Privacy information


Introduction

‍mySHOEFITTERis committed to protecting your data. With the following data protection information, 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 data protection information applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular in our mobile applications.

The controller for the processing of personal data pursuant to Art. 4 No. 7 DSGVO is:

mySHOEFITTER GmbH
Münsterstraße 5
59065 Hamm
Germany

Managing director authorized to represent the company:
Frederik Dürr

Phone: +49 (0) 2381 8775964
E-mail: info@myshoefitter.com

Processing overview

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
  • Contract data
  • Content data (e.g. entries in online forms).
  • Contact details (e.g. email, phone numbers).
  • Meta/communication data (e.g. device information, browser information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Service data in the web app and web store (e.g. video sequences and images of the right and left foot, calculated foot lengths and widths, session ID, shopping carts).


This data is stored in log files of our system. The aforementioned data is not stored together with other personal data.

It is necessary that our system temporarily stores the IP address so that delivery of the web app to your computer can take place. For the duration of the respective use of our web app, your IP address must remain stored for this purpose. The storage in log files therefore serves the functionality of the web app. In addition, we use this data to optimize our web app and secure our information technology systems. The data is not used for marketing purposes in this context. The legal basis for the temporary storage of the data and the log files is our legitimate interest pursuant to Art. 6 para. 1 p. 1 lit. f) of the German Data Protection Regulation (hereinafter: "DS-GVO").


If you are using our Services for your minor child, you must have appropriate lawful authorization to measure your child and provide us with the photo or video sequences of your child. By providing us with your child's data, you, as the authorized party, consent to us processing the personal data for the purpose of providing our Services.


Categories of affected persons

  • Customers.
  • Interested parties.
  • Communication partner.
  • Users.
  • Sweepstakes and Contest Entrants.
  • Business and Contractual Partners.
  • Participants.


Processing purposes

  • A/B testing.
  • Provision of our online offer and user-friendliness.
  • Conversion measurement.
  • Click tracking.
  • Direct marketing (e.g. by e-mail or postal mail).
  • Targeting.
  • Contact requests and communication.
  • Feedback.
  • Application Procedure.
  • Profiles with user-related information (creation of user profiles).
  • Information Technology Infrastructure.
  • Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Safety measures.
  • Tracking.
  • Conduct sweepstakes and contests.
  • Surveys and questionnaires (e.g., surveys with input options, multiple-choice questions).
  • Provision of contractual services and customer service.
  • Function and optimization of the web application.
  • Managing and responding to inquiries.
  • Preparation of studies and case studies.
  • Target group formation (determination of target groups relevant for marketing purposes or other output of content).


Applicable legal basis
Below you will find an overview of the legal basis of the GDPR on which we base the processing of personal data. Please note that in addition to the provisions of the GDPR, national data protection provisions of your or our country of residence or domicile may apply. Should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 (1) p. 1 lit. a. DSGVO) - The data subject has given his/her consent to the processing of personal data concerning him/her for a specific purpose or purposes.
  • Contract performance 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 a party or for the performance of pre-contractual measures taken at the data subject's request.
  • Legal obligation (Art. 6 para. 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, in particular where the data subject is a child.


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 (§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 to ensure a level of protection appropriate to the risk 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.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, transfer, safeguarding of availability and its separation. 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 bar 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. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we 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 group of companies: We may transfer personal data to other companies within our group of companies or grant them access to this data. Insofar as this transfer is for administrative purposes, the transfer of the data is based on our legitimate corporate and business interests or takes place insofar as it is necessary for the fulfillment of our contract-related obligations or if the consent of the data subjects or a legal permission exists.


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 is only done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we only process or allow data to be 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 to DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_d).


Cookies use

Cookies are small text files or other memory tags that store information on end devices and read information from the end devices. For example, to store the login status in a user account, a shopping cart content in an e-shop, the content accessed or functions used of an online offer. Cookies can also be used for various purposes, e.g. for purposes of functionality, security and convenience of online offers as well as the creation of analyses of visitor flows.

Consent notices: We use cookies in accordance with the law. Therefore, we obtain prior consent from users, except when it is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, are absolutely necessary to provide the telemedia service (i.e., our online offering) expressly requested by users. The strictly necessary cookies usually include cookies with functions related to the display and operability of the online offer , load balancing, security, storage of users' preferences and choices or similar purposes related to the provision of the main and secondary functions of the online offer requested by the users. The revocable consent will be clearly communicated to the users and will contain the information regarding the respective cookie use.

