Data Protection

Privacy Policy

This privacy policy explains the nature, scope and purpose of the processing of personal data (hereinafter referred to as ‘data’) in connection with the provision of our services, as well as within our online platform and the associated websites, functions and content, and external online presences, such as z.B. our social media profiles (hereinafter collectively referred to as the ‘online service’). With regard to the terminology used, such as z.B. For the terms ‘processing’ and ‘controller’, please refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

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Data controller

www.miniSchoggi.ch
MiniSchoggi Ltd
Industriestrasse 20, 9300 Wittenbach
Email: info@minischoggi.ch
Tel: +41 (0)44 480 14 14
Managing Director: Thomas Ramseier
Link to the legal notice: https://www.minischoggi.ch/gb/module/dgtranslationall/urlstranslation?parent_rewrite=module%2Fdgtranslationall&rewrite=urlstranslation
Contact details for the Data Protection Officer: Thomas Ramseier, info@minischoggi.ch, 044 480 14 14, miniSchoggi GmbH, Industriestrasse 20, 9300 Wittenbach, Switzerland

Types of data processed

- Stock data (z.B., personal master data, names or addresses).
- Contact details (z.B., email, telephone numbers).
- Content data (z.B., text entries, photographs, videos).
- Usage data (z.B., websites visited, interest in content, times of access).
- Meta/communication data (z.B., device information, IP addresses).

Categories of data subjects

Visitors and users of the online service (hereinafter, we shall collectively refer to the data subjects as ‘users’).

Purpose of the processing

- To provide the online service, its functions and content.
- Responding to enquiries and communicating with users.
- Safety measures.
- Audience measurement/marketing

Terminology used

‘Personal data’ means any information relating to an identified or identifiable natural person (hereinafter referred to as the ‘data subject’); a natural person is regarded as identifiable if they 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 (z.B. (cookie) or by reference to one or more specific characteristics which reflect the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

‘Processing’ means any operation or set of operations which is carried out on personal data, whether or not by automated means. The term is broad and covers virtually any handling of data.

‘Pseudonymisation’ means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures that ensure the personal data is not attributed to an identified or identifiable natural person.

‘Profiling’ means any form of automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s work performance, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements of that natural person.

The term ‘controller’ refers to 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.

‘Data processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the data controller.

Relevant legal bases

In accordance with Article 13 of the GDPR, we hereby inform you of the legal bases for our data processing activities. For users within the scope of the General Data Protection Regulation (GDPR), d.h. With regard to the EU and the EEC, unless the legal basis is specified in the privacy policy, the following applies:
The legal basis for obtaining consent is Article 6(1)(a) and Article 7 of the GDPR;
The legal basis for processing data for the purpose of providing our services, carrying out contractual measures and responding to enquiries is Article 6(1)(b) of the GDPR;
The legal basis for processing data in order to fulfil our legal obligations is Article 6(1)(c) of the GDPR;
Where the processing of personal data is necessary to protect the vital interests of the data subject or of another natural person, Article 6(1)(d) of the GDPR serves as the legal basis.
The legal basis for the processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Article 6(1)(e) of the GDPR.
The legal basis for processing data to safeguard our legitimate interests is Article 6(1)(f) of the GDPR.
The processing of data for purposes other than those for which it was collected is governed by the provisions of Article 6(4) of the GDPR.
The processing of special categories of data (as defined in Article 9(1) of the GDPR) is governed by the provisions of Article 9(2) of the GDPR.

Security measures

In accordance with the statutory requirements, and taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk.

These measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, input of, and disclosure of the data, ensuring its availability and its segregation. Furthermore, we have established procedures to ensure that data subjects’ rights are upheld, that data is deleted and that we respond to any data breaches. Furthermore, we take the protection of personal data into account right from the development and selection of hardware, software and procedures, in accordance with the principle of data protection by design and by default.

Cooperation with data processors, joint controllers and third parties

Where, in the course of our data processing activities, we disclose data to other individuals and organisations (data processors, joint controllers or third parties), transfer it to them or otherwise grant them access to the data, this is done only on the basis of a legal authorisation (z.B. if the transfer of data to third parties, such as payment service providers, is necessary for the performance of the contract), users have given their consent, there is a legal obligation to do so, or on the basis of our legitimate interests (z.B. when using agents, web hosting providers, etc.).

