Privacy policy

Introduction

With the following privacy policy, we would like to inform you about what types of your personal data (hereinafter also referred to as ‘data’) we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, mobile, as well as 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: 11.12.2024

Person responsible

Robin Strohäker / PAVE+ Ltd.
Dekan- Stockmayer- Straße 1
72202 Nagold
Germany

E-Mail-Address: info@paveplus.com

Telephone: +497452 63 10 600

Imprint: https://www.supersiteskills.com/impressum

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 (e.g., names, addresses).
Content data (e.g., entries in online forms).
Contact data (e.g., email, telephone numbers).
Meta/communication data (e.g., device information, IP addresses).
Usage data (e.g., websites visited, interest in content, access times).
Location data (information on the geographical location of a device or person).
Contract data (e.g., contract subject matter, term, customer category).
Payment data (e.g., bank details, invoices, payment history).

Categories of data subjects

Business and contractual partners.
Prospects.
Communication partners.
Customers.
Users (e.g., website visitors, users of online services).

Purposes of processing

Assessment of creditworthiness and credit rating.
Provision of our online offering and user-friendliness.
Evaluation of visit actions.
Office and organizational procedures.
Cross-device tracking (cross-device processing of user data for marketing purposes).
Direct marketing (e.g., by email or post).
Interest-based and behavioral marketing.
Contact inquiries and communication.
Conversion measurement (measurement of the effectiveness of marketing measures).
Profiling (creation of user profiles).
Remarketing.
Reach measurement (e.g., access statistics, recognition of returning visitors).
Security measures.
Tracking (e.g., interest-/behavior-based profiling, use of cookies).
Provision of contractual services and customer service.
Administration and response to inquiries.
Target group formation (determination of target groups relevant for marketing purposes or other delivery of content).

Automated decisions in individual cases

Credit report (decision based on a credit check).

Relevant legal bases

Below, we provide the legal basis of the General Data Protection Regulation (GDPR) on which we process personal data. Please note that in addition to the provisions of the GDPR, the national data protection regulations in your or our country of residence and domicile may apply. Should more specific legal bases apply in individual cases, we will inform you of these in the privacy policy.

Consent (Article 6 (1) (a) GDPR) – The data subject has given their consent to the processing of personal data concerning them for one or more specific purposes.
Contractual performance and pre-contractual inquiries (Article 6 (1) (b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Legal obligation (Article 6 (1) (c) GDPR) – Processing is necessary to fulfill a legal obligation to which the controller is subject.
Legitimate interests (Article 6 (1) (f) GDPR) – Processing is necessary to protect the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject which require protection of personal data override the legitimate interests.

Security measures

In accordance with legal requirements, taking into account the state of the art, implementation costs, and the nature, scope, circumstances, and purposes of processing, as well as the varying probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

These measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as the access, input, and transfer of data, ensuring its availability, and segregation. Furthermore, we have established procedures that ensure the exercise of data subjects’ rights, the deletion of data, and responses to data threats. Furthermore, we consider the protection of personal data right from the development and selection of hardware, software, and processes in accordance with the principle of data protection, through technology design, and through data protection-friendly default settings.

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

Transfer and disclosure of personal data

As part of our processing of personal data, it may happen that the data is transmitted to or disclosed to other bodies, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks, or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

Data processing in third countries

If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if the processing takes place as part of the use of third-party services or the disclosure or transmission of data to other persons, bodies, or companies, this will only be done in accordance with legal requirements.

Subject to express consent or contractually or legally required transmission, we only process or have data processed in third countries with a recognized level of data protection, a contractual obligation through so-called standard protection clauses of the EU Commission, if certifications or binding internal data protection regulations are in place (Articles 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

Within the framework of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the level of data protection for certain US companies as secure within the framework of the adequacy decision of July 10, 2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). In our privacy policy, we inform you which service providers we use are certified under the Data Privacy Framework.

Use of cookies

Cookies are small text files or other storage memories that store information on end devices and retrieve information from them. For example, they can store the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed, or the functions used within an online offering. Cookies can also be used for various purposes, e.g., to ensure the functionality, security, and convenience of online offerings, as well as to create analyses of visitor flows.

