Privacy Policy

Privacy Policy

Introduction

With this 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 privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, mobile, as well as 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: 01.12.2021

content summary

Person responsible

Sanjay Sauldie / iROi Global OÜ
Sepapaja 6, Tallinn 15551, Estonia

Persons authorized to represent: Owner: iROi Global OÜ, represented by Sanjay Sauldie

E-mail address:gdpr@simplefair.events

Imprint: Link to Imprint

Contact Data Protection Officer

Sanjay Sauldie / iROi Global OÜ
Sepapaja 6, Tallinn 15551, Estonia
gdpr@simplefair.events

Overview of the processing

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 (e.g. names, addresses).
  • Content data (e.g. entries in online forms).
  • Contact data (e.g. e-mail, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Use data (e.g. web pages visited, interest in content, access times).
  • Location data (information about the geographical position of a device or a person).
  • Contract data (e.g., subject of contract, term, customer category).
  • Payment data (e.g. bank details, invoices, payment history).

Categories of data subjects

  • Business and contractual partners.
  • Interested parties.
  • Communication partners.
  • Customers.
  • Users (e.g. website visitors, users of online services).

Purposes of processing

  • Assessment of creditworthiness and creditworthiness.
  • Providing our online services and user experience.
  • Visit action evaluation.
  • Office and organization procedures.
  • Cross-device tracking (cross-device processing of user data for marketing purposes).
  • Direct marketing (e.g., via email or postal mail).
  • Interest-based and behavioral marketing.
  • Contact requests and communication.
  • Conversion measurement (measuring the effectiveness of marketing efforts).
  • Profiling (creating user profiles).
  • Remarketing.
  • Range measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures.
  • Tracking (e.g. interest / behavioral profiling, use of cookies).
  • Provision of contractual services and customer service.
  • Managing and responding to requests.
  • Targeting (determination of target groups relevant for marketing purposes or other output of content).

Automated decisions on a case-by-case basis

  • Bonitätsauskunft (decision based on a credit check).

Relevant legal bases

In the following, we share the legal bases of the General Data Protection Regulation (GDPR) on the basis of which we process personal data. Please note that in addition to the regulations of the GDPR, the national data protection regulations in your or our country of residence and domicile may apply. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 para. 1 p. 1 lit. a. GDPR) – The data subject has given his or her consent to the processing of personal data concerning him or her for one or more specific purposes.
  • Contractual performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures carried out at the data subject’s request.
  • Legal obligation (Art. 6 para. 1 p. 1 lit. c. GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Rightful interests (Art. 6 para. 1 p. 1 lit. f. GDPR) – Processing is necessary for the purposes of protecting the legitimate interests of the controller or of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

Security measures

We take appropriate technical and organizational measures in accordance with the law, taking into account the state of the art, the costs of implementation 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, the 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.

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

Transmission and disclosure of personal data

In the course of our processing of personal data, it happens that the data is transmitted to or disclosed to other entities, companies, legally independent organizational units or persons. Recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of 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 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 process or allow the data to be processed only in third countries with a recognized level of data protection, a contractual obligation by so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (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 )

Use of cookies

Cookies are text files that contain data from websites or domains visited and are stored by a browser on the user’s computer. The primary purpose of a cookie is to store information about a user during or after their visit to an online site. The stored information may include, for example, language settings on a website, login status, a shopping cart, or where a video was watched. We further include in the term cookies other technologies that perform the same functions as cookies (e.g., when user details are stored using pseudonymous online identifiers, also referred to as “user ID-Numbers”)

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
  • Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user revisits a website. Likewise, the interests of users used for range measurement or marketing purposes can be stored in such a cookie.
  • First-party cookies: First-party cookies are set by ourselves.
  • Third-party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or absolutely necessary) cookies: Cookies can be, on the one hand, absolutely necessary for the operation of a website (e.g. to store logins or other user input or for security reasons).
  • Statistics, marketing and personalization cookies: Furthermore, cookies are usually also used in the context of range measurement and when a user’s interests or behaviour (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that matches their potential interests. This process is also referred to as “tracking,” i.e., tracing the potential interests of users. . Insofar as we use cookies or “tracking” technologies, we inform you separately in our privacy policy or in the context of obtaining consent.