Notes on legal bases under data protection law: The legal basis under data protection law on which we process users' personal data using cookies depends on whether we ask users for 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 a business operation of our online offer and improvement of its usability) or, if this is done in the context 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 the cookies in the course of this privacy policy or as part of our consent and processing procedures.

Storage duration: In terms of storage duration, the following types of cookies 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 end device (e.g. browser or mobile app).

Permanent cookies: Permanent cookies remain stored even after the end 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, user data collected with the help of cookies can be used for reach measurement. 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 (so-called "opt-out"): Users can revoke the consent they have given at any time and object to processing in accordance with the legal requirements. Among other things, users can restrict the use of cookies in their browser settings (although this may also restrict the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.


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

Further guidance on processing operations, procedures and services:

Processing of cookie data on the basis of consent: We use a cookie consent management procedure, in the context of 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; legal basis: consent (Art. 6 para. 1 p. 1 lit. a) 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 in order to fulfill our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. In addition, we process the data to safeguard our rights and for the purpose of administrative tasks associated with these obligations and company organization. Furthermore, we process the data on the basis of our legitimate interests in proper and business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.

We inform the contractual partners which data are required for the aforementioned purposes before or in the course of 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., in principle 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. The statutory retention period is ten years for documents relevant under tax law as well as for commercial books, inventories, opening balances, annual financial statements, the work instructions required to understand these documents and other organizational documents and accounting records, and six years for received commercial and business letters and reproductions of sent commercial and business letters. The period shall commence at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was prepared, the commercial or business letter was received or sent, or the accounting document was created, furthermore the recording was made or the other documents were created.

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 shall apply in the relationship between the users and the providers.

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 and process data (e.g. IP addresses, time data, identification numbers, consent status).

Affected persons: Customers; prospective customers; business and contractual partners.

Purposes of processing: providing contractual services and customer service; security measures; contact requests and communications; office and organizational procedures; managing and responding to requests; conversion measurement (measuring the effectiveness of marketing activities); profiles with user-related information (creating user profiles).

Legal basis: Contract fulfillment and pre-contractual requests (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).


Further guidance on processing operations, procedures and services:

Customer account: Customers can create an account within our online offer (e.g. customer or user account, in short "customer account"). If registration of a customer account is required, customers 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. In the course of registration and subsequent logins and use of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove registration and prevent any misuse of the customer account. If the customer account has been terminated, the data of the customer account will be deleted after the termination date, unless they are kept for other purposes than the provision in the customer account or must be kept for legal reasons (e.g. internal storage of customer data, order transactions or invoices). It is the responsibility of the customers to secure their data upon termination of the customer account; legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Economic analyses and market research: For business reasons and in order to be able to recognize market trends, wishes of contractual partners and users, we analyze the data we have 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, if available, take into account the profiles of registered users together with their details, e.g. on services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarized, i.e. anonymized values. Furthermore, we take into account the privacy of users and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g., as summarized data); legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Offer of software and platform services: We process the data of our users, registered users and any test users (hereinafter uniformly referred to as "users") in order to be able to provide our contractual services to them as well as on the basis of legitimate interests in order to ensure the security of our offer and to be able to develop it further. The required information is identified as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGV


Provision of the online offer and web hosting

We process the users' data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or terminal device.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status); content data (e.g. entries in online forms).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.).); security measures.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).


Further guidance on processing operations, procedures and services:

  • Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called "web hoster"); Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
  • Collection of access data and log files: Access to our online offer is logged in the form of so-called "server log files". The server log files may include the address and name of the web pages and files accessed, the date and time of access, the 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; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data whose further storage is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.
  • E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage 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. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).


Registration, login and user account

Users can create a user account. In the course of registration, users are provided with the required mandatory data and processed for the purpose of providing the user account on the basis of contractual obligation fulfillment. The processed data includes in particular the login information (username, password and an e-mail address).

Within the scope 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 can be informed by e-mail about processes relevant to their user account, such as technical changes.

  • 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, management and response to requests.
  • Legal basis: Contract fulfillment and pre-contractual requests (Art. para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. para. 1 p. 1 lit. f. DSGVO).


Single sign-on login

Single sign-on" or "single sign-on logon or authentication" refers to procedures that allow users to log on to a provider of single sign-on procedures (e.g., a social network), including our online offering, with the aid of a user account. The prerequisite for single sign-on authentication is that users are registered with the respective single sign-on provider and enter the required access data in the online form provided for this purpose, or are already registered with the single sign-on provider and confirm the single sign-on registration via button.

