Clickservice Logo

Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes, and to what extent. This 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 services”).

The terms used are not gender-specific.

Status: January 17, 2024

Table of Contents

Responsible

Hajro Plaku / Clickservice GmbH
An den Alten Schanzen 25/49
1220 Vienna

E-mail address: office@clickservice.at
Telephone: +43 1 280 35 26
Imprint: clickservice.at/en/imprint

Overview of processing activities

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

Types of data processed

  • Inventory data.
  • Payment details.
  • Location data.
  • Contact details.
  • Content data.
  • Contract details.
  • Usage data.
  • Metadata, communication data and process data.

Categories of affected persons

  • Customers.
  • Interested parties.
  • Communication partner.
  • Users.
  • Business and contractual partners.

Purposes of processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Contact requests and communication.
  • Security measures.
  • Range measurement.
  • Tracking.
  • Office and organizational procedures.
  • Conversion measurement.
  • Managing and responding to inquiries.
  • Feedback.
  • Marketing.
  • Profiles containing user-related information.
  • Provision of our online services and user-friendliness.
  • Information technology infrastructure.

Relevant legal bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases under 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 establishment. Furthermore, should more specific legal bases apply in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) – The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  • Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) – The processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) – The processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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.

National data protection regulations in Austria: In addition to the GDPR data protection regulations, national data protection regulations apply in Austria. These include, in particular, the Federal Act on the Protection of Natural Persons with regard to the Processing of Personal Data (Data Protection Act – DSG). The Data Protection Act contains, in particular, special provisions regarding the right of access, the right to rectification or erasure, the processing of special categories of personal data, processing for other purposes and data transfers, as well as automated decision-making in individual cases.

Security measures

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

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 to, input of, transfer of, and ensuring the availability and separation of the data. Furthermore, we have established procedures that guarantee the exercise of data subject rights, the deletion of data, and responses to data breaches. We also consider the protection of personal data during the development and selection of hardware, software, and processes, in accordance with the principles of data protection by design and by default.

TLS/SSL encryption (https): To protect user data transmitted through our online services, we use TLS/SSL encryption. Secure Sockets Layer (SSL) is the standard technology for securing internet connections by encrypting data transmitted between a website or app and a browser (or between two servers). Transport Layer Security (TLS) is an updated and more secure version of SSL. Hypertext Transfer Protocol Secure (HTTPS) appears in the URL when a website is secured with an SSL/TLS certificate.

Transfer of personal data

As part of our processing of personal data, it may be necessary to transfer or disclose data to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, IT service providers or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data to protect your data.

International data transfers

Data processing in third countries: If we process data in a third country (i.e., outside the European Union (EU) and the European Economic Area (EEA)) or if processing takes place in the context of using third-party services or disclosing or transferring data to other persons, bodies, or companies, this is done only in accordance with legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers only take place if the level of data protection is ensured by other means, in particular through standard contractual clauses (Art. 46 para. 2 lit. c) GDPR), explicit consent, or in the case of a transfer required by contract or law (Art. 49 para. 1 GDPR). We will inform you of the legal basis for the transfer to a third country with the individual providers from the third country, whereby the adequacy decisions take precedence. Information on transfers to third countries and existing adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

EU-US Trans-Atlantic Data Privacy Framework: Under the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the level of data protection for certain US companies as adequate in its adequacy decision of July 10, 2023. The list of certified companies and further information on the DPF can be found on the US Department of Commerce website at [website address missing in original text]. https://www.dataprivacyframework.gov/ . We inform you in our privacy policy which of our service providers are certified under the Data Privacy Framework.

Deletion of data

The data we process will be deleted in accordance with legal requirements as soon as the consent to process it is withdrawn or other permissions cease to apply (e.g., if the purpose for processing this data no longer exists or it is no longer necessary for that purpose). If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted to those purposes. This means that the data will be blocked and not processed for any other purpose. This applies, for example, to data that must be retained for commercial or tax law reasons, or whose storage is necessary for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person. Our privacy policy may also contain further information on the retention and deletion of data that takes precedence for the respective processing activities.

