Zum Inhalt
Enquire now
Enquire now

Privacy Policy

LITTY HANDELSGESELLSCHAFT MBH 

INTRODUCTION

 

With the following Privacy Policy, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes and to what extent. This 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, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offering”).

Last updated: 11 September 2019

 

Controller

Marie-Therese Litty-Panitz
Litty Handelsgesellschaft mbH
Kaltenbacher Weg 12
83355 Grabenstätt

Authorised representatives: Richard Litty, Marie-Therese Litty-Panitz

Email address: marie.litty@tungsten.de

Legal notice: Https://tungsten.de/company/legal_notice

 

Overview of processing operations

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).

Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, curriculum vitae, certificates, as well as other information provided with regard to a specific position or voluntarily by applicants concerning their person or qualifications).

Content data (e.g. text entries, photographs, videos).

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).

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

Payment data (e.g. bank details, invoices, payment history).

 

Categories of data subjects

Applicants, business and contractual partners, interested parties, communication partners, customers, users (e.g. website visitors, users of online services).

 

Purposes of processing

  • Provision of our online offer and user friendliness.
  • Visitor action evaluation.
  • Application procedure (justification and possible subsequent implementation as well as possible subsequent termination of the employment relationship.).
  • Office and organisational procedures.
  • Direct marketing (e.g. by email or post).
  • Feedback (e.g. collecting feedback via online form).
  • Interest-based and behavioural marketing.
  • Contact enquiries and communication.
  • Conversion measurement (measuring the effectiveness of marketing measures).
  • Profiling (creating user profiles).
  • Remarketing.
  • Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Tracking (e.g. interest/behavioural profiling, use of cookies).
  • Contractual services and service.
  • Administration and response to enquiries.

 

Relevant legal bases

In the following, we share the legal bases of the General Data Protection Regulation (GDPR), on the basis of which we process personal data. Please note that in addition to the regulations of the GDPR, the national data protection regulations in your or our country of residence and domicile may apply.

  • Consent (Art. 6 (1) p. 1 lit. a GDPR) – The data subject has given their consent to the processing of personal data relating to them for a specific purpose or purposes.
  • Performance of a contract and pre-contractual enquiries (Art. 6 (1) p. 1 lit. b. GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures carried out at the data subject’s request.
  • Legal obligation (Art. 6 (1) p. 1 lit. c. GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 (1) p. 1 lit. f. GDPR) – Processing is necessary to protect the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
  • Art. 9 (1) p. 1 lit. b GDPR (application procedure as a pre-contractual or contractual relationship) (Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants so that the controller or the data subject can exercise the rights accruing to them under labour law and social security and social protection law and fulfil their obligations in this respect, the processing of this data is carried out pursuant to Art. 9 (2) lit. b. GDPR, in the case of the protection of vital interests of the applicants or other persons pursuant to Art. 9 (2) lit. c. GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s fitness for work, for medical diagnostics, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 (2) lit. h. GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 (2) lit. a. GDPR). – .

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

Security measures

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

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. We also have procedures in place to ensure the exercise of data subjects’ rights, the deletion of data and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

Shortening of the IP address: If it is possible for us to do so or if it is not necessary to store the IP address, we will shorten your IP address or have it shortened. In the case of IP address shortening, also known as “IP masking”, the last octet, i.e. the last two numbers of an IP address, are deleted (in this context, the IP address is an identifier individually assigned to an internet connection by the online access provider). 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): In order to protect your data transmitted via our online offer, we use SSL encryption. You can recognise such encrypted connections by the prefix https:// in the address line of your browser.

Transmission and disclosure of personal data

In the course of our processing of personal data, it may happen that the data is transferred to other bodies, companies, legally independent organisational units or persons or that it is disclosed to them. The 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 that are integrated into a website. In such cases, we observe 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 our organisation: We may transfer or provide access to personal data to other entities within our organisation. Where this transfer is for administrative purposes, the transfer of data is based on our legitimate business and commercial interests or is made where it is necessary for the performance of our contract-related obligations or where there is consent from the data subjects or legal permission.