Notes on consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, unless this is not required by law. Consent is not necessary, in particular, if the storage and retrieval of information, including cookies, is absolutely necessary to provide users with a telemedia service they have expressly requested (i.e., our online offering). The revocable consent will be clearly communicated to users and will contain information about the respective cookie usage.

Notes on data protection law: The legal basis for processing users’ personal data with the help of cookies depends on whether we ask users for their consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g., in the commercial operation of our online offering and improving its usability) or, if this occurs as part of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We explain the purposes for which we process cookies in the course of this privacy policy or as part of our consent and processing procedures.

Storage period: With regard to the storage period, we distinguish between the following types of cookies:

Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their device (e.g., browser or mobile application).
Permanent cookies: Permanent cookies remain stored even after the device 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 user data collected through cookies can be used to measure reach. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., when obtaining consent), users should assume that cookies are permanent and 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 your consent or to object to the processing of your data using cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection using your browser settings, e.g., by deactivating the use of cookies (although this may also limit the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared using a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. You can also obtain further objection information in the information about the service providers and cookies used.

Processing of cookie data based on consent: We use a cookie consent management procedure within which users’ consent to the use of cookies or the processing operations and providers named in the cookie consent management procedure can be obtained, managed and revoked by users. The declaration of consent is saved so that it does not have to be requested again and so that consent can be proven in accordance with legal obligations. 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 consent to a user or their device. Subject to individual information about the providers of cookie management services, the following information applies: Consent can be stored for up to two years. A pseudonymous user identifier is created and stored along with the time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and device used.

Cookie settings/opt-out option:

Datenschutz Einstellungen

Commercial and business services

We process data from our contractual and business partners, e.g., customers and interested parties (collectively referred to as “Contractual Partners”) within the framework of contractual and comparable legal relationships, as well as related measures and within the framework of communication with the contractual partners (or pre-contractually), e.g., to answer inquiries.

We process this data to fulfill our contractual obligations, to protect 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 pass on the data of our contractual partners to third parties to the extent necessary for the aforementioned purposes or to fulfill 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). The contractual partners will be informed about other forms of processing, e.g., for marketing purposes, in this privacy policy.

We inform our contractual partners which data is required for the aforementioned purposes before or during data collection, e.g., in online forms, by special marking (e.g., colors) or symbols (e.g., asterisks, etc.), or in person.

We delete the data after the expiration of statutory warranty and similar obligations, i.e., generally after four years, unless the data is stored in a customer account, e.g., for as long as it must be retained for legal archiving reasons (e.g., for tax purposes, usually ten years). If a period does not explicitly begin on a specific date and is at least one year, it automatically begins 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 period is the date on which the termination or other termination of the legal relationship takes effect. 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.

To the extent that we use third-party providers or platforms to provide our services, the terms and conditions and privacy policies of the respective third-party providers or platforms apply to the relationship between users and the providers.

Customer account: Contractual partners can create an account within our online offering (e.g., customer or user account, “customer account” for short). If registration of a customer account is required, the 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. During registration, as well as subsequent logins and use of the customer account, we store the customers’ IP addresses along with the access times in order to verify registration and prevent any misuse of the customer account.

If customers have canceled their customer account, the data relating to the customer account will be deleted, unless retention is required for legal reasons. It is the customer’s responsibility to back up their data after terminating their account.

Economic analyses and market research: For business reasons and market trends, Wünsche der Economic analyses and market research: For business reasons and in order to identify market trends and the wishes of contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc., whereby the group of data subjects may include contractual partners, interested parties, customers, visitors, and users of our online offering.

The analyses are carried out for the purpose of business evaluations, marketing, and market research (e.g., to determine customer groups with different characteristics). In doing so, we may, where available, consider the profiles of registered users, including their information, e.g., regarding services used. The analyses serve our sole purpose and are not disclosed externally, unless they are anonymous analyses with summarized, i.e., anonymized values. Furthermore, we respect the privacy of users and process the data for analysis purposes pseudonymously and, where feasible, anonymously (e.g., as summarized data).