Authentication takes place directly with the respective single sign-on provider. In the course of such authentication, we receive a user ID with the information that the user is logged in under this user ID at the respective single sign-on provider and an ID that cannot be used by us for other purposes (so-called "user handle"). Whether additional data is transmitted to us depends solely on the single sign-on procedure used, on the data releases selected as part of authentication and also on which data users have released in the privacy or other settings of the user account with the single sign-on provider. Depending on the single sign-on provider and the user's choice, this can be different data, usually the e-mail address and the user name. The password entered as part of the single sign-on procedure with the single sign-on provider is neither visible to us nor is it stored by us.

Users are asked to note that their details stored with us may be automatically matched with their user account with the single sign-on provider, but that this is not always possible or actually occurs. If, for example, the users' e-mail addresses change, they must change them manually in their user account with us.

We may use single sign-on login, if agreed with users, as part of or prior to contract performance, where users have been asked to do so, process it as part of consent, and otherwise use it based on the legitimate interests of us and the interests of users in an effective and secure login system.

Should users ever decide that they no longer wish to use the link of their user account with the single sign-on provider for the single sign-on procedure, they must remove this link within their user account with the single sign-on provider. If users wish to delete their data from us, they must cancel their registration with us.

Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).

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

Purposes of processing: provision of contractual services and customer service; security measures; registration procedures.

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


Contact

When contacting us (e.g. by contact form, e-mail, telephone or via social media), the information of the inquiring persons is processed insofar as this is necessary to answer the contact requests and any requested measures.

The response to contact requests in the context of contractual or pre-contractual relationships is made in order 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.

  • 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).
  • Affected persons: Communication partners.
  • Purposes of processing: contact requests and communication.
  • Legal basis: Contract fulfillment and pre-contractual requests (Art. para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art.para. 1 p. 1 lit. f. DSGVO).


Cloud services

We use software services accessible via the Internet and running on the servers of their providers (so-called "cloud services", also referred to as "software as a service") for the following purposes: document storage and management, calendar management, emailing, spreadsheets and presentations, sharing documents, content and information with specific recipients or publishing web pages, forms or other content and information, as well as chats and participation in audio and video conferences.

In this context, personal data may be processed and stored on the servers of the providers, insofar as these are part of communication processes with us or are otherwise processed by us as set out in the context of this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents. The cloud service providers also process usage data and metadata used by them for security purposes and service optimization.

If we use cloud services to provide forms or other documents and content to other users or publicly accessible websites, the providers may store cookies on users' devices for the purposes of web analytics or to remember users' settings (e.g., in the case of media control).

Notes on legal bases: If we ask for consent to use the cloud services, the legal basis of the processing is consent. Furthermore, their use may be a component of our (pre)contractual services, provided that the use of the cloud services has been agreed within this framework. Otherwise, the users' data is processed on the basis of our legitimate interests (i.e., interest in efficient and secure management and collaboration processes)

  • 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).
  • Affected persons: Customers, employees (e.g. employees, applicants, former employees), interested parties, communication partners.
  • Purposes of processing: office and organizational procedures.
  • Legal basis: Consent (Art. para. 1 p. 1 lit. a. DSGVO), Contract performance and pre-contractual requests (Art. para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. para. 1 p. 1 lit. f. DSGVO).


Web analysis, monitoring and optimization

Web analytics (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 require 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.

For these purposes, so-called user profiles may be created and stored in a file (so-called "cookie") or similar procedures may be used with 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.

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 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: Reach measurement (e.g. access statistics, recognition of returning visitors), profiles with user-related information (creation of user profiles), click tracking, A/B tests, feedback (e.g. collecting feedback via online form), heat maps (mouse movements on the part of users that are combined to form an overall picture.), surveys and questionnaires (e.g. surveys with input options, multiple choice questions), marketing.
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. para. 1 p. 1 lit. f. DSGVO).


Online Marketing

We process personal data for online marketing purposes, which may include, in particular, marketing advertising space or displaying promotional and other content (collectively, "Content") based on users' potential interests and measuring 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 for 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 the 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 user data (such as e-mail addresses or names) is stored as part 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 also 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 may be associated with the profiles. This is the case if, for example, the users are members of a social network whose online marketing procedures we use and the network links the users' profiles with the aforementioned data. We ask that you note that users can make additional agreements with the providers, e.g., by giving their 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 methods have led to a so-called conversion, i.e., for example, to a contract being concluded 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.


