This privacy notice defines the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the associated websites, functions and contents as well as external online presences, e.g. our social media profiles (hereinafter jointly referred to as “online offer”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in art. 4 of the General Data Protection Regulation (GDPR).
22159 Hamburg, Germany
+49 (0) 1756614447
Types of data processed:
– Inventory data (e.g. names, addresses).
– Contact information (e.g. e-mail, telephone numbers).
– Content data (e.g. texts, photographs, videos).
– Usage data (e.g. websites visited, interest in content, access times).
– Meta/communication data (e.g. device information, IP addresses).
Categories of Data Subjects
Visitors and users of the online offer (hereinafter referred to as “users”).
Purpose of processing
– Provision of the online offer, its functions and contents.
– Answer contact requests and communicate with users.
– Security measures.
“Personal data” means any information relating to an identified or identifiable natural person (“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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“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; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
In accordance with art. 13 GDPR, we inform you of the legal basis of our data processing. If the legal basis is not mentioned in the privacy notice, the following applies: the legal basis for obtaining consents is art. 6 sec. 1 lit. a and art. 7 GDPR; the legal basis for processing for the performance of our services and performance of contractual measures as well as for answering inquiries is art. 6 sec. 1 lit. b GDPR; the legal basis for processing to fulfil our legal obligations is art. 6 sec. 1 lit. c GDPR, and the legal basis for processing to protect our legitimate interests is art. 6 sec. 1 lit. f GDPR. In the event that the vital interests of the data subject or another natural person require the processing of personal data, article 6(1)(d) GDPR serves as the legal basis.
Cooperation with Processors and Third Parties
If we disclose data to other persons and companies (processors or third parties) within the scope of our processing, transmit such data to them or otherwise grant them access to the data, this shall only take place on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers, is required for contract fulfilment pursuant to art. 6 sec. 1 lit. b GDPR) provided that you have expressed your consent, there is a legal obligation or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we appoint third parties with the processing of data on the basis of a contract, this processing shall be carried out according to art. 28 GDPR.
Transfers to Third Countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if the processing takes place in the context of the use of third-party services or disclosure or transfer of data to third parties, such processing shall be carried out only for the fulfilment of our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or leave the data in a third country only if the special requirements of art. 44 GDPR apply. For example, this means that processing is carried out on the basis of special guarantees, such as the officially recognised determination of a data protection level (e.g. for the USA by the “Privacy Shield”) or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).
Rights of Data Subjects
You have the right to request confirmation as to whether the data concerned is being processed and to request information about these data as well as further information and a copy of the data in accordance with art. 15 GDPR.
In accordance with article 16 GDPR, you have the right to request a rectification or correction of your personal data.
In accordance with art. 17 GDPR, you have the right to demand that relevant data be deleted immediately or, alternatively, to demand a restriction on the processing of the data in accordance with art. 18 GDPR.
You have the right to receive the personal data concerning you, which you have provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data has been provided.
In accordance with art. 77 GDPR, you also have the right to file a complaint with the competent supervisory authority.
Conditions for Consent
You have the right to withdraw consents pursuant to art. 7 sec. 3 GDPR with future effect.
Right to Object
You can object to the future processing of the data concerning you in accordance with art. 21 GDPR at any time. You may object in particular to the processing for direct marketing purposes.
Cookies and Right to Object in Direct Advertising
“Cookies” are small files that are stored on the user’s computer. Different data can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after visiting an online offer. Temporary cookies called also “session cookies” or “transient cookies” are cookies that are deleted after a user leaves an online offer and closes its browser. For example, the content of a shopping basket or a login status can be stored in such a cookie. Cookies are referred to as “permanent” or “persistent” if they are stored even after the browser is closed. For example, the login status can be saved when users visit a website after several days. Likewise, the interests of users used for marketing purposes may be stored in such a cookie. “Third-party cookies” are cookies that are offered by providers other than the person responsible for operating the online offer (otherwise they are referred to as “first-party cookies”).
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
Deletion of Data
In accordance with statutory requirements in Germany, records are kept for 6 years in accordance with § 257 (1) HGB (trading books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting documents etc.) and for 10 years in accordance with § 147 (1) AO (books, records, management reports, accounting documents, commercial and business letters, documents relevant for taxation etc.).