Data processing in third countries

If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of using third-party services or disclosing or transferring data to other persons, entities or companies, this will only be done in accordance with legal requirements.

Subject to express consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognised level of data protection, which includes US processors certified under the “Privacy Shield”, or on the basis of special guarantees, such as contractual obligation through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 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 ).

Use of cookies

“Cookies” are small files that are stored on users’ devices. Cookies can be used to store various data. The information may include, for example, the language settings on a website, the login status, a shopping cart or where a video was watched.

Cookies are usually also used when a user’s interests or behaviour (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that corresponds to their potential interests. This procedure is also referred to as “tracking”, i.e. tracking the potential interests of users. We also include in the term cookies other technologies that perform the same functions as cookies (e.g. where user details are stored using pseudonymous online identifiers, also known as “user IDs”).

Insofar as we use cookies or “tracking” technologies, we will inform you separately in our Privacy Policy.

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

Revocation and objection (opt-out): Regardless of whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent you have given or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”).

You can initially declare your objection by means of your browser settings, e.g. by deactivating the use of cookies (whereby this may also restrict the functionality of our online offer).

An objection to the use of cookies for online marketing purposes can be declared by means of a variety of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/ or generally at http://optout.aboutads.info.

Processing of cookie data on the basis of consent:: Before we process or have processed data in the context of the use of cookies, we ask users for consent that can be revoked at any time. Before consent has been given, cookies are only used if they are necessary for the operation of our online offer. Their use is based on our interest and the interest of users in the expected functionality of our online offer.

  • Types of data processed: Usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal basis: Consent (Art. 6 (1) p. 1 lit. a GDPR), Legitimate interests (Art. 6 (1) p. 1 lit. f. GDPR).

Cookie settings:

Retrieve cookie settings again here

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”) 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 enquiries.

We process this data to fulfil our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as for business organisation. Within the framework of the applicable law, we only pass on contractual partners’ data to third parties to the extent that this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or with the consent of the contractual partners (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 further forms of processing, e.g. for marketing purposes, within the framework of this Privacy Policy.

We advise contractual partners which data is required for the aforementioned purposes before or in the course of data collection, e.g. in online forms, by means of special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.

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

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

Craft services: We process the data of our customers and clients (hereinafter uniformly referred to as "customers") in order to enable them to select, purchase or commission the selected services or works as well as associated activities as well as their payment and delivery or execution or performance.

The information required is identified as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for delivery and invoicing as well as contact information in order to be able to confer.

Further information on commercial services: We process the data of our customers and clients (hereinafter uniformly referred to as "customers") in order to enable them to select, purchase or commission the selected services or works as well as associated activities as well as their payment and delivery or execution or performance.

The information required 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 confer.

  • 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 contract, term, customer category).
  • Data subjects: Interested parties, business and contractual partners.
  • Purposes of processing: Contractual performance and service, contact requests and communication, office and organisational procedures, administration and response to enquiries.
  • Legal basis: Contractual performance and pre-contractual enquiries (Art. 6 (1) p. 1 lit. b. GDPR), Legal obligation (Art. 6 (1) p. 1 lit. c. GDPR), Legitimate interests (Art. 6 (1) p. 1 lit. f. GDPR).

Payment service provider

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

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

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

  • Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses)
  • Data subjects: Customers, interested parties.
  • Purposes of processing: Contractual services and service.
  • Legal bases: Contract performance and pre-contractual enquiries (Art. 6 (1) p. 1 lit. b. GDPR), Legitimate Interests (Art. 6 (1) p. 1 lit. f. GDPR).

Services used and service providers:

Making contact

When contacting us (e.g. via contact form, email, telephone or via social media), the information provided by the enquirer is processed to the extent necessary to respond to the contact requests and any measures requested.