Shop and e-commerce: We process our customers’ data to enable them to select, purchase, or order the selected products, goods, and related services, as well as to pay for and deliver them or execute them. If necessary to execute an order, we use service providers, in particular postal, forwarding, and shipping companies, to carry out delivery or execution for our customers. We utilize the services of banks and payment service providers to process payment transactions. The required information is marked as such within the ordering or similar purchase process and includes the information needed for delivery, provision, and billing, as well as contact information for any follow-up questions.

Types of data processed: Inventory data (e.g., names, addresses), payment data (e.g., bank details, invoices, payment history), contact data (e.g., email, telephone numbers), contract data (e.g., subject matter of the 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 inquiries and communication, office and organizational procedures, administration and response to inquiries, security measures, visitor action analysis, interest-based and behavioral marketing, profiling (creation of user profiles).
Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

Provision of the online offer and web hosting

In order to provide our online offering securely and efficiently, we utilize the services of one or more web hosting providers from whose servers (or servers managed by them) the online offering can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space, and database services, as well as security and technical maintenance services.

The data processed in the context of providing the hosting service may include all information relating to users of our online offering that arises during use and communication. This usually includes the IP address, which is necessary to deliver the content of online offerings to browsers, and all entries made within our online offering or on websites.

Email sending and hosting: The web hosting services we use also include the sending, receiving, and storage of emails. For these purposes, the addresses of the recipients and senders, as well as other information regarding the email transmission (e.g., the providers involved), and the content of the respective emails are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that emails are generally not sent encrypted over the Internet. Emails are generally encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We therefore cannot assume any responsibility for the transmission path of the emails between the sender and the recipient on our server.

Collection of access data and log files: We (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user’s operating system, the referrer URL (the previously visited page), and usually IP addresses and the requesting provider.

The server log files can be used for security purposes, e.g., to prevent server overload (particularly in the case of abusive attacks, so-called DDoS attacks), and to ensure server utilization and stability.

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).
- Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

Contact us

When you contact us (e.g., via contact form, email, telephone, or social media), the information provided by the person contacting you will be processed to the extent necessary to respond to the contact requests and any requested actions.

Responses to contact requests within the framework of contractual or pre-contractual relationships are made to fulfill our contractual obligations or to respond to (pre-)contractual inquiries, and otherwise based on our legitimate interests in responding to the inquiries.

Types of data processed: Inventory data (e.g., names, addresses), contact data (e.g., email, 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: Communication partners, interested parties.
Purposes of processing: Contact inquiries and communication, administration and response to inquiries.
Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

Services and service providers used: Contact form: If users contact us via our contact form, email, or other communication channels, we process the data provided to us in this context to process the communicated request. For this purpose, we process personal data within the framework of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfillment, and otherwise based on our legitimate interests as well as the interests of our communication partners in responding to the requests and our statutory retention periods.

Newsletters and electronic notifications

We send newsletters, emails, and other electronic notifications (hereinafter “newsletters”) only with the recipient’s consent or legal permission. If the newsletter content is specifically described when registering for the newsletter, it is decisive for the user’s consent. Otherwise, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to provide your email address. However, we may ask you to provide a name for the purpose of addressing you personally in the newsletter or other information if this is necessary for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter is generally carried out using a so-called double opt-in procedure. This means that after registration, you will receive an email asking you to confirm your registration. This confirmation is necessary to ensure that no one can register using someone else’s email address. Newsletter registrations are logged in order to be able to verify the registration process in accordance with legal requirements. This includes storing the registration and confirmation times, as well as the IP address. Changes to your data stored by the shipping service provider are also 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 previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address on a blocking list (so-called “blacklist”) for this purpose alone.

The registration process is logged based on our legitimate interests for the purpose of proving its proper execution. If we commission a service provider to send emails, this is done based on our legitimate interests in an efficient and secure shipping system.

Notes on legal bases: Newsletters are sent based on the recipient’s consent or, if consent is not required, based on our legitimate interests in direct marketing, provided and to the extent permitted by law, e.g., in the case of advertising to existing customers. If we commission a service provider to send emails, this is done on the basis of our legitimate interests. The registration process is recorded based on our legitimate interests to demonstrate that it was carried out in compliance with the law.

Content: Information about us, our services, promotions, and offers.Types of data processed: Inventory data (e.g., names, addresses), contact data (e.g., email, 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.

