Data protection
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Table of contents
- Person responsible
- Overview of processing
- Relevant legal bases
- Safety measures
- Transmission of personal data
- International data transfers
- General information on data storage and deletion
- Business services
- Provision of the online offer and web hosting
- Use of cookies
- Blogs and publication media
- Contact and enquiry management
- Newsletter and electronic notifications
- Advertising communication via e-mail, post, fax or telephone
- Prize draws and competitions
- Web analysis, monitoring and optimisation
- Online marketing
- Affiliate programmes and affiliate links
- Customer reviews and evaluation process
- Presence in social networks (social media)
- Plug-ins and embedded functions and content
Person responsible
Shane Buchs
Bahnhofstrasse 49
9470 Buchs SG
Switzerland
T: +41 81 756 00 30
E: shane.buchs@swissmediadesign.com
Overview of processing
The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
- Inventory data.
- Employee data.
- Payment data.
- Location data.
- Contact details.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and process data.
- Protocol data.
Categories of affected persons
- Beneficiary and client.
- Employees.
- Interested parties.
- Communication partner.
- Users.
- Competition and contest participants.
- Business and contractual partners.
Purposes of the processing
- Provision of contractual services and fulfilment of contractual obligations.
- Communication.
- Safety measures.
- Direct marketing.
- Reach measurement.
- Tracking.
- Office and organisational procedures.
- Target group formation.
- Affiliate tracking.
- Organisational and administrative procedures.
- Organising competitions and contests.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online services and user-friendliness.
- Establishment and implementation of employment relationships.
- Information technology infrastructure.
- Public relations.
- Sales promotion.
- Business processes and business management procedures.
Relevant legal bases
Relevant legal bases according to the Swiss Data Protection Act: If you are located in Switzerland, we process your data on the basis of the Swiss Federal Act on Data Protection ("Swiss FADP" for short). Unlike the GDPR, for example, the Swiss FADP does not require that a legal basis for the processing of personal data be specified and that the processing of personal data be carried out in good faith, lawfully and proportionately (Art. 6 para. 1 and 2 of the Swiss FADP). In addition, personal data will only be obtained by us for a specific purpose recognisable to the data subject and will only be processed in a way that is compatible with this purpose (Art. 6 para. 3 of the Swiss FADP).
Safety measures
We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, 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 the access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data threats. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and processes in accordance with the principle of data protection, through technology design and data protection-friendly default settings.
Transmission of personal data
As part of our processing of personal data, it may be transmitted to other bodies, companies, legally independent organisational units or persons or disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and in particular conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.
International data transfers
Disclosure of personal data abroad: In accordance with the Swiss FADP, we only disclose personal data abroad if adequate protection of the data subjects is guaranteed (Art. 16 Swiss FADP). If the Federal Council has not established adequate protection (list: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we take alternative security measures. These may include international contracts, specific guarantees, data protection clauses in contracts, standard data protection clauses approved by the Federal Data Protection and Information Commissioner (FDPIC) or internal company data protection regulations recognised in advance by the FDPIC or a competent data protection authority in another country.
According to Art. 16 of the Swiss FADP, exceptions for the disclosure of data abroad may be authorised if certain conditions are met, including consent of the data subject, performance of a contract, public interest, protection of life or physical integrity, data made public or data from a register provided for by law. These disclosures are always made in accordance with the legal requirements.
General information on data storage and deletion
We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consents are revoked or there is no further legal basis for the processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer storage or archiving of the data.
In particular, data that must be stored for commercial or tax law reasons or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.
Our data protection information contains additional information on the retention and deletion of data that applies specifically to certain processing operations.
If there is more than one indication of the retention period or deletion period for a date, the longest period is always decisive.
If a period does not expressly begin on a specific date and is at least one year, it shall automatically start at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the deadline is the date on which the cancellation or other termination of the legal relationship takes effect.
We process data that is no longer stored for the originally intended purpose, but due to legal requirements or other reasons, exclusively for the reasons that justify its storage.
Further information on processing operations, procedures and services:
- Storage and deletion of data: The following general time limits apply to storage and archiving in accordance with Swiss law:
- 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting vouchers and invoices as well as all necessary work instructions and other organisational documents (Art. 958f of the Swiss Code of Obligations (CO)).
