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Data Privacy 



Introduction

With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as "data" for short) that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part of the provision of our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "Online Offer").

The terms used are not gender-specific. Status: November 26, 2021

Table of Contents

  • Introduction

  • Person responsible

  • Overview of processing operations

  • Relevant legal bases

  • Security measures

  • Transfer of personal data

  • Data processing in third countries

  • Deletion of data

  • Use of cookies

  • Business services

  • Payment procedures

  • Provision of the online offer and web hosting

  • Special notes on applications (apps)

  • Purchase of applications via app stores

  • Registration, login and user account

  • Community functions

  • Blogs and publication media

  • Contact and inquiry management

  • Newsletter and electronic notifications

  • Promotional communication via e-mail, mail, fax, or telephone

  • Web analytics, monitoring and optimization

  • Online marketing

  • Presence in social networks (social media).

  • Plugins and embedded functions as well as content.

  • Modification and updating of the privacy policy

  • Rights of data subjects

  • Definitions of terms
     

Responsible

Maik Neubauer, Managing Director, LEX AI GmbH 
interhuder Weg 29, 22085 Hamburg, Germany
E-mail address: privacy@lexai.co.

Overview of processing operations

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

  • Inventory data (e.g. names, addresses).

  • Content data (e.g. entries in online forms).

  • Contact data (e.g. e-mail, telephone numbers).

  • Meta/communication data (e.g. device information, IP addresses).

  • Usage data (e.g. web pages visited, interest in content, access times).

  • Image and/ or video recordings (e.g. photographs or video recordings of a person).

  • Contract data (e.g. subject matter of contract, term, customer category).

  • Payment data (e.g. bank details, invoices, payment history). Categories of data subjects.

  • Business and contractual partners.

  • Interested parties.

  • Communication partners.

  • Customers.

  • Users (e.g. website visitors, users of online services).
     

Purposes of processing.

  • Provision of our online offer and user-friendliness.

  • Conversion measurement (measuring the effectiveness of marketing measures).

  • Office and organizational procedures.

  • Content delivery network (CDN).

  • Direct marketing (e.g., via e-mail or postal mail).

  • Feedback (e.g., collecting feedback via online form).

  • Marketing.

  • Contact requests and communication.

  • Profiles with user-related information (creating user profiles).

  • Reach measurement (e.g., access statistics, recognition of returning visitors).

  • Security measures.

  • Provision of contractual services and customer service.

  • Administration and response to inquiries. Relevant legal basis The following is an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If, in addition, more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.
     

Relevant legal bases

The following is an overview of the legal basis of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.
 

  • Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO) - The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.

  • Performance of a contract and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO) - Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures carried out at the data subject's request.

  • Legal obligation (Art. 6 (1) p. 1 lit. c. DSGVO) - Processing is necessary for compliance with a legal obligation to which the controller is subject.

  • Legitimate interests (Art. 6 (1) p. 1 lit. f. DSGVO) - Processing is necessary for the purposes of the legitimate interests of the controller or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
     

National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for employment purposes (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

Security measures

We take appropriate technical and organizational 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 access to, input of, disclosure of, assurance of availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, the deletion of data, and responses to data compromise. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

IP address shortening: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not required, the IP address is shortened (also referred to as "IP masking"). In this process, the last two digits or the last part of the IP address after a period are removed or replaced by wildcards. The shortening of the IP address is intended to prevent or make it significantly more difficult to identify a person by their IP address.

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

Transmission of personal data In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. 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 comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data. Data transfer within the organization: We may transfer personal data to other entities within our organization or grant them access to such data. Where this transfer is for administrative purposes, the transfer of data is based on our legitimate business and operational interests or is made where it is necessary to fulfill our contract-related obligations or where we have the consent of the data subjects or legal permission.

Data processing in third countries

If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies, this will only be done in accordance with the legal requirements. Subject to express consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not necessary for the purpose). If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. That is, the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defense of legal claims or to protect the rights of another natural or legal person. Within the scope of our data protection notices, we may provide users with further information on the deletion as well as on the retention of data that specifically applies to the respective processing operations.