Purposes of processing: Direct marketing (e.g., by email or post).

Legal basis: Consent (Art. 6 (1) (a) GDPR), Legitimate interests (Art. 6 (1) (f) GDPR).

Opt-out option: You can unsubscribe from our newsletter at any time, i.e., revoke your consent or object to further receipt. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email.

Services and service providers used:

CleverReach: Email marketing platform;
Service provider: CleverReach GmbH & Co. KG, //CRASH Building, Schafjückenweg 2, 26180 Rastede, Germany;
Website: https://www.cleverreach.com/de;
Privacy Policy: https://www.cleverreach.com/de/datenschutz/;
Data processing agreement: Concluded with the provider.

Web analysis, monitoring and optimization

Web analytics (also known as “reach measurement”) is used to evaluate visitor traffic to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. Reach analysis allows us to identify, for example, the time of day our online offering or its functions or content are most frequently used or encourage reuse. Likewise, we can understand which areas require optimization.

In addition to web analytics, we may also use testing procedures to, for example, test and optimize different versions of our online offering or its components.

For these purposes, so-called user profiles may be created and stored in a file (so-called “cookie”), or similar procedures may be used for the same purpose. This information may include, for example, content viewed, websites visited and elements used there, 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 depending on the provider.

Users’ IP addresses are also collected. However, we use an IP masking process (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no user data (such as email addresses or names) is stored for web analysis, A/B testing, and optimization; instead, pseudonyms are used. 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 purposes of the respective processes.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-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.

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 recurring visitors), tracking (e.g., interest-based/behavioral profiling, use of cookies), visitor action analysis, profiling (creation of user profiles).
Security measures: IP masking (pseudonymization of the IP address).
Legal basis: Consent (Art. 6 (1) (a) GDPR), Legitimate interests (Art. 6 (1) (f) GDPR).

Services and service providers used:

Google Analytics: We use Google Analytics to measure and analyze the use of our online offering based on a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analytics information to a device in order to identify which content users have accessed within one or more usage processes, which search terms they used, accessed these again, or interacted with our online offering. The time and duration of use are also stored, as are the sources of users who refer to our online offering and the technical aspects of their devices and browsers.
Pseudonymous profiles of users are created using information from the use of various devices, and cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics does provide rough geographic location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based counterparts). For EU data traffic, the IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. It is not logged, is not accessible, and is not used for any 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 basis: consent (Art. 6 (1) (a) GDPR); website: https://marketingplatform.google.com/intl/de/about/analytics/; security measures: IP masking (pseudonymization of the IP address); data protection declaration: https://policies.google.com/privacy; data processing agreement: https://business.safety.google/adsprocessorterms/; basis for third country transfers: Data Privacy Framework (DPF); Opt-out option: Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, settings for displaying advertisements: https://myadcenter.google.com/personalizationoff; further information: https://business.safety.google/adsservices/ (types of processing and data processed).
Google as the recipient of consent: The consent granted by users as part of a consent dialog (also known as “cookie opt-in/consent,” “cookie banner,” etc.) serves several purposes. Firstly, it helps us fulfill our obligation to obtain consent to the storage and retrieval of information on and from users’ devices (in accordance with the ePrivacy Directive). Secondly, it covers the processing of users’ personal data in accordance with data protection regulations. Furthermore, this consent also applies to Google, as the company is required by the Digital Markets Act to obtain consent for personalized services. Therefore, we share the status of consents granted by users with Google. Our consent management software informs Google whether consents have been granted or not. The goal is to ensure that users’ consents, whether granted or not, are taken into account when using Google Analytics and when integrating features and external services. This allows users’ consent and its revocation within the scope of Google Analytics and other Google services in our online offering to be dynamically adapted depending on user selection;
Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
Legal basis: Consent (Art. 6 (1) (a) GDPR);
Website: https://support.google.com/analytics/answer/9976101?hl=de;
Privacy policy: https://policies.google.com/privacy.
Google Tag Manager: Google Tag Manager is a solution that allows us to manage so-called website tags via an interface and thus integrate other services into our online offering (further information can be found in this privacy policy). Therefore, the Tag Manager itself (which implements the tags) does not create user profiles or store cookies. Google only receives the user’s IP address, which is necessary to run Google Tag Manager. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy;
Data processing agreement:
https://business.safety.google/adsprocessorterms;
Basis for third-country transfer: Data Privacy Framework, Standard Contractual Clauses (https://business.safety.google/adsprocessorterms);
Further information: https://privacy.google.com/businesses/adsservices (types of processing and data processed).