Rights of data subjects

Rights of data subjects under the GDPR: 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, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) of the GDPR, including profiling based on those provisions. Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right of withdrawal for consents: You have the right to withdraw any consent you have given at any time.
  • Right to information: You have the right to request confirmation as to whether data concerning you is being processed, and to access this data as well as further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: In accordance with legal requirements, you have the right to request the completion of your personal data or the correction of inaccurate personal 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 without undue delay, or alternatively, in accordance with legal requirements, to request a restriction of the processing of the data.
  • Right to data portability: You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format, or to request its transmission to another controller, in accordance with the legal requirements.
  • Right to lodge a complaint with a 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, your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Use of cookies

Cookies are small text files or other storage markers that store information on and read information from end devices. For example, they can be used to save login status in a user account, shopping cart contents in an online store, accessed content, or used functions of an online service. Cookies can also be used for various other purposes, such as improving the functionality, security, and user-friendliness of online services, as well as analyzing visitor traffic.

Information on consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users unless legally required. In particular, consent is not necessary if the storage and reading of information, including cookies, is strictly necessary to provide users with a telemedia service (i.e., our online service) they have expressly requested. Strictly necessary cookies generally include those with functions that serve the display and operation of the online service, load balancing, security, the storage of user preferences and choices, or similar purposes related to providing the main and secondary functions of the online service requested by the user. The revocable consent is clearly communicated to users and includes information on the respective cookie usage.

Information on the legal basis for data protection: The legal basis for processing users’ personal data using cookies depends on whether we request user consent. If users consent, the legal basis for processing their data is their explicit consent. Otherwise, data processed using cookies is processed based on our legitimate interests (e.g., in the efficient operation of our online services and improving their usability) or, if this is necessary for fulfilling our contractual obligations, if the use of cookies is required to meet these obligations. We explain the purposes for which we process cookies in this privacy policy or within the framework of our consent and processing procedures.

Storage duration: The following types of cookies are distinguished with regard to storage duration:

  • Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user leaves an online service and closes their device (e.g., browser or mobile application).
  • Persistent cookies: Persistent cookies remain stored even after the user closes their device. This allows, for example, login status to be saved or preferred content to be displayed directly when the user revisits a website. Similarly, user data collected using cookies can be used for audience measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., when obtaining consent), users should assume that cookies are persistent and can be stored for up to two years.

General information on revocation and objection (so-called “opt-out”): Users can withdraw their consent at any time and object to processing in accordance with legal requirements. To do this, users can, among other things, restrict the use of cookies in their browser settings (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be made via the websites. https://optout.aboutads.info und https://www.youronlinechoices.com/ will be explained.

  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Complianz: Cookie consent management; Service provider: Execution on servers and/or computers under its own data protection responsibility; Website: https://complianz.io/; Privacy policy: https://complianz.io/legal/;. Further information: An individual user ID, language, types of consent, and the time of their submission are stored server-side and in a cookie on the user’s device.

Business services

We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as “contractual partners”), within the framework of contractual and similar legal relationships as well as related measures and in the context of communication with the contractual partners (or pre-contractually), e.g. to answer inquiries.

We process this data to fulfill our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations, and remedying warranty claims and other service disruptions. Furthermore, we process the data to protect our rights and for the purposes of the administrative tasks associated with these obligations, as well as for company organization. We also process the data based on our legitimate interests in proper and efficient business management and security measures to protect our contractual partners and our business operations from misuse, compromise of their data, secrets, information, and rights (e.g., involving telecommunications, transport, and other support services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Within the framework of applicable law, we only disclose contractual partner data to third parties to the extent necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners are informed about other forms of processing, e.g., for marketing purposes, within the scope of this privacy policy.

We will inform our contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special markings (e.g. colors) or symbols (e.g. stars or similar), or personally.

We delete data after the expiry of statutory warranty periods and comparable obligations, i.e., generally after four years, unless the data is stored in a customer account, for example, as long as it must be retained for legal archiving purposes. The statutory retention period is ten years for tax-relevant documents, as well as for commercial books, inventories, opening balance sheets, annual financial statements, the work instructions necessary for understanding these documents, and other organizational documents and accounting records. For received commercial and business correspondence and copies of sent commercial and business correspondence, the retention period is six years. This period begins at the end of the calendar year in which the last entry was made in the book, the inventory, opening balance sheet, annual financial statement, or management report was prepared, the commercial or business correspondence was received or sent, the accounting record was created, the record was made, or the other documents were created.

