Privacy Policy

This privacy policy informs you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offering and the websites, features and content connected to it, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as the “online offering”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Controller

Types of data processed

• Inventory data (e.g. names, addresses).
• Contact data (e.g. email, phone numbers).
• Content data (e.g. text entries, photographs, videos).
• Usage data (e.g. websites visited, interest in content, access times).
• Meta/communication data (e.g. device information, IP addresses).

Categories of data subjects

Visitors and users of the online offering (hereinafter we also refer to the data subjects collectively as “users”).

Purpose of processing

• Providing the online offering, its functions and content.
• Answering contact requests and communicating with users.
• Security measures.
• Reach measurement/marketing.

Terms used

“Personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers virtually any handling of data.

“Pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures designed to ensure that the personal data are not attributed to an identified or identifiable natural person.

“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

“Controller” means 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.

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Relevant legal bases

In accordance with Art. 13 GDPR, we inform you of the legal basis for our data processing. Where the legal basis is not stated in this privacy policy, the following applies: the legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 GDPR; the legal basis for processing to perform our services and carry out contractual measures and to respond to enquiries is Art. 6(1)(b) GDPR; the legal basis for processing to fulfil our legal obligations is Art. 6(1)(c) GDPR; and the legal basis for processing to protect our legitimate interests is Art. 6(1)(f) GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6(1)(d) GDPR serves as the legal basis.

Security measures

In accordance with Art. 32 GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.

These measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, input into, transfer of, and the securing and separation of the data. We have also established procedures to ensure the exercise of data subject rights, the deletion of data and responses to data risks. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and procedures, in accordance with the principle of data protection through technology design and through data-protection-friendly default settings (Art. 25 GDPR).

Cooperation with processors and third parties

Insofar as we disclose data to other persons and companies (processors or third parties) in the course of our processing, transfer it to them, or otherwise grant them access to the data, this only takes place on the basis of a legal permission (e.g. if a transfer of the data to third parties, such as payment service providers, is necessary for the performance of a contract pursuant to Art. 6(1)(b) GDPR), you have consented, a legal obligation provides for this, or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we commission third parties to process data on the basis of a so-called “data processing agreement”, this is done on the basis of Art. 28 GDPR.

Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or if this occurs in the context of using third-party services or disclosing or transferring data to third parties, this only takes place if it is necessary to fulfil our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation, or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or allow data to be processed in a third country if the specific requirements of Art. 44 et seq. GDPR are met. This means that processing takes place, for example, on the basis of special guarantees, such as the officially recognised determination of a level of data protection corresponding to that of the EU, or compliance with officially recognised specific contractual obligations (so-called “standard contractual clauses”).

Rights of data subjects

You have the right to request confirmation as to whether the data concerned is being processed, and to information about that data as well as further information and a copy of the data in accordance with Art. 15 GDPR.

In accordance with Art. 16 GDPR, you have the right to request the completion of data concerning you or the correction of inaccurate data concerning you.

In accordance with Art. 17 GDPR, you have the right to demand that the relevant data be deleted without delay, or alternatively, in accordance with Art. 18 GDPR, to demand a restriction of the processing of the data.

You have the right to demand that the data concerning you that you have provided to us be handed over to you in accordance with Art. 20 GDPR, and to demand that it be transferred to other controllers.

You also have the right, pursuant to Art. 77 GDPR, to lodge a complaint with the competent supervisory authority.

Right of withdrawal

You have the right to withdraw consent given, with future effect, pursuant to Art. 7(3) GDPR.

Right to object

You may object at any time to the future processing of data concerning you in accordance with Art. 21 GDPR. The objection may in particular be made against processing for the purposes of direct marketing.

Cookies and right to object to direct marketing

“Cookies” are small files that are stored on users' computers. Various information can be stored within cookies. A cookie primarily serves to store information about a user (or the device on which the cookie is stored) during or after their visit to an online offering. Cookies that are deleted after a user leaves an online offering and closes their browser are referred to as temporary cookies, “session cookies” or “transient cookies”. Cookies that remain stored even after the browser is closed are referred to as “permanent” or “persistent” cookies. Cookies offered by providers other than the controller operating the online offering are referred to as “third-party cookies” (otherwise, if they are only the controller's own cookies, they are referred to as “first-party cookies”).

