privacy policy
privacy policy
preamble
With the following data protection declaration, we would like to inform you about which types of your personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent. This data protection declaration applies to all processing of personal data carried out by us, both in the context 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 offering").
The terms used are not gender-specific.
As of May 17, 2023
table of contents
- preamble
- responsible person
- Overview of processing
- Relevant legal bases
- security measures
- transmission of personal data
- data processing in third countries
- deletion of data
- use of cookies
- Business Services
- Use of online platforms for offer and sales purposes
- Providers and services used in the course of business activities
- provision of the online offer and web hosting
- Registration, login and user account
- blogs and publication media
- contact and inquiry management
- newsletters and electronic notifications
- web analysis, monitoring and optimization
- online marketing
- Presences in social networks (social media)
- Plugins and embedded functions and content
- Change and update of the privacy policy
- rights of the data subjects
responsible person
Modeverlag Lutterloh
Marcus Lutterloh
Modeverlag Lutterloh, Kemptener Straße 84, 88131 Lindau (Bodensee), Germany
E-mail address:
info@lutterloh-system.de
Phone:
0049 17612889922
Imprint:
https://lutterloh-system.de/pages/impressum
Overview of processing
The following overview summarises the types of data processed and the purposes of their processing and refers to the persons concerned.
types of data processed
- inventory data.
- payment details.
- location data.
- contact details.
- content data.
- contract data.
- usage data.
- Meta-, communication- and procedural data.
Special categories of data
- health data.
categories of data subjects
- Customers.
- interested parties.
- communication partner.
- 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 organizational procedures.
- conversion measurement.
- Managing and responding to inquiries.
- feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online offering and user-friendliness.
- Information technology infrastructure.
Relevant legal bases
Below you will find an overview of the legal bases of the GDPR 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. If more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.
- Consent (Article 6 (1) sentence 1 lit. a) GDPR) - The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
- Contract performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR) - The processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.
- Legal obligation (Article 6 (1) sentence 1 lit. c) GDPR) – The processing is necessary to fulfill a legal obligation to which the controller is subject.
- Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR) - Processing is necessary to safeguard the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject which require protection of personal data prevail.
In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes in particular the law on protection against misuse of personal data in data processing (Federal Data Protection Act - BDSG). 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 and automated decision-making in individual cases, including profiling. It also 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. In addition, 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, to ensure a level of protection appropriate to the risk.
The measures include in particular ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, transfer, securing availability and separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to threats to data. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
Shortening the IP address: 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 necessary, the IP address is shortened (also known as "IP masking"). The last two digits or the last part of the IP address after a period are removed or replaced by placeholders. The shortening of the IP address is intended to prevent or significantly complicate the identification of a person based on their IP address.
TLS encryption (https): We use TLS encryption to protect the data you transmit via our online service. You can recognize encrypted connections of this type by the prefix https:// in the address bar of your browser.
transmission of personal data
As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons or that it is disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that 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 third-party services or the disclosure or transmission of data to other persons, bodies or companies, this will only be done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transmission, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, if certifications or binding internal data protection regulations exist (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).
deletion of data
The data we process is deleted in accordance with legal requirements as soon as the consents to processing are revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or it is no longer required for the purpose). If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.
Our data protection notices may also contain further information on the storage and deletion of data, which apply primarily to the respective processing operations.
use of cookies
Cookies are small text files or other storage notes that store information on end devices and read information from the end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed or the functions used in an online service. Cookies can also be used for different purposes, e.g. to ensure the functionality, security and convenience of online services and to create analyses of visitor flows.
Notes on consent: We use cookies in accordance with legal regulations. We therefore obtain prior consent from users, unless this is not required by law. Consent is not necessary in particular if the storage and reading of information, including cookies, is absolutely necessary in order to provide users with a telemedia service expressly requested by them (i.e. our online offering). Strictly necessary cookies generally include cookies with functions that serve to display and operate the online offering, load balancing, security, storing user preferences and choices, or similar purposes related to providing the main and secondary functions of the online offering requested by users. Revocable consent is clearly communicated to users and contains information about the respective cookie usage.