- 10 years - Data necessary for the consideration of potential claims for damages or similar contractual claims and rights, as well as for the processing of related enquiries based on previous business experience and standard industry practice, are stored for the statutory limitation period of ten years, unless a shorter period of five years is applicable, which is relevant in certain cases (Art. 127, 130 CO). Claims for rent, lease and capital interest as well as other periodic services, from the supply of food, for catering and for debts to landlords, as well as from handicraft work, retail sale of goods, medical care, professional work of lawyers, legal agents, procurators and notaries and from the employment relationship of employees expire after five years (Art. 128 CO).
Business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners"), in the context of contractual and comparable legal relationships and associated measures and with regard to communication with the contractual partners (or pre-contractual), for example to respond to enquiries.
We use this data to fulfil our contractual obligations. These include, in particular, the obligations to provide the agreed services, any updating obligations and remedies in the event of warranty and other service disruptions. In addition, we use the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations and the company organisation. In addition, we process the data on the basis of our legitimate interests both in proper and efficient business management and in security measures to protect our contractual partners and our business operations from misuse, jeopardising their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. Contractual partners will be informed about other forms of processing, such as for marketing purposes, as part of this privacy policy.
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 labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.
We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after four 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 ten years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications and generally after the end of the order.
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); contract data (e.g. subject matter of the contract, duration, customer category); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Persons concerned: Service recipients and clients; interested parties. Business and contractual partners.
- Purposes of the processing: Provision of contractual services and fulfilment of contractual obligations; security measures; communication; office and organisational procedures; organisational and administrative procedures. Business processes and business management procedures.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Online shop, order forms, e-commerce and delivery: We process our customers' data to enable them to select, purchase or order the selected products, goods and associated services, as well as their payment and delivery or fulfilment. If necessary for the fulfilment of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or fulfilment for our customers. We use the services of banks and payment service providers to process payment transactions. The required information is labelled as such in the order or comparable purchase process and includes the information required for delivery or provision and billing as well as contact information in order to be able to hold any consultations; Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Provision of the online offer and web hosting
We process users' data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or end device.
- Processed data types: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Log data (e.g. log files relating to logins or the retrieval of data or access times).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Provision of our online services and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files". The server log files may include the address and name of the web pages and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks), and also to ensure the utilisation of the servers and their stability; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further storage is required for evidence purposes is excluded from deletion until the respective incident has been finally clarified.
Use of cookies
Cookies are small text files or other storage notes that store information on end devices and read it from them. For example, to store the log-in status in a user account, the contents of a shopping basket in an e-shop, the content accessed or the functions used in an online offering. Cookies can also be used for various purposes, for example to ensure the functionality, security and convenience of online services and to create analyses of visitor flows.
Notes on consent: We use cookies in accordance with the statutory provisions. We therefore obtain prior consent from users, unless this is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide users with a telemedia service they have expressly requested (i.e. our online offering). The revocable consent is clearly communicated to you and contains the information on the respective use of cookies.
Information on the legal basis for data protection: The legal basis under data protection law on which we process users' personal data using cookies depends on whether we ask for their consent. If users accept, the legal basis for processing their data is their declared consent. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and the improvement of its usability) or, if this is done in the context of the fulfilment of our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. We will explain the purposes for which we use cookies in the course of this privacy policy or as part of our consent and processing procedures.
Storage duration: With regard to the storage period, a distinction is made between the following types of cookies:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their end device (e.g. browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the log-in status can be saved and favourite content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. If we do not provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), they should assume that they are permanent and that the storage duration can be up to two years.
General information on cancellation and objection (opt-out): Users can revoke the consent they have given at any time and also object to the processing in accordance with the legal requirements, also by means of the privacy settings of their browser.
