Privacy Policy

Introduction

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

Please note that the terms used are not gender specific.

Status: January 13, 2020

Table of contents

  • Introduction
  • Responsible
  • Overview of the processing operations
  • Relevant legal bases
  • Security measures
  • Transmission and disclosure of personal data
  • Data processing in third countries
  • Use of cookies
  • Performance of tasks in accordance with the articles of association or rules of procedure
  • Payment service provider
  • Blogs and publication media
  • Provision of the online offer and web hosting
  • Newsletter and Broadcasting
  • Online marketing
  • Presence in social networks
  • Plugins and embedded functions and content
  • Deletion of data
  • Amendment and update of the privacy policy
  • Rights of data subjects
  • Definitions of terms

Responsible:

Jonathan Widder

Constructive News e. V.

Soldiner Str. 19

13359 Berlin

Germany

Authorized representatives: Jonathan Widder (Director)

E-mail address: info (at) constructive-news.org

Legal notice: https://squirrel-news.net/imprint

Overview of the processing operations

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

Types of data processed:

  1. Inventory data (e.g. names, addresses)
  2. Content data (e.g. text entries, photographs, videos)
  3. Contact data (e.g. e-mail, telephone numbers)
  4. Meta/communication data (e.g. device information, IP addresses)
  5. Usage data (e.g. websites visited, interest in content, access times)
  6. Contract data (e.g. subject matter of the contract, duration, customer category)
  7. Payment data (e.g. bank details, invoices, payment history)

Categories of data subjects

  1. Business and contractual partners
  2. Users / readers (e.g. website visitors, users of online services)
  3. Donors, members
  4. Purposes of the processing
  5. Provision of our online offer and user-friendliness
  6. Visitor action evaluation
  7. Direct marketing (e.g. by e-mail or post)
  8. Feedback (e.g. collecting feedback via online form)
  9. Interest-based and behaviour-based marketing
  10. Contact requests and communication
  11. Conversion measurement (measuring the effectiveness of marketing measures)
  12. Profiling (creating user profiles)
  13. Remarketing
  14. Reach measurement (e.g. access statistics, recognition of returning visitors)
  15. Tracking (e.g. interest/behavioural profiling, use of cookies)
  16. Contractual performance and service
  17. Administration and answering of inquiries

Relevant legal bases

In the following section, we provide the legal basis of the basic data protection regulation (DSGVO), on the basis of which we process personal data. Please note that in addition to the regulations of the DSGVO, national data protection regulations may apply in your or our country of residence and domicile.

  1. Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO) – The data subject has given his or her consent to the processing of personal data relating to him or her for one or more specific purposes.
  2. Fulfilment of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. FADP) – Processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the request of the data subject.
  3. Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. FADP) – Processing is necessary to safeguard the legitimate interests of the controller or of a third party unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data prevail.

National data protection regulations in Germany

In addition to the data protection regulations of the basic data protection regulation, national regulations on data protection apply in Germany. These include in particular the law on protection against misuse of personal data in data processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to deletion, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision making in individual cases including profiling.

Furthermore, it regulates data processing for the purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Additionally, state data protection laws of the individual federal states may apply.

Security measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection commensurate with the risk.

Those measures shall include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, safeguarding of availability and segregation of data relating to them. Furthermore, we have established procedures to ensure that data subjects’ rights are exercised, data is deleted and responses to data threats are made. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures in accordance with the principle of data protection, by designing technology and by using data protection-friendly default settings.

SSL encryption (https):

To protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.

Transmission and disclosure of personal data

Within the scope of our processing of personal data, it happens that the data is transferred to other bodies, companies, legally independent organisational units or persons or that it is disclosed to them. The recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases we observe the legal requirements and in particular conclude appropriate contracts or agreements with the recipients of your data which serve to protect your data.

Data processing in third countries

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

Subject to express consent or to contractual or legally required transfers, we process or allow the data to be processed only in third countries with a recognized level of data protection, including the US processors certified under the Privacy Shield, or on the basis of special guarantees, such as contractual obligations under so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

Use of cookies

Cookies are text files that contain data from websites or domains visited and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after his visit within an online offer. The stored information may include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was viewed. The term “cookies” also includes other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also known as “user IDs”).

