Privacy policy
Preamble
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" for short) that 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 as part of the provision of our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "Online Offer").
The terms used are not gender-specific.
Status: May 28, 2023
Table of contents
Preamble
Person responsible
Overview of processing operations
Relevant legal basis
Security measures
Data processing in third countries
Deletion of data
Use of cookies
Business services
Payment procedures
Provision of the online offer and web hosting
Contact and inquiry management
Promotional communication via e-mail, mail, fax or telephone
Web analysis, monitoring and optimization
Online marketing
Customer reviews and evaluation procedures
Presence in social networks (social media)
Plugins and embedded functions and content
Modification and updating of the privacy policy
Rights of data subjects
Definitions
Responsible
VAT number: DE343191393
Tax number: 37/300/50399
Oleksandr Yanovskyi
Deutschland / Germany
Game Boosting GmbH
E-Mail
Email address:
retail@gameboosting.io
Outbox:
https://padpad.net/
Overview of the processing operations
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 data.
Contact data.
Content data.
Contract data.
Usage data.
Meta, communication and procedural data.
Categories of data subjects
Customers.
Interested parties.
Communication partners.
Users.
Business and contractual partners.
Purposes of processing
Provision of contractual services and customer service.
Contact requests and communication.
Security measures.
Direct marketing.
Reach measurement.
Tracking.
Office and organization procedures.
Conversion measurement.
Managing and responding to inquiries.
Feedback.
Marketing.
Profiles with user-related information.
Provision of our online services and user experience.
Information technology infrastructure.
Relevant legal bases
Below you will find an overview of the legal bases of the DSGVO, on the basis of 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 domicile. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.
Consent (Art. 6 (1) p. 1 lit. a) GDPR) - The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
Performance of a contract and pre-contractual requests (Art. 6 (1) p. 1 lit. b) DSGVO) - Processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures carried out at the data subject's request.
Legal obligation (Art. 6 (1) p. 1 lit. c) DSGVO) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
Legitimate interests (Art. 6 (1) p. 1 lit. f) DSGVO) - Processing is necessary for the purposes of the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. These include, in particular, the Act 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 erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for employment purposes (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. Furthermore, 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 appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, the deletion of data, and responses to data compromise. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software as well as procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
IP address shortening: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not required, the IP address is shortened (also referred to as "IP masking"). In this process, the last two digits or the last part of the IP address after a period are removed or replaced by wildcards. The shortening of the IP address is intended to prevent or make it significantly more difficult to identify a person by their IP address.
TLS encryption (https): To protect your data transmitted via our online offer, we use TLS encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.
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 the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies, this will only be done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence 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).
Deletion of data
The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not necessary for the purpose). If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. That is, 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 storage is necessary for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.
Our privacy notices may also contain further information on the retention and deletion of data, which will take precedence for the respective processing operations.
Use of cookies
Cookies are small text files or other notes in memory that store information on terminal devices and read information from terminal devices. For example, to store the login status of a user account, the contents of a shopping cart in an online store, access to content or used functions of an online offer. In addition, cookies can be used for various purposes, for example, to ensure the functionality, security and convenience of online offers and to analyze visitor flows.
Consent information: We use cookies within the scope of legal requirements. Therefore, we obtain the prior consent of users unless required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary to provide users with the telemedia service they have expressly requested (i.e. our online offering). Absolutely necessary cookies generally include cookies with functions that enable the display and operation of the online offering, load balancing, security, storage of user preferences and selections, or similar purposes related to the provision of basic and additional functions of the online offering requested by users. . The revoked consent will be clearly communicated to users and will contain information on the intended use of cookies.
Notes on legal bases under data protection law: The legal basis under data protection law on which we process users' personal data using cookies depends on whether we ask users for consent. If users provide consent, the legal basis for the processing of their data is the declared consent. Otherwise, the processing of data processed by cookies is based on our legitimate interests (e.g., in the economic exploitation of our online offer and the improvement of its usability) or, if this is done in the context of the performance of our contractual obligations, if the use of cookies that are necessary for the performance of our contractual obligations. For what purposes do we process cookies,
Expiration date: With regard to the storage period, a distinction is made between the following types of cookies:
Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after the user leaves the online offer and closes his end device (e.g. browser or mobile application).
Persistent cookies. Persistent cookies remain stored even after the terminal device is closed. For example, the login status can be saved or the desired content can be displayed directly when the user visits the website again. Likewise, user data collected through cookies can be used for reach measurement. Unless we provide users with explicit information about the type and duration of cookies (e.g., when obtaining consent), users should assume that cookies are permanent and can be stored for up to two years.
