with an applicant, the submitted data will be stored for the purpose of
processing the employment relationship in compliance with legal requirements. If no employment
contract is concluded with the applicant by the controller, the application documents shall be
automatically erased two months after notification of the refusal decision, provided that no other
legitimate interests of the controller are opposed to the erasure. Other legitimate interest in
this relation is, e.g. a burden of proof in a procedure under the General Equal Treatment Act
(AGG).
15. Data protection provisions about the application and use of Google AdSense
On this website, the controller has integrated Google AdSense. Google AdSense is an online service
which allows the placement of advertising on third-party sites. Google AdSense is based on an
algorithm that selects advertisements displayed on third-party sites to match with the content of
the respective third-party site. Google AdSense allows an interest-based targeting of the Internet
user, which is implemented by means of generating individual user profiles.
The operating company of Google’s AdSense component is Alphabet Inc., 1600 Amphitheatre Pkwy,
Mountain View, CA 94043-1351, United States.
The purpose of Google’s AdSense component is the integration of advertisements on our website.
Google AdSense places a cookie on the information technology system of the data subject. The
definition of cookies is explained above. With the setting of the cookie, Alphabet Inc. is enabled
to analyze the use of our website. With each call-up to one of the individual pages of this
Internet site, which is operated by the controller and into which a Google AdSense component is
integrated, the Internet browser on the information technology system of the data subject will
automatically submit data through the Google AdSense component for the purpose of online
advertising and the settlement of commissions to Alphabet Inc. During the course of this technical
procedure, the enterprise Alphabet Inc. gains knowledge of personal data, such as the IP address of
the data subject, which serves Alphabet Inc., inter alia, to understand the origin of visitors and
clicks and subsequently create commission settlements.
The data subject may, as stated above, prevent the setting of cookies through our website at any
time by means of a corresponding adjustment of the web browser used and thus permanently deny the
setting of cookies. Such an adjustment to the Internet browser used would also prevent Alphabet
Inc. from setting a cookie on the information technology system of the data subject. Additionally,
cookies already in use by Alphabet Inc. may be deleted at any time via a web browser or other
software programs.
Furthermore, Google AdSense also uses so-called tracking pixels. A tracking pixel is a miniature
graphic that is embedded in web pages to enable a log file recording and a log file analysis
through which a statistical analysis may be performed. Based on the embedded tracking pixels,
Alphabet Inc. is able to determine if and when a website was opened by a data subject, and which
links were clicked on by the data subject. Tracking pixels serve, inter alia, to analyze the flow
of visitors on a website.
Through Google AdSense, personal data and information—which also includes the IP address, and is
necessary for the collection and accounting of the displayed advertisements—is transmitted to
Alphabet Inc. in the United States of America. These personal data will be stored and processed in
the United States of America. The Alphabet Inc. may disclose the collected personal data through
this technical procedure to third parties.
Google AdSense is further explained under the following link:
16. Data protection provisions about the application and use of Google Analytics (with anonymization function)
On this website, the controller has integrated the component of Google Analytics (with the
anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection,
gathering, and analysis of data about the behavior of visitors to websites. A web analysis service
collects, inter alia, data about the website from which a person has come (the so-called referrer),
which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web
analytics are mainly used for the optimization of a website and in order to carry out a
cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain
View, CA 94043-1351, United States.
For the web analytics through Google Analytics the controller uses the application_anonymizeIp(). By means of this application the IP address of the Internet connection of the
data subject is abridged by Google and anonymised when accessing our websites from a Member State
of the European Union or another Contracting State to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses
the collected data and information, inter alia, to evaluate the use of our website and to provide
online reports, which show the activities on our websites, and to provide other services concerning
the use of our Internet site for us.
Google Analytics places a cookie on the information technology system of the data subject. The
definition of cookies is explained above. With the setting of the cookie, Google is enabled to
analyze the use of our website. With each call-up to one of the individual pages of this Internet
site, which is operated by the controller and into which a Google Analytics component was
integrated, the Internet browser on the information technology system of the data subject will
automatically submit data through the Google Analytics component for the purpose of online
advertising and the settlement of commissions to Google. During the course of this technical
procedure, the enterprise Google gains knowledge of personal information, such as the IP address of
the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks,
and subsequently create commission settlements.