The following cookie types and functions are distinguished:

  1. Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user leaves an online offer and closes his browser.
  2. Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The interests of users used for reach measurement or marketing purposes can also be stored in such a cookie.
  3. First-party cookies: First-party cookies are set by ourselves.
  4. Third party cookies: Third party cookies are mainly used by advertisers (so-called third parties) to process user information.
  5. Necessary (also: essential or imperative) cookies: Cookies can be absolutely necessary for the operation of a website (e.g. to store logins or other user input or for security reasons).
  6. Statistical, marketing and personalization cookies: Furthermore, cookies are usually also used in the context of range measurement as well as when the interests of a user or his or her behavior (e.g. viewing certain content, using functions, etc.) on individual web pages are stored in a user profile. Such profiles are used to show users e.g. content that corresponds to their potential interests. This procedure is also known as “tracking”, i.e., following the potential interests of users. . If we use cookies or “tracking” technologies, we will inform you separately in our data protection declaration or when obtaining your consent.

Notes on legal bases:

The legal basis on which we process your personal data with the help of cookies depends on whether we ask you for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed with the aid of cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfil our contractual obligations.

General notes on revocation and objection (opt-out):

Depending on whether the processing is based on consent or legal permission, you have the possibility at any time to revoke a given consent or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection by means of the settings of your browser, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online service).

An objection to the use of cookies for online marketing purposes can also be declared by means of a variety of services, especially in the case of tracking, via the websites http://optout.aboutads.info and http://www.youronlinechoices.com/. In addition, you can receive further notices of objection in the context of the information on the service providers and cookies used.

Processing of cookie data based on consent: 

Before we process data within the scope of the use of cookies or have them processed, we ask users for their consent, which can be revoked at any time. Before consent has not been given, cookies are used if necessary, which are necessary for the operation of our online offer. Their use is based on our interest and the interest of the users in the expected functionality of our online offer.

  1. Processed types of data: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  2. Persons concerned: Users (e.g. website visitors, users of online services).
  3. Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Performance of tasks in accordance with the articles of association or rules of procedure

We process the data of our members, supporters, interested parties, business partners or other persons (collectively “data subjects”), if we have a membership or other business relationship with them and perform our duties and are recipients of services and benefits. In all other respects, we process the data of Data Subjects on the basis of our legitimate interests, e.g. if administrative tasks or public relations work are involved.

The data processed, the type, scope and purpose of such processing and the necessity of processing them are determined by the underlying membership or contractual relationship, from which the necessity of any data information also arises (in other respects we refer to required data).

We delete data that is no longer necessary for the provision of our statutory and business purposes. This is determined according to the respective tasks and contractual relationships. We retain the data for as long as they may be relevant to the processing of the business and also with regard to any warranty or liability obligations based on our legitimate interest in their regulation. The necessity of storing the data is regularly reviewed; otherwise the statutory storage obligations apply.

  • Processed data types: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of the contract, duration, customer category).
  • Persons concerned: Users (e.g. website visitors, users of online services), members, business and contractual partners.
  • Purposes of processing: contractual services and performance, contact requests and communication, administration and answering of requests.
  • Legal basis: Fulfilment of contracts and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Payment service provider

Within the framework of contractual and other legal relationships, due to legal obligations or otherwise based on our legitimate interests, we offer the persons concerned efficient and secure payment options and use other payment 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 name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient related data. These details are required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored by them. 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 payment service providers may transmit the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the General Terms and Conditions and the data protection notices of the payment service providers.

The terms and conditions and the data protection information of the respective payment service providers apply to the payment transactions, which can be called up within the respective websites or transaction applications. We also refer to these for further information and the assertion of rights of revocation, information and other rights of affected persons.

  • Processed data types: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, and payment history), contract data (e.g. subject matter of the contract, duration, and customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Customers, interested parties.
  • Purposes of processing: contractual services and performance, contact requests and communication, affiliate tracking.
  • Legal basis: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Services used and service providers:

  1. PayPal: payment services and solutions (e.g. PayPal, PayPal Plus, Braintree); service providers: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; website: https://www.paypal.com/de; privacy policy:  https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
  2. Stripe: payment services; service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; website: https://stripe.com/de; privacy policy: https://stripe.com/de/privacy.
  3. Donorbox: Rebel Idealist LLC, 5 3rd St, Suite 900, San Francisco, CA 94103; Website: https://donorbox.org; privacy policy: https://donorbox.org/privacy
  4. Fundraisingbox: Wikando GmbH, Schießgrabenstr. 32, 86150 Augsburg; Website: https://www.fundraisingbox.com; privacy policy:  https://www.fundraisingbox.com/datenschutz/ 

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data are processed for the purposes of the publication medium only to the extent necessary for its presentation and for communication between authors and readers or for security reasons. In addition, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.