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

  • Types of data processed: Inventory data (e.g., names, addresses); Payment data (e.g., bank details, invoices, payment history); Contact data (e.g., email addresses, telephone numbers); Contract data (e.g., subject matter of the contract, term, customer category).
  • Affected persons: Interested parties. Business and contractual partners.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; handling contact requests and communication; office and organizational procedures. Administration and response to inquiries.
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Agency services: We process our clients’ data within the scope of our contractual services, which may include, for example, conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consulting services and training services; legal basis: performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
  • Project and development services: We process the data of our customers and clients (hereinafter referred to collectively as “customers”) to enable them to select, acquire or commission the chosen services or works as well as related activities, and to pay for and provide or execute or perform them.

    The required information is marked as such within the framework of the conclusion of the order, purchase order or comparable contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations. If we receive access to information from end customers, employees or other persons, we process it in accordance with legal and contractual requirements; Legal basis: fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 Sentence 1 Letter b) GDPR).

Payment procedure

As part of contractual and other legal relationships, due to legal obligations or otherwise based on our legitimate interests, we offer the data subjects efficient and secure payment options and use other service providers in addition to banks and credit institutions (collectively “payment service providers”).

The data processed by the payment service providers includes inventory data, such as: B. the name and address, bank details, such as. B. Account numbers or credit card numbers, passwords, TANs and checksums as well as contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered will only be processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the data may be transmitted by the payment service provider to credit reporting agencies. The purpose of this transmission is to check identity and creditworthiness. For this purpose, we refer to the general terms and conditions and data protection information of the payment service providers.

The terms and conditions and data protection notices of the respective payment service providers apply to payment transactions, which can be accessed on the respective websites or transaction applications. We also refer to these for further information and to assert cancellation, information and other rights of those affected.

  • Types of data processed: inventory data (e.g. names, addresses); Payment data (e.g. bank details, invoices, payment history); Contract data (e.g. subject matter of the contract, term, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
  • Affected persons: customers. interested parties.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations.
  • Legal basis: fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 Sentence 1 Letter b) GDPR).

Further information on processing procedures, methods and services:

  • Stripe: Payment services (technical connection of online payment methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal basis: Fulfillment of the contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://stripe.com; Privacy Policy: https://stripe.com/de/privacy. Basis for third country transfer: EU-US Data Privacy Framework (DPF).

Provision of online offerings and web hosting

We process users’ data in order to be able 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 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, times, identification numbers, consent status); Content data (e.g. entries in online forms).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.).). Security measures.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Provision of online offerings on our own/dedicated server hardware: To provide our online offerings, we use server hardware operated by us as well as the associated storage space, computing capacity and software; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. 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”. The server log files may include the address and name of the websites and files accessed, date and time of access, amounts of data transferred, notification of successful retrieval, 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. B. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the utilization of the servers and their stability; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is necessary for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
  • Hetzner: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.hetzner.com; Data protection declaration: https://www.hetzner.com/de/rechts/datenschutz. Order processing contract: https://docs.hetzner.com/de/general/general-terms-and-conditions/data-privacy-faq/.
  • WordPress.com: hosting and software for creating, providing and operating websites, blogs and other online offerings; Service provider: Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://wordpress.com; Data protection declaration: https://automattic.com/de/privacy/; Order processing agreement: https://wordpress.com/support/data-processing-agreements/. Basis for third country transfer: EU-US Data Privacy Framework (DPF).

Contact and inquiry management

When you contact us (e.g. by post, contact form, email, telephone or via social media) as well as within the framework of existing user and business relationships, the information provided by the inquiring person is processed to the extent that this is necessary to answer the contact request and any requested measures.

  • Types of data processed: Contact details (e.g., email addresses, 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, timestamps, identification numbers, consent status).
  • Affected persons: Communication partner.
  • Purposes of processing: Contact inquiries and communication; managing and responding to inquiries; Feedback (e.g. collecting feedback via online form). Provision of our online offering and user-friendliness.
  • Legal basis:: Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR). Fulfillment of the contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further information on processing procedures, methods and services:

  • Contact form: If users contact us via our contact form, email or other communication channels, we process the data provided to us in this context to process the request communicated; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).