- Processed data types: Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing operations, procedures and services:
- Processing of cookie data on the basis of consent: We use a consent management solution in which the user's consent to the use of cookies or to the procedures and providers mentioned in the consent management solution is obtained. This procedure is used to obtain, log, manage and revoke consent, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on users' end devices. As part of this procedure, user consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure. Users also have the option of managing and revoking their consent. The declarations of consent are stored in order to avoid repeated requests and to be able to provide proof of consent in accordance with legal requirements. The storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information on the providers of consent management services is available, the following general information applies: Consent is stored for up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g. relevant categories of cookies and/or service providers) and information on the browser, the system and the end device used; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
We use the "Real Cookie Banner" consent tool to manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents. Details on how "Real Cookie Banner" works can be found at <a href="/en/»https://devowl.io/de/rcb/datenverarbeitung/»/" rel="»noreferrer»" target="»_blank»">https://devowl.io/rcb/data-processing/</a>.
The legal basis for the processing of personal data in this context is Art. 6 para. 1 lit. c GDPR and Art. 6 para. 1 lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.
The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data is only processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. In addition, we refer to the information on the processing of visitors to our publication medium in the context of this data protection notice.
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Feedback (e.g. collecting feedback via online form); provision of our online services and user-friendliness; security measures. Organisational and administrative procedures.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Comments and contributions: If users leave comments or other contributions, their IP addresses may be stored on the basis of our legitimate interests. This is done for our security in case someone leaves illegal content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves may be prosecuted for the comment or post and are therefore interested in the identity of the author. we also reserve the right to process user information for the purpose of spam detection on the basis of our legitimate interests. on the same legal basis, we reserve the right to store users' IP addresses for the duration of surveys and to use cookies in order to avoid multiple votes. the personal information provided in the comments and posts, any contact and website information as well as the content information will be stored permanently by us until the user objects; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Contact and enquiry management
When contacting us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the data of the enquiring persons are processed insofar as this is necessary to answer the contact enquiries and any measures requested.
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Persons concerned: Communication partner.
- Purposes of the processing: Communication; organisational and administrative procedures; feedback (e.g. collecting feedback via online form). Provision of our online services and user-friendliness.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing operations, procedures and services:
- Contact form: When contacting us via our contact form, by e-mail or other communication channels, we process the personal data transmitted to us to answer and process the respective request. This generally includes details such as name, contact information and any other information that is provided to us and is required for appropriate processing. We use this data exclusively for the stated purpose of establishing contact and communication; Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Newsletter and electronic notifications
We send newsletters, e-mails and other electronic notifications (hereinafter "newsletter") exclusively with the consent of the recipient or on the basis of a legal basis. If the content of the newsletter is mentioned when registering for the newsletter, this content is decisive for the user's consent. To subscribe to our newsletter, it is normally sufficient to provide your e-mail address. However, in order to be able to offer you a personalised service, we may ask you to provide your name so that we can address you personally in the newsletter or to provide further information if this is necessary for the purpose of the newsletter.
Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a potential defence against claims. An individual request for erasure is possible at any time, provided that the former existence of 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 block list solely for this purpose.
The registration process is logged on the basis of our legitimate interests for the purpose of verifying that it is carried out correctly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system.
Contents:
Information about us, our services, promotions and offers.
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
- Persons concerned: Communication partner.
- Purposes of the processing: Direct marketing (e.g. by e-mail or post).
- Storage and deletion: 3 years - Contractual claims (AT) (Data necessary to consider potential warranty claims and claims for damages or similar contractual claims and rights, as well as to process related enquiries, based on past business experience and standard industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 1478, 1480 ABGB)). 10 years - Contractual claims (CH) (Data necessary for the consideration of potential claims for damages or similar contractual claims and rights, as well as for the processing of related enquiries based on past business experience and standard industry practice, will be stored for the statutory limitation period of ten years, unless a shorter period of five years is applicable, which is relevant in certain cases (Art. 127, 130 CO)).
- Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Possibility of objection (opt-out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options given above, preferably e-mail.
Further information on processing operations, procedures and services:
- Measurement of opening and click rates: The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from our server or its server, if we use a dispatch service provider, when the newsletter is opened. As part of this retrieval, technical information, such as details of 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 our newsletter based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked on. The information is assigned to the individual newsletter recipients and stored in their profiles until it is deleted. The analyses are used to recognise 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 measurement of opening and click rates and the storage of the measurement results in the user profiles; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Advertising communication via e-mail, post, fax or telephone
We process personal data for the purposes of advertising communication, which may take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.