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

Duration of storage: If we do not provide you with explicit information about the storage period of permanent cookies (e.g. in the context of a so-called cookie opt-in), please assume that the storage period can be up to two years.

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent you have given or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection by means of your browser settings, e.g. by deactivating the use of cookies (whereby this may also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ In addition, you can obtain further objection information in the context of the information on the service providers and cookies used.

Processing of cookie data on the basis of consent: Before we process or have processed data in the context of the use of cookies, we ask users for consent that can be revoked at any time. Before the consent has not been expressed, cookies are used at most, which are absolutely necessary for the operation of our online offer.

Cookie settings/ -opposition:

DateVersionConsents

Essential

Essential cookies enable basic functions and are necessary for the proper function of the website.

Matomo

NameMatomo
Providersimplefair
PurposeCookie by Matomo used for website analytics. Generates statistical data on how the visitor uses the website.
Privacy Policyhttps://simplefair.events/lp/privacy-policy-2/
Cookie Name_pk_*.*
Cookie Expiry13 Months

Vimeo

NameVimeo
ProviderVimeo Inc., 555 West 18th Street, New York, New York 10011, USA
PurposeUsed to unblock Vimeo content.
Privacy Policyhttps://vimeo.com/privacy
Host(s)player.vimeo.com
Cookie Namevuid

Statistics

Statistics cookies collect information anonymously. This information helps us to understand how our visitors use our website.

Marketing

Marketing cookies are used by third-party advertisers or publishers to display personalized ads. They do this by tracking visitors across websites.

External Media

If External Media cookies are accepted, access to those contents no longer requires manual consent.

Google Maps

NameGoogle Maps
ProviderGoogle Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
PurposeUsed to unblock Google Maps content.
Privacy Policyhttps://policies.google.com/privacy?hl=en&gl=en
Host(s).google.com
Cookie NameNID-Number
Cookie Expiry6 Month

Instagram

NameInstagram
ProviderMeta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland
PurposeUsed to unblock Instagram content.
Privacy Policyhttps://www.instagram.com/legal/privacy/
Host(s).instagram.com
Cookie Namepigeon_state
Cookie ExpirySession

OpenStreetMap

NameOpenStreetMap
ProviderOpenstreetmap Foundation, St John’s Innovation Centre, Cowley Road, Cambridge CB4 0WS, United Kingdom
PurposeUsed to unblock OpenStreetMap content.
Privacy Policyhttps://wiki.osmfoundation.org/wiki/Privacy_Policy
Host(s).openstreetmap.org
Cookie Name_osm_location, _osm_session, _osm_totp_token, _osm_welcome, _pk_id., _pk_ref., _pk_ses., qos_token
Cookie Expiry1-10 Years

YouTube

NameYouTube
ProviderGoogle Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
PurposeUsed to unblock YouTube content.
Privacy Policyhttps://policies.google.com/privacy?hl=en&gl=en
Host(s)google.com
Cookie NameNID-Number
Cookie Expiry6 Month

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • People Concerned: users (e.g., website visitors, users of online services).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Commercial and business services

We process data of our contractual and business partners, e.g. customers and prospective customers (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 to fulfil our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as for the business organization. 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 for the fulfilment of legal obligations or with the consent of the data subjects (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). 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 during data collection, e.g. in online forms, by means of special marking (e.g. colours) or symbols (e.g. asterisks or similar), or in person.

We delete the data after the expiry of legal warranty and comparable obligations, i.e., generally after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons (e.g., for tax purposes generally 10 years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications of the order, generally after the end of the order.

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.

Customer account: Contractual partners can create an account within our online offer (e.g. customer or user account, in short, “customer account”). If the registration of a customer account is required, contractual partners 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. In the course of registration and subsequent logins and use of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove registration and prevent any misuse of the customer account.

If customers have terminated their customer account, the data relating to the customer account will be deleted, unless their retention is required for legal reasons. It is the responsibility of customers to back up their data when their customer account is terminated.

Economic analyses and market research: For business reasons and in order to be able to recognize market trends, wishes of contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc., whereby contractual partners, interested parties, customers, visitors and users of our online offer may fall into the group of persons concerned.

