Company: SuS GmbH Schwerin
Street no.: Nordring 16
Zip code, City, Country: 19073 ,Wittenförden, Germany
Commercial Register/No.: Schwerin Local Court HRB 4739
Managing Director: Dipl.-Ing. Kristina Knaack
Telephone number: 0385 / 64704 – 93
E-mail address: email@example.com
Types of data processed:
– Inventory data (e.g., names, addresses).
– Contact details (e.g., e-mail, telephone numbers).
– Content data (e.g., text entries, photographs, videos).
– Contract data (e.g., subject matter of the contract, term, customer category).
– Payment data (e.g. bank details, payment history).
– Usage data (e.g., websites visited, interest in content, access times).
– Meta/communication data (e.g., device information, IP addresses).
Processing of special categories of data (Art. 9 (1) GDPR):
No special categories of data are processed.
Categories of data subjects affected by the processing:
– Customers, interested parties, visitors and users of the online offer, business partners.
In the following, we also refer to the persons concerned collectively as “users”.
Purpose of the processing
– Provision of the online offer, its contents and store functions.
– Provision of contractual services, service and customer care.
– Answering contact requests and communicating with users.
– Marketing, advertising and market research.
– Safety measures.
Status: June / 2020
1. terms used
1.1. “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
1.2. “Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is far-reaching and covers practically any handling of data.
1.3. The “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.
2 Relevant legal bases
4. safety measures
4.1. We take appropriate technical and organizational 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 risk of varying likelihood and severity for the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk; the measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, disclosure, safeguarding of availability and their separation. We have also set up 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 data protection-friendly default settings (Art. 25 GDPR).
4.2. The security measures include in particular the encrypted transmission of data between your browser and our server.
5. disclosure and transmission of data
5.1. If we disclose data to other persons and companies (processors or third parties) as part of our processing, transfer it to them or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g. if the data is transferred to third parties, such as payment service providers, in accordance with Art. 6 Para. 1 lit. b GDPR), you have given your consent, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, hosting providers, tax, business and legal advisors, customer care, accounting, billing and similar services that allow us to efficiently and effectively fulfill our contractual obligations, administrative tasks and duties).
5.2. If we commission third parties with the processing of data on the basis of a so-called “order processing contract”, this is done on the basis of Art. 28 GDPR.
6. 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 the use of third-party services or disclosure or transfer of data to third parties, this will only take place if it is done to fulfill 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 process or have the data processed in a third country only if the special 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 recognized determination of a level of data protection corresponding to the EU (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).
7 Rights of the data subjects
7.1. You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR.
7.2. You have accordingly. In accordance with Art. 16 GDPR, you have the right to request the completion of data concerning you or the correction of incorrect data concerning you.
7.3. In accordance with Art. 17 GDPR, you have the right to demand that the data in question be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with Art. 18 GDPR.
7.4. You have the right to request to receive the data concerning you that you have provided to us in accordance with Art. 20 GDPR and to request that it be transferred to other data controllers.
7.5. You also have acc. Art. 77 GDPR, you have the right to lodge a complaint with the competent supervisory authority.
8. right of withdrawal
You have the right to withdraw your consent in accordance with. Art. 7 para. 3 GDPR with effect for the future.
9. right of objection
You can object to the future processing of data concerning you at any time in accordance with Art. 21 GDPR. The objection may be made in particular against processing for direct marketing purposes.
10. cookies and right to object to direct advertising
10.1. Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit to an online service. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes their browser. For example, the content of a shopping cart in an online store or a login status can be stored in such a cookie. Permanent” or “persistent” cookies are cookies that remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. The interests of users can also be stored in such a cookie and used for reach measurement or marketing purposes. Third-party cookies” are cookies from providers other than the controller who operates the online service (otherwise, if they are only the controller’s cookies, they are referred to as “first-party cookies”).
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
11. deletion of data
11.2. According to legal requirements, the data is stored for 6 years in accordance with § 257 para. 1 HGB (trading books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting vouchers, etc.) and for 10 years in accordance with § 147 para. 1 AO (books, records, management reports, accounting vouchers, commercial and business letters, documents relevant for taxation, etc.).