The cookie is used to store personal information, such as the access time, the location from which
the access was made, and the frequency of visits of our website by the data subject. With each
visit to our Internet site, such personal data, including the IP address of the Internet access
used by the data subject, will be transmitted to Google in the United States of America. These
personal data are stored by Google in the United States of America. Google may pass these personal
data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any
time by means of a corresponding adjustment of the web browser used and thus permanently deny the
setting of cookies. Such an adjustment to the Internet browser used would also prevent Google
Analytics from setting a cookie on the information technology system of the data subject. In
addition, cookies already in use by Google Analytics may be deleted at any time via a web browser
or other software programs.
In addition, the data subject has the possibility of objecting to a collection of data that are
generated by Google Analytics, which is related to the use of this website, as well as the
processing of this data by Google and the chance to preclude any such. For this purpose, the data
subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and
install it. This browser add-on tells Google Analytics through a JavaScript, that any data and
information about the visits of Internet pages may not be transmitted to Google Analytics. The
installation of the browser add-ons is considered an objection by Google. If the information
technology system of the data subject is later deleted, formatted, or newly installed, then the
data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on
was uninstalled by the data subject or any other person who is attributable to their sphere of
competence, or is disabled, it is possible to execute the reinstallation or reactivation of the
browser add-ons.
Further information and the applicable data protection provisions of Google may be retrieved under
the following links:
Google Analytics is further explained under the following link:
17. Data protection provisions about the application and use of Google Remarketing
On this website, the controller has integrated Google Remarketing services. Google Remarketing is a
feature of Google AdWords, which allows an enterprise to display advertising to Internet users who
have previously resided on the enterprise’s Internet site. The integration of Google Remarketing
therefore allows an enterprise to create user-based advertising and thus shows relevant
advertisements to interested Internet users.
The operating company of the Google Remarketing services is the Google Inc., 1600 Amphitheatre
Pkwy, Mountain View, CA 94043-1351, United States.
The purpose of Google Remarketing is the insertion of interest-relevant advertising. Google
Remarketing allows us to display ads on the Google network or on other websites, which are based on
individual needs and matched to the interests of Internet users.
Google Remarketing sets a cookie on the information technology system of the data subject. The
definition of cookies is explained above. With the setting of the cookie, Google enables a
recognition of the visitor of our website if he calls up consecutive web pages, which are also a
member of the Google advertising network. With each call-up to an Internet site on which the
service has been integrated by Google Remarketing, the web browser of the data subject identifies
automatically with Google. During the course of this technical procedure, Google receives personal
information, such as the IP address or the surfing behaviour of the user, which Google uses, inter
alia, for the insertion of interest relevant advertising.
The cookie is used to store personal information, e.g. the Internet pages visited by the data
subject. Each time we visit our Internet pages, personal data, including the IP address of the
Internet access used by the data subject, is transmitted to Google in the United States of America.
These personal data are stored by Google in the United States of America. Google may pass these
personal data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any
time by means of a corresponding adjustment of the web browser used and thus permanently deny the
setting of cookies. Such an adjustment to the Internet browser used would also prevent Google from
setting a cookie on the information technology system of the data subject. In addition, cookies
already in use by Google may be deleted at any time via a web browser or other software programs.
In addition, the data subject has the possibility of objecting to the interest-based advertising by
Google. For this purpose, the data subject must call up the link to www.google.de/settings/ads and
make the desired settings on each Internet browser used by the data subject.
Further information and the actual data protection provisions of Google may be retrieved under the
following link:
18. Data protection provisions about the application and use of Google-AdWords
On this website, the controller has integrated Google AdWords. Google AdWords is a service for
Internet advertising that allows the advertiser to place ads in Google search engine results and
the Google advertising network. Google AdWords allows an advertiser to pre-define specific keywords
with the help of which an ad on Google’s search results only then displayed, when the user utilizes
the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network,
the ads are distributed on relevant web pages using an automatic algorithm, taking into account the
previously defined keywords.
The operating company of Google AdWords is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA
94043-1351, UNITED STATES.
The purpose of Google AdWords is the promotion of our website by the inclusion of relevant
advertising on the websites of third parties and in the search engine results of the search engine
Google and an insertion of third-party advertising on our website.
If a data subject reaches our website via a Google ad, a conversion cookie is filed on the
information technology system of the data subject through Google. The definition of cookies is
explained above. A conversion cookie loses its validity after 30 days and is not used to identify
the data subject. If the cookie has not expired, the conversion cookie is used to check whether
certain sub-pages, e.g, the shopping cart from an online shop system, were called up on our
website. Through the conversion cookie, both Google and the controller can understand whether a
person who reached an AdWords ad on our website generated sales, that is, executed or canceled a
sale of goods.