Promotional communication via e-mail, 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, mail or fax, in accordance with legal requirements.

Recipients have the right to revoke consent given at any time or to object to promotional communications at any time.

After revocation or objection, we store the data required to prove the previous authorization for contacting or sending for up to three years after the end of the year of revocation or objection based on our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. Based on the legitimate interest to permanently observe the revocation or objection of the users, we further store the data required to avoid a renewed contact (e.g., depending on the communication channel, the e-mail address, telephone number, name).


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

Affected persons: Communication partners.

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

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


Communication via messenger

We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, on encryption, on the use of the metadata of the communication and on your objection options.

You can also contact us by alternative means, e.g. via telephone or e-mail. Please use the contact options provided to you or the contact options specified within our online offer.

In the case of end-to-end encryption of content (i.e., the content of your message and attachments), please note that the communication content (i.e., the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use an up-to-date version of Messenger with encryption enabled to ensure that message content is encrypted.

However, we also point out to our communication partners that the providers of the messengers cannot view the content, but they can find out that and when communication partners communicate with us and that technical information about the device used by the communication partners and, depending on the settings of their device, also location information (so-called metadata) is processed.

Notes on legal basis: If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and they contact us on their own initiative, for example, we use Messenger in the relationship with our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners in communication via Messenger. Furthermore, we would like to point out that we do not transmit the contact data provided to us to the messengers for the first time without your consent.


Newsletter 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. Insofar as 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.

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 personal address in the newsletter, or further information, if this is necessary for the purposes of the newsletter.

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 event 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.

Contents:

Information about us, our services, promotions and offers.

Types of data processed: inventory data (e.g., names, addresses); contact data (e.g., email, phone numbers); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).

Affected persons: Communication partners.

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

Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).

Option to object (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.


Surveys and polls

We conduct surveys and interviews in order to collect information for the respective communicated survey or interview purpose. The surveys and questionnaires we conduct (hereinafter "surveys") are evaluated anonymously. Personal data is only processed insofar as this is necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address in order to display the survey in the user's browser or to enable the survey to be resumed with the aid of a cookie).


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 and procedural data (e.g. IP addresses, time data, identification numbers, consent status).

Affected persons: Communication partner; Participant.

Purposes of processing: feedback (e.g. collecting feedback via online form).

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

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, the data of the users within social networks is usually processed 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 may also be stored in the usage profiles irrespective of the devices used by the users (in particular 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 data protection declarations and information provided by the operators of the respective networks.
Also in the case of requests for information and the assertion of data subject rights, we 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 need help, 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 and process data (e.g. IP addresses, time data, identification numbers, consent status).
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 basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

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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 display of this content or function. 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, the time of visit and other information about the use of our online offer as well as be combined with such information from other sources.

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.


Management, organization and auxiliary tools

We use services, platforms and software from other providers (hereinafter referred to as "third-party providers") for the purposes of organizing, managing, planning and providing our services. When selecting third-party providers and their services, we observe the legal requirements.

In this context, personal data may be processed and stored on the servers of the third-party providers. This may involve various data that we process in accordance with this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents.

If users are referred to third-party providers or their software or platforms in the course of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimization or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.


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 and procedural data (e.g. IP addresses, time information, identification numbers, consent status).

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

Purposes of processing: contact requests and communication; provision of contractual services and customer service; office and organizational procedures.

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


Data deletion

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 required for the purpose).

If the data is not deleted because it is required for other and legally permissible purposes, its processing is limited to these purposes. I.e., 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 for the protection of the rights of another natural or legal person.

As part of our privacy notice, we may provide users with additional information regarding the deletion as well as the retention of data that is specific to each processing operation


Changes and update of the privacy policy

‍Weask you to regularly inform yourself about the content of our privacy policy. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this 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.

If we provide addresses and contact information of companies and organizations in this privacy statement, please note that the addresses may change over time and please 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 Art. bis 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 relating to you which is carried out on the basis of Art. 6. Paragraph 1 lit. e or f DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.
  • Right of revocation for consents: You have the right to revoke any consent you have given at any time.
  • Right of access: You have the right to request confirmation as to whether data in question is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the law, you have the right to request that data concerning you be completed or that inaccurate data concerning you be rectified.
  • Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data relating to you be erased immediately or, alternatively, to request restriction of the processing of the data in accordance with the law.
  • 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.


Status: July 2023

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