  1. Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, and videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  2. Persons concerned: Users (e.g. website visitors, users of online services).
  3. Purposes of processing: contractual services and performance, feedback (e.g. collecting feedback via online form).
  4. Legal basis: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Provision of the online offer and web hosting

In order to provide our online services securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online services can be accessed. For these purposes we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security and technical maintenance services.

The data processed within the scope of providing the hosting offer may include all data concerning the users of our online offer, which are generated within the scope of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

E-mail dispatch and hosting

The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. 

The aforementioned data may also be processed for the purpose of SPAM detection. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.

Collection of access data and log files

We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). Server log files may include the address and name of the web pages and files accessed, date and time of access, data volume transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the capacity utilisation of the servers and their stability.

  • Processed data types: Content data (e.g. text entries, photographs, and videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Newsletter and Broadcasting

We send newsletters, e-mails and other electronic notifications (hereinafter “newsletters”) only with the consent of the recipients or a legal permission. If the contents of the newsletter are specifically described in the context of a registration for the newsletter, they are decisive for the consent of the users. Furthermore, our newsletters contain information about our services and us.

In order to register for our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name for the purpose of personal contact in the newsletter, or other details if these are necessary for the purposes of the newsletter.

Double opt-in procedure

The registration to our newsletter is always done in a so-called Double-Opt-In-Process. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can register with foreign e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored by the shipping service provider are also logged.

Deletion and restriction of processing

We may store the deleted e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that we have previously given our consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time. In case of obligations to permanently observe contradictions, we reserve the right to store the e-mail address in a blacklist for this purpose alone.

The logging of the registration procedure is carried out on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Information on legal bases

The dispatch of newsletters is based on the consent of the recipients or, if consent is not required, on our legitimate interests in direct marketing, if and to the extent permitted by law, e.g. in the case of advertising to existing customers. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests in order to prove that it was carried out in accordance with the law.

Measurement of success

The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a dispatch service provider, from their server. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and the time of the retrieval, is initially collected.

This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined by means of the IP address) or the access times. This analysis also includes determining whether the newsletter is opened, when it is opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. 

However, it is neither our endeavour nor, if used, that of the dispatch service provider to observe individual users. Rather, the evaluations serve to identify the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves our business interests and meets the expectations of the users.

A separate revocation of the performance measurement is unfortunately not possible, in which case the entire newsletter subscription must be cancelled or objected to.

  • Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
  • Affected persons: communication partners.
  • Purposes of processing: direct marketing (e.g. by e-mail or post).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Opt-out

You can cancel the receipt of our newsletter at any time, i.e. revoke consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter, or can use one of the contact options listed above, preferably e-mail.

Online marketing

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 and the measurement of their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which the user information relevant for the presentation of the aforementioned content is stored. This information may include, for example, the content viewed, web pages visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed.

The IP addresses of users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect the users. In general, the online marketing procedure does not store any clear user data (such as e-mail addresses or names), but pseudonyms. This means that we as well as the providers of the online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles.

As a rule, the information in the profiles is stored in the cookies or by means of similar procedures. These cookies can later be read out and analysed for the purpose of presenting content on other websites that use the same online marketing procedure, and can also be supplemented with additional data and stored on the server of the online marketing procedure provider.

As an exception, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing procedure we use and the network connects the profiles of the users in the aforementioned data. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.

As a matter of principle, we only receive access to summarized information about the success of our advertisements. However, we can check in the context of so-called conversion measurements which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyse the success of our marketing measures.

Unless otherwise stated, we ask you to assume that cookies used are stored for a period of two years.