12. order processing in the online store and customer account
12.1. We process our customers’ data as part of the ordering process in our online store in order to enable them to select and order the selected products and services, as well as their payment and delivery or execution.
12.2. The processed data includes inventory data, communication data, contract data, payment data and the data subjects include our customers, interested parties and other business partners. Processing is carried out for the purpose of providing contractual services in the context of operating an online store, billing, delivery and customer services. We use session cookies to store the contents of the shopping cart and permanent cookies to store the login status.
12.3. The processing is carried out on the basis of Art. 6 para. 1 lit. b (execution of order processes) and c (legally required archiving) GDPR. The information marked as required is necessary for the establishment and fulfillment of the contract. We only disclose the data to third parties within the scope of delivery, payment or within the scope of legal permissions and obligations towards legal advisors and authorities. The data is only processed in third countries if this is necessary to fulfill the contract (e.g. at the customer’s request for delivery or payment).
12.4. Users can optionally create a user account in which they can view their orders in particular. As part of the registration process, users are provided with the required mandatory information. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, subject to their retention for commercial or tax law reasons. Art. 6 para. 1 lit. c GDPR is necessary. Information in the customer account remains until it is deleted with subsequent archiving in the event of a legal obligation. It is the responsibility of users to back up their data before the end of the contract in the event of termination.
12.5. We store the IP address and the time of the respective user action as part of the registration and renewed logins and use of our online services. The storage is based on our legitimate interests, as well as those of the user in protection against misuse and other unauthorized use. This data will not be passed on to third parties unless it is necessary for the pursuit of our claims or there is a legal obligation to do so in accordance with. Art. 6 para. 1 lit. c GDPR.
12.6. The deletion takes place after the expiry of statutory warranty and comparable obligations, the necessity of storing the data is reviewed every three years; in the case of statutory archiving obligations, the deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) retention obligation); information in the customer account remains until its deletion.
13. business analyses and market research
13.1. In order to operate our business economically and identify market trends, customer and user requirements, we analyze the data we have on business transactions, contracts, inquiries, etc. In doing so, we process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. GDPR, whereby the data subjects include customers, interested parties, business partners, visitors and users of the online offer. The analyses are carried out for the purpose of business management evaluations, marketing and market research. In doing so, we can take into account the profiles of registered users with details of their purchase transactions, for example. The analyses help us to increase user-friendliness, optimize our offer and improve business efficiency. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarized values.
13.2. If these analyses or profiles are personal, they will be deleted or anonymized upon termination by the user, otherwise after two years from the conclusion of the contract. In addition, the overall business analyses and general trend determinations are prepared anonymously wherever possible.
2. it is permissible to check the creditworthiness of a customer if there is otherwise a risk of non-payment, i.e. if the goods are delivered without payment having been received (i.e. if the customer chooses to purchase on account). However, there is no risk of non-payment if, for example, the customer chooses the prepayment option or makes the payment via a third-party provider such as PayPal.
It should also be noted that obtaining an automatic credit report constitutes an “automated decision in individual cases” pursuant to Art. 6 para. 1 lit. a GDPR. Art. 22 GDPR, i.e. a legal decision without human involvement. This is permissible if the customer has consented or if this decision is necessary for the conclusion of the contract. Whether the decision is necessary has not yet been conclusively clarified, but is often taken for granted, including by the author of this sample. However, if you want to exclude any risk, you should obtain consent.
Consent is also required if the credit report is already used to decide whether the “on account” option should be displayed at all. It could have been that the customer would have opted for prepayment or PayPal anyway and the credit check would not have been necessary.
Such consent could, for example, read as follows:
14. credit report
14.1. If we make advance payments (e.g. when purchasing on account), we reserve the right to obtain identity and creditworthiness information for the purpose of assessing the credit risk on the basis of mathematical-statistical procedures from specialized service companies (credit agencies) in order to safeguard our legitimate interests.
14.2. As part of the credit report, we transmit the following personal data of the customer (name, postal address, date of birth, information on the type of contract, bank details [please specify further data if necessary]) to the following credit agencies:
[Please specify the credit agencies here, e.g.:] SCHUFA company (SCHUFA Holding AG, Kormoranweg 5, 65201 Wiesbaden), data protection information: https://www.schufa.de/de/ueber-uns/daten-scoring/.