Recipients have the right to withdraw their consent at any time or to object to advertising communication at any time.
After revocation or objection, we store the data required to prove the previous authorisation for contacting or sending up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defence against claims. On the basis of the legitimate interest in permanently observing the revocation or objection of the user, we also store the data required to avoid renewed contact (e.g. depending on the communication channel, the e-mail address, telephone number, name).
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and e-mail addresses or telephone numbers). Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
- Persons concerned: Communication partner.
- Purposes of the processing: Direct marketing (e.g. by e-mail or post); marketing. Sales promotion.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Prize draws and competitions
We process personal data of participants in competitions and contests only in compliance with the relevant data protection regulations, insofar as the processing is contractually required for the provision, implementation and handling of the competition, the participants have consented to the processing or the processing serves our legitimate interests (e.g. in the security of the competition or the protection of our interests against misuse through the possible collection of IP addresses when submitting competition entries).
If participants' contributions are published as part of the competitions (e.g. as part of a vote or presentation of the competition entries or winners or reporting on the competition), we would like to point out that the names of the participants may also be published in this context. Participants can object to this at any time.
If the competition takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as "online platform"), the terms of use and data protection provisions of the respective platforms also apply. In these cases, we would like to point out that we are responsible for the information provided by the participants as part of the competition and that enquiries regarding the competition should be addressed to us.
The participants' data will be deleted as soon as the competition or contest has ended and the data is no longer required to inform the winners or because no further queries about the competition are to be expected. In principle, participants' data will be deleted no later than 6 months after the end of the competition. Winners' data may be retained for longer, e.g. to answer queries about the prizes or to fulfil the prize; in this case, the retention period depends on the type of prize and is up to three years for items or services, e.g. to be able to process warranty claims. Furthermore, participants' data may be stored for longer, e.g. in the form of reporting on the competition in online and offline media.
If data was also collected for other purposes as part of the competition, its processing and the retention period are based on the data protection information for this use (e.g. in the case of registration for the newsletter as part of a competition).
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and e-mail addresses or telephone numbers). Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
- Persons concerned: Competition and contest participants.
- Purposes of the processing: Organising competitions and contests.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Web analysis, monitoring and optimisation
Web analysis (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, for example, recognise at what time our online offering or its functions or content are most frequently used or invite visitors to reuse them. It also enables us to understand which areas require optimisation.
In addition to web analysis, we may also use test procedures, for example to test and optimise different versions of our online offering or its components.
Unless otherwise stated below, profiles, i.e. data summarised for a usage process, can be created for these purposes and information can be stored in a browser or end device and then read out. The information collected includes, in particular, websites visited and the elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data from us or from the providers of the services we use, it is also possible to process location data.
In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored in the context of web analysis, A/B testing and optimisation, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective process.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user 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 draw your attention to the information on the use of cookies in this privacy policy.
- Processed data types: Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online services and user-friendliness.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).
- Safety measures: IP masking (pseudonymisation of the IP address).
- Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Google Analytics: We use Google Analytics to measure and analyse the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or e-mail addresses. It is used to assign analysis information to an end device in order to recognise which content users have called up within one or more usage processes, which search terms they have used, which they have called up again or which they have interacted with our online offering. The time of use and its duration are also stored, as well as the sources of the users that refer to our online offering and technical aspects of their end devices and browsers.
Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies can be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: City (and the city's inferred latitude and longitude), Continent, Country, Region, Subcontinent (and ID-based counterparts). For EU traffic, the IP address data is used exclusively for this derivation of geolocalisation data before it is immediately deleted. They are not logged, are not accessible and are not used for other purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Safety measures: IP masking (pseudonymisation of the IP address); Privacy policy: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms/; Basis for third country transfers: Adequacy decision (Ireland); Possibility of objection (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=deSettings for the display of adverts: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (Types of processing and data processed).