Notes on legal bases

If we ask users to give their consent to the use of third parties, the legal basis for processing data is consent. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Users (e.g. website visitors, users of online services), interested parties.
  • Purposes of processing: Tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, visitor action analysis, interest-based and behavioural marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures: IP-Masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Possibility of objection (opt-out)

We refer to the data protection notices of the respective providers and the possibilities of objection stated for the providers (so-called “opt-out”). If no explicit opt-out option has been specified, it is possible to switch off cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary form for the respective areas:

  1. Europe: https://www.youronlinechoices.eu.
  2. Canada: https://www.youradchoices.ca/choices.
  3. USA: https://www.aboutads.info/choices.
  4. Cross-regional: http://optout.aboutads.info

Services used and service providers

  1. Google Analytics: online marketing and web analytics; service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com/intl/de/about/analytics/; privacy policy: https://policies.google.com/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; opt-out: opt-out plug-in: http://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertising: https://adssettings.google.com/authenticated.
  2. Google Ads and Conversion Measurement: We use the online marketing process “Google Ads” to place ads in the Google advertising network (e.g., in search results, in videos, on web pages, etc.) to be displayed to users who have a presumed interest in the ads. We also measure the conversion of the ads. However, we only know the total number of anonymous users who clicked on our ad and were redirected to a page with a so-called “conversion tracking tag”. We do not receive any information that can be used to identify users. Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.

Presence on social networks

We maintain online presences within social networks in order to communicate with the users active there or to offer information about us there.

Please note that user data may be processed outside the European Union. This can result in risks for the users, because the enforcement of the users’ rights could be made more difficult. With regard to US providers that are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we would like to point out that they thereby undertake to comply with the data protection standards of the EU.

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

For a detailed description of the respective forms of processing and the possibilities of objection (opt-out), please refer to the data protection declarations and information provided by the operators of the respective networks.

Additionally in the case of requests for information and the assertion of data subject rights, we would like to point out that these can most effectively be asserted with the providers. Only the providers have access to the data of the users and can take appropriate measures and provide information directly. Should you nevertheless require assistance, please contact us.

  • Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, and videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Purposes of processing: contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
  • Legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Services used and service providers

  1. Instagram: Social network; Service provider: Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA; Web site: https://www.instagram.com; Privacy policy: http://instagram.com/about/legal/privacy.
  2. Facebook: Social network; service provider: Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy Statement: https://www.facebook.com/about/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Opt-Out: Settings for advertisements: https://www.facebook.com/settings?tab=ads; Additional Privacy Notice: Agreement on joint processing of personal data on Facebook Pages: https://www.facebook.com/legal/terms/page_controller_addendum, Privacy Notice for Facebook Pages: https://www.facebook.com/legal/terms/information_about_page_insights_data.
  3. LinkedIn: social network; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; website: https://www.linkedin.com; privacy statement: https://www.linkedin.com/legal/privacy-policy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active; opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  4. Twitter: social network; service provider: Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Privacy Policy: https://twitter.com/de/privacy, (Settings) https://twitter.com/personalization; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.
  5. Xing: social network; service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Website: https://www.xing.de; Privacy Policy: https://privacy.xing.com/de/datenschutzerklaerung.

Plugins and embedded functions and content

We include in our online offer functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as “third party providers”). These may be, for example, graphics, videos or social media buttons as well as contributions (hereinafter uniformly referred to as “content”).

The integration always requires that the third party providers of such content process the IP address of the users, as without the IP address they would not be able to send the content to their browsers. The IP address is therefore required for the display of these contents or functions. We make every effort to use only such content whose respective providers use the IP address only to deliver the content. Third party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain technical information about the browser and operating system, websites to be referred to, the time of visit and other details about the use of our online offer, as well as being linked to such information from other sources.

Notes on legal bases

If we ask users for their consent to use third party providers, the legal basis for processing data is consent. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness, contractual services and service.
  • Legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Services used and service providers

  1. Google Fonts: We integrate the fonts (“Google Fonts”) of the provider Google, whereby the data of the users are used solely for the purpose of displaying the fonts in the users’ browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform presentation and taking into account possible licensing restrictions for their integration. service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://fonts.google.com/; privacy policy: https://policies.google.com/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TRkEAAW&status=Active.

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consent permitted for processing is revoked or other permissions cease to apply (e.g. if the purpose for processing these data ceases to apply or if they are not necessary for the purpose).