We may use temporary and permanent cookies and will clarify this within the scope of this privacy policy.

If users do not want cookies to be stored on their computer, they are asked to disable the corresponding option in their browser's system settings. Stored cookies can be deleted in the browser's system settings. Excluding cookies may lead to functional limitations of this online offering.

A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US website aboutads.info/choices or the EU website youronlinechoices.com. Furthermore, the storage of cookies can be prevented by disabling them in the browser settings.

Deletion of data

The data processed by us will be deleted or its processing restricted in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and there are no statutory retention obligations preventing deletion. If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted.

Under statutory provisions in Germany, retention is required in particular for 10 years pursuant to §§ 147(1) AO, 257(1) nos. 1 and 4, (4) HGB (books, records, management reports, accounting vouchers, commercial books, documents relevant for taxation, etc.) and 6 years pursuant to § 257(1) nos. 2 and 3, (4) HGB (commercial correspondence).

Under statutory provisions in Austria, retention is required in particular for 7 years pursuant to § 132(1) BAO (accounting records, receipts/invoices, accounts, business papers, statement of income and expenses, etc.), for 22 years in connection with real property, and for 10 years for documents relating to electronically supplied services, telecommunications, broadcasting and television services provided to non-business customers in EU member states for which the Mini One Stop Shop (MOSS) is used.

Contact

When contacting us (e.g. via contact form, email, telephone or social media), the user's information is processed to handle and respond to the contact request in accordance with Art. 6(1)(b) GDPR.

We delete requests once they are no longer necessary. We check whether they are still necessary every two years; statutory archiving obligations remain unaffected.

Hosting

The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, security services, and technical maintenance services, which we use for the purpose of operating this online offering.

In doing so, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta- and communication data of customers, prospective customers and visitors to this online offering on the basis of our legitimate interests in the efficient and secure provision of this online offering pursuant to Art. 6(1)(f) GDPR in conjunction with Art. 28 GDPR (conclusion of a data processing agreement).

Collection of access data and log files

We, or our hosting provider, collect data on every access to the server on which this service is hosted (so-called server log files), on the basis of our legitimate interests within the meaning of Art. 6(1)(f) GDPR. This access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

For security reasons (e.g. to investigate abuse or fraud), log file information is stored for a maximum of 7 days and then deleted. Data whose further storage is required for evidentiary purposes is excluded from deletion until the incident in question has been finally clarified.

Social media presences

We maintain online presences within social networks and platforms in order to communicate with customers, prospective customers and users active there and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.

Unless otherwise stated in this privacy policy, we process the data of users if they communicate with us within the social networks and platforms, e.g. by writing posts on our online presences or sending us messages.

Integration of third-party services and content

Within our online offering, on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offering within the meaning of Art. 6(1)(f) GDPR), we use content or service offerings from third-party providers in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).

This always requires that the third-party providers of this content perceive the IP address of the user, as without the IP address they could not send the content to the user's browser. The IP address is therefore required for the display of this content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes.

Vimeo

We may embed videos from the “Vimeo” platform provided by Vimeo Inc., Attention: Legal Department, 555 West 18th Street, New York, New York 10011, USA.
Privacy policy: vimeo.com/privacy. Please note that Vimeo may use Google Analytics; in this regard we refer to Google's privacy policy (google.com/policies/privacy) as well as opt-out options for Google Analytics (tools.google.com/dlpage/gaoptout) or Google's settings for data use for marketing purposes (adssettings.google.com).

YouTube

We embed videos from the “YouTube” platform provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Privacy policy: google.com/policies/privacy, opt-out: adssettings.google.com/authenticated.

Based on a template from Datenschutz-Generator.de by RA Dr. Thomas Schwenke.