Online marketing
We process personal data for the purpose of online marketing, which may include in particular the marketing of advertising space or the presentation of advertising and other content (collectively referred to as "content") based on the potential interests of users and the measurement of its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (the so-called "cookie") or similar procedures are used, by means of which the information about the user relevant for the presentation of the aforementioned content is stored. This 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 and functions used. If users have consented to the collection of their location data, this can also be processed.
The IP addresses of users are also stored. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) for user protection. 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 neither we nor the providers of the online marketing processes know the actual identity of the users, but only the information stored in their profiles.
The statements in the profiles are generally stored in the cookies or by means of similar procedures. These cookies can generally also be read later on other websites that use the same online marketing process and analysed for the purpose of displaying content and supplemented with further data and stored on the server of the online marketing process provider.
In exceptional cases, it is possible to assign clear data to the profiles, primarily if, for example, the users are members of a social network whose online marketing processes we use and the network links the user profiles with the aforementioned data. Please note that users can make additional agreements with the providers, for example by giving their consent during registration.
In principle, we only receive access to summarised information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e. to the conclusion of a contract with us, for example. The conversion measurement is used solely to analyse the success of our marketing measures.
Unless otherwise stated, we ask you to assume that cookies are stored for a period of two years.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, user 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 draw your attention to the information on the use of cookies in this privacy policy.
Information on cancellation and objection:
We refer to the data protection notices of the respective providers and the opt-out options provided by the providers. If no explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. However, this may restrict the functions of our online offering. We therefore recommend the following additional opt-out options, which are summarised 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) Cross-territorial: https://optout.aboutads.info.
- Processed data types: Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest/behavioural profiling, use of cookies); target group formation; marketing. Profiles with user-related information (creation of user profiles).
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).
- Safety measures: IP masking (pseudonymisation of the IP address).
Affiliate programmes and affiliate links
We include so-called affiliate links or other references (which may include search masks, widgets or discount codes, for example) to the offers and services of third-party providers (collectively referred to as "affiliate links") in our online offering. If users follow the affiliate links or subsequently take advantage of the offers, we may receive a commission or other benefits from these third-party providers (collectively referred to as "commission").
In order to be able to track whether the users have taken up the offers of an affiliate link used by us, it is necessary for the respective third-party providers to learn that the users have followed an affiliate link used within our online offer. The assignment of the affiliate links to the respective business transactions or other actions (e.g. purchases) serves the sole purpose of commission settlement and is cancelled as soon as it is no longer required for this purpose.
For the purposes of the aforementioned assignment of affiliate links, the affiliate links can be supplemented by certain values that are part of the link or can be stored elsewhere, e.g. in a cookie. The values may include, in particular, the source website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer and an online identifier of the user.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, user 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 draw your attention to the information on the use of cookies in this privacy policy.
- Processed data types: Contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Persons concerned: Interested parties. Users (e.g. website visitors, users of online services).
- Purposes of the processing: Affiliate tracking.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Customer reviews and evaluation process
We participate in review and rating procedures in order to evaluate, optimise and advertise our services. If users rate us or otherwise provide feedback via the participating review platforms or procedures, the general terms and conditions or terms of use and the providers' data protection notices also apply. As a rule, the evaluation also requires registration with the respective providers.
In order to ensure that the reviewers have actually used our services, we transmit the necessary data relating to the customer and the service used (including name, email address and order number or item number) to the relevant review platform with the customer's consent. This data is used solely to verify the authenticity of the user.
- Processed data types: Contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Persons concerned: Service recipients and clients. Users (e.g. website visitors, users of online services).
- Purposes of the processing: Feedback (e.g. collecting feedback via online form). Marketing.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
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 the users active there or to offer information about us.
We would like to point out that user data may be processed outside of the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce user rights.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behaviour and the resulting interests of users. The latter may in turn be used, for example, to place adverts within and outside the networks that presumably correspond to the interests of the users. Cookies are therefore generally stored on the user's computer, in which the user's usage behaviour and interests are stored. In addition, data can also be stored in the user profiles independently of the devices used by the users (especially if they are members of the respective platforms and are logged in there).
For a detailed description of the respective forms of processing and the opt-out options, please refer to the data protection declarations 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 would also like to point out that these can be asserted most effectively with the providers. Only the latter have access to the user data and can take appropriate measures and provide information directly. Should you nevertheless require assistance, you can contact us.