14.3. We process the information received from the credit agencies on the statistical probability of a payment default as part of an appropriate discretionary decision on the establishment, execution and termination of the contractual relationship. We reserve the right to refuse payment on account or any other advance payment in the event of a negative result of the credit check.
14.4. The decision as to whether we make advance payments is made in accordance with Art. 22 GDPR solely on the basis of an automated decision in individual cases, which our software makes on the basis of the information provided by the credit agency.
14.5 If we obtain express consent from you, the legal basis for the credit report and the transfer of the customer’s data to the credit agencies is the consent in accordance with Art. 14.3 of the GDPR. Art. 6 para. 1 lit. a, 7 GDPR. If no consent is obtained, our legitimate interests in the security of your payment claim are the legal basis in accordance with Art. 6 para. 1 lit. a GDPR. Art. 6 para. 1 lit. f. GDPR.
15. contact and customer service
15.1. When contacting us (via contact form or e-mail), the user’s details are used to process the contact request and its processing in accordance with Art. 6 para. 1 lit. f GDPR. Art. 6 para. 1 lit. b) GDPR is processed.
15.2. User data may be stored in our Customer Relationship Management System (“CRM System”) or comparable inquiry organization.
15.3. We delete the requests if they are no longer required. We review the necessity every two years; we store requests from customers who have a customer account permanently and refer to the customer account details for deletion. The statutory archiving obligations also apply.
16. collection of access data and log files
16.1. We collect data 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), IP address and the requesting provider.
16.2. Log file information is stored for security reasons (e.g. to investigate misuse or fraud) for a maximum of seven days and then deleted. Data whose further retention is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
17. online presence in social media
17.1. We maintain our website on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR online presences within social networks and platforms in order 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.
17.3. We use Google Analytics to display the ads placed by Google and its partners within advertising services only to those users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Google (so-called “remarketing” or “Google Analytics audiences”). With the help of remarketing audiences, we also want to ensure that our ads correspond to the potential interest of users and are not annoying.
18 Google Analytics
18.2. Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law(https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
18.3. Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services associated with the use of this online offer and the use of the Internet. Pseudonymous user profiles can be created from the processed data.
18.4. We only use Google Analytics with activated IP anonymization. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
18.5. The IP address transmitted by the user’s browser is not merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of data generated by the cookie and related to their use of the online offer to Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
18.6. You can find further information on data use by Google, setting and objection options on Google’s websites: https://www.google.com/intl/de/policies/privacy/partners (“Data use by Google when you use our partners’ websites or apps”), https://policies.google.com/technologies/ads (“Data use for advertising purposes”), https://adssettings.google.com/authenticated (“Manage information that Google uses to show you advertising”).
19 Google Re/Marketing Services
19.1. On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use the marketing and remarketing services (“Google Marketing Services”) of Google LLC. GDPR) the marketing and remarketing services (“Google Marketing Services” for short) of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).
19.2. Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
19.3. Google marketing services allow us to display advertisements for and on our website in a more targeted manner in order to present users only with advertisements that potentially match their interests. If, for example, a user is shown ads for products that they have shown an interest in on other websites, this is referred to as “remarketing”. For these purposes, when our and other websites on which Google marketing services are active are called up, a code from Google is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as “web beacons”) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). The cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file records which websites the user has visited, what content they are interested in and which offers they have clicked on, as well as technical information on the browser and operating system, referring websites, time of visit and other information on the use of the online offer. The IP address of users is also recorded, whereby we inform Google Analytics that the IP address is shortened within member states of the European Union or in other contracting states of the Agreement on the European Economic Area and only in exceptional cases is it transmitted in full to a Google server in the USA and shortened there. The IP address is not merged with the user’s data within other Google offers. Google may also combine the above-mentioned information with information from other sources. If the user subsequently visits other websites, he can be shown ads tailored to his interests.