Contact requests in the context of contractual or pre-contractual relationships are answered in order to fulfil our contractual obligations or to answer (pre)contractual requests and otherwise on the basis of legitimate interests in answering these requests.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. text entries, photographs, videos).
  • Data subjects: Communication partners.
  • Purposes of processing: Contact enquiries and communication.
  • Legal bases: Contract performance and pre-contractual enquiries (Art. 6 (1) p. 1 lit. b. GDPR), Legitimate Interests (Art. 6 (1) p. 1 lit. f. GDPR).

Provision of our online offer and web hosting

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

The data processed in the course of providing the hosting service may include all information relating to the users of our online service that is generated in the course of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

Email dispatch and hosting: The web hosting services we use also include the sending, receiving and storing of emails. For these purposes, the addresses of the recipients and senders as well as further information regarding email dispatch (e.g. the providers involved) and the contents of the respective emails are processed. The aforementioned data may also be processed for the purpose of recognising SPAM. Please note that emails on the internet are generally not sent in encrypted form. As a rule, emails are encrypted in transit, but (unless a so-called end-to-end encryption procedure 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 emails between the sender and the reception on our server.

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

The server log files may be used, on the one hand, for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilisation of the servers and their stability.

  • Types of data processed: Content data (e.g. text entries, photographs, videos). Usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Contractual services and service.
  • Legal basis: legitimate interests (Art. 6 (1) p. 1 lit. f. GDPR).

Services used and service providers:

Application procedure

The application procedure requires applicants to provide us with the data necessary for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the details provided there.

In principle, the required information includes personal information such as name, address, contact details and proof of the qualifications required for a position. Upon request, we will be happy to provide additional information about which details are required.

If provided, applicants can submit their applications to us using an online form. The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications by email. Please note that emails on the internet are generally not sent in encrypted form. As a rule, emails are encrypted in transit, but not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the application between the sender and the receipt on our server.

For the purposes of applicant search, submission of applications and selection of applicants, we may make use of third party applicant management or recruitment software and platforms and services, subject to legal requirements.

Applicants are welcome to contact us regarding the method of submission of the application or to send us the application by post.

Processing of special categories of data: Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants so that the controller or the data subject can exercise the rights accruing to them under labour law and social security and social protection law and fulfil their obligations in this respect, the processing of this data is carried out pursuant to Art. 9 (2) lit. b. GDPR, in the case of the protection of vital interests of the applicants or other persons pursuant to Art. 9 (2) lit. c. GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s fitness for work, for medical diagnostics, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 (2) lit. h. GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 (2) lit. a. GDPR).

Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is not successful, the applicants’ data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Subject to a justified revocation by the applicants, the deletion will take place at the latest after the expiry of a period of six months so that we can answer any follow-up questions about the application and fulfil our obligations to provide evidence under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements.

Inclusion in an applicant pool: Inclusion in an applicant pool, where offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the ongoing application process and that they can revoke their consent at any time for the future.

  • Types of data processed: Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, curriculum vitae, certificates, as well as other information provided with regard to a specific position or voluntarily by applicants concerning their person or qualifications).
  • Data subjects: Applicant.
  • Purposes of processing: Application procedure (justification and possible subsequent implementation as well as possible subsequent termination of the employment relationship.).
  • Legal basis: Art. 9 (1) p. 1 lit. b GDPR (application procedure as a pre-contractual or contractual relationship) (Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants so that the controller or the data subject can exercise the rights accruing to them under labour law and social security and social protection law and fulfil their obligations in this respect, their processing is carried out in accordance with Art. 9 (2) lit. b. GDPR, in the case of the protection of vital interests of the applicants or other persons pursuant to Art. 9 (2) lit. c. GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s fitness for work, for medical diagnostics, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 (2) lit. h. GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 (2) lit. a. GDPR)..

Newsletter and wide communication

We send newsletters, emails and other electronic notifications (hereinafter “newsletters”) only with the consent of the recipients or a legal permission. If the contents of a newsletter are specifically described in the context of a registration, they are decisive for the users’ consent. Apart from that, our newsletters contain information about our services and us.

