Privacy Policy
preamble
With the following privacy policy, we would like to inform you about which types of your personal data (hereinafter also referred to as “data”) 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 providing 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 the “online offering”).
The terms used are not gender-specific.
As of October 8, 2023
Table of Contents
- preamble
- Person responsible
- Overview of processing
- Representative in the European Union
- Relevant legal bases
- Security measures
- Transmission of personal data
- International data transfers
- Rights of data subjects
- Use of cookies
- Business services
- Payment methods
- Provision of the online offer and web hosting
- Registration, login and user account
- Blogs and publication media
- Contact and inquiry management
- Web analysis, monitoring and optimization
- Customer reviews and rating processes
- Presences in social networks (social media)
- Plugins and embedded functions and content
Person responsible
Galaxy Belmondo 897 LLC
30 N Gould St Ste R
Sheridan, WY 82801
USA
E-mail address:
Info@ocean-view-consulting.com
Representative in the European Union
Overview of processing
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.
- Payment details.
- Contact details.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and procedural data.
- Event data (Facebook).
Categories of data subjects
- Customers.
- Interested parties.
- Communication partner.
- Users.
- Business and contractual partners.
Purposes of processing
- Provision of contractual services and fulfillment of contractual obligations.
- Contact requests and communication.
- Security measures.
- Reach measurement.
- Office and organizational procedures.
- Managing and responding to inquiries.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online offering and user-friendliness.
- Information technology infrastructure.
Relevant legal bases
Relevant legal bases under the GDPR: Below you will find an overview of the legal bases under the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases apply in individual cases, we will inform you of these in the privacy policy.
- Consent (Article 6 (1) (a) GDPR) – The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
- Contractual performance and pre-contractual inquiries (Article 6 (1) (b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.
- Legal obligation (Article 6 (1) (c) GDPR) – Processing is necessary to fulfill a legal obligation to which the controller is subject.
- Legitimate interests (Article 6 (1) (f) GDPR) – Processing is necessary to protect the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject which require protection of personal data prevail.
Security 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, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.
These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as the access, input, and transfer of data, ensuring its availability, and segregation. Furthermore, we have established procedures that ensure the exercise of data subjects’ rights, the deletion of data, and responses to data threats. Furthermore, we consider the protection of personal data right from the development and selection of hardware, software, and processes in accordance with the principle of data protection, through technology design, and through data protection-friendly default settings.
Transmission of personal data
As part of our processing of personal data, it may happen that the data is transmitted to or disclosed to other bodies, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.
International data transfers
Data processing in third countries: If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if the processing takes place as part of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers only take place if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 (2) (c) GDPR), express consent or in the case of contractually or legally required transfer (Art. 49 (1) GDPR). Otherwise, we will inform you of the basis for third-country transfers from the individual providers in the third country, with the adequacy decisions taking priority. Information on third country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de.
EU-US Trans-Atlantic Data Privacy Framework: Within the framework of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the level of data protection for certain US companies as secure within the framework of the adequacy decision of July 10, 2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). We inform you in our privacy policy which service providers we use are certified under the Data Privacy Framework.
Rights of data subjects
Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:
- Right of objection: You have the right to object at any time to the processing of personal data concerning you based on Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw consent 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 request 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 statutory provisions, to request that the data concerning you be completed or that inaccurate data concerning you be corrected.
- Right to erasure and restriction of processing: You have the right, in accordance with the statutory provisions, to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
- Right to data portability: You have the right to receive the data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transmitted to another controller.
- Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right 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 violates the provisions of the GDPR.
Use of cookies
Cookies are small text files or other storage devices that store information on end devices and read information from end devices. For example, they can store the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed, or the functions used in an online offering. Cookies can also be used for various purposes, such as ensuring the functionality, security, and convenience of online offerings, as well as creating analyses of visitor flows.
Notes on consent: We use cookies in accordance with legal regulations. We therefore obtain prior consent from users unless this is not required by law. Consent is not necessary in particular if the storage and reading of information, including cookies, is absolutely necessary in order to provide users with a telemedia service expressly requested by them (i.e. our online offering). Strictly necessary cookies generally include cookies with functions that serve to display and operate the online offering, load balancing, security, storing user preferences and selection options, or similar purposes related to providing the main and secondary functions of the online offering requested by users. Revocable consent is clearly communicated to users and contains information about the respective cookie usage.
Notes on data protection legal bases: The data protection legal basis on which we process users’ personal data with the help of 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 the commercial operation of our online offering and improving its usability) or, if this occurs as part of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We clarify the purposes for which we process cookies in the course of this data protection declaration or as part of our consent and processing procedures.