We use hosting services to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services that we use for the purpose of operating this online offer.
We or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure way according to art. 6 sec. 1 lit. f GDPR in conjunction with art. 28 GDPR.
Collection of Access Data and Log Files
We or our hosting provider collect the following data on the basis of our legitimate interests within the meaning of art. 6 sec. 1 lit. f. GDPR on each access to the server on which this service is located (so-called server log files). Access data includes the name of the accessed website, file, date and time of access, transferred data volume, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Log file information is stored for a maximum of 7 days for security reasons (e.g. to investigate misuse or fraud) and then deleted. Data whose further storage is required for evidentiary purposes are excluded from deletion until the respective incident has been clarified.
Administration, Financial Accounting, Office Organization, Contact Management
We process data within the framework of administrative tasks as well as the organisation of our company, financial accounting and compliance with legal obligations, such as archiving. We process the same data as part of the performance of our contractual services. The processing is performed according to art. 6 sec. 1 lit. c. GDPR and art. 6 sec. 1 lit. f. GDPR. Customers, prospects, business partners and website visitors are affected by the processing. The purpose of this processing is the administration, financial accounting, office organization and archiving of data. These are tasks which are needed for the maintenance of our business activities and the provision of our services. The deletion of the data with regard to contractual services and contractual communication corresponds to the information provided in these processing activities.
We disclose or transmit data to tax authorities and consultants, such as tax consultants or auditors.
Furthermore, we store information about suppliers, event organisers and other business partners on the basis of our business interests, e.g. for the purpose of establishing a contact at a later date. We store this data, which is mainly company-related, permanently.
When contacting us (e.g. via contact form, e-mail, telephone or social media), the user’s details are processed for processing the contact inquiry in accordance with art. 6 sec. 1 lit. b) GDPR. User information can be stored in a customer relationship management system (“CRM system”) or comparable system.
We delete requests if they are no longer necessary. We review this requirement every two years; the statutory obligations for archiving apply accordingly.
We have profiles in social networks and on platforms in order to communicate with active customers, interested parties and users and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and the data processing guidelines of their respective operators apply.
Integration of Third-party Services and Content
Within our online offer, we use content or services from third parties such as videos or fonts (hereinafter uniformly referred to as “content”).
This means that the third-party providers of this content receive the user’s IP address since they could not send the content to their browser without the IP address. Therefore, the IP address is required to display this content. We make every effort to use only content from providers who use the IP address only to deliver content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags can be used to evaluate information such as visitor traffic on the pages of this website. This pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring websites, visiting time and other information about the use of our online offer, as well as be linked to such information from other sources.
Facebook Social Plugins
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of art. 6 sec. 1 lit. f. GDPR), we use social plugins (“plugins”) of the social network www.facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The plugins can display interaction elements or content (e.g. videos, graphics or text) and are identified by one of the Facebook logos (white “f” on blue tile, the term “like” or a “thumbs up” sign) or are marked with the addition “Facebook Social Plugin”. The list and appearance of Facebook Social Plugins can be found here: https://developers.facebook.com/docs/plugins/.
Facebook is certified under the Privacy Shield Agreement and thus guarantees to comply with the GDPR (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
When users use a function of this online offer that contains such a plugin, their device establishes a direct connection to the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated into the online offer. The processed data can be used to create user profiles. Therefore, we have no influence on the amount of data Facebook collects with the help of this plugin and inform users according to our level of knowledge.
By integrating these plugins, Facebook receives information that a user has opened the corresponding page of the online offer. If the user is logged into Facebook, Facebook can assign the visit to its Facebook account. When users interact with the plugins, such as pressing the Like button or posting a comment, the information is sent directly from their device to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to obtain and store their IP address. According to Facebook, only anonymized IP addresses are stored in Germany.
The purpose and scope of the data collection and the processing and use of the data by Facebook, as well as the relevant rights and setting options for the protection of the users’ privacy can be found in Facebook’s privacy notice: https://www.facebook.com/about/privacy/.
If users are on Facebook and do not want Facebook to collect data about them via this online offer and link it to their membership data stored on Facebook, they must log out of Facebook before using our online offer and delete their cookies. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US page http://www.aboutads.info/choices/ or the EU page http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
Translation from German. In case of any controversy between the German and English version, the German version applies.