Where we disclose or transfer data to other companies within our group, or otherwise grant them access to such data, this is done, in particular, for administrative purposes as a legitimate interest and, in addition, on a basis that complies with legal requirements.

Transfers to third countries

Where we process data in a third country (d.h. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation, or where this occurs in connection with the use of third-party services or the disclosure or transfer of data to other individuals or organisations, this shall only take place where it is necessary to fulfil our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to statutory or contractual authorisations, we shall only process or allow the data to be processed in a third country where the statutory requirements are met. D.h. processing takes place z.B. on the basis of specific safeguards, such as an officially recognised determination that a level of data protection equivalent to that of the EU has been achieved (z.B. (for the USA, through the ‘Privacy Shield’) or compliance with officially recognised specific contractual obligations.

Rights of data subjects

You have the right to request confirmation as to whether the data in question is being processed, and to request access to this data, as well as further information and a copy of the data, in accordance with the statutory requirements.

In accordance with the statutory provisions, you have the right to request that the data relating to you be completed or that any inaccurate data relating to you be rectified.

In accordance with the relevant legal provisions, you have the right to request that the data in question be erased without delay or, alternatively, to request that the processing of the data be restricted in accordance with the relevant legal provisions.

You have the right to request that the data relating to you, which you have provided to us, be made available to you in accordance with the statutory requirements, and to request that it be transferred to other data controllers.

You also have the right, in accordance with the relevant legal provisions, to lodge a complaint with the competent supervisory authority.

Right of withdrawal

You have the right to withdraw any consent you have given with effect for the future.

Right to object

You may object at any time to the future processing of your personal data in accordance with the statutory provisions. In particular, you may object to the processing of your data for the purposes of direct marketing.

Cookies and the right to object to direct marketing

‘Cookies’ are small files that are stored on users’ computers. Various types of information can be stored within cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit to a website. Temporary cookies, also known as ‘session cookies’ or ‘transient cookies’, are cookies that are deleted once a user leaves an online service and closes their browser. Such a cookie may z.B. the contents of a shopping basket in an online shop or a login status. Cookies that remain stored even after the browser has been closed are referred to as ‘permanent’ or ‘persistent’. This allows z.B. The login status is stored so that users can access the site again after several days. Similarly, such a cookie may store users’ interests, which are used for audience measurement or marketing purposes. ‘Third-party cookies’ are cookies provided by providers other than the controller operating the online service (whereas, if only the controller’s own cookies are used, these are referred to as ‘first-party cookies’).

We may use temporary and permanent cookies, and we provide further information on this in our privacy policy.

If users do not wish to have cookies stored on their computer, they are asked to disable the relevant option in their browser’s settings. Stored cookies can be deleted via the browser’s settings. Disabling cookies may result in some features of this website not working properly.

A general objection to the use of cookies for online marketing purposes can be lodged with a wide range of services – particularly in the case of tracking – via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/ explained. Furthermore, you can prevent cookies from being stored by disabling them in your browser settings. Please note that, in that case, you may not be able to use all the features of this website.

Deletion of data

The data we process will be deleted or its processing restricted in accordance with statutory requirements. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and there are no statutory retention obligations preventing its deletion.

Unless the data is deleted because it is required for other, legally permissible purposes, its processing will be restricted. D.h. The data will be blocked and will not be processed for any other purposes. This applies z.B. for data that must be retained for commercial or tax reasons.

Changes and updates to the privacy policy

We ask that you check the content of our privacy policy regularly. We will update the privacy policy as soon as changes to the data processing activities we carry out make this necessary. We will inform you as soon as the changes require any action on your part (z.B. consent) or any other individual notification is required.

Business-related processing

In addition, we process
- Contract details (z.B., subject matter of the contract, term, customer category).
- Payment details (z.B., bank details, payment history)
from our customers, prospective customers and business partners for the purposes of providing contractual services, customer care, marketing, advertising and market research.

Video and still images

The customer agrees that miniSchoggi may, during on-site courses and live online courses, take photographs and make video recordings of the customer and participants for whom the customer has made a booking or to whom the customer is transferring the booking, and that miniSchoggi may use these for advertising purposes, both itself and by passing them on to third parties and publishing them. This consent and the associated rights are valid indefinitely, both in terms of time and geographical scope, for both print and online use. The customer, as well as any participants for whom they have made a booking or to whom they are transferring the booking, have the option, prior to the start of the booked course, to declare in writing to miniSchoggi that they do not consent to the taking of photographs or video recordings of themselves or their images. Such declarations must be sent in writing to info@minischoggi.ch.