19.4. User data is processed pseudonymously as part of Google marketing services. This means that Google does not store and process the user’s name or email address, for example, but processes the relevant data in relation to cookies within pseudonymous user profiles. This means that, from Google’s point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie owner, regardless of who this cookie owner is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymization. The information collected by Google marketing services about users is transmitted to Google and stored on Google’s servers in the USA.
19.5. The Google marketing services we use include the online advertising program “Google AdWords”. In the case of Google AdWords, each AdWords customer receives a different “conversion cookie”. Cookies can therefore not be tracked via the websites of AdWords customers. The information collected with the help of the cookie is used to create conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers find out the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not receive any information with which users can be personally identified.
19.8. We can also use the “Google Optimizer” service. Google Optimizer allows us to track the effects of various changes to a website (e.g. changes to input fields, design, etc.) as part of so-called “A/B testing”. Cookies are stored on users’ devices for these test purposes. Only pseudonymous user data is processed.
19.9. We may also use the “Google Tag Manager” to integrate and manage Google analysis and marketing services on our website.
19.11. If you wish to object to interest-based advertising by Google marketing services, you can use the setting and opt-out options provided by Google: https://adssettings.google.com/authenticated.
Furthermore, when using the Facebook pixel, we use the additional function “extended matching” (where data such as telephone numbers, e-mail addresses or Facebook IDs of users) to create target groups (“Custom Audiences” or “Look Alike Audiences”) are transmitted to Facebook (encrypted). Further information on “extended adjustment “: https://www.facebook.com/business/help/611774685654668).
We also use the “Custom Audiences from File” process of the social network Facebook, Inc. In this case, the email addresses of the newsletter recipients are uploaded to Facebook. The upload process is encrypted. The upload is used solely to determine the recipients of our Facebook ads. We want to ensure that the ads are only shown to users who are interested in our information and services.
To prevent the collection of your data using the Facebook pixel on our website, please click the following link: Facebook opt-out Note: If you click the link, an “opt-out” cookie will be stored on your device. If you delete the cookies in this browser, you will have to click the link again. Furthermore, the opt-out only applies within the browser you are using and only within our web domain on which the link was clicked.
20 Facebook, Custom Audiences and Facebook marketing services
20.1 Within our online offer, the so-called “Facebook pixel” of the social network Facebook, which is operated by Facebook Inc, 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are resident in the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), is used due to our legitimate interests in the analysis, optimization and economic operation of our online offer and for these purposes.
20.2. Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
20.3. With the help of the Facebook pixel, it is possible for Facebook to determine the visitors of our online offer as a target group for the display of ads (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites 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 are not annoying. With the help of the Facebook pixel, we can also track the effectiveness of 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”).
20.4. The processing of data by Facebook takes place within the framework of Facebook’s Data Usage Policy. Accordingly, general information on the display of Facebook ads can be found in Facebook’s data usage policy: https://www.facebook.com/policy.php. Specific information and details about the Facebook pixel and how it works can be found in Facebook’s help section: https://www.facebook.com/business/help/651294705016616.
20.5. You can object to the collection by the Facebook pixel and use of your data to display Facebook ads. To set which types of ads are displayed to you within Facebook, you can go to the page set up by Facebook and follow the instructions on the settings for usage-based advertising: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
21 Facebook Social Plugins
21.1 On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR. GDPR) social plugins (“plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The plugins can display interaction elements or content (e.g. videos, graphics or text contributions) and are recognizable by one of the Facebook logos (white “f” on a blue tile, the terms “Like”, “Gefällt mir” or a “thumbs up” sign) or are marked with the addition “Facebook Social Plugin”. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
21.2. Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
21.3. When a user accesses a function of this online offering that contains such a plugin, their device establishes a direct connection with the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated into the online offering. User profiles can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects with the help of this plugin and therefore inform users according to our level of knowledge.
21.4. By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to their Facebook account. When users interact with the plugins, for example by clicking the Like button or leaving a comment, the corresponding information is transmitted directly from your device to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to find out and store their IP address. According to Facebook, only an anonymized IP address is stored in Germany.
21.5. The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the relevant rights and setting options for protecting the privacy of users, can be found in Facebook’s data protection information: https://www.facebook.com/about/privacy/.