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 may, if available, take into account the profiles of registered users together with their details, e.g. on services used. The analyses serve us alone and are not disclosed externally unless they are anonymous analyses with summarized, i.e. anonymized values. Furthermore, we take into account the privacy of users and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as summarized data).

Shop 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 so that any consultation can be held.

  • 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. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • People concerned: Interested parties, business and contractual partners, customers.
  • Purposes of processing: Providing contractual services and customer service, contact requests and communications, office and organizational procedures, managing and responding to requests, security measures, visit action evaluation, interest-based and behavioral marketing, profiling (creating user profiles).
  • Legal basis: Contract performance and pre-contractual requests (Art. 6 para 1 p. 1 lit. b. GDPR), Legal obligation (Art. 6 para 1 p. 1 lit. c. GDPR), Legitimate interests (Art. 6 para 1 p. 1 lit. f. GDPR).

Payment Service Provider

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 payment 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 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 refer to these likewise 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 data (e.g. device information, IP addresses).
  • People concerned: customers, prospective customers.
  • Purposes of processing: Provision of contractual services and customer service.
  • Legal basis: Contract performance and pre-contractual requests (Art. 6 para 1 p. 1 lit. b. GDPR), Legitimate interests (Art. 6 para 1 p. 1 lit. f. GDPR).

Services used and service providers:

Provision of the online offer and web hosting

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

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

Email sending and hosting: The web hosting services we use also includes the sending, receiving and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for SPAM detection purposes. Please note that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on each access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes 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.

  • Types of data processed: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • People Concerned: users (e.g., website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 para 1 p. 1 lit. f. GDPR).

Webhosting-Provider: Zone Media OÜ, Reg. no. 10577829, Lõõtsa 5, Tallinn 11415, Republic of Estonia

Contacting us

When contacting us (for example, by contact form, e-mail, telephone or via social media), the information of the requesting persons is processed to the extent necessary to respond to the contact requests and any requested action.

The response to the contact requests in the context of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to respond to (pre)contractual requests and otherwise on the basis of legitimate interests in responding to the requests.

  • 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 data (e.g. device information, IP addresses).
  • People concerned: communication partners, interested parties.
  • Purposes of processing: contact requests and communication, management and response to requests.
  • Legal basis: Contract performance and pre-contractual requests (Art. 6 para 1 p. 1 lit. b. GDPR), Legitimate interests (Art. 6 para 1 p. 1 lit. f. GDPR).

Services used and service providers:

Newsletters and electronic notifications

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

In order to subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name, for the purpose of personal address in the newsletter, or further information, if this is necessary for the purposes of the newsletter.

Double-Opt-In-Procedure: The registration for our newsletter takes place in principle in a so-called double-opt-in procedure. That is, you will receive an e-mail after registration, in which you will be asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise, changes to your data stored with the dispatch service provider are logged.

Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to be able to prove consent formerly given. The processing of this data will be limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a blacklist for this purpose alone.

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. Insofar as we commission a service provider with the dispatch of e-mails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system.

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

Contents: Information about us, our services, promotions and offers.

Analysis and performance measurement: 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. In the course of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the retrieval, are initially collected.

This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined with the help of 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. For technical reasons, this information can indeed be assigned to individual newsletter recipients. However, it is neither our intention nor, if used, that of the dispatch service provider to observe individual users. Rather, the evaluations serve us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

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

Unfortunately, a separate revocation of the performance measurement is not possible, in this case the entire newsletter subscription must be cancelled, or it must be contradicted.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
  • People concerned: communication partners.
  • Purposes of processing: Direct marketing (eg by e-mail or postal).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).
  • Opposition (Opt-Out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent, or object to further receipt. A link to cancel the newsletter you will find either at the end of each newsletter or can otherwise use one of the above contact options, preferably e-mail, for this purpose.

Services used and service providers:

Web analytics, 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 behaviour, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can recognize, for example, 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 analysis, we may also use test procedures, for example, to test and optimize different versions of our online offering or its components.

For these purposes, so-called user profiles may be created and stored in a file (so-called “cookie”) or similar procedures may be used with the same purpose. This information may include, for example, content viewed, web pages visited and elements used there and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed, depending on the provider.

The IP addresses of 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. This means that 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.