The data and information collected through the use of the conversion cookie is used by Google to
create visit statistics for our website. These visit statistics are used in order to determine the
total number of users who have been served through AdWords ads to ascertain the success or failure
of each AdWords ad and to optimize our AdWords ads in the future. Neither our company nor other
Google AdWords advertisers receive information from Google that could identify the data subject.
The conversion cookie stores personal information, e.g. the Internet pages visited by the data
subject. Each time we visit our Internet pages, personal data, including the IP address of the
Internet access used by the data subject, is transmitted to Google in the United States of America.
These personal data are stored by Google in the United States of America. Google may pass these
personal data collected through the technical procedure to third parties.
The data subject may, at any time, prevent the setting of cookies by our website, as stated above,
by means of a corresponding setting of the Internet browser used and thus permanently deny the
setting of cookies. Such a setting of the Internet browser used would also prevent Google from
placing a conversion cookie on the information technology system of the data subject. In addition,
a cookie set by Google AdWords may be deleted at any time via the Internet browser or other
software programs.
The data subject has a possibility of objecting to the interest based advertisement of Google.
Therefore, the data subject must access from each of the browsers in use the link
https://www.google.de/settings/ads and set the desired settings.
Further information and the applicable data protection provisions of Google may be retrieved under
the following link:
18. Data protection provisions about the application and use of Matomo
On this website, the controller has integrated the Matomo component. Matomo is an open-source
software tool for web analysis. Web analysis is the collection, gathering and evaluation of data on
the behavior of visitors from Internet sites. A web analysis tool collects, inter alia, data on the
website from which a data subject came to a website (so-called referrer), which pages of the
website were accessed or how often and for which period of time a sub-page was viewed. A web
analysis is mainly used for the optimization of a website and the cost-benefit analysis of Internet
advertising.
The software is operated on the server of the controller, the data protection-sensitive log files
are stored exclusively on this server.
The purpose of the Matomo component is the analysis of the visitor flows on our website. The
controller uses the obtained data and information, inter alia, to evaluate the use of this website
in order to compile online reports, which show the activities on our Internet pages.
Matomo sets a cookie on the information technology system of the data subject. The definition of
cookies is explained above. With the setting of the cookie, an analysis of the use of our website
is enabled. With each call-up to one of the individual pages of this website, the Internet browser
on the information technology system of the data subject is automatically through the Matomo
component prompted to submit data for the purpose of online analysis to our server. During the
course of this technical procedure, we obtain knowledge about personal information, such as the IP
address of the data subject, which serves to understand the origin of visitors and clicks.
The cookie is used to store personal information, such as the access time, the location from which
access was made, and the frequency of visits to our website. With each visit of our Internet pages,
these personal data, including the IP address of the Internet access used by the data subject, are
transferred to our server. These personal data will be stored by us. We do not forward this
personal data to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any
time by means of a corresponding adjustment of the web browser used and thus permanently deny the
setting of cookies. Such an adjustment to the used Internet browser would also prevent Matomo from
setting a cookie on the information technology system of the data subject. In addition, cookies
already in use by Matomo may be deleted at any time via a web browser or other software programs.
In addition, the data subject has the possibility of objecting to a collection of data relating to
a use of this Internet site that are generated by Matomo as well as the processing of these data by
Matomo and the chance to preclude any such. For this, the data subject must set a “Do Not Track”
option in the browser.
With each setting of the opt-out cookie, however, there is the possibility that the websites of the
controller are no longer fully usable for the data subject.
Further information and the applicable data protection provisions of Matomo may be retrieved under
the following link:
20. Data protection provisions about the use of PayPal as a payment processor
On this website, the controller has integrated components of PayPal. PayPal is an online payment
service provider. Payments are processed via so-called PayPal accounts, which represent virtual
private or business accounts. PayPal is also able to process virtual payments through credit cards
when a user does not have a PayPal account. A PayPal account is managed via an e-mail address,
which is why there are no classic account numbers. PayPal makes it possible to trigger online
payments to third parties or to receive payments. PayPal also accepts trustee functions and offers
buyer protection services.
The European operating company of PayPal is PayPal (Europe) S.à.r.l. & Cie. S.C.A., 22-24 Boulevard
Royal, 2449 Luxembourg, Luxembourg.
If the data subject chooses “PayPal” as the payment option in the online shop during the ordering
process, we automatically transmit the data of the data subject to PayPal. By selecting this
payment option, the data subject agrees to the transfer of personal data required for payment
processing.
The personal data transmitted to PayPal is usually first name, last name, address, email address,
IP address, telephone number, mobile phone number, or other data necessary for payment processing.