Use of cookies

Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user's computer. A cookie is primarily used to store information about a user during or after his visit within an online offer. Stored information may include, for example, language settings on a website, login status, a shopping cart, or where a video was watched. We further include in the term cookies other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also referred to as "user IDs")

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session cookies): temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.

  • Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users used for range measurement or marketing purposes can be stored in such a cookie.

  • First-party cookies: First-party cookies are set by ourselves.

  • **Third-party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.

  • Necessary (also: essential or absolutely necessary) cookies: Cookies may be absolutely necessary for the operation of a website (e.g., to store logins or other user input or for security reasons).

  • Statistical, marketing and personalization cookies: Furthermore, cookies are usually also used in the context of range measurement and when a user's interests or behavior (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that matches their potential interests. This process is also referred to as "tracking", i.e., tracking the potential interests of users. Insofar as we use cookies or "tracking" technologies, we will inform you separately in our data protection declaration or in the context of obtaining consent.
     

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

Storage period: Unless we provide you with explicit information on the storage period of permanent cookies (e.g. in the context of a so-called cookie opt-in), please assume that the storage period can be up to two years.

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

Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the consent of users to the use of cookies, or the processing and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users. Here, the declaration of consent is stored in order not to have to repeat its query and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies), in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years.
Here, a pseudonymous user identifier is formed and stored with the time of consent, information on the scope of consent (e.g., which categories of cookies and/or service providers) as well as the browser, system and end device used.
 

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

  • Data subjects: Users (e.g., website visitors, users of online services).

  • Legal basis: consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
     

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 as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer inquiries.

We process this data to fulfill our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as for business organization. Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or for the fulfillment of legal obligations or with the consent of the data subjects (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.
We inform the contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.

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

Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.

Customer account: Contractual partners can create an account within our online offer (e.g. customer or user account, "customer account" for short). If registration of a customer account is required, contractual partners will be informed of this as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. Within the scope of registration and subsequent logins and uses of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove the registration and prevent any misuse of the customer account.

If customers have terminated their customer account, the data relating to the customer account will be deleted, unless their retention is required for legal reasons. It is the responsibility of customers to back up their data when their customer account is terminated.
Store and e-commerce: We process the data of our customers to enable them to select, purchase or order the selected products, goods and related services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery, or execution to our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is identified as such in the context of the order or comparable acquisition process and includes the information required for delivery, or provision and billing, as well as contact information in order to be able to make any consultations.
 

  • Types of data processed: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

  • Data subjects: Interested parties, business and contractual partners, customers.

  • Purposes of processing: provision of contractual services and customer service, contact requests and communication, office and organizational procedures, administration and response to requests, security measures.

  • Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
     

Payment procedure

In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other service providers for this purpose in addition to banks and credit institutions (collectively, "payment service providers").

The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is required in order to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e., we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the payment service providers transmit the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the terms and conditions and data protection information of the payment service providers.

For payment transactions, the terms and conditions and data protection notices of the respective payment service providers apply, which can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and assertion of revocation, information and other data subject rights.
 

  • Types of data processed: inventory data (e.g., names, addresses), payment data (e.g., bank details, invoices, payment history), contract data (e.g., subject matter of contract, term, customer category), usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses), contact data (e.g., e-mail, telephone numbers).

  • Data subjects: Customers, interested parties.

  • Purposes of processing: provision of contractual services and customer service.

  • Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
     

Services and service providers used:
 

Provision of the online offer and web hosting

In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services. The data processed as part of the provision of the hosting offer may include all information relating to the users of our online offer, which is generated as part of the use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites. E-mail sending and hosting: The web hosting services we use also include the sending, receiving and storing of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for SPAM detection purposes. Please note that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. Therefore, we cannot assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server. Collection of access data and log files: We ourselves (or our web hosting provider) collect data on each access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume 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 may be used on the one hand for security purposes, e.g. to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the utilization of the servers and their stability. Content Delivery Network: We use a "content delivery network" (CDN). A CDN is a service with the help of which content of an online offer, in particular large media files such as graphics or program scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet.
 