- Processed data types: Contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Communication; feedback (e.g. collecting feedback via online form). Public relations.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Instagram: Social network, allows you to share photos and videos, comment on and favourite posts, send messages, subscribe to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basis for third country transfers: Adequacy decision (Ireland).
- Facebook pages: Profiles within the social network Facebook - We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see "Things you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/privacy/policy/), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see "Device information" in the Facebook Data Policy: https://www.facebook.com/privacy/policy/). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services, known as "Page Insights", for page operators to help them understand how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook ("Information on Page Insights", https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information on Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data). The joint responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of data to the parent company Meta Platforms, Inc. in the USA; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basis for third country transfers: Adequacy decision (Ireland).
- LinkedIn: Social network - We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitors' data generated for the purpose of creating the "page insights" (statistics) of our LinkedIn profiles.
This data includes information about the types of content that users view or interact with, or the actions they take, as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data) and information from the user's profile, such as job function, country, industry, hierarchy level, company size and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy
We have entered into a special agreement with LinkedIn Ireland ("Page Insights Joint Controller Addendum (the 'Addendum')", https://legal.linkedin.com/pages-joint-controller-addendum), which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to LinkedIn). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection of data by and transfer to Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of Ireland Unlimited Company, in particular the transfer of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third country transfers: Adequacy decision (Ireland). Possibility of objection (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. - X: Social network; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://x.com; Privacy policy: https://twitter.com/de/privacy. Basis for third country transfers: Adequacy decision (Ireland).
Plug-ins and embedded functions and content
We incorporate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may be, for example, graphics, videos or city maps (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, 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 or function. We endeavour 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 analyse 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 offering, but may also be linked to such information from other sources.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, user 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 draw your attention to the information on the use of cookies in this privacy policy.
- Processed data types: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); metadata, communication data and process data (e.g. IP addresses, time data, identification numbers, persons involved); inventory data (e.g. full name, home address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and posts and contributions, etc.). full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Location data (information on the geographical position of a device or person).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Provision of our online services and user-friendliness.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).
- Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Google Fonts (obtained from the Google server): Obtaining fonts (and symbols) for the purpose of a technically secure, maintenance-free and efficient use of fonts and symbols with regard to up-to-dateness and loading times, their uniform presentation and consideration of possible licence restrictions. The provider of the fonts is informed of the user's IP address so that the fonts can be made available in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) are transmitted that are necessary for the provision of the fonts depending on the devices used and the technical environment. This data may be processed on a server of the font provider in the USA - When visiting our online offering, users' browsers send their browser HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving fonts). The Google Fonts Web API provides users with the Google Fonts Cascading Style Sheets (CSS) and then the fonts specified in the CCS. These HTTP requests include (1) the IP address used by the respective user to access the Internet, (2) the requested URL on the Google server and (3) the HTTP headers, including the user agent, which describes the browser and operating system versions of the website visitors, as well as the referral URL (i.e. the web page on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and are not analysed. The Google Fonts Web API logs details of HTTP requests (requested URL, user agent and referrer URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wishes to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must adapt the font that is generated for the respective browser type. The user agent is primarily logged for debugging and used to generate aggregated usage statistics to measure the popularity of font families. These summarised usage statistics are published on the "Analyses" page of Google Fonts. Finally, the referral URL is logged so that the data can be used for production maintenance and an aggregated report on the top integrations can be generated based on the number of font requests. According to Google, it does not use any of the information collected by Google Fonts to create profiles of end users or to place targeted adverts; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy; Basis for third country transfers: Adequacy decision (Ireland). Further information: https://developers.google.com/fonts/faq/privacy?hl=de.
- Google Maps: We integrate the maps of the "Google Maps" service provided by Google. The processed data may include, in particular, IP addresses and user location data; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy. Basis for third country transfers: Adequacy decision (Ireland).
- YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Basis for third country transfers: Adequacy decision (Ireland). Possibility of objection (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=deSettings for the display of adverts: https://myadcenter.google.com/personalizationoff.
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