Web analysis, monitoring and optimization

Web analysis (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and can contain behavior, interests or demographic information about visitors, such as: B. age or gender, as pseudonymous values. With the help of range analysis we can e.g. B. identify at what time our online offering or its functions or content are used most frequently or invite reuse. We can also understand which areas require optimization.

In addition to web analysis, we can also use testing procedures, e.g. B. to test and optimize different versions of our online offering or its components.

Unless otherwise stated below, profiles, i.e. h. Data summarized to form a usage process is created and information is stored in a browser or in a terminal device and read out 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 about times of use. If users have agreed to the collection of their location data to us or to the providers of the services we use, location data can also be processed.

The users’ IP addresses are also stored. However, we use an IP masking process (i.e. pseudonymization by shortening the IP address) to protect users. In general, as part of web analysis, A/B testing and optimization, no clear user data (such as email addresses or names) is stored, but rather pseudonyms. This means that we and the providers of the software used do not 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 procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
  • Affected persons: 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 (creating user profiles). Provision of our online offering and user-friendliness.
  • Security measures: IP-Masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing procedures, methods and services:

  • Google Analytics 4: We use Google Analytics to measure and analyze the use of our online services based on a pseudonymous user identification number. This identification number does not contain any unique data such as names or email addresses. It serves to assign analytical information to a device in order to recognize which content users have accessed within one or more browsing sessions, which search terms they have used, whether they have revisited the content, or how they have interacted with our online services. The time and duration of use are also recorded, as well as the sources of users who refer to our online services and technical aspects of their devices and browsers. Pseudonymous user profiles are created using information from the use of various devices, and cookies may be used for this purpose. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides approximate geographic location data by deriving the following metadata from IP addresses: city (and the city’s derived latitude and longitude), continent, country, region, subcontinent (and ID-based counterparts). For EU data traffic, IP address data is used exclusively for deriving geolocation data before being immediately deleted. It is not logged, is not accessible, and is not used for any other purpose. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), Standard Contract Clauses (https://business.safety.google/adsprocessorterms); Right to object (Opt-Out): Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for displaying advertisements: https://myadcenter.google.com/home. Further information: https://business.safety.google/adsservices/ (Types of processing and processed data).
  • Google Tag Manager: Google Tag Manager is a solution that allows us to manage website tags via a single interface and thus integrate other services into our online offering (see further details in this privacy policy). The Tag Manager itself (which implements the tags) does not, for example, create user profiles or store cookies. Google only receives the user’s IP address, which is necessary for the Google Tag Manager to function.; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland; Legal basis: Einwilligung (Art. 6 Abs. 1 S. 1 lit. a) DSGVO); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement:
    https://business.safety.google/adsprocessorterms. Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), Standard Contract Clauses (https://business.safety.google/adsprocessorterms).

Onlinemarketing

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

For these purposes, so-called user profiles are created and stored in a file (a so-called “cookie”) or similar methods are used to store user information relevant to displaying the aforementioned content. This information may include, for example, viewed content, visited websites, used online networks, as well as communication partners and technical information such as the browser used, the computer system used, and information about usage times and functions used. If users have consented to the collection of their location data, this data may also be processed.

Users’ IP addresses are also stored. However, we use available IP masking methods (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no clear user data (such as email addresses or names) is stored as part of the online marketing process; instead, pseudonyms are used. This means that neither we nor the providers of the online marketing methods know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is generally stored in cookies or using similar methods. These cookies can later be read on other websites that use the same online marketing methods and analyzed for the purpose of displaying content, as well as supplemented with further data and stored on the server of the online marketing provider.

In exceptional cases, personal data may be associated with profiles. This occurs, for example, when users are members of a social network whose online marketing methods we use and the network links the user profiles with the aforementioned information. Please note that users may enter into additional agreements with the providers, for example, by giving their consent during registration.