  • Types of data processed: Content data (e.g., entries in online forms), usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses).

  • Data subjects: Users (e.g., website visitors, users of online services).

  • Purposes of processing: provision of our online offer and user-friendliness, content delivery network (CDN).

  • Legal grounds: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
     

Services used and service providers:
 

Special notes on applications (apps)

We process the data of the users of our application insofar as this is necessary to provide the application and its functionalities to the users, to monitor its security and to further develop it. We may also contact users in compliance with legal requirements, provided that the communication is necessary for purposes of administration or use of the application. In all other respects, we refer to the data protection information in this privacy policy with regard to the processing of users' data. Legal basis: the processing of data required for the provision of the functionalities of the application serves the fulfillment of contractual obligations. This also applies if the provision of the functionalities requires authorization of the users (e.g. releases of device functions). If the processing of data is not necessary for the provision of the functionalities of the application, but serves the security of the application or our business interests (e.g. collection of data for purposes of optimizing the application or security purposes), it is based on our legitimate interests. If users are explicitly asked for their consent to the processing of their data, the processing of the data covered by the consent is based on the consent.

Commercial use: We process the data of users of our application, registered users and any test users (hereinafter uniformly referred to as "users") in order to be able to provide our contractual services to them and on the basis of legitimate interests in order to ensure the security of our application and to be able to develop it further. The required information is identified as such in the context of the conclusion of the use, order, purchase order or comparable contract and may include the information required for the provision of services and for any billing, as well as contact information in order to be able to hold any consultations.
Storage of a Universally Unique Identifier (UUID): The Application stores a so-called Universally Unique Identifier (UUID) for the purpose of analyzing the use and functionality of the Application as well as storing the User's settings. This identifier is generated during the installation of this application (but is not associated with the device, so it is not a device identifier in this sense), remains stored between the launch of the application as well as its updates, and is deleted when users remove the application from their device. Device permissions to access functionality and data: The use of our Application or its functionalities may require users to have permissions to access certain functions of the devices used or the, data stored on the devices or accessible by means of the devices. By default, these permissions must be granted by users and can be revoked at any time in the settings of the respective devices. The exact procedure for controlling app permissions may depend on the users' device and software. If clarification is needed, users can contact us. We would like to point out that denial or revocation of the respective permissions may affect the functionality of our app.
Access to the camera as well as stored recordings: In the course of using our Application, image and/or video recordings (which also includes audio recordings) of Users (and of other persons covered by the recordings) are processed by accessing the camera functions or stored recordings. Access to the camera functions or stored recordings requires an authorization by the users that can be revoked at any time. In each case, the processing of the image and/or video recordings serves only to provide the respective functionality of our application, in accordance with its description to users, or its typical and expected functionality.
Processing of stored contacts: As part of the use of our application, the contact information of individuals (name, email address, phone number) stored in the contact directory of the device is processed. The use of the contact information requires user authorization, which can be revoked at any time. The use of the contact information serves in each case only to provide the respective functionality of our application, according to its description to the users, or its typical and expected functionality. Users are advised that permission to process contact information must be permitted and, in the case of natural persons in particular, requires their consent or legal permission.

Use of contact information for contact matching purposes: the data of contacts stored in the contact directory of the device may be used to check whether these contacts also use our application. For this purpose, the contact data of the respective contacts (which includes phone number and email address as well as names) are uploaded to our server and used only for the purpose of matching.
 

  • Types of data processed: inventory data (e.g., names, addresses), meta/communication data (e.g., device information, IP addresses), payment data (e.g., bank details, invoices, payment history), contract data (e.g., subject matter of the contract, term, customer category), image and/or video recordings (e.g., photographs or video recordings of a person).

  • Data subjects: Users (e.g., website visitors, users of online services).

  • Purposes of processing: provision of contractual services and customer service.