Notes on legal bases: Insofar as we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

      • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
      • People Concerned: 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), visit action evaluation, profiling (creation of user profiles).
      • Security measures: IP masking (pseudonymization of the IP address).
      • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Services used and service providers:

      • Matomo (without cookies): Matomo is a privacy-friendly web analytics software that is used without cookies and in which the recognition of returning users is done with the help of a so-called “digital fingerprint”, which is stored anonymously and changed every 24 hours; In the “digital fingerprint” user movements within our online offer are recorded with the help of pseudonymized IP addresses in combination with user-side browser settings so that conclusions about the identity of individual users are not possible; Service provider: Self-hosted web analytics/reach measurement; website: https://matomo.org/

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 the measurement of 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 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 and information on usage times. If users have consented to the collection of their location data, this may also be processed.

The IP addresses of users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect 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 cookies or by means of similar procedures. These cookies can later generally 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 profiles of the users 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.

Notes on legal bases: Insofar as we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

Facebook Pixel: With the help of the Facebook Pixel, it is possible for Facebook, on the one hand, to determine the visitors to our online offer as a target group for the display of advertisements (so-called “Facebook Ads”). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those users on Facebook and within the services of partners cooperating with Facebook (so-called “Audience Network” https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products that are evident from the web pages visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of users and do not have a harassing effect. Furthermore, with the help of the Facebook pixel, we can track the effectiveness of the Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion measurement”).

      • Types of data processed: Usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information about the geographical position of a device or a person).
      • People concerned: users (e.g. website visitors, users of online services), interested parties.
      • Purposes of processing: Tracking (e.g., interest/behavioral profiling, use of cookies), remarketing, visit action evaluation, interest-based and behavioral marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g.. e.g. access statistics, recognition of returning visitors), target group formation (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes)
      • Security measures: IP masking (pseudonymization of the IP address).
      • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).
      • Opposition (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, there is on the one hand the possibility that you disable cookies in the settings of your browser. However, this may restrict functions of our online offer. We therefore additionally recommend the following 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

Services used and service providers:

      • Google Tag Manager: Google Tag Manager is a solution that allows us to manage so-called website tags through one interface and thus integrate other services into our online offer. The Tag Manager itself (which implements the tags) does not process any personal data of the users. With regard to the processing of users’ personal data, please refer to the following information on Google services. Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent Company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy
      • Google Analytics: online marketing and web analytics; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com/intl/de/about/analytics/; 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.
      • Google Ads and Conversion Measurement: We use the online marketing method “Google Ads” to place ads on the Google 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. Furthermore, we measure the conversion of the ads. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page tagged with a so-called “conversion tracking tag”. However, we ourselves do not receive any information that can be used to identify users. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy
      • Google Ad Manager: We use the “Google Marketing Platform” (and services such as “Google Ad Manager”) to place ads on the Google advertising network (e.g., in search results, in videos, on web pages, etc.). The Google Marketing Platform is characterized by the fact that ads are displayed in real time based on presumed user interests. This allows us to display ads for and within our online offering in a more targeted manner to present users only with ads that potentially match their interests. For example, if a user is shown ads for products they were interested in on other online offerings, this is referred to as “remarketing.” Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy
      • Facebook Pixel: Service Provider: https://www.facebook.com, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, Parent Company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; website: https://www.facebook.com; privacy policy: https://www.facebook.com/about/privacy; opt-out: https://www.facebook.com/settings?tab=ads

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 could make it 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 also 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 help, then you can contact us.

      • 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 data (e.g. device information, IP addresses).
      • People Concerned: users (e.g., website visitors, users of online services).
      • Purposes of processing: contact requests and communication, tracking (e.g. interest/behavioral profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
      • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Services used and service providers:

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 social media buttons as well as posts (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 display of this content or functionality. 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 also 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.

Notes on legal bases: Insofar as we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

      • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographical position of a device or a person), content data (e.g. entries in online forms), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
      • People concerned: users (e.g. website visitors, users of online services), communication partners.
      • Purposes of processing: Provision of our online offer and user experience, provision of contractual services and customer service, contact requests and communication, tracking (e.g. interest/behavioral profiling, use of cookies), interest-based and behavioral marketing, profiling (creation of user profiles), security measures, management and response to requests.
      • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR), consent (Art. 6 para. 1 p. 1 lit. a. GDPR), contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. GDPR).