Order processing in the online shop and customer account

We process our customers’ data as part of the ordering process in our online shop to enable them to select and order the products and services of their choice, and to facilitate payment, delivery and fulfilment.

The data processed includes inventory data, communication data, contractual data and payment data; the data subjects affected by this processing include our customers, prospective customers and other business partners. The processing is carried out for the purpose of providing contractual services in connection with the operation of an online shop, billing, delivery and customer services. In doing so, we use session cookies to store the contents of the shopping basket and persistent cookies to store the login status.

Data is processed for the purpose of providing our services and carrying out contractual obligations (z.B. Processing of orders) and insofar as it is required by law (z.B., statutory archiving of business transactions for commercial and tax purposes). The information marked as required is necessary for the conclusion and performance of the contract. We only disclose data to third parties in connection with delivery, payment or in accordance with statutory permissions and obligations, as well as where this is based on our legitimate interests, about which we inform you in this privacy policy (z.B., including solicitors, tax advisers, financial institutions, freight forwarders and public authorities).

Users have the option of creating a user account, which allows them, in particular, to view their orders. During the registration process, users are informed of the required mandatory details. User accounts are not public and cannot be indexed by search engines. Once users have closed their user account, their data relating to that account will be deleted, unless retention is necessary for commercial or tax law reasons. Information in the customer account remains there until it is deleted, after which it is archived in the event of a legal obligation or to safeguard our legitimate interests (z.B., in the event of legal disputes). It is the responsibility of users to back up their data in the event of termination before the end of the contract.

When users register, log in again or use our online services, we store their IP address and the time of the respective user action. This data is stored on the basis of our legitimate interests, as well as the users’ interests in protection against misuse and other unauthorised use. As a general rule, this data is not disclosed to third parties, unless such disclosure is necessary to pursue our legal claims as a legitimate interest or there is a legal obligation to do so.

Deletion takes place once the statutory warranty period and any other contractual rights or obligations have expired (z.B., payment claims or obligations to perform under contracts with customers), with the necessity of retaining the data being reviewed every three years; where data is retained due to statutory archiving obligations, it is deleted once those obligations have expired.

Agency services

We process our customers’ data as part of our contractual services, which include conceptual and strategic consultancy, campaign planning, software and design development and consultancy or maintenance, the implementation of campaigns and processes, server administration, data analysis and consultancy services, and training services.

In doing so, we process inventory data (z.B., customer master data, such as names or addresses), contact details (z.B., email, telephone numbers), content data (z.B., text entries, photographs, videos), contract details (z.B., subject matter of the contract, term), payment details (z.B., bank details, payment history), usage and metadata (z.B. as part of the evaluation and performance measurement of marketing activities). As a general rule, we do not process special categories of personal data, unless these form part of commissioned processing. Data subjects include our customers, prospective customers and their own customers, users, website visitors or employees, as well as third parties. The purpose of the processing is to provide contractual services, carry out billing and deliver our customer service. The legal bases for processing are set out in Article 6(1)(b) of the GDPR (contractual services) and Article 6(1)(f) of the GDPR (analysis, statistics, optimisation, security measures). We process data that is necessary for the establishment and fulfilment of contractual services and indicate that the provision of such data is required. Disclosure to external parties takes place only where necessary within the scope of a contract. When processing data provided to us in the context of a contract, we act in accordance with the client’s instructions and the legal requirements for data processing on behalf of a client pursuant to Article 28 of the GDPR, and we do not process the data for any purposes other than those specified in the contract.

We delete the data once statutory warranty obligations and similar obligations have expired. The necessity of retaining the data is reviewed every three years; in the case of statutory archiving obligations, the data is deleted once these have expired (6 years, in accordance with Section 257(1) of the German Commercial Code (HGB), 10 years, in accordance with Section 147(1) of the German Fiscal Code (AO)). In the case of data disclosed to us by the client in the context of a contract, we shall delete the data in accordance with the terms of the contract, generally upon completion of the contract.