Notes on data protection legal bases: The data protection legal basis on which we process users' personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and improving its usability) or, if this is done as part of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We will explain the purposes for which we process cookies in the course of this data protection declaration or as part of our consent and processing processes.
Storage period: With regard to the storage period, the following types of cookies are distinguished:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed his or her device (e.g. browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the device 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 user data collected using cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.
General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also object to processing in accordance with the legal requirements in Art. 21 GDPR. Users can also declare their objection via the settings of their browser, e.g. by deactivating the use of cookies (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ .
Cookie settings/opt-out option:
https://lutterloh-system45.myshopify.com/pages/agb
- Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR).
Further information on processing procedures, methods and services:
- Processing of cookie data based on consent: We use a cookie consent management procedure within the framework of which the consent of users to the use of cookies or the processing and providers mentioned in the cookie consent management procedure can be obtained and managed and revoked by the users. The declaration of consent is stored so that it does not have to be requested again and so that consent can be proven in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information about the providers of cookie management services, the following information applies: The duration of the storage of the consent can be up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and device used; Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR).
Business Services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners") within the framework of contractual and comparable legal relationships as well as related measures and within the framework of communication with the contractual partners (or pre-contractually), e.g. to answer inquiries.
We process this data in order to fulfil our contractual obligations. This includes in particular the obligations to provide the agreed services, any updating obligations and remedy in the event of warranty and other service disruptions. In addition, we process the data to protect our rights and for the purposes of the administrative tasks associated with these obligations and the company organization. In addition, we process the data on the basis of our legitimate interests in proper and economical business management and in security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. 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 pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. The contractual partners are informed about other forms of processing, e.g. for marketing purposes, in the context of this data protection declaration.
We inform our contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by special marking (e.g. colours) or symbols (e.g. asterisks or similar), or in person.
We delete the data after statutory warranty and similar obligations have expired, i.e., generally after 4 years, unless the data is saved 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 for tax purposes as well as for commercial books, inventories, opening balance sheets, annual financial statements, the work instructions required to understand these documents and other organizational documents and accounting documents, and six years for received commercial and business letters and reproductions of sent commercial and business letters. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, opening balance sheet, annual financial statements or management report was drawn up, the commercial or business letter was received or sent, or the accounting document was created, the recording was made or the other documents were created.
To the extent that 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 to 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 the contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
- Affected persons: customers; interested parties; 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; Conversion measurement (measurement of the effectiveness of marketing measures); Profiles with user-related information (creation of user profiles).
- Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR); Legal obligation (Art. 6 Para. 1 Clause 1 Letter c) GDPR); Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).
Further information on processing procedures, methods and services:
- Customer account: Customers can create an account within our online offering (e.g. customer or user account, "customer account" for short). If the registration of a customer account is required, customers will be informed of this as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. As part of the registration and subsequent logins and use of the customer account, we save the customers' IP addresses along with the access times in order to be able to prove registration and prevent any misuse of the customer account. If the customer account has been terminated, the customer account data will be deleted after the termination date, unless it is kept for purposes other than making it available in the customer account or must be kept for legal reasons (e.g. internal storage of customer data, order processes or invoices). It is the customer's responsibility to back up their data when terminating the customer account; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).
- Economic analyses and market research: For business reasons and in order to be able to identify market trends and the wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, inquiries, etc., whereby the group of persons affected may include contractual partners, interested parties, customers, visitors and users of our online offer. The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we can take into account the profiles of registered users, including their information, e.g. on services used, if available. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarized, i.e. anonymized values. Furthermore, we take the privacy of the users into account and process the data for the analysis purposes as pseudonymously as possible and, if possible, anonymously (e.g. as summarized data); legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).
- Shop and e-commerce: We process our customers' data to enable them to select, purchase or order the selected products, goods and associated services, as well as to pay for and deliver or execute them. If necessary to execute an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution for our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such in the order or comparable purchase process and includes the information required for delivery, provision and billing, as well as contact information in order to be able to hold any consultations; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).