Services used and service providers:

Deletion of data

The data processed by us will be deleted in accordance with legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (for example, 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. I.e., 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.

Further information on the deletion of personal data can further be provided in the context of the individual data protection notices of this privacy policy.

Change and update of the privacy policy

We ask you to regularly inform yourself about the content of our privacy policy. We will adjust the privacy statement as soon as the changes in the data processing activities we carry out make this 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.

If 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 data subjects

As a data subject, you are entitled to various rights under the GDPR, arising in particular from Articles 15 to 21 of the GDPR:

      • Right of objection: you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) of the GDPR; 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 of revocation for consents: You have the right to revoke granted consents at any time.
      • Right of access: 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 legal requirements.
      • Right to rectification: You have the right, in accordance with the law, to request that the data concerning you be completed or that inaccurate data concerning you be rectified.
      • Right to erasure and restriction of processing: You have, in accordance with the law, the right to request that data concerning you be erased without undue delay, or alternatively, in accordance with the law, to request the restriction of the processing of the data.
      • Right to data portability: You have the right to receive data relating to 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: You also have the right, in accordance with the law, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Definitions of terms

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 Article 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.

    • Visit action evaluation: “Visit action evaluation” (English “conversion tracking”) refers to 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 allows us to track whether the ads we have placed on other websites have been successful).
    • Credit information: Automated decisions are based on automatic data processing without human intervention (for example, in the case of automatic rejection of a purchase on account, an online credit application or an online application process without any human intervention. Such automated decisions are only allowed under Art. 22 GDPR if data subjects consent, if they are necessary for the performance of a contract, or if national laws allow such decisions.
    • Cross-device tracking: Cross-device tracking is a form of tracking in which users’ behavioural and interest information is collected across devices in so-called profiles by assigning users an online identifier. This allows user information to be analyzed for marketing purposes, irrespective of the browsers or devices used (e.g. cell phones or desktop computers). For most providers, the online identifier is not linked to clear data, such as names, postal addresses or e-mail addresses.
    • IP masking: “IP masking” is a method in which the last octet, i.e., the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing methods, especially in online marketing
    • Interest-based and behavioural marketing: We speak of interest-based and/or behavioural marketing when the potential interests of users in ads and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behaviour (eg visiting certain websites and staying on them, buying behaviour or interaction with other users), which are stored in a so-called profile. Cookies are usually used for these purposes.
    • Conversion measurement: Conversion measurement 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 allows 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 (eg. e.g. cookie) or to one or more special characteristics that are an expression of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
    • Profiling: “Profiling” is any form of automated processing of personal data that consists of using such personal data to analyze, evaluate or, in order to predict (e.g., the interests in certain content or the use of certain services), certain personal aspects relating to a natural person (depending on the type of profiling, this may include information concerning age, gender, location data and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people). e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
    • Range measurement: Range measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and may include the behaviour or interests of visitors in certain information, such as the content of web pages. 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 the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
    • Remarketing: One speaks of “remarketing” or “retargeting” when, for example, for advertising purposes, it is noted which products a user has been interested in on a website, in order to remind the user of these products on other websites, e.g. in advertisements.
    • Location data: Location data is created when a mobile device (or another device with the technical requirements of a location determination) connects to a radio cell, a WLAN or similar technical mediators and functions of location determination. Location data is used to indicate the geographically determinable position on earth at which the respective device is located. Location data can be used, for example, to display map functions or other information dependent on a location.
    • Tracking: One speaks of “tracking” when the behaviour of users can be traced across several online offers. As a rule, with regard to the online offers used, behavioural and interest information is stored in cookies or on servers of the providers of the tracking technologies (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 that is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data, whether collecting, analyzing, storing, transmitting or erasing.
    • Target group formation: One speaks of target group formation (or “Custom Audiences”) when target groups are determined for advertising purposes, e.g. insertion of advertisements. For example, based on the interest of a user in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online store in which he viewed the products. In turn, we speak of “lookalike audiences” (or similar target groups) when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were formed. For purposes of the formation of Custom Audiences and Lookalike Audiences are usually used cookies and web beacons.

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