Onlinemarketing

We process personal data for online marketing purposes, 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 users’ potential interests, as well as the measurement of their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”), or similar processes are used to store user information relevant to the presentation of the aforementioned content. 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.

Users’ IP addresses are also collected. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, no user data (such as email addresses or names) is stored within the online marketing process, but rather pseudonyms. This means that neither we nor the providers of the online marketing process know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is generally stored in cookies or similar processes. These cookies can generally be read later on other websites that use the same online marketing process, analyzed for the purpose of displaying content, and supplemented with additional data and stored on the server of the online marketing process provider.

In exceptional cases, user data can be assigned to profiles. This is the case, for example, if the users are members of a social network whose online marketing process we use, and the network links the user profiles with the aforementioned information. Please note that users can enter into additional agreements with the providers, e.g., by consenting during registration.

We generally only receive access to summarized information about the success of our advertisements. However, we can use conversion tracking to determine which of our online marketing processes have led to a conversion, i.e., for example, the conclusion of a contract with us. Conversion tracking is used solely to analyze the success of our marketing efforts.

Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.

Types of data processed: Usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses), location data (information on the geographical location of a device or person).
Data subjects: Users (e.g., website visitors, users of online services), interested parties.
Purposes of processing: Tracking (e.g., interest-/behavior-based profiling, use of cookies), remarketing, visitor action analysis, interest-based and behavior-based marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g., access statistics, recognition of returning visitors), target group building (determination of target groups relevant for marketing purposes or other content delivery), cross-device tracking (cross-device processing of user data for marketing purposes).
Security measures: IP masking (pseudonymization of the IP address).
Legal basis: Consent (Art. 6 (1) (a) GDPR), Legitimate interests (Art. 6 (1) (f) GDPR).
Opt-out option: We refer to the privacy policy of the respective providers and the opt-out options specified for the providers (so-called “opt-out”). If no explicit opt-out option has been provided, you have the option of deactivating cookies in your browser settings. However, this may limit the functionality of our online offering. We therefore recommend the following opt-out options, which are summarized for each region:
a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://www.youradchoices.ca/choices.
c) USA: https://www.aboutads.info/choices.
d) Cross-regional: https://optout.aboutads.info.

Services and service providers used:

Google Ad Manager: We use the “Google Ad Manager” service to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.). Google Ad Manager is characterized by the fact that ads are displayed in real time based on the presumed interests of users. This allows us to show ads for our online offering to users who may have a potential interest in our offering or who have previously shown an interest in it, as well as to measure the success of the ads. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/; Data processing terms for Google advertising products: Information about the services, data processing terms between controllers and standard contractual clauses for third-country transfers of data: https://business.safety.google/adscontrollerterms; if Google acts as a processor, data processing terms for Google advertising products and standard contractual clauses for third-country transfers of data: https://business.safety.google/adsprocessorterms.
Google Ads and conversion measurement: Online marketing methods for placing content and ads within the service provider’s advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who are likely to be interested in the ads. We also measure the conversion of ads, i.e., whether users have used them as an opportunity to interact with the ads and use the advertised offers (so-called conversions). However, we only receive anonymous information and no personal information about individual users. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Legal basis: Consent (Art. 6 (1) (a) GDPR), Legitimate Interests (Art. 6 (1) (f) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: Types of processing and the data processed: https://business.safety.google/adsservices/; Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.

Presences in social networks (social media)

We maintain online presences within social networks and, in this context, process user data 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 could result in risks for users, for example, because it could make it more difficult to enforce users’ rights.

Furthermore, user data is generally processed within social networks for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of users. These user profiles can, in turn, be used, for example, to place advertisements within and outside the networks that presumably correspond to users’ interests. For these purposes, cookies are generally stored on users’ computers, in which the user behavior and interests are stored. Furthermore, user profiles can also store data independent of the devices used by users (especially if users are members of the respective platforms and are logged in to them).