We generally only receive access to aggregated information about the success of our advertisements. However, through conversion tracking, we can examine which of our online marketing methods have led to a conversion, i.e., for example, a contract signed with us. Conversion tracking is used solely to analyze the success of our marketing efforts.

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

  • Types of data processed: Usage data (e.g., websites visited, interest in content, access times); meta, communication and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Audience measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest-/behavior-based profiling, use of cookies); marketing; profiles with user-related information (creation of user profiles). Conversion measurement (measuring the effectiveness of marketing measures).
  • Security measures: IP-Masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Right to object (Opt-Out): We refer you to the privacy policies of the respective providers and the opt-out options provided by those providers. If no explicit opt-out option is specified, you can disable cookies in your browser settings. However, this may limit the functionality of our website. We therefore also recommend the following opt-out options, which are offered for specific areas:

    a) Europa: https://www.youronlinechoices.eu.
    b) Kanada: https://www.youradchoices.ca/choices.
    c) USA: https://optout.aboutads.info.
    d) Across regions: https://optout.aboutads.info.

Further information on processing procedures, methods and services:

  • Google Ads and conversion tracking: Online marketing methods for placing content and ads within the service provider’s advertising network (e.g., in search results, videos, on websites, etc.) so that they are displayed to users who have a likely interest in the ads. We also measure ad conversion, i.e., whether users have taken the opportunity to interact with the ads and use the advertised offers (so-called conversion). However, we only receive anonymous information and no personal information about individual users. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF); Further information: Types of processing and processed data: https://business.safety.google/adsservices/. Data processing conditions between controllers and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.

Presence in social networks (Social Media)

We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about ourselves.

Please note that user data may be processed outside the European Union. This may pose risks for users, as it could, for example, make it more difficult to enforce their rights.

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on usage patterns and the resulting user interests. These user profiles can then be used to display advertisements, both within and outside the networks, that are likely to correspond to the users’ interests. For these purposes, cookies are typically stored on users’ computers, recording their usage patterns and interests. Additionally, user profiles can also store data independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in).

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

Regarding requests for information and the assertion of data subject rights, we would like to point out that these can be most effectively addressed directly with the service providers. Only the providers have access to user data and can take appropriate action and provide information directly. However, should you require assistance, you can contact us.

  • Types of data processed: Contact details (e.g., email addresses, 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, timestamps, identification numbers, consent status).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Contact requests and communication; Feedback (e.g. collecting feedback via online form). Marketing.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Instagram: Social network; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland; Legal basis: Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f) DSGVO); Website: https://www.instagram.com. Privacy Policy: https://instagram.com/about/legal/privacy.
  • Facebook Pages: Profiles within the social network Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), Standard Contract Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum); Further information: We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content users view or interact with, or the actions they take (see “Things you and others do and provide” in the Facebook Data Policy).: https://www.facebook.com/policy), as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see “Device Information” in the Facebook Data Policy): https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, known as “Page Insights,” to page administrators so they can gain insights into how people interact with their pages and the content associated with them. We have a specific agreement with Facebook (“Information about Page Insights”), https://www.facebook.com/legal/terms/page_controller_addendum). This agreement specifically regulates the security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of data subjects (i.e., users can, for example, submit requests for information or deletion directly to Facebook). Further information can be found in the “Page Insights Information” section. (https://www.facebook.com/legal/terms/information_about_page_insights_data). Joint responsibility is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, particularly the transfer of data to its parent company, Meta Platforms, Inc., in the USA.
  • LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Irland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), Standard Contract Clauses (https://legal.linkedin.com/dpa); Right to object (Opt-Out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out; Further information:
    Together with LinkedIn Ireland Unlimited Company, we are responsible for collecting (but not further processing) visitor data for the purpose of generating “Page Insights” (statistics) for our LinkedIn profiles.
    This data includes information about the types of content users view or interact with, the actions they take, and information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data) and information from user profiles, such as job title, country, industry, hierarchical level, company size, and employment status. Information on data protection regarding the processing of user data by LinkedIn can be found in LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy
    We have concluded a special agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum (the ‘Addendum’)”, https://legal.linkedin.com/pages-joint-controller-addendum), which in particular regulates which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, submit requests for information or deletion directly to LinkedIn). The rights of users (in particular the rights to information, erasure, objection, and lodging a complaint with the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection of data by and its transfer to Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of Ireland Unlimited Company, which specifically concerns the transfer of data to its parent company, LinkedIn Corporation, in the USA.