  • Legal bases: consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
     

Purchase of applications via app stores

The purchase of our app takes place via special online platforms operated by other service providers to (so-called "app stores"). In this context, the privacy notices of the respective app stores apply in addition to our privacy notices. This applies in particular with regard to the methods used on the platforms for reach measurement and interest-based marketing, as well as any obligation to pay costs.
 

  • Types of data processed: inventory data (e.g., names, addresses), payment data (e.g., bank details, invoices, payment history), contact data (e.g., e-mail, telephone numbers), contract data (e.g., subject matter of contract, term, customer category), usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses).

  • Data subjects: Customers.

  • Purposes of processing: provision of contractual services and customer service.

  • Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
     

Services and service providers used:
 

Registration, login and user account

Users can create a user account. As part of the registration process, users are provided with the required mandatory data and processed for the purposes of providing the user account based on contractual obligation fulfillment. The processed data includes in particular the login information (username, password and an e-mail address). In the context of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorized use. As a matter of principle, this data is not passed on to third parties unless it is necessary for the prosecution of our claims or there is a legal obligation to do so. Users may be informed by e-mail about events relevant to their user account, such as technical changes. Registration with a clear name: Due to the nature of our community, we ask users to use our service only by using clear names. I.e. the use of pseudonyms is not permitted. Users' profiles are public: Users' profiles are publicly visible and accessible. Two-factor authentication: Two-factor authentication provides an additional layer of security for your user account and ensures that only you can access your account, even if someone else knows your password. For this purpose, you will need to perform another authentication measure in addition to your password (e.g., enter a code sent to a mobile device). We will inform you about the procedure we use. Deletion of data after termination: When users have terminated their user account, their data relating to the user account will be deleted, subject to any legal permission, obligation or consent of the users.
It is the responsibility of users to back up their data upon termination prior to the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract.
 

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), meta/communication data (e.g. device information, IP addresses).

  • Data subjects: Users (e.g., website visitors, users of online services).

  • Purposes of processing: provision of contractual services and customer service, security measures, administration and response to inquiries.

  • Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
     

Community Functions The community functions provided by us allow users to enter into conversations or other exchanges with each other. Please note that the use of the community functions is only permitted in compliance with the applicable legal situation, our terms and guidelines and the rights of other users and third parties.
User contributions are public: The contributions and content created by users are publicly visible and accessible.

Storage of data for security purposes: User contributions and other input are processed for the purposes of community and conversation functions and, subject to legal obligations or legal permission, are not released to third parties. An obligation to surrender may arise in particular in the case of illegal contributions for the purposes of legal prosecution. We would like to point out that, in addition to the content of the contributions, their time and the IP address of the user are also stored. This is done in order to be able to take appropriate measures to protect other users and the community.

Right to delete: The deletion of contributions, content or information of users is permissible after proper consideration to the extent necessary if there are concrete indications that they represent a violation of legal regulations, our specifications or the rights of third parties.

Restricted deletion of conversation contributions: Out of consideration for other users, the user's contributions to conversations remain stored even after termination and account deletion, so that conversations, comments, advice or similar. Communication between and among users does not lose its meaning or reverse. User names are deleted or pseudonymized if they were not already pseudonyms. Users may request complete deletion of conversation posts at any time by contacting us.

Protection of own data: Users decide for themselves what data they disclose about themselves within our online offering. For example, when users provide personal information or participate in conversations. We ask users to protect their data and to disclose personal data only with caution and only to the extent necessary. In particular, we ask users to note that they must protect access data quite particularly and use secure passwords (i.e., above all, character combinations that are as long and random as possible).
 

  • Types of data processed: Usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

  • Data subjects: Users (e.g., website visitors, users of online services).

  • Purposes of processing: provision of contractual services and customer service, security measures.

  • Legal bases: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
     

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data are processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.
Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.
Furthermore, we reserve the right to process the user's details for the purpose of spam detection on the basis of our legitimate interests.
On the same legal basis, we reserve the right to store the IP addresses of users for the duration of surveys and to use cookies in order to avoid multiple votes.
The personal information provided in the context of comments and contributions, any contact and website information as well as the content-related information will be stored permanently by us until the user objects.
 