Unless the data are deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose retention is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.

Further information on the deletion of personal data can also be provided in the individual data protection notes of this data protection declaration.

Amendment and updating of the data protection declaration

We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes make it necessary for you to cooperate (e.g. consent) or to receive other individual notification.

If we provide addresses and contact information of companies and organisations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.

Rights of data subjects

As data subjects, they are entitled to various rights under the DSGVO, which result in particular from Art. 15 to 18 and 21 DSGVO:

  1. Right of objection: You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data relating to you which is carried out on the basis of Art. 6 paragraph 1 letter e or f FADP; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing, including profiling, insofar as it is linked to such direct marketing.
  2. Right to withdraw consent: You have the right to withdraw any consent given at any time.
  3. Right of access: You have the right to obtain confirmation as to whether data in question is being processed and to obtain information on such data and to obtain further information and copies of the data in accordance with the law.
  4. Right of rectification: You have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you in accordance with the law.
  5. Right to erasure and restriction of processing: You have the right to request that data concerning you be erased immediately or, alternatively, to request a restriction of processing of the data in accordance with the law.
  6. Right to data transferability: You have the right to receive data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transferred to another responsible party.
  7. Complaints to the supervisory authority: You also have the right, in accordance with the statutory provisions, to lodge a complaint with a supervisory authority, in particular in the Member State in which you are normally resident, your place of work or the place where the infringement is alleged to have occurred, if you consider that the processing of personal data relating to you is in breach of the DPA.

Definitions of terms

This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined above all in Art. 4 DSGVO. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.

  1. Affiliate tracking: As part of affiliate tracking, links are logged with the help of which the linking websites refer users to websites with product or other offers. The operators of the respective linking websites can receive a commission if users follow these so-called affiliate links and then take advantage of the offers (e.g. buy goods or services). For this purpose, it is necessary for the providers to be able to track whether users who are interested in certain offers subsequently take notice of them at the instigation of the affiliate links. Therefore, for affiliate links to work, it is necessary to add certain values to them, which become part of the link or are stored elsewhere, e.g. in a cookie. These values include, in particular, the initial website (referrer), the time, an online identification of the operator of the website on which the affiliate link was located, an online identification of the respective offer, an online identification of the user as well as tracking specific values, such as advertising material ID, partner ID and categorizations.
  2. Conversion tracking: Conversion tracking is a method of determining the effectiveness of marketing activities. For this purpose, a cookie is usually stored on the user’s devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, we can use this to track whether the ads we have placed on other websites have been successful).
  3. IP-Masking: “IP-Masking” is a method in which the last octet, i.e. the last two numbers of an IP address, are deleted so that the IP address can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymizing processing procedures, especially in online marketing
  4. Interest-based and behavioral marketing: Interest-based and/or behavioral marketing is when potential interests of users in advertisements and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behaviour (e.g. visiting and staying on certain websites, buying behaviour or interaction with other users), which is stored in a so-called profile. As a rule, cookies are used for these purposes.
  5. Conversion measurement: Conversion measurement is a method by which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users’ devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, we can use this to track whether the ads we have placed on other websites have been successful.
  6. Personal Data: “Personal Data” shall mean 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 one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  7. Profiling: “profiling” is any automated processing of personal data consisting of the use of personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information on age, gender, location and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people). Cookies and web beacons are often used for profiling purposes.
  8. Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behaviour or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, identify at what time visitors visit their website and what content they are interested in. This enables them to better adapt the contents of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis purposes in order to recognise returning visitors and thus obtain more precise analyses of the use of an online offering.
  9. Remarketing: One speaks of “remarketing” or “retargeting”, e.g. when it is noted for advertising purposes in which products a user was interested on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  10. Tracking: One speaks of “tracking” if the behaviour of users can be traced across several online offers. As a rule, behavioral and interest information regarding the online offers used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
  11. Controller: The term “Controller” refers to the natural or legal person, authority, institution or other body which alone or jointly with others determines the purposes and means of processing personal data.
  12. Processing: “processing” shall mean any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually all processing of data, whether it be collection, analysis, storage, communication or deletion.

Created with Datenschutz-Generator.de by Dr. Thomas Schwenke.