General information on revocation and objection (opt-out): Users can revoke their consent at any time as well as object to processing in accordance with the legal requirements of Art. 21 DSGVO. Users can also express their objection via their browser settings, for example by deactivating the use of cookies (which may also limit the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be made via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ .
Cookie Settings/Opt-Out:
https://apps.shopify.com/eu-cookie-bar?search_id=8ea69626-d8b0-46c3-8c56-bf345f661178&surface_detail=cookie&surface_inter_position=1&surface_intra_position=4&surface_type=search
Legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f DSGVO); consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
Further information on processing processes, procedures and services:
Consent-based cookie data processing: we use a cookie consent management procedure, under which the consent of users to the use of cookies or their processing and providers named in the cookie consent management procedure are obtained, managed and revoked the user. . The declaration of consent is stored here in order to avoid a repetition of the request and to be able to prove the consent in accordance with a legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-out cookie or through comparable technologies), so that the consent can be assigned to the user or his device. Depending on the individual details of the cookie management service provider, the following information applies: Consent can be stored for up to two years. A pseudonymous user ID is created and stored with the time of consent, information about the scope of consent (e.g. which categories of cookies and/or service providers), as well as the browser, system and end device used; legal basis: consent (Art. 6 para. 1 p. 1 lit. a DSGVO).
Business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners") in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer inquiries.
We process this data in order to fulfill our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. In addition, we process the data to safeguard our rights and for the purpose of administrative tasks associated with these obligations and company organization. Furthermore, we process the data on the basis of our legitimate interests in proper and business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary 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 the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.
We inform the contractual partners which data is required for the aforementioned purposes before or in the course of data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.
We delete the data after expiry of legal warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g., as long as it must be kept for legal archiving reasons. The statutory retention period is ten years for documents relevant under tax law as well as for commercial books, inventories, opening balances, annual financial statements, the work instructions required to understand these documents and other organizational documents and accounting records, and six years for received commercial and business letters and reproductions of sent commercial and business letters. The period shall commence at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was prepared, the commercial or business letter was received or dispatched or the accounting document was created, furthermore the recording 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 data protection notices of the respective third-party providers or platforms apply in the relationship between the 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., e-mail, telephone numbers); contract data (e.g., subject matter of contract, term, customer category); usage data (e.g., web pages visited, interest in content, access times); meta, communication and process data (e.g., IP addresses, time information, identification numbers, consent status).
Data subjects: Customers; prospective customers; business and contractual partners.
Purposes of processing: provision of contractual services and customer service; security measures; contact requests and communication; office and organizational procedures; administration and response to requests.
Legal Grounds: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legal obligation (Art. 6 para. 1 p. 1 lit. c) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further notes on processing processes, procedures and services:
Store and e-commerce: We process the data of our customers to enable them to select, purchase or order the selected products, goods and related services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery, or execution to our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is identified as such in the context of the order or comparable acquisition process and includes the information needed for delivery, or provision and billing, as well as contact information in order to be able to contact you if necessary; legal basis: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Payment procedure
In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other service providers for this purpose in addition to banks and credit institutions (collectively, "payment service providers").
The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is required in order to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e., we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the payment service providers transmit the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the terms and conditions and data protection information of the payment service providers.
For payment transactions, the terms and conditions and data protection notices of the respective payment service providers apply, which can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and assertion of revocation, information and other data subject rights.
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 contract, term, customer category); 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); contact data (e.g., email, phone numbers).
Data subjects: Customers; prospective customers.
Purposes of processing: provision of contractual services and customer service.
Legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Further notes on processing operations, procedures and services:
Apple Pay: payment services (technical connection of online payment methods); service providers: Apple Inc, Infinite Loop, Cupertino, CA 95014, USA; Legal basis: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://www.apple.com/de/apple-pay/; Privacy policy: https://www.apple.com/legal/privacy/de-ww/.
Giropay: Payment services (technical connection of online payment methods); Service provider: giropay GmbH, An der Welle 4, 60322 Frankfurt, Germany; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://www.giropay.de; Privacy policy: https://www.giropay.de/rechtliches/datenschutzerklaerung/.
Google Pay: payment services (technical connection of online payment methods); service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); website: https://pay.google.com/intl/de_de/about/; privacy policy: https://policies.google.com/privacy.
Klarna: Payment services (technical connection of online payment methods); Service provider: Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://www.klarna.com/de; Privacy policy: https://www.klarna.com/de/datenschutz.