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

  • Data subjects: Users (e.g., website visitors, users of online services).

  • Purposes of processing: provision of contractual services and customer service, feedback (e.g. collecting feedback via online form), security measures, managing and responding to requests.

  • Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
     

Contact and inquiry management

When contacting us (e.g. via contact form, email, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

The response to the contact inquiries as well as the management of contact and inquiry data in the context of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to respond to (pre)contractual inquiries and otherwise on the basis of legitimate interests in responding to the inquiries and maintaining user or business relationships.
 

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms).

  • Data subjects: Communication partners.

  • Purposes of processing: contact inquiries and communication.

  • Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
     

Services used and service providers:
 

Newsletters and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter "newsletter") only with the consent of the recipients or a legal permission. If the contents of the Newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. Otherwise, our newsletters contain information about our services and us.
In order to subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name, for the purpose of a personal address in the newsletter, or further information, if this is necessary for the purposes of the newsletter.
Double opt-in procedure: The registration for our newsletter is always carried out in a so-called double opt-in process. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise, changes to your data stored with the dispatch service provider are logged.
Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove consent formerly given. The processing of this data will be 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. In the case of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list (so-called "block list") for this purpose alone.
The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. 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 sending system.
Notes on legal basis: The newsletter is sent on the basis of the recipients' consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of existing customer advertising. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to prove that it was carried out in accordance with the law.

Content: Information about us, our services, promotions and offers.
Measurement of opening and click-through rates: The newsletters contain a so-called "web-beacon", i.e., a pixel-sized file that is retrieved from our server, or, if we use a shipping service provider, from their server, when the newsletter is opened. In the course of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the retrieval, are initially collected.
This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. We use the evaluations to identify 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 rates and click rates as well as storage of the measurement results in the users' profiles and their further processing are based on the users' consent.
Unfortunately, a separate revocation of the performance measurement is not possible, in which case the entire newsletter subscription must be cancelled, or it must be contradicted. In this case, the stored profile information will be deleted.
 

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).

  • Data subjects: Communication partners, users (e.g., website visitors, users of online services).

  • Purposes of processing: direct marketing (e.g., via e-mail or postal mail), reach measurement (e.g., access statistics, recognition of returning visitors), conversion measurement (measurement of the effectiveness of marketing measures), profiles with user-related information (creation of user profiles).

  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

  • 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 above contact options, preferably e-mail, for this purpose.
     

Services used and service providers:
 

Promotional communication via email, mail, fax or telephone.

We process personal data for the purposes of promotional communication, which may take place via various channels, such as e-mail, telephone, post or fax, in accordance with the legal requirements.
Recipients have the right to revoke consent given at any time or to object to promotional communication at any time.
After revocation or objection, we may store the data required to prove consent for up to three years based on our legitimate interests before deleting it. The processing of this data will be limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.
 

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).

  • Data subjects: Communication partners.

  • Purposes of processing: direct marketing (e.g., by e-mail or postal mail).

  • Legal bases: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
     

Web analysis, monitoring and optimization

Web analysis (also referred to as "reach measurement") is used to evaluate the flow of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can recognize, for example, at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimization.
In addition to web analytics, we may also use testing procedures, for example, to test and optimize different versions of our online offering or its components.

Unless otherwise stated below, profiles, i.e. data summarized for a usage process, may be created for these purposes and information may be stored in a browser, or in a terminal device, and read from it. The information collected includes, in particular, websites visited and 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 agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed.
The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, in the context of web analysis, A/B testing and optimization, no clear data of the users (such as e-mail addresses or names) are stored, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

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

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

  • Data subjects: Users (e.g., website visitors, users of online services).

  • Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors), profiles with user-related information (creation of user profiles).

  • Security measures: IP masking (pseudonymization of the IP address).