Use of online platforms for offer and sales purposes
We offer our services on online platforms operated by other service providers. In this context, the data protection notices of the respective platforms apply in addition to our data protection notices. This applies in particular with regard to the execution of the payment process and the methods used on the platforms for range measurement and interest-based marketing.
- 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 the contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
- Data subjects: Customers.
- Purposes of processing: Provision of contractual services and customer service; marketing.
- Legal basis: Contractual performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR); legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
- shopify: Platform through which e-commerce services are offered and carried out. The services and processes carried out in connection with them include in particular online shops, websites, their offers and content, community elements, purchase and payment transactions, customer communication as well as analysis and marketing; Service provider: Shopify International Limited, Victoria Buildings, 2nd floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR); Website: https://www.shopify.de ; Data protection declaration: https://www.shopify.de/legal/datenschutz .
Providers and services used in the course of business activities
As part of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers ("services" for short) in compliance with legal requirements. Their use is based on our interests in proper, lawful and
- Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history ); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); contract data (e.g. contract subject, term, customer category ).
- Affected persons: customers; interested parties; users (e.g. website visitors, users of ); business and contractual partners.
- Purposes of processing: Provision of contractual services and customer service; office and organizational procedures.
- Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
provision of the online offer and web hosting
We process user 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 device.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, 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 (Article 6 (1) sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
- Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files". The server log files can include the address and name of the websites and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (particularly in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR); Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that needs to be retained for evidentiary purposes will not be deleted until the incident in question has been finally resolved.
Registration, login and user account
Users can create a user account. During registration, users are provided with the required mandatory information and this information is processed for the purpose of providing the user account on the basis of contractual obligations. The data processed includes in particular the login information (user name, password and an email address).
When you use our registration and login functions and the user account, we save the IP address and the time of the respective user action. The data is saved on the basis of our legitimate interests and those of the users in protection against misuse and other unauthorized use. This data is generally not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users may be informed by email about events relevant to their user account, such as technical changes.
- Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: provision of contractual services and customer service; security measures; administration and response to inquiries; provision of our online offer and user-friendliness.
- Legal basis: Contractual performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR); legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
- Registration with pseudonyms: Users may use pseudonyms as user names instead of real names; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- User profiles are not public: User profiles are not publicly visible or accessible.
- No obligation to retain data: It is the responsibility of the user to back up their data in the event of termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).
blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data is only processed for the purposes of the publication medium to the extent that it is necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium in the context of this data protection notice.
- Types of data processed: Inventory data (e.g. names, addresses); 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 information, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and customer service; feedback (e.g. collecting feedback via online form); provision of our online offer and user-friendliness; security measures; administration and response to inquiries.
- Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
- Comments and contributions: When users leave comments or other contributions, their IP addresses can be stored on the basis of our legitimate interests. This is done for our security in case someone leaves illegal content in comments and contributions (insults, prohibited political propaganda, etc.). In this case, we ourselves can be held liable for the comment or contribution and are therefore interested in the identity of the author. Furthermore, we reserve the right to process the user's information for the purpose of spam detection on the basis of our legitimate interests. On the same legal basis, we reserve the right to store the IP addresses of users for the duration of surveys and to use cookies to avoid multiple voting. The personal information provided in the context of comments and contributions, any contact and website information as well as the content information will be stored by us permanently until the user objects; legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).
contact and inquiry management
When you contact us (e.g. by post, contact form, e-mail, telephone or via social media) and within the framework of existing user and business relationships, the information provided by the inquiring persons is processed to the extent necessary to answer the contact inquiries and any requested measures.
- Types of data processed: contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
- Data subjects: communication partners.
- Purposes of processing: contact requests and communication; administration and response to inquiries; feedback (e.g. collecting feedback via online form); provision of our online offer and user-friendliness.
- Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR); Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).