Mastercard: payment services (technical connection of online payment methods); service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; legal basis: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); website: https://www.mastercard.de/de-de.html; Datenschutzerklärung: https://www.mastercard.de/de-de/datenschutz.html.
PayPal: Payment services (technical connection of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; legal basis: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); website: https://www.paypal.com/de; privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
Stripe: payment services (technical connection of online payment methods); service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://stripe.com; Privacy policy: https://stripe.com/de/privacy.
Visa: payment services (technical connection of online payment methods); service provider: Visa Europe Services Inc, London Branch, 1 Sheldon Square, London W2 6TT, GB; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://www.visa.de; Privacy policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html.
Provision of the online offer and web hosting
We process the users' data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or terminal device.
Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
Data subjects: Users (e.g., website visitors, users of online services).
Purposes of processing: provision of our online offer 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 p. 1 lit. f) DSGVO).
Further notes on processing processes, procedures and services:
Collection of access data and log files: Access to our online offer is logged in the form of so-called "server log files". The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files may be used, on the one hand, for security purposes, e.g., to prevent server overload (especially in the event 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 p. 1 lit. f) DSGVO); Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.
Contact and inquiry management
When contacting us (e.g. by mail, contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.
Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
Data subjects: Communication partners.
Purposes of processing: contact inquiries and communication; managing and responding to inquiries; feedback (e.g. collecting feedback via online form); providing our online offer and user experience.
Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Further notes on processing operations, procedures and services:
Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context for the purpose of processing the communicated request; legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) DSGVO), Legitimate Interests (Art. 6 para. 1 sentence 1 lit. f) DSGVO).
Promotional communication via e-mail, mail, fax or telephone.
We process personal data for the purposes of promotional communication, which may take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.
Recipients have the right to revoke consent given at any time or to object to promotional communication at any time.
After revocation or objection, we store the data required to prove the previous authorization to contact or send for up to three years after the end of the year of revocation or objection based on our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. Based on the legitimate interest of permanently observing the user's revocation or objection, we also store the data required to avoid contacting the user again (e.g., depending on the communication channel, the e-mail address, telephone number, name).
Types of data processed: inventory data (e.g., names, addresses); contact data (e.g., email, phone numbers).
Data subjects: Communication partners.
Purposes of processing: direct marketing (e.g. by e-mail or post).
Legal grounds: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Web analysis, monitoring and optimization
Web analytics (also referred to as "reach measurement") is used to evaluate the flow of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimization.
In addition to web analytics, we may also use testing procedures, for example, to test and optimize different versions of our online offering or its components.
Unless otherwise stated below, profiles, i.e. data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and read from it. The information collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used, and information on usage times. If users have agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed.
The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, in the context of web analysis, A/B testing and optimization, no clear data of the users (such as e-mail addresses or names) are stored, but pseudonyms. That is, we as well as 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., web pages visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
Data subjects: Users (e.g., website visitors, users of online services).
Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors); profiling with user-related information (creation of user profiles); tracking (e.g. interest/behavior-based profiling, use of cookies); provision of our online offer and user experience.
Security measures: IP masking (pseudonymization of the IP address).
Legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
Further notes on processing processes, procedures and services:
Google Optimize: Software for the analysis and optimization of online offers on the basis of feedback functions as well as pseudonymously performed measurements and analyses of user behavior, which may include in particular A/B tests (measurement of popularity and user-friendliness of different content and functions), measurement of click paths and interaction with content and functions of the online offer; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: consent (Art. 6 (1) p. 1 lit. a) DSGVO); Website: https://optimize.google.com; Privacy policy: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms; Standard contractual clauses (ensuring level of data protection in case of processing in third countries): https://business.safety.google/adsprocessorterms; Further information: https://privacy.google.com/businesses/adsservices (types of processing as well as data processed).
Google Analytics: web analytics, reach measurement as well as measurement of user flows; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Datenschutzerklärung: https://policies.google.com/privacy;
Order processing contract: https://business.safety.google/adsprocessorterms; Standard contractual clauses (guaranteeing the level of data protection in the case of processing in third countries): https://business.safety.google/adsprocessorterms; Opt-out option: Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de; Settings for the display of advertisements: https://adssettings.google.com/authenticated; Further information: https://privacy.google.com/businesses/adsservices (types of processing as well as data processed).
