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Privacy policy

This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the websites, functions and contents connected with it as well as external online presences, such as our Social Media Profile. (hereinafter jointly referred to as the “online offer”). With regard to the terms used, such as “personal data” or their “processing”, we refer to the definitions in Art. 4 of the Basic Data Protection Regulation (DSGVO).

Responsible person

Status: 07.08.2020

Types of data processed:

Processing of special categories of data (Art. 9 para. 1 DSGVO):

In principle, no special categories of data are processed unless they are supplied for processing by the users, e.g. entered in online forms.

Categories of data subjects concerned by the processing:

Purpose of the processing:

In accordance with Art. 13 DSGVO, we inform you of the legal basis of our data processing. If the legal basis is not stated in the data protection declaration, the following applies: The legal basis for obtaining consents is Art. 6 Para. 1 lit. a and Art. 7 DSGVO, the legal basis for processing for the purpose of fulfilling our services and implementing contractual measures and answering enquiries is Art. 6 Para. 1 lit. b DSGVO, the legal basis for processing for the purpose of fulfilling our legal obligations is Art. 6 Para. 1 lit. c DSGVO, and the legal basis for processing for the purpose of safeguarding our legitimate interests is Art. 6 Para. 1 lit. f DSGVO. In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6 paragraph 1 lit. d DSGVO serves as the legal basis.

Amendments and updates to the Data Protection Declaration

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

Security measures

In accordance with Art. 32 DSGVO and 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 varying probability of occurrence 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 commensurate with the risk; these measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling the physical access to the data, as well as the access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures to ensure that data subjects’ rights are exercised, data is deleted, and we respond to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly default settings (Art. 25 DSGVO).

The security measures include in particular the encrypted transmission of data between your browser and our server.

Cooperation with contract processors and third parties

If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transfer it to them or otherwise grant them access to the data, this will only be done on the basis of a legal authorisation (e.g. if the data must be transferred to third parties, such as payment service providers, in accordance with Art. 6 Para. 1 letter b DSGVO for the fulfilment of the contract), if you have given your consent, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosters, etc.).

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

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 is done in the context of using the services of third parties or disclosure or transfer of data to third parties, this will only take place if it is done to fulfil our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we will only process or transfer data to a third country if the special requirements of Art. 44 ff. DSGVO. In other words, processing is carried out, 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 (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).

Rights of data subjects

Right of withdrawal

You have the right to revoke consents granted in accordance with Art. 7 Para. 3 DSGVO with effect for the future.

Right of objection

You can object to the future processing of data concerning you at any time in accordance with Art. 21 DSGVO. In particular, you may object to processing for the purposes of direct advertising.

Deletion of data

The data processed by us will be deleted or restricted in their processing in accordance with articles 17 and 18 DSGVO. Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory storage obligations. If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

In accordance with legal requirements, data is stored in particular for 6 years in accordance with § 257 Paragraph 1 HGB (commercial books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting vouchers, etc.) and for 10 years in accordance with § 147 Paragraph 1 AO (books, records, management reports, accounting vouchers, commercial and business letters, documents relevant for taxation, etc.).

Provision of contractual services

We process inventory data (e.g., names and addresses as well as contact data of users), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services in accordance with Art. 6 para. 1 lit b. DSGVO. The entries marked as obligatory in online forms are required for the conclusion of the contract.

Contact us

When contacting us (via contact form or e-mail), the user’s details are processed for the purpose of handling the contact request and its processing in accordance with Art. 6 Para. 1 lit. b) DSGVO.

Collection of access data and log files

On the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO data about every access to the server on which this service is located (so-called server log files). The 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), abbreviated IP address and the requesting provider.

For security reasons (e.g. to clarify misuse or fraud), log file information is stored for a maximum of seven days and then deleted. Data whose further storage is required for evidential purposes is excluded from deletion until final clarification of the respective incident.

By executing the software, the following key data is transmitted to our servers:

A complete sample extract of the transmitted data can be found here: graylog-dsgvo.csv

The basis is our legitimate interest within the meaning of Art. 6 Para. 1 lit. f. DSGVO.

The transmitted data will be stored for a maximum of seven days and then deleted. Excluded from this are anonymised Statistics (e.g. which operating system versions are still in use).

Twilio

The IP address is used to determine which country it is assigned to (GeoIP assignment). Should these are outside the EU, Twilio is used for the transmission of VoIP data (TURN/Stun server). Since the call data itself is encrypted, Twilio only gets access to metadata (e.g. IP address, duration of the call etc.).

More information about Twilio’s data protection can be found here: https://www.twilio.com/legal/privacy

Online presence in social media

We maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties 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 our privacy policy, we will process the data of users who communicate with us within the social networks and platforms, e.g. write articles on our online presences or send us messages.

Integration of third party services and content

Within our online offer, we set the following priorities on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO), we use content or service offers from third parties in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”). This always presupposes that the third-party providers of such content are aware of the IP address of the users, as without the IP address they would not be able to send the content to their browsers. The IP address is therefore required to display this content. We make every effort to use only such content whose respective providers use the IP address solely for the purpose of delivering the content. Third party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information on the browser and operating system, referring web pages, visiting time and other details on the use of our online offer, as well as being able to be linked to such information from other sources.

The following presentation offers an overview of third party providers and their contents, together with links to their data protection declarations, which contain further information on the processing of data and, in some cases already mentioned here, the possibility of objection (so-called opt-out):

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