For a detailed description of the respective processing methods and the opt-out options, please refer to the privacy policies 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 like to point out that these can be most effectively asserted with the providers. Only the providers have access to user data and can directly take appropriate measures and provide information. If you still need help, please contact us.

Types of data processed: Inventory data (e.g., names, addresses), contact data (e.g., email, 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, tracking (e.g., interest-/behavior-based profiling, use of cookies), remarketing, reach measurement (e.g., access statistics, recognition of returning visitors).
Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

Services and service providers used:

Instagram: Social network, enables sharing photos and videos, commenting on and favorite posts, sending messages, and subscribing to profiles and pages. Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR);
Website: https://www.instagram.com;
Privacy policy: https://privacycenter.instagram.com/policy/;
Basis for third-country transfers: Data Privacy Framework (DPF).
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 users use (e.g., IP addresses, operating system, browser type, language preferences, 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 called “Page Insights” to 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 specifically regulates the security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of those affected (i.e., users can, for example, submit information or deletion requests directly to Facebook). Users’ rights (in particular the right 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). Joint controllership is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, particularly with regard to the transmission 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 basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.facebook.com;
Privacy policy: https://www.facebook.com/privacy/policy/; Basis for third country transfers: Data Privacy Framework (DPF).
LinkedIn: Social Network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not further processing) of visitor data for the purpose of creating “Page Insights” (statistics) for our LinkedIn profiles.
This data includes information about the types of content users view or interact with, or the actions they take, as well as information about the devices users use (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 concluded a special agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum (the ‘Addendum’)”, https://legal.linkedin.com/pages-joint-controller-addendum), which specifically regulates the security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, direct requests for information or deletion to LinkedIn). Users’ rights (in particular the right to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint controllership is limited to the collection of data by and transmission 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 transmission of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR);
Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: Data Privacy Framework (DPF); Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
YouTube: Soziales Netzwerk und Videoplattform; Dienstanbieter: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland, Mutterunternehmen: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Datenschutzerklärung: https://policies.google.com/privacy; Widerspruchsmöglichkeit (Opt-Out): https://adssettings.google.com/authenticated; Grundlage Drittlandübermittlung: Data Privacy Framework.

Plugins and embedded functions and content

We integrate 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 include, for example, graphics, videos, social media buttons, and posts (hereinafter collectively referred to as “content”).

Integration always requires that the third-party providers of this content process the users’ IP address, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content or functions. We endeavor to only use content whose respective providers use the IP address solely 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. These “pixel tags” enable information such as visitor traffic on the pages of this website to be evaluated. 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, the time of visit, and other information about the use of our online services, as well as 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 consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-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.

Types of data processed: Usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses), location data (information on the geographical location of a device or person), content data (e.g., entries in online forms), inventory data (e.g., names, addresses), contact data (e.g., email, telephone numbers).
Data subjects: Users (e.g., website visitors, users of online services), communication partners.
Purposes of processing: Provision of our online offering and user-friendliness, provision of contractual services and customer service, contact inquiries and communication, tracking (e.g., interest-based/behavioral profiling, use of cookies), interest-based and behavioral marketing, profiling (creation of user profiles), security measures, administration and response to inquiries.
Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR), consent (Art. 6 (1) (a) GDPR), contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).

Eingesetzte Dienste und Diensteanbieter:

Google Maps: We integrate maps from the “Google Maps” service provided by Google. The data processed may include, in particular, users’ IP addresses and location data. Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Consent (Art. 6 (1) (a) GDPR); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF).
YouTube-Videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF); Possibility of objection (opt-out): Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff.

Deletion of data

The data we process will be deleted in accordance with legal requirements as soon as the consents permitted for processing are revoked or other permissions no longer apply (e.g., if the purpose for processing this data no longer applies or it is no longer required for that purpose).

If the data is not deleted because it is required for other legally permissible purposes, its processing will be limited to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons, or whose storage is necessary to assert, exercise, or defend legal claims or to protect the rights of another natural or legal person.

Further information on the deletion of personal data can also be found in the individual data protection notices of this privacy policy.