Google Analytics 4: We use Google Analytics to measure and analyze the use of our online offer on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to an end device in order to recognize which content users have accessed within one or various usage processes, which search terms they have used, have accessed again or have interacted with our online offering. Likewise, the time of use and its duration are stored, as well as the sources of users referring to our online offer and technical aspects of their end devices and browsers. In the process, pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used. In Analytics, higher level geographic location data is provided by collecting the following metadata based on IP search: "city" (and the derived latitude and longitude of the city), "continent", "country", "region", "subcontinent" (and the ID-based equivalents). To ensure the protection of user data in the EU, Google receives and processes all user data via domains and servers within the EU. The IP address of users is not logged and is shortened by the last two digits by default. The shortening of the IP address takes place on EU servers for EU users. In addition, all sensitive data collected from users in the EU is deleted before being collected via EU domains and servers; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: consent (Art. 6 (1) p. 1 lit. a) DSGVO); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms/; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://business.safety.google/adsprocessorterms; Opt-out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated; Further information: https://privacy.google.com/businesses/adsservices (types of processing as well as data processed).
Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offering (please refer to further information in this privacy policy). With the Tag Manager itself (which implements the tags), therefore, no profiles of users are created or cookies are stored, for example. Google only learns the IP address of the user, which is necessary to run the Google Tag Manager; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: consent (Art. 6 (1) p. 1 lit. a) DSGVO); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Order processing agreement: https://business.safety.google/adsprocessorterms; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://business.safety.google/adsprocessorterms.
Online marketing
We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or display of promotional and other content (collectively, "content") based on potential user interests and measuring its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar procedures are used, by means of which the information about the user relevant for the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information, such as the browser used, the computer system used and information on usage times and functions used. 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 users. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, 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.
The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can later generally also be read on other websites that use the same online marketing procedure and analyzed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.
Exceptionally, clear data can be assigned to the profiles. This is the case if, for example, the users are members of a social network whose online marketing procedure we use and the network links the users' profiles with the aforementioned data. We ask to note that users may make additional arrangements with the providers, e.g., by giving consent as part of the registration process.
In principle, we only receive access to summarized information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e., for example, to a conclusion of a contract with us. The conversion measurement is used solely to analyze the success of our marketing measures.
Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.
Types of data processed: Usage data (e.g., web pages visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
Data subjects: Users (e.g., website visitors, users of online services).
Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest/behavior-based profiling, use of cookies); marketing; profiling with user-related information (creating 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 p. 1 lit. a) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Option to object (opt-out): We refer to the data protection notices of the respective providers and the objection options given to the providers (so-called "opt-out"). If no explicit opt-out option has been specified, you have the option of disabling cookies in your browser settings. However, this may restrict functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for the respective areas: a) Europe: https://www.youronlinechoices.eu b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Inter-territory: https://optout.aboutads.info.
Further notes on processing operations, procedures and services:
Google Ads and conversion measurement: online marketing process for the purpose of placing content and ads within the service provider's advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. In addition, we measure the conversion of the ads, i.e. whether users have taken them as an 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) DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) DSGVO); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Further information: Types of processing as well as data processed: https://privacy.google.com/businesses/adsservices; Data processing conditions between data controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
Google Adsense with personalized ads: We use the Google Adsense service with personalized ads, with the help of which ads are displayed within our online offer and we receive remuneration for their display or other use; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Further information: Types of processing as well as data processed: https://privacy.google.com/businesses/adsservices; Google Advertising Products Data Processing Terms: Information on services Data processing conditions between data controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
Google Adsense with non-personalized ads: We use the Google Adsense service with non-personalized ads, with the help of which ads are displayed within our online offer and we receive remuneration for their display or other use; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: consent (Art. 6 para. 1 p. 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Other information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices; Google Ads Controller-Controller Data Protection Terms and standard contractual clauses for data transfers to third countries: https://business.safety.google/adscontrollerterms.
Customer reviews and rating procedures
We participate in review and rating processes in order to evaluate, optimize and promote our services. If users rate us or otherwise provide feedback via the participating rating platforms or procedures, the General Terms and Conditions of Business or Use and the privacy notices of the providers also apply. As a rule, the rating also requires registration with the respective providers.
In order to ensure that the persons rating have actually used our services, we transmit the data required for this with the consent of the customer to the respective rating platform with regard to the customer and the service used (including name, e-mail address and order number or item number). This data is used solely to verify the authenticity of the user.
Types of data processed: contractual data (e.g., subject matter of contract, term, customer category); usage data (e.g., web pages visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
Data subjects: Customers; users (e.g., website visitors, users of online services).
Purposes of processing: feedback (e.g. collecting feedback via online form); marketing.