In order 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 personal address in the newsletter, or further details, if these are necessary for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter is always carried out in a so-called double opt-in procedure. This means that after registration, you will receive an email in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other people’s email addresses. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored with the dispatch 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 to be able to prove consent previously given. The processing of this data is limited to the purpose of a possible defence against claims. An individual deletion request 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 email address in a blacklist 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 emails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Notes on legal basis: Newsletters are sent on the basis of the recipients’ consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and insofar as this is permitted by law, e.g. in the case of existing customer advertising. Insofar as we commission a service provider to send emails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to demonstrate that it has been carried out in accordance 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, phone numbers), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g. by email or post).
  • Legal basis: Consent (Art. 6 (1) p. 1 lit. a GDPR), Legitimate interests (Art. 6 (1) p. 1 lit. f. GDPR).
  • Option to object (opt-out): You can cancel 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 use one of the contact options given above, preferably email, for this purpose.

Promotional communication by post, fax or telephone

We process personal data for the purpose of promotional communication, which may take place via various channels, such as email, telephone, post or fax. In this context, we comply with legal requirements and obtain the necessary consents unless the communication is permitted by law.

Recipients have the right to revoke consents granted at any time or to object to the promotional communication at any time.

After revocation or objection, we may store the data required to prove consent for up to three years based on our legitimate interests before deleting it. The processing of this data is limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g. by email or post).
  • Legal basis: Consent (Art. 6 (1) p. 1 lit. a GDPR), Legitimate interests (Art. 6 (1) p. 1 lit. f. GDPR).

Online marketing

We process personal data for online marketing purposes, including but not limited to the display of promotional and other content (collectively, “content”) based on the potential interests of users and the measurement of its effectiveness.

For these purposes, so-called user profiles are created and stored in a file (a so-called “cookie”) or similar procedures are used, by means of which the information about the user relevant to the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed.

The IP addresses of users are also stored. However, we use IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no real user data (such as email addresses or names) are stored within the scope of our online marketing procedure, but pseudonyms instead. This means that we, as well as the providers of the online marketing procedures, do not know users’ actual identity, 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 generally also be read at a later time on other websites that use the same online marketing procedure and analysed for the purpose of displaying content. They can also be supplemented with further data and stored on the server of the online marketing procedure provider.

In exceptional cases, real data may be assigned to profiles. This is the case, for example, if users are members of a social network whose online marketing procedures we use and the network connects the users’ profiles in the aforementioned information. It should be noted that users can make additional agreements with providers, for instance by giving their consent as part of the registration process.

In principle, we only receive access to summarised information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e. to a conclusion of a contract with us, for example. The conversion measurement is used solely to analyse the success of our marketing initiatives.

Notes on legal basis: If we ask users for their consent to use third-party providers, with the legal basis for processing data being 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. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services), interested parties.
  • Purposes of processing: Tracking (e.g. interest/behavioural profiling, cookie use), remarketing, conversion tracking, interest-based and behavioural marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, returning visitor recognition).
  • Security measures: IP masking (pseudonymisation of the IP address).
  • Legal basis: Consent (Art. 6 (1) p. 1 lit. a GDPR), Legitimate interests (Art. 6 (1) p. 1 lit. f. GDPR).
  • Option to object (opt-out): We refer to the data protection notices of the respective providers and the objection options given for the providers (so-called \“opt-out\”). If no explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for the respective areas: a) Europe: https://www.youronlinechoices.eu.
    b) Canada: https://www.youradchoices.ca/choices.
    c) US: https://www.aboutads.info/choices.
    d) Cross-territorial: http://optout.aboutads.info.

Services used and service providers:

In addition to the settings in the cookie box, you can also prevent collection by Google Analytics here by clicking on the following link. An opt-out cookie will be set, which prevents the collection of your data when visiting this website:

Click here to be excluded from collection via Google Tag Manager.

Google AdWords and conversion measurement: We use the online marketing method Google “AdWords” to place ads in the Google advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. We also measure ad conversion. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page marked with a so-called “conversion tracking tag”. However, we ourselves do not receive any information with which users can be identified. 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; Privacy Shield (guaranteeing the level of data protection when processing data in the US): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.

Rating platforms

We participate in evaluation processes in order to evaluate, optimise and promote our services. If users rate us or otherwise provide feedback via the participating rating platforms or procedures, the General Terms and Conditions of Business or Use and the Privacy Policies of the providers also apply. As a rule, the rating also requires registration with the respective providers.

In order to ensure that the people who are giving ratings have actually used our services, we transmit, with our customers’ consent, the data required for this in terms of the customer and the service used to the respective rating platform (including name, email address and order number or item number). This data is used solely to verify the authenticity of the user.

Rating widget: We integrate so-called “rating widgets” into our online offer. A widget is a functional and content element integrated into our online offer that displays variable information. It may be displayed, for instance, in the form of a seal or comparable element, sometimes also called a “badge”. Here, the corresponding content of the widget is indeed displayed within our online offer, but it is retrieved at that moment from the servers of the respective widget provider. This is the only way to always show the current content, especially the current rating. For this purpose, a data connection must be established from the website accessed within our online offer to the widget provider’s server and the widget provider receives certain technical data (access data, including IP address), which are necessary so that the content of the widget can be delivered to the user’s browser.

Furthermore, the widget provider receives information that users have visited our online offer. This information may be stored in a cookie and used by the widget provider to identify which online services participating in the rating process have been visited by the user. The information may be stored in a user profile and used for advertising or market research purposes.

  • Types of data processed: Contractual data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Customers, users (e.g. website visitors, users of online services).
  • Purposes of processing: Feedback (e.g. collecting feedback via online form), reach measurement (e.g. access statistics, returning visitor recognition), conversion tracking, interest-based and behavioural marketing, profiling (creating user profiles).
  • Legal basis: Consent (Art. 6 (1) p. 1 lit. a GDPR), Legitimate interests (Art. 6 (1) p. 1 lit. f. GDPR).

Services used and service providers:

Presence in social networks

We maintain online presences within social networks in order to communicate with the users active there or to offer information about us there.

We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users’ rights. With regard to US providers that are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we point out that they thereby undertake to comply with EU data protection standards.

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

For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the Privacy Policies and information provided by the respective network operators.

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

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. text entries, photographs, videos), 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 communications, tracking (e.g. interest/behavioural profiling, cookie usage), remarketing.
  • Legal basis: legitimate interests (Art. 6 (1) p. 1 lit. f. GDPR).

Services used and service providers:

Plugins and embedded functions and content

We integrate functional and content elements into our online offer that are obtained from the respective providers’ servers (hereinafter referred to as “third-party providers”). These can be, for example, graphics, videos or social media buttons as well as posts (hereinafter uniformly referred to as “content”).

This integration always requires that the third-party providers of this content process the user’s IP address, as without the IP address they could not send the content to their browser. The IP address is thus required for the presentation of these contents or functions. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. These “pixel tags” can be used to analyse 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 contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as being linked to such information from other sources.

Notes on legal basis: If we ask users for their consent to use third-party providers, with the legal basis for processing data being 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. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness, contractual performance and service.
  • Legal basis: legitimate interests (Art. 6 (1) p. 1 lit. f. GDPR).

Services used and service providers:

  • Google Fonts: We integrate the fonts (\“Google Fonts\”) of the provider Google, whereby users’ data is used solely for the purpose of displaying the fonts in users’ browsers. The integration is based on our legitimate interests in the technically secure, maintenance-free and efficient use of fonts, their uniform display and taking into account possible licensing restrictions for their integration. 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://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the US): https://www.privacyshield.gov/participant?id=a2zt0000000TRkEAAW&status=Active.
  • Google Maps: We integrate the maps of the “Google Maps” service of the provider Google. The data processed may include, in particular, users’ IP addresses and location data, which, however, are not collected without their consent (usually executed within the framework of the settings of their mobile devices). 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://maps.google.de; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the US): https://www.privacyshield.gov/participant?id=a2zt0000000TRkEAAW&status=Active; Possibility of objection (opt-out): Opt-out plugin: http://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • ReCaptcha: We integrate the function “\ReCaptcha\” for bot recognition, e.g. when data is entered in online forms. Users’ behavioural data (e.g. mouse movements or queries) are evaluated in order to distinguish humans from bots. 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://www.google.com/recaptcha/; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the US): https://www.privacyshield.gov/participant?id=a2zt0000000TRkEAAW&status=Active; Possibility of objection (opt-out): Opt-out plugin: http://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • Borlabs cookie: This website uses a Borlabs cookie, which sets a technically necessary cookie (Borlabs cookie) to remember your cookie settings. A Borlabs cookie does not collect any personal data. The cookie (Borlabs cookie) stores the consent you gave when visiting our website. If you wish to revoke these consents, simply delete the cookie from your browser. When you then revisit the website, you will be asked for your cookie consent again.

Deletion of data

The data we process will be deleted in accordance with legal requirements as soon as their consents for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not necessary for the purpose).

If the data is not deleted because it is required for other, legally permissible purposes, their processing will be limited to these purposes. This means 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 defence of legal claims or for the protection of 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.

Amendment and updating of the Privacy Policy

We ask you to regularly inform yourself about the contents of our Privacy Policy. We adapt our Privacy Policy as soon as 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.

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 18 and 21 GDPR:

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to revoke consent: You have the right to revoke any consent given at any time.
  • Right to information: You have the right to request confirmation as to whether the data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: You have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be corrected.
  • Right to deletion and restriction of processing: In accordance with the legal requirements, you have the right to demand that data relating to you be deleted without delay or, alternatively, to demand a restriction of the processing of the data in accordance with the legal requirements.
  • Right to data portability: You have the right to receive data relating to you that you have provided to us in a structured, commonly used and machine-readable format, or to request that it be transferred to another controller, in accordance with the law.
  • Complaint to the supervisory authority: You also have the right, in accordance with the law, 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 consider that the processing of personal data concerning you infringes the GDPR.

Definitions of terms

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

  • Conversion tracking: “Conversion tracking” refers to a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on users’ devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we have placed on other websites have been successful.
  • IP masking: IP masking is a method of deleting the last octet, i.e. the last two numbers of an IP address, so that the IP address can no longer be used to uniquely identify a person. IP masking is thus a means of pseudonymising processing procedures, especially in online marketing.
  • Interest-based and behavioural marketing: Interest-based and/or behavioural marketing is when users’ potential interest in ads or other content are predetermined as accurately as possible. This is done on the basis of information about their previous behaviour (e.g. visiting certain websites and staying on them, buying behaviour or interaction with other users), which is stored in a so-called profile. Cookies are generally used for these purposes.
  • Conversion measurement: Conversion measurement is a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on users’ devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we have placed on other websites have been successful.
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiling: “Profiling” is any form of automated processing of personal data which consists of using that personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information relating to age, gender, location and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people) (e.g. interests in certain content or products, click behaviour 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 the flow of visitors to an online offering and may include visitors’ behaviour or interests in certain information, such as content on web pages. With the aid of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt their website content to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognise returning visitors and thus obtain more precise analyses of the usage of an online offering.
  • Remarketing: We speak of “remarketing” or “retargeting” when, for example, for advertising purposes, it is noted 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.
  • Tracking: “Tracking” is when user behaviour can be traced across several online services. As a rule, behavioural and interest information with regard to the online offerings used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can subsequently be used, for example, to display advertisements to users that are likely to correspond to their interests.
  • Controller A “controller” is the natural or legal person, public authority, agency or other body which alone, or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes practically any handling of data, be it collection, evaluation, storage, transmission or deletion.
Created with Datenschutz-Generator.de by Dr. jur. Thomas Schwenke