Storage period: With regard to the storage period, 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 offering and closed their device (e.g. browser or mobile application).
- Persistent cookies: Persistent cookies remain stored even after the device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected through cookies can be used to measure reach. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., when obtaining consent), users should assume that cookies are permanent and can be stored for up to two years.
General information on revocation and objection (so-called “opt-out”): Users can revoke their consent at any time and object to processing in accordance with legal requirements. To do so, users can, among other things, restrict the use of cookies in their browser settings (although this may also limit the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ .
- Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR). Consent (Art. 6 (1) (a) GDPR).
Further information on processing procedures, methods and services:
- Processing of cookie data based on consent: We use a cookie consent management procedure within which users’ consent to the use of cookies, or to the processing operations and providers named in the cookie consent management procedure, can be obtained, managed, and revoked by users. The declaration of consent is saved so that it does not have to be requested again and so that consent can be proven in accordance with legal obligations. Storage can be on the server side and/or in a cookie (so-called opt-in cookie or with the help of comparable technologies) in order to be able to assign consent to a user or their device. Subject to individual information about the providers of cookie management services, the following information applies: Consent can be stored for up to two years. A pseudonymous user identifier is created and stored along with the time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers), as well as the browser, system, and device used. Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Business services
We process data of our contractual and business partners, e.g., customers and interested parties (collectively referred to as “contractual partners”) within the framework of contractual and comparable legal relationships as well as related measures and within the framework of communication with the contractual partners (or pre-contractually), e.g., to answer inquiries.
We process this data to fulfill our contractual obligations. This includes, in particular, the obligation to provide the agreed services, any update obligations, and remedy in the event of warranty and other service disruptions. Furthermore, we process the data to protect our rights and for the purposes of the administrative tasks associated with these obligations, as well as company organization. Furthermore, we process the data based on our legitimate interests in proper and efficient business management and in security measures to protect our contractual partners and our business operations from misuse and the endangerment of their data, secrets, information, and rights (e.g., 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 pass on contractual partners’ data to third parties to the extent necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed of other forms of processing, e.g., for marketing purposes, in this privacy policy.
We will inform our contractual partners which data is required for the aforementioned purposes before or during data collection, e.g., in online forms, by special marking (e.g., colors) or symbols (e.g., asterisks or similar), or in person.
We delete the data after statutory warranty and similar obligations have expired, i.e. generally after four 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 balance sheets, annual financial statements, the work instructions necessary to understand these documents and other organizational documents and accounting documents, and six years for received commercial and business letters and reproductions of sent commercial and business letters. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, opening balance sheet, annual financial statements or 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.
To the extent that we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply to the relationship between 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. email, telephone numbers); contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
- Data subjects: customers; interested parties; business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; security measures; contact requests and communication; office and organizational procedures; administration and response to inquiries.
- Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Legal obligation (Art. 6 (1) (c) GDPR); Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Shop and e-commerce: We process our customers’ data to enable them to select, purchase, or order the selected products, goods, and related services, as well as to pay for and deliver them or execute them. If necessary to execute an order, we use service providers, in particular postal, forwarding, and shipping companies, to carry out the delivery or execution for our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such within the order or similar purchase process and includes the information needed for delivery, provision, and billing, as well as contact information for any follow-up questions. Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
Payment methods
Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the data subjects efficient and secure payment options and, in addition to banks and credit institutions, we use other service providers for this purpose (collectively “payment service providers”).
The data processed by the payment service providers includes inventory data such as name and address, bank details such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, amount, and recipient-related information. This information is required to process the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account- or credit card-related information, only information confirming or rejecting the payment. Under certain circumstances, the payment service providers may transmit the data to credit agencies. This transmission is for the purpose of identity and credit checks. For more information, please refer to the terms and conditions and the privacy policy of the payment service providers.
Payment transactions are subject to the terms and conditions and privacy policy of the respective payment service providers, which are available on the respective websites or transaction applications. We also refer to these for further information and to assert your rights of withdrawal, information, and other data subjects.
- 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 the contract, term, customer category); 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); contact data (e.g. email, telephone numbers).
- Data subjects: customers and interested parties.
- Purposes of processing: provision of contractual services and fulfillment of contractual obligations.
- Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
Further information on processing procedures, methods and services:
- Amazon Payments: Payment services (technical connection of online payment methods); Service provider: Amazon Payments Europe SCA, 38 avenue JF Kennedy, L-1855 Luxembourg; Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Website: https://pay.amazon.de/ . Privacy policy: https://pay.amazon.de/help/201212490 .