Legal grounds: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further notes on processing processes, procedures and services:
Rating widget: we integrate so-called "rating widgets" into our online offer. A widget is a functional and content element integrated into our online offer that displays changeable information. It can be displayed, for example, in the form of a seal or comparable element, sometimes also called a "badge". In this case, the corresponding content of the widget is displayed within our online offer, but it is retrieved at that moment from the servers of the respective widget provider. This is the only way to always show the current content, especially the current rating. For this purpose, a data connection must be established from the website accessed within our online offering to the widget provider's server, and the widget provider receives certain technical data (access data, including IP address) that are necessary so that the content of the widget can be delivered to the user's browser. Furthermore, the widget provider receives information that users have visited our online offer. This information may be stored in a cookie and used by the widget provider to identify which online offers participating in the evaluation process have been visited by the user. The information may be stored in a user profile and used for advertising or market research purposes; legal basis: legitimate interests (Art. 6 (1) p. 1 lit. f) DSGVO).
Trustpilot: rating platform; service provider: Trustpilot A/S, Pilestræde 58, 5, 1112 Copenhagen, Denmark; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://de.trustpilot.com; Privacy policy: https://de.legal.trustpilot.com/end-user-privacy-terms.
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 users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for the users because, for example, it may be more difficult to enforce the rights of the users.
Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and 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 behavior and interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).
For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the privacy statements and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can take appropriate measures and provide information directly. If you still need assistance, you can contact us.
Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
Data subjects: 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 p. 1 lit. f) DSGVO).
Further notes on processing operations, procedures and services:
Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 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 - We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data of 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 under "Things You and Others Do and Provide" in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices users use (e.g., IP addresses, operating system, browser type, language settings, cookie data; see under "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, so-called "Page Insights", to Page operators so that they can gain insights into how people interact with their Pages and with the content associated with them. We have entered into a special agreement with Facebook ("Page Insights Information," https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the data subject rights (i.e., users can, for example, direct information or deletion requests to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority), are not restricted by the agreements with Facebook. Further information can be found in the "Information on Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data); service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal Grounds: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Standard Contractual Clauses (ensuring level of data protection for processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Further Information: Shared Responsibility Agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data. Joint accountability is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of data to the parent company Meta Platforms, Inc. in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
Plugins and embedded functions and content
We incorporate into our online offering functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These can be, for example, graphics, videos or city maps (hereinafter uniformly referred to as "content").
The integration always requires that the third-party providers of this content process the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus required for the presentation of this content or function. We strive to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to analyze information such as visitor traffic on the pages of this website. The pseudonymous information may further be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer as well as be linked to such information from other sources.
Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status); inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of our online offer and user-friendliness.
Legal grounds: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further notes on processing operations, procedures and services:
YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Opt-out: Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de; Ad Display Settings: https://adssettings.google.com/authenticated.
Change and update of the privacy policy
We ask you to regularly inform yourself about the content of our privacy policy. We adapt the privacy policy as soon as the changes in the data processing carried out by us make it necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
Where we provide addresses and contact information of companies and organizations in this privacy statement, please note that the addresses may change over time and please check the information before contacting us.
Rights of the data subjects
As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:
Right to object: you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data relating to you which is carried out on the basis of Art. 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is 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; this also applies to profiling insofar as it is related to such direct marketing.
Right to withdraw consent: You have the right to revoke any consent given at any time.
Right to information: you have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
Right to rectification: In accordance with the legal requirements, you have the right to request that the data concerning you be completed or that the incorrect data concerning you be rectified.
Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be erased without delay or, alternatively, to demand restriction of the processing of the data in accordance with the legal requirements.
Right to data portability: 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 demand its transfer to another responsible party.
Complaint to supervisory authority: without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the requirements of the GDPR.
Definitions
This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined primarily in Art. 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are sorted alphabetically.
Conversion measurement: Conversion measurement (also referred to as "visit action evaluation") is a procedure with 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 take place and then retrieved again on the target website. For example, this enables us to track whether the ads we have placed on other websites have been successful.
Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "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. 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 "profiles" for short, includes any type of automated processing of personal data that consists in using such personal data to analyze, evaluate or to predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g., interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include visitors' behavior or interests in certain information, such as website content. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
Tracking: We speak of "tracking" when the behavior of users can be traced across several online offerings. As a rule, behavioral and interest information is stored in cookies or on servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can subsequently be used, for example, to display advertisements to users that are likely to correspond to their interests.
Controller: a "controller" is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
Processing: "Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data, be it collection, evaluation, storage, transmission or deletion.
Created with free Datenschutz-Generator.de by Dr. Thomas Schwenke