Further information on processing procedures, methods and services:
- Contact form: If users contact us via our contact form, email or other communication channels, we process the data communicated to us in this context to process the communicated request; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
newsletters and electronic notifications
We only send newsletters, emails and other electronic notifications (hereinafter "newsletters") with the consent of the recipient or with legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user's consent. In addition, our newsletters contain information about our services and us.
To subscribe to our newsletter, it is generally sufficient to provide your email address. However, we may ask you to provide a name for the purpose of addressing you personally in the newsletter or other information if this is necessary for the purposes of the newsletter.
Double opt-in procedure: Registration for our newsletter is always carried out using a so-called double opt-in procedure. This means that after registration you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register using someone else's email address. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider are also logged.
Deletion and restriction of processing: We can store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address in a block list (so-called "block list") for this purpose alone.
The registration process is logged on the basis of our legitimate interests for the purpose of proving that it was carried out correctly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure shipping system.
Contents:
Information about us, our services, promotions and offers.
- Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status); usage data (e.g. websites visited, interest in content, access times).
- Special categories of personal data: health data (Article 9 (1) GDPR).
- Data subjects: communication partners.
- Purposes of processing: direct marketing (e.g. by e-mail or post).
- Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR); Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
- Opt-out option: You can cancel your subscription to our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email.
Further information on processing procedures, methods and services:
- Measuring opening and click rates: 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 shipping service provider, from its server. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, is initially collected. This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. The evaluations help us to recognize the reading habits of our users and adapt our content to them or to send different content according to the interests of our users. The measurement of the opening rates and the click rates as well as storage of the measurement results in the user profiles ; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR).
- Rapidmail: email marketing platform; service provider: rapidmail GmbH, Augustinerplatz 2, 79098 Freiburg i.Br., Germany; legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR); website: https://www.rapidmail.de ; data protection declaration: https://www.rapidmail.de/datenschutz ; order processing contract: https://www.rapidmail.de/hilfe/datenschutzvertrag-nach-eu-dsgvo-abschliessen .
web analysis, monitoring and optimization
Web analysis (also known as "reach measurement") is used to evaluate the flow of visitors to our online offering and can 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, identify at what time our online offering or its functions or content are most frequently used or invite reuse. We can also understand which areas require optimization.
In addition to web analysis, we can also use testing procedures to test and optimize, for example, 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 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 consented to us or the providers of the services we use collecting their location data, location data can also be processed.
The IP addresses of the users are also stored. However, we use an IP masking process (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored as part of web analysis, A/B testing and optimization, but rather pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.
- 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 information, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles); tracking (e.g. interest/behavior-related profiling, use of cookies); provision of our online offer and user-friendliness.
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR).
Further information on processing procedures, methods and services:
- Google Optimize: Software for analyzing and optimizing online offers based on feedback functions as well as pseudonymously conducted measurements and analyses of user behavior, which can include in particular A/B tests (measurement of the 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 Para. 1 Clause 1 lit. a) GDPR); Website: https://optimize.google.com ; Privacy policy: https://policies.google.com/privacy ; Order processing agreement: https://business.safety.google/adsprocessorterms ; Standard contractual clauses (guaranteeing data protection level when processing in third countries): https://business.safety.google/adsprocessorterms ; Further information: https://privacy.google.com/businesses/adsservices (types of processing and data processed).
- Google Analytics: reach measurement and web analysis; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); website: https://marketingplatform.google.com/intl/de/about/analytics/ ; privacy policy: https://policies.google.com/privacy ; order processing agreement: https://business.safety.google/adsprocessorterms/ ; standard contractual clauses (guaranteeing data protection level when processing in third countries): https://business.safety.google/adsprocessorterms ; possibility of objection (opt-out): opt-out plug-in: 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 and data processed).
- Google Analytics: web analysis, reach measurement and measurement of user flows; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); website: https://marketingplatform.google.com/intl/de/about/analytics/ ; privacy policy: https://policies.google.com/privacy ; order processing agreement: https://business.safety.google/adsprocessorterms ; standard contractual clauses (guaranteeing data protection level when processing in third countries): https://business.safety.google/adsprocessorterms ; possibility of objection (opt-out): opt-out plug-in: 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 and data processed).