  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
     

Services used and service providers:
 

Online marketing

We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or presentation of promotional and other content (collectively, "content") based on potential user interests and the measurement of its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar procedures are used, by means of which the information about the user relevant to the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed.
The IP addresses of users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of the users (such as e-mail addresses or names) are stored in the context of the online marketing process, but pseudonyms. This means that we, as well as the providers of the online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles. The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can later generally be read on other websites that use the same online marketing procedure and analyzed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.
Exceptionally, clear data can be assigned to the profiles. This is the case if, for example, the users are members of a social network whose online marketing procedure we use and the network links the users' profiles with the aforementioned data. We ask to note that users may make additional arrangements with the providers, e.g., by giving consent as part of the registration process.
In principle, we only receive access to summarized information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e., for example, to a conclusion of a contract with us. The conversion measurement is used solely to analyze the success of our marketing measures.
Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.

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

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

  • Data subjects: Users (e.g., website visitors, users of online services).

  • Purposes of processing: marketing, profiles with user-related information (creation of user profiles).

  • Security measures: IP masking (pseudonymization of the IP address).

  • Legal bases: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

  • Option to object (opt-out): We refer to the data protection notices of the respective providers and the options for objection given to the providers (so-called "opt-out"). 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 functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for the respective areas: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-territory: https://optout.aboutads.info.
     

Services used and service providers:

Presence in social networks (social media).

We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for the users because, for example, it could make it more difficult to enforce the rights of the users.

Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behavior and interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).
For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the privacy statements and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can take appropriate measures and provide information directly. If you still require assistance, you can contact us.
 

  • Types of data processed: contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

  • Data subjects: Users (e.g., website visitors, users of online services).

  • Purposes of processing: contact requests and communication, feedback (e.g. collecting feedback via online form), marketing.

  • Legal grounds: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
     

Services used and service providers:


Plugins and embedded functions and content

We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These can be, for example, graphics, videos or 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, since without the IP address they could not send the content to their browser. The IP address is thus required for the presentation of these contents or functions. We strive to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer as well as be linked to such information from other sources.
Notes on legal basis: 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, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

Services used and service providers:

Change and update of the privacy policy

We ask you to regularly inform yourself about the content of our privacy policy. We adapt the privacy policy as soon as the changes in the data processing carried out by us make it necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
Insofar as we provide addresses and contact information of companies and organizations in this data protection declaration, we ask you to note that the addresses may change over time and ask you to check the information before contacting us.

Rights of the data subjects

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

  • Right of objection: you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.

  • Right to withdraw consent: You have the right to revoke any consent given at any time.

  • Right to information: you have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with legal requirements. Right to rectification: You have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be rectified. Right to rectification: In accordance with the legal requirements, you have the right to request that the data concerning you be completed or that the incorrect data concerning you be rectified.

  • Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be erased without delay or, alternatively, to demand restriction of the processing of the data in accordance with the legal requirements.

  • Right to data portability: You have the right to receive data relating to you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to request that it be transferred to another controller.

  • Complaint to supervisory authority: In accordance with the law and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you usually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
     

Definitions

This section provides you with an overview of the terms used in this Privacy Policy. Many of the terms are taken from the law and defined primarily in Article 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are sorted alphabetically.
 

  • Content Delivery Network (CDN): A "Content Delivery Network" (CDN) is a service with the help of which the content of an online offering, in particular large media files such as graphics or program scripts, can be delivered more quickly and securely with the help of regionally distributed servers connected via the Internet.

  • IP masking: "IP masking" refers to a method in which the last octet, i.e., the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing methods, especially in online marketing

  • Conversion measurement: conversion measurement (also referred to as "visit action evaluation") is a method used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users' devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we have placed on other websites have been successful.

  • Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (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.

  • Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any type of automated processing of personal data that consists of using such personal data to analyze, evaluate or to predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g., interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.

  • Reach measurement: Reach measurement (also referred to as web analytics) is used to evaluate the visitor flows of an online offering and can include visitors' behavior or interests in certain information, such as website content. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.

  • Controller: "Controller" is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.

  • Processing: "Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data, be it collection, evaluation, storage, transmission or deletion.

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