Changes and updates to the privacy policy

We ask you to inform yourself regularly about the content of our privacy policy. We will adapt this privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g., consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting us.

Rights of data subjects

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

Right of objection: You have the right to object at any time to the processing of personal data concerning you based on Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct marketing.
Right of withdrawal of consent: You have the right to withdraw consent at any time.
Right of information: You have the right to request confirmation as to whether the data in question is being processed and to receive information about this data, as well as further information and a copy of the data in accordance with the statutory requirements.
Right to rectification: You have the right to request the completion of the data concerning you or the rectification of inaccurate data concerning you in accordance with the statutory requirements.
Right to erasure and restriction of processing: You have the right, in accordance with the statutory provisions, to request that data concerning you be erased immediately or, alternatively, to request that processing of the data be restricted in accordance with the statutory provisions.
Right to data portability: You have the right to receive the data concerning you that you have provided to us in a structured, common, and machine-readable format, in accordance with the statutory provisions, or to request that it be transmitted to another controller.
Complaint to a supervisory authority: You also have the right, in accordance with the statutory provisions, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you believe that the processing of personal data concerning you violates the GDPR.

Definitions of terms

This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined primarily in Art. 4 GDPR. The legal definitions are binding. The following explanations, however, are primarily intended to facilitate understanding. The terms are sorted alphabetically.

Conversion tracking: “Conversion tracking” refers to a process that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user’s device within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, this allows us to track whether the ads we place on other websites were successful.
Credit report: Automated decisions are based on automatic data processing without human intervention (e.g., in the case of an automatic rejection of a purchase on account, an online credit application, or an online application process without any human intervention). Such automated decisions are only permissible under Art. 22 GDPR if the data subject consents, if they are necessary for the performance of a contract, or if national law permits these decisions.
Cross-device tracking: Cross-device tracking is a form of tracking in which user behavior and interest information is collected across devices in so-called profiles by assigning users an online identifier. This allows user information to be analyzed, usually for marketing purposes, regardless of the browser or device used (e.g., mobile phones or desktop computers). For most providers, the online identifier is not linked to clear data such as names, postal addresses, or email addresses.
IP masking: IP masking is 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 procedures, particularly in online marketing.
Interest-based and behavioral marketing: Interest-based and/or behavioral marketing is used when users’ potential interests in advertisements and other content are predetermined as precisely as possible. This is done based on information about their previous behavior (e.g., visiting and staying on certain websites, purchasing behavior, or interaction with other users), which is stored in a so-called profile. Cookies are typically used for these purposes.
Conversion measurement: Conversion measurement is a method used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user’s device within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to understand whether the ads we place on other websites were 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. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Profiling: “Profiling” refers to any form of automated processing of personal data consisting of the use of personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information concerning age, gender, location and movement data, interaction with websites and their content, purchasing behavior, and social interactions with other people) (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 known as web analytics) is used to evaluate visitor flows to 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, for example, determine when visitors visit their website and what content they are interested in. This allows them, for example, to better adapt the content of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis purposes to recognize returning visitors and thus obtain more precise analyses of the use of an online service.
Remarketing: “Remarketing” or “retargeting” refers to the practice of noting, for example, for advertising purposes, which products a user was interested in on a website in order to remind the user of these products on other websites, e.g., in advertisements.
Location data: Location data is generated when a mobile device (or another device with the technical requirements for location determination) connects to a cell tower, a Wi-Fi network, or similar technical intermediaries and location determination functions. Location data is used to indicate the geographically identifiable position on Earth of the respective device. Location data can be used, for example, to display map functions or other location-dependent information.
Tracking: The term ‘tracking’ is used when the behaviour of users can be traced across several online offers. As a rule, behavioural and interest information is stored in cookies or on the servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can then be used, for example, to display adverts to users that are likely to correspond to their interests.
Controller: ‘Controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Processing: ‘Processing’ means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and encompasses practically every handling of data, whether it is collecting, analysing, storing, transmitting or deleting.
Target group formation: Target group formation (or ‘custom audiences’) is when target groups are determined for advertising purposes, e.g. the display of adverts. For example, based on a user’s interest in certain products or topics on the internet, it can be concluded that this user is interested in adverts for similar products or the online shop in which they viewed the products.