The processing of the purchase contract also requires such personal data, which are in connection
with the respective order.
The transmission of the data is aimed at payment processing and fraud prevention. The controller
will transfer personal data to PayPal, in particular, if a legitimate interest in the transmission
is given. The personal data exchanged between PayPal and the controller for the processing of the
data will be transmitted by PayPal to economic credit agencies. This transmission is intended for
identity and creditworthiness checks.
PayPal will, if necessary, pass on personal data to affiliates and service providers or
subcontractors to the extent that this is necessary to fulfill contractual obligations or for data
to be processed in the order.
The data subject has the possibility to revoke consent for the handling of personal data at any
time from PayPal. A revocation shall not have any effect on personal data which must be processed,
used or transmitted in accordance with (contractual) payment processing.
The applicable data protection provisions of PayPal may be retrieved under the following link:
21. Data protection provisions about the application and use of Flattr
On this website, the controller has integrated components of the enterprise Flattr. Flattr is a
social payment service from Sweden, which allows the user to distribute donations to media
providers on the Internet through deposits on a credit account and by the provision of a monthly
budget. The users of the service may instruct Flattr, by clicking on a Flattr button that is
integrated on the website of a media provider, to distribute its fixed monthly budget to this media
provider.
The operating company of Flattr is Flattr AB, Box 4111, 203 12 Malmo, Sweden.
With each call-up to one of the individual pages of this Internet site, which is operated by the
controller and into which a Flattr component was integrated, the Internet browser on the
information technology system of the data subject is automatically prompted to download a display
of the corresponding Flattr component from Flattr through the Flattr component. During the course
of this technical procedure, Flattr is made aware of what specific sub-sites of our website are
visited by the data subject.
If the data subject is logged in at the same time at Flattr, Flattr detects with each call-up to
our website by the data subject—and for the entire duration of their stay on our Internet site—what
specific sub-site of our Internet page was visited by the data subject. This information is
collected by the Flattr component and associated with the respective Flattr account of the data
subject. If the data subject clicks on the Flattr button integrated into our website, then this
information is transmitted to Flattr for billing purposes. The data subject has already agreed to
the transmission of such information towards Flattr.
Further information and the applicable data protection provisions of Flattr may be retrieved under
the following link:
22. Legal basis for the processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain
consent for a specific processing purpose. If the processing of personal data is necessary for the
performance of a contract to which the data subject is party, as is the case, for example, when
processing operations are necessary for the supply of goods or to provide any other service, the
processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations
which are necessary for carrying out pre-contractual measures, for example in the case of inquiries
concerning our products or services. Is our company subject to a legal obligation by which
processing of personal data is required, such as for the fulfillment of tax obligations, the
processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be
necessary to protect the vital interests of the data subject or of another natural person. This
would be the case, for example, if a visitor were injured in our company and his name, age, health
insurance data or other vital information would have to be passed on to a doctor, hospital or other
third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing
operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing
operations which are not covered by any of the abovementioned legal grounds, if processing is
necessary for the purposes of the legitimate interests pursued by our company 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. Such processing operations are
particularly permissible because they have been specifically mentioned by the European legislator.
He considered that a legitimate interest could be assumed if the data subject is a client of the
controller (Recital 47 Sentence 2 GDPR).
23. The legitimate interests pursued by the controller or by a third party
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest
is to carry out our business in favor of the well-being of all our employees and the shareholders.
24. Period for which the personal data will be stored
The criteria used to determine the period of storage of personal data is the respective statutory
retention period. After expiration of that period, the corresponding data is routinely deleted, as
long as it is no longer necessary for the fulfillment of the contract or the initiation of a
contract.
25. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or
can also result from contractual provisions (e.g. information on the contractual partner).
Sometimes it may be necessary to conclude a contract that the data subject provides us with
personal data, which must subsequently be processed by us. The data subject is, for example,
obliged to provide us with personal data when our company signs a contract with him or her. The
non-provision of the personal data would have the consequence that the contract with the data
subject could not be concluded. Before personal data is provided by the data subject, the data
subject must contact the Data Protection Officer (address see above). The DPO clarifies to the data
subject whether the provision of the personal data is required by law or contract or is necessary
for the conclusion of the contract, whether there is an obligation to provide the personal data and
the consequences of non-provision of the personal data.
26. Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.
This Privacy Policy has been generated by the Privacy Policy Generator of the German Association
for Data Protection that was developed in cooperation with
Privacy Lawyers from WILDE BEUGER
SOLMECKE, Cologne.
The text contains modifications from the controller.