- Google Analytics 4: We use Google Analytics to measure and analyze the use of our online offering based on 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 a device in order to recognize which content users have accessed within one or more usage processes, which search terms they have used, accessed them again or interacted with our online offering. The time of use and its duration are also stored, as well as the sources of users who refer to our online offering and technical aspects of their devices and browsers. Pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used. Analytics provides higher-level geographic location data by collecting the following metadata based on the 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 user's IP address is not logged and is shortened by the last two digits by default. The IP address is shortened on EU servers for EU users. In addition, all sensitive data collected from users in the EU is deleted before it is recorded via EU domains and servers; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/ ; Data protection declaration: https://policies.google.com/privacy ; Data processing agreement: https://business.safety.google/adsprocessorterms/ ; Standard contractual clauses (guaranteeing data protection level when processing in third countries): https://business.safety.google/adsprocessorterms ; Possibility of objection (opt-out): Opt-out plug-in: 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 and 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 (for further information, please refer to this data protection declaration). The Tag Manager itself (which implements the tags) therefore does not create user profiles or store cookies, for example. Google only learns the user's IP address, 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 Para. 1 Clause 1 lit. a) GDPR); Website: https://marketingplatform.google.com ; Data protection declaration: https://policies.google.com/privacy ; Order processing agreement: https://business.safety.google/adsprocessorterms ; Standard contractual clauses (guaranteeing data protection level when processing in third countries): https://business.safety.google/adsprocessorterms .
online marketing
We process personal data for the purposes of online marketing, which may include in particular the marketing of advertising space or the presentation 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 information about the user relevant to 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 as well as information on usage times and functions used. If users have consented to the collection of their location data, this can also be processed.
The IP addresses of the 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 email addresses or names) is stored as part of the online marketing process, but rather pseudonyms. This means that neither we nor the providers of the online marketing process know the actual identity of the users, only the information stored in their profiles.
The information in the profiles is usually stored in cookies or using similar processes. These cookies can generally also be read later on other websites that use the same online marketing process and analyzed for the purposes of displaying content, as well as supplemented with further data and stored on the server of the online marketing process provider.
In exceptional cases, clear data can be assigned to profiles. This is the case if, for example, the users are members of a social network whose online marketing processes we use and the network links the users' profiles with the aforementioned information. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.
In principle, we only receive access to summarized information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, ie, for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyze the success of our marketing measures.
Unless otherwise stated, please assume that cookies used will be stored for a period of two years.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, 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-related profiling, use of cookies); marketing; profiles with user-related information (creation of user profiles); conversion measurement (measurement of the effectiveness of marketing measures).
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR); Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
- Opt-out option: Please refer to the privacy policy of the respective provider and the opt-out options provided by the provider (so-called “opt-out”). If no explicit opt-out option has been provided, you have the option of deactivating cookies in your browser settings. However, this may restrict the functions of our online offering. We therefore also recommend the following opt-out options, which are summarized for each region: a) Europe: https://www.youronlinechoices.eu . b) Canada: https://www.youradchoices.ca/choices . c) USA: https://www.aboutads.info/choices . d) Cross-regional: https://optout.aboutads.info .
Further information on processing procedures, methods and services:
- Google Ads and conversion measurement: Online marketing procedures for the purpose of placing content and advertisements within the service provider's advertising network (e.g. in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the advertisements. In addition, we measure the conversion of the advertisements, i.e. whether users have taken them as an opportunity to interact with the advertisements 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 S. 1 lit. a) GDPR), Legitimate Interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://marketingplatform.google.com ; Privacy Policy: https://policies.google.com/privacy ; Further information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices ; Data processing conditions between 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 offering 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 S. 1 lit. a) GDPR); Website: https://marketingplatform.google.com ; Privacy policy: https://policies.google.com/privacy ; Further information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices ; Data processing conditions for Google advertising products: Information about the services, data processing conditions between 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 offering 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 S. 1 lit. a) GDPR); <