Contractual services

We process the data of our contractual partners and prospective clients, as well as other clients, customers, clients or contractual partners (collectively referred to as ‘contractual partners’) in accordance with Article 6(1)(b) GDPR, in order to provide our contractual or pre-contractual services to them. The data processed in this context, as well as the nature, scope, purpose and necessity of its processing, are determined by the underlying contractual relationship.

The data processed includes the master data of our contractual partners (z.B., names and addresses), contact details (z.B. email addresses and telephone numbers) and contract details (z.B., services used, contract details, contractual correspondence, names of contact persons) and payment details (z.B., bank details, payment history).

As a general rule, we do not process special categories of personal data, unless they form part of processing carried out on our behalf or in accordance with a contract.

We process data that is necessary for the establishment and fulfilment of contractual obligations and draw attention to the necessity of providing such data, unless this is already evident to the contracting parties. Data will only be disclosed to external individuals or organisations if this is required under the terms of a contract. When processing data entrusted to us in connection with a contract, we act in accordance with the client’s instructions and the relevant legal requirements.

When you use our online services, we may store the IP address and the time of the relevant user action. This data is stored on the basis of our legitimate interests, as well as the users’ interests in protection against misuse and other unauthorised use. As a general rule, this data is not disclosed to third parties, unless it is necessary for the pursuit of our claims in accordance with Article 6(1)(f) of the GDPR or there is a legal obligation to do so in accordance with Article 6(1)(c) of the GDPR.

Data will be deleted once it is no longer required for the fulfilment of contractual or statutory duties of care, or for dealing with any warranty or similar obligations, with the necessity of retaining the data being reviewed every three years; Otherwise, the statutory retention obligations apply.

External payment service providers

We use external payment service providers whose platforms enable both us and our users to carry out payment transactions (z.B., each with a link to the privacy policy, PayPal (https://www.paypal.com/de/webapps/mpp/ua/privacy-full), Klarna (https://www.klarna.com/de/datenschutz/), Skrill (https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/), Giropay (https://www.giropay.de/rechtliches/datenschutz-agb/), visas (https://www.visa.de/datenschutz), Mastercard (https://www.mastercard.de/de-de/datenschutz.html), American Express (https://www.americanexpress.com/de/content/privacy-policy-statement.html) and Postfinance (https://www.postfinance.ch/de/detail/rechtliches-barrierefreiheit.html) and Powerpay (https://www.powerpay.ch/de/datenschutz?ref=)

In the context of fulfilling contracts, we use payment service providers on the basis of Article 6(1)(b) of the GDPR. Furthermore, we use external payment service providers on the basis of our legitimate interests pursuant to Article 6(1)(f) of the GDPR in order to offer our users effective and secure payment options.

The data processed by payment service providers includes master data such as z.B. the name and address, bank details, such as z.B. Account numbers or credit card numbers, passwords, TANs and checksums, as well as details relating to the contract, the amount and the recipient. This information is required to carry out the transactions. However, the data entered is processed and stored solely by the payment service providers. D.h. We do not receive any account or credit card details, but only information confirming the payment or indicating that it has been declined. In some circumstances, the payment service providers may pass on the data to credit reference agencies. The purpose of this transfer is to verify identity and creditworthiness. In this regard, we refer you to the terms and conditions and privacy policies of the payment service providers.

Payment transactions are subject to the terms and conditions and privacy policies of the respective payment service providers, which are available on their respective websites or within the transaction applications. We also refer you to these for further information and for exercising your rights of withdrawal, access and other data subject rights.

Administration, financial accounting, office organisation, contact management

We process data in connection with administrative tasks, the organisation of our business, financial accounting and compliance with legal obligations, such as z.B. archiving. In this context, we process the same data that we process in the course of providing our contractual services. The legal bases for processing are Article 6(1)(c) of the GDPR and Article 6(1)(f) of the GDPR. This processing affects customers, prospective customers, business partners and website visitors. The purpose of, and our legitimate interest in, the processing lies in administration, financial accounting, office organisation and the archiving of data – in other words, tasks that serve to maintain our business operations, fulfil our responsibilities and provide our services. The erasure of data relating to contractual services and contractual communication is in accordance with the information provided in relation to these processing activities.

In this context, we disclose or transfer data to the tax authorities and advisers, such as z.B., tax advisers or auditors, as well as other fee-charging bodies and payment service providers.

Furthermore, in accordance with our commercial interests