21.6. If a user is a Facebook member and does not want Facebook to collect data about them via this online service and link it to their membership data stored on Facebook, they must log out of Facebook and delete their cookies before using our online service. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
22nd Jetpack (WordPress Stats)
22.1. On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use the Jetpack plugin (here sub-function “WordPress Stats”). GDPR) the Jetpack plugin (here the sub-function “WordPress Stats”), which integrates a tool for the statistical evaluation of visitor access and is provided by Automattic, Inc. 132 Hawthorne Street San Francisco, CA 94107, USA. Jetpack uses so-called “cookies”, text files that are stored on your computer and that enable your use of the website to be analyzed.
22.2. Automattic is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000CbqcAAC&status=Active).
23rd Amazon partner program
24. communication by post, e-mail, fax or telephone
27.1 We use means of distance communication, such as post, telephone or e-mail, for business transactions and marketing purposes. In doing so, we process inventory data, address and contact data as well as contract data of customers, participants, interested parties and communication partners.
27.2 The processing is carried out on the basis of Art. 6 para. 1 lit. a, Art. 7 GDPR, Art. 6 para. 1 lit. f GDPR in conjunction with legal requirements for advertising communications. Contact will only be made with the consent of the contact partners or within the scope of the legal permissions and the processed data will be deleted as soon as they are no longer required and otherwise with objection/revocation or discontinuation of the authorization basis or legal archiving obligations.
25.1. With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.
25.2. Content of the newsletter: We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter “newsletter”) only with the consent of the recipient or legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user’s consent. Our newsletters also contain information about our products, offers, promotions and our company.
25.3. Double opt-in and logging: Registration for our newsletter takes place in a so-called double opt-in procedure. This means that you will receive an e-mail after registration asking you to confirm your registration. This confirmation is necessary so that no one can log in with other people’s e-mail addresses. 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 with the shipping service provider are also logged.
25.5. If we use a dispatch service provider, the dispatch service provider may, according to its own information, use this data in pseudonymous form, i.e. without allocation to a user, to optimize or improve its own services, e.g. to technically optimize the dispatch and presentation of the newsletter or for statistical purposes to determine which countries the recipients come from. However, the mailing service provider does not use the data of our newsletter recipients to write to them itself or pass it on to third parties.
25.6. Registration data: To subscribe to the newsletter, simply enter your e-mail address. Optionally, we ask you to enter a name so that we can address you personally in the newsletter.
25.7. 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 mailing service provider, from their 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 are initially collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor, if used, that of the shipping service provider to monitor individual users. The evaluations serve us much more 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.
25.8. Germany: The newsletter is sent and its success measured on the basis of the recipient’s consent in accordance with Art. 6 para. 1 lit. a GDPR. Art. 6 para. 1 lit. a, Art. 7 GDPR in conjunction with § 7 para. 2 No. 3 UWG or on the basis of the legal permission in accordance with. § 7 para. 3 UWG.
25.9. The logging of the registration process is based on our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR. Art. 6 para. 1 lit. f GDPR and serves as proof of consent to receive the newsletter.
25.10. Newsletter recipients can cancel the receipt of our newsletter at any time, i.e. revoke their consent. You will find a link to unsubscribe from the newsletter at the end of each newsletter. At the same time, their consent to performance measurement expires. A separate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be canceled. When you unsubscribe from the newsletter, your personal data will be deleted unless their retention is legally required or justified, in which case their processing will be limited to these exceptional purposes. In particular, we may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before we delete them for the purpose of sending the newsletter 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 former existence of consent is confirmed at the same time.
26. integration of third-party services and content
26.1. On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use content or service offers from third-party providers within our online offer. GDPR), we use content or service offers from third-party providers 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 this content are aware of the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content. We endeavor to only use content whose respective providers only use the IP address to deliver 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 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 being linked to such information from other sources.
26.2. The following presentation provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and, in some cases already mentioned here, options for objection (so-called opt-out)
– If our customers use third-party payment services (e.g. PayPal or Sofortüberweisung), the terms and conditions and data protection information of the respective third-party providers, which can be accessed within the respective websites or transaction applications, apply.