Plugins and embedded functions as well as content

We integrate functional and content elements into our online services that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may include, for example, graphics, videos, or city maps (hereinafter collectively referred to as “content”).

The integration of third-party content always requires that these providers process users’ IP addresses, as they cannot send the content to users’ browsers without them. The IP address is therefore necessary for displaying this content or these functions. We strive to use only content from providers who use IP addresses solely for content delivery. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. These pixel tags allow for the analysis of information such as visitor traffic on the pages of this website. The pseudonymized information can also be stored in cookies on users’ devices and may include, among other things, technical information about the browser and operating system, referring websites, the time of visit, and other information about the use of our online services, as well as be combined with such information from other sources.

  • Types of data processed: Usage data (e.g., websites visited, interest in content, access times); metadata, communication and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status). Location data (information on the geographic position of a device or person).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online service and user-friendliness.
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Integration of third-party software, scripts, or frameworks (e.g., jQuery): We integrate software into our online services that we retrieve from third-party servers (e.g., function libraries that we use for the presentation or user-friendliness of our online services). In doing so, the respective providers collect users’ IP addresses and may process them for the purpose of transmitting the software to users’ browsers, for security purposes, and for evaluating and optimizing their services. Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Google Fonts (hosted on our own server): Provision of font files for the purpose of a user-friendly presentation of our online services; Service provider: The Google Fonts are hosted on our server; no data is transmitted to Google; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Font Awesome (deployed on your own server): Display of fonts and symbols; Service provider: The Font Awesome icons are hosted on our server; no data is transmitted to the provider of Font Awesome; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Google Maps: We integrate maps from the “Google Maps” service provided by Google. The data processed may include, in particular, users’ IP addresses and location data. Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy. Basis for third-country transfer: EU-US Data Privacy Framework (DPF).

Changes and updates to the privacy policy

We ask that you regularly review the content of our privacy policy. We will update the privacy policy as soon as changes to our data processing activities make this necessary. We will inform you if any changes require action on your part (e.g., consent) or any other individual notification.

If we provide addresses and contact information for companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting them.

Definitions of terms

This section provides an overview of the terms used in this privacy policy. Where terms are legally defined, those legal definitions apply. The following explanations are primarily intended to aid understanding.

  • Conversion tracking: Conversion tracking (also known as “visit action analysis”) is a method used to determine the effectiveness of marketing measures. Typically, a cookie is stored on users’ devices within the websites where the marketing measures are implemented and then retrieved again on the target website. For example, this allows us to track whether the ads we placed on other websites were successful.
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of “profiles with user-related information,” or simply “profiling,” encompasses any type of automated processing of personal data that involves using this personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this can include various information concerning demographics, behavior, and interests, such as interaction with websites and their content, etc.). Examples of such profiling include interests in specific content or products, click behavior on a website, or location. Cookies and web beacons are frequently used for profiling purposes.
  • Audience measurement: Audience measurement (also known as web analytics) is used to analyze visitor traffic to an online service and can include visitors’ behavior or interests in specific information, such as website content. With the help of audience analysis, operators of online services can, for example, determine when users visit their websites and which content they are interested in. This allows them to better tailor website content to the needs of their visitors. Pseudonymous cookies and web beacons are frequently used for audience analysis purposes to recognize returning visitors and thus obtain more accurate analyses of online service usage.
  • Location data: Location data is generated when a mobile device (or another device with the technical capabilities for location tracking) connects to a cell tower, Wi-Fi network, or similar location-determining technology. Location data indicates the geographically identifiable position of the device on Earth. Location data can be used, for example, to display map functions or other location-dependent information.
  • Tracking: “Tracking” refers to the process of observing user behavior across multiple online services. Typically, behavioral and interest information related to the online services used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
  • Controller: The term “controller” refers to 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 or on sets of personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, be it collection, analysis, storage, transmission, or erasure.

Created with the free data privacy generator Datenschutz-Generator.de by Dr. Thomas Schwenk