- American Express: Payment services (technical connection of online payment methods); Service provider: American Express Europe SA, Theodor-Heuss-Allee 112, 60486 Frankfurt am Main, Germany; Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Website: https://www.americanexpress.com/de . Privacy policy: https://www.americanexpress.com/de/legal/online-datenschutzerklarung.html .
- Apple Pay: Payment services (technical connection of online payment methods); Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Website: https://www.apple.com/de/apple-pay/ . Privacy policy: https://www.apple.com/legal/privacy/de-ww/ .
- Mastercard: Payment services (technical connection of online payment methods); Service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Website: https://www.mastercard.de/de-de.html . Privacy policy: https://www.mastercard.de/de-de/datenschutz.html .
- PayPal: Payment services (technical connection of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à rl et Cie, SCA, 22-24 Boulevard Royal, L-2449 Luxembourg; Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Website: https://www.paypal.com/de . Privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full .
- Stripe: Payment services (technical connection of online payment methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR); Website: https://stripe.com ; Privacy Policy: https://stripe.com/de/privacy . Basis for third-country transfer: EU-US Data Privacy Framework (DPF) .
- Visa: Payment services (technical connection of online payment methods); Service provider: Visa Europe Services Inc., London branch, 1 Sheldon Square, London W2 6TT, GB; Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Website: https://www.visa.de . Privacy policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html .
Provision of the online offer and web hosting
We process user data 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 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 information, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online services and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
- Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files.” Server log files may include the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. Server log files may be used for security purposes, e.g., to prevent server overload (particularly in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure server utilization and stability; legal basis: legitimate interests (Art. 6 (1) (f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that needs to be retained for evidentiary purposes will not be deleted until the incident in question has been finally resolved.
Registration, login and user account
Users can create a user account. During registration, users are provided with the required mandatory information and processed for the purpose of providing the user account based on contractual obligations. The processed data includes, in particular, login information (username, password, and an email address).
When you use our registration and login functions, as well as your user account, we store your IP address and the time of each user action. This storage is based on our legitimate interests and those of the users in protecting against misuse and other unauthorized use. This data is generally not shared with third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users may be informed by email about events relevant to their user account, such as technical changes.
- Types of data processed: Inventory data (e.g., names, addresses); contact data (e.g., email, telephone numbers); content data (e.g., entries in online forms); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; security measures; administration and response to inquiries; provision of our online offering and user-friendliness.
- Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Registration with pseudonyms: Users may use pseudonyms as usernames instead of real names; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
Blogs and publication media
We use blogs or similar means of online communication and publication (hereinafter “publication medium”). Readers’ data is processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers, or for security reasons. Furthermore, we refer to the information on the processing of visitors to our publication medium in this privacy policy.
- Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Feedback (e.g., collecting feedback via online form); Provision of our online offering and user-friendliness; Security measures; Administration and response to inquiries.
- Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Comments and posts: When users leave comments or other posts, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone leaves illegal content in comments or posts (insults, prohibited political propaganda, etc.). In this case, we ourselves may be held liable for the comment or post and are therefore interested in the identity of the author.
Furthermore, we reserve the right to process user information for the purpose of spam detection based on our legitimate interests.
On the same legal basis, we reserve the right to store users’ IP addresses for the duration of surveys and to use cookies to avoid multiple voting.
The personal information, any contact and website information, as well as the content information provided in comments and posts will be permanently stored by us until the user objects;
legal basis: legitimate interests (Art. 6 (1) (f) GDPR). - UpdraftPlus: Backup software and backup storage; Service provider: Simba Hosting Ltd., 11 Barringer Way, St. Neots, Cambs., PE19 1LW, GB; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://updraftplus.com/ . Privacy policy: https://updraftplus.com/data-protection-and-privacy-centre/ .
Contact and inquiry management
When you contact us (e.g. by post, contact form, email, telephone or via social media) as well as within the framework of existing user and business relationships, the information provided by the person making the inquiry will be processed to the extent necessary to answer the contact inquiries and any requested measures.
- Types of data processed: Contact data (e.g., email, telephone numbers); content data (e.g., entries in online forms); usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
- Data subjects: communication partners.
- Purposes of processing: Contact requests and communication; administration and response to inquiries; feedback (e.g., collecting feedback via online form). Provision of our online offering and user-friendliness.
- Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
Web analysis, monitoring and optimization
Web analytics (also known as “reach measurement”) is used to evaluate visitor traffic to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. Reach analysis allows us to determine, for example, when our online offering or its functions or content are most frequently used or encourage reuse. Likewise, we can understand which areas require optimization.
In addition to web analysis, we may also use testing procedures to, for example, test and optimize different versions of our online offering or its components.
Unless otherwise stated below, profiles, i.e., data summarized for a usage process, may be created for these purposes, and information may be stored in a browser or on a device and read from it. The information collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used, and information on usage times. If users have consented to the collection of their location data by us or by the providers of the services we use, location data may also be processed.
Users’ IP addresses are also stored. However, we use an IP masking process (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no user data (such as email addresses or names) is stored for web analysis, A/B testing, and optimization; instead, pseudonyms are used. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.
- 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 information, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g., access statistics, recognition of recurring visitors); profiles with user-related information (creation of user profiles); provision of our online offering and user-friendliness.
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Google Analytics 4: We use Google Analytics to measure and analyze the use of our online offering based on a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to a device in order to recognize which content users have accessed within one or more usage processes, which search terms they used, accessed these again, or interacted with our online offering. The time and duration of use are also stored, as are the sources of users who refer to our online offering and technical aspects of their devices and browsers. Pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used for this purpose. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics does provide rough geographic location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based counterparts). For EU data traffic, the IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. It is not logged, is not accessible, and is not used for any other purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/ ; Privacy policy: https://policies.google.com/privacy ; Data processing agreement: https://business.safety.google/adsprocessorterms/ ; Basis for third country transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses ( https://business.safety.google/adsprocessorterms ); Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de , Settings for displaying advertisements: https://adssettings.google.com/authenticated . Further information: https://business.safety.google/adsservices/ (types of processing and the data processed).
Customer reviews and rating processes
We participate in review and rating processes to evaluate, optimize, and promote our services. If users rate us via the participating rating platforms or processes or otherwise provide feedback, the general terms and conditions or terms of use and the privacy policy of the providers also apply. Typically, the rating also requires registration with the respective providers.
To ensure that the reviewers have actually used our services, we transmit, with the customer’s consent, the necessary data regarding the customer and the service used to the respective review platform (including name, email address, and order number or item number). This data is used solely to verify the user’s authenticity.
- Types of data processed: Contract data (e.g., subject matter of the contract, term, customer category); usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
- Data subjects: customers; users (e.g. website visitors, users of online services).
- Purposes of processing: Feedback (e.g., collecting feedback via online form). Marketing.
- Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
Presences in social networks (social media)
We maintain online presences within social networks and, in this context, process user data in order to communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This could pose risks for users, for example, because it could make it more difficult to enforce their rights.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of the users. These user profiles can then be used, for example, to place advertisements within and outside the networks that presumably correspond to the users’ interests. For these purposes, cookies are generally stored on users’ computers in which the user behavior and interests are stored. Furthermore, data can also be stored in the user profiles regardless of the devices used by the users (particularly if the users are members of the respective platforms and are logged in to them).
For a detailed description of the respective processing methods and the options for opting out, please refer to the privacy policies and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would like to point out that these can be most effectively asserted with the providers. Only the providers have access to the user data and can directly take appropriate measures and provide information. If you still need assistance, please contact us.
- Types of data processed: Contact data (e.g., email, telephone numbers); content data (e.g., entries in online forms); usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time information, 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 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.instagram.com . Privacy policy: https://instagram.com/about/legal/privacy .
- Facebook Pages: Profiles within the social network Facebook – We, together with Meta Platforms Ireland Limited, are responsible for collecting (but not further processing) data from visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content users view or interact with, or the actions they take (see “Things you and others do and provide” in the Facebook Data Policy: https://www.facebook.com/policy ), as well as information about the devices users use (e.g., IP addresses, operating system, browser type, language settings, cookie data; see “Device Information” in the Facebook Data Policy: https://www.facebook.com/policy ). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services called “Page Insights” to page operators so that they can gain insights into how people interact with their Pages and the content associated with them. We have concluded a special agreement with Facebook (“Information on Page Insights”, https://www.facebook.com/legal/terms/page_controller_addendum ), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of those affected (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular the right to information, deletion, objection and complaint to the responsible supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information on Page Insights” ( https://www.facebook.com/legal/terms/information_about_page_insights_data ); Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.facebook.com ; Privacy Policy: https://www.facebook.com/about/privacy ; Basis for third-country transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses ( https://www.facebook.com/legal/EU_data_transfer_addendum ). Further information: Joint Controller Agreement: https://www.facebook.com/legal/terms/information_about_page_insights_dataJoint controllership is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular the transmission of data to its parent company, Meta Platforms, Inc., in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.linkedin.com ; Privacy policy: https://www.linkedin.com/legal/privacy-policy ; Data processing agreement: https://legal.linkedin.com/dpa ; Basis for transfer to third countries: Standard contractual clauses ( https://legal.linkedin.com/dpa ). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out .
Plugins and embedded functions and content
We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may include, for example, graphics, videos, or city maps (hereinafter collectively referred to as “content”).
Integration always requires that the third-party providers of this content process the user’s IP address, as without the IP address they would not be able to send the content to their browser. The IP address is therefore required to display this content or functions. We endeavor 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. The “pixel tags” can be used to evaluate 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 offering, as well as be linked to such information from other sources.
- 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 information, identification numbers, consent status); inventory data (e.g., names, addresses); contact data (e.g., email, telephone numbers); content data (e.g., entries in online forms); Event data (Facebook) (“Event data” is data that can be transmitted by us to Facebook, for example via Facebook pixel (via apps or other means) and relates to people or their actions. The data includes, for example, information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.; the event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); event data does not contain the actual content (such as comments written), login information, or contact information (i.e., no names, email addresses, or phone numbers). Event data is deleted by Facebook after a maximum of two years, and the target groups created from it when our Facebook account is deleted.
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online services and user-friendliness.
- Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR). Consent (Art. 6 (1) (a) GDPR).
Further information on processing procedures, methods and services:
- Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offering that we retrieve from servers of other providers (e.g. function libraries that we use to display or user-friendliness our online offering). In doing so, the respective providers collect the IP address of the users and can process this for the purposes of transmitting the software to the user’s browser as well as for security purposes and to evaluate and optimize their offering. – We integrate software into our online offering that we retrieve from servers of other providers (e.g. function libraries that we use to display or user-friendliness our online offering). In doing so, the respective providers collect the IP address of the users and can process this for the purposes of transmitting the software to the user’s browser as well as for security purposes and to evaluate and optimize their offering; legal basis: legitimate interests (Art. 6 (1) (f) GDPR).
- Facebook plugins and content: Facebook social plugins and content – This can include, for example, content such as images, videos or texts and buttons that users can use to share content from this online offering within Facebook. The list and appearance of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/ – We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt during a transmission (but not the further processing) of “event data” that Facebook collects or receives during a transmission using the Facebook social plugins (and content embedding functions) that run on our online offering for the following purposes: a) displaying content and advertising information that corresponds to the presumed interests of users; b) delivering commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) Improving ad delivery and personalizing features and content (e.g., improving the recognition of which content or advertising information presumably corresponds to users’ interests). We have concluded a special agreement with Facebook (“Addendum for Controllers”, https://www.facebook.com/legal/controller_addendum ), which specifically regulates the security measures Facebook must observe ( https://www.facebook.com/legal/terms/data_security_terms ) and in which Facebook has agreed to fulfill the rights of those affected (i.e., users can, for example, direct information or deletion requests to Facebook). Note: If Facebook provides us with measurements, analyses and reports (which are aggregated, i.e. do not contain any information about individual users and are anonymous to us), this processing does not take place within the framework of joint controllership, but on the basis of a data processing agreement (“Data Processing Terms”, https://www.facebook.com/legal/terms/dataprocessing ), the “Data Security Terms” ( https://www.facebook.com/legal/terms/data_security_terms ) and, with regard to processing in the USA, on the basis of standard contractual clauses (“Facebook EU Data Transfer Addendum”, https://www.facebook.com/legal/EU_data_transfer_addendum ). The rights of users (in particular the right to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 (1) (a) GDPR); Website: https://www.facebook.com ; Privacy Policy: https://www.facebook.com/about/privacy . Basis for third-country transfer: EU-US Data Privacy Framework (DPF) .
- Google Fonts (provision on our own server): Provision of font files for the purpose of a user-friendly presentation of our online offering; Service provider: The Google Fonts are hosted on our server; no data is transmitted to Google; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
- YouTube videos: video content; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: legitimate interests (Art. 6 (1) (f) GDPR); website: https://www.youtube.com ; data protection declaration: https://policies.google.com/privacy ; basis for transfer to third countries: EU-US Data Privacy Framework (DPF) . Possibility of objection (opt-out): opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de , settings for the display of advertisements: https://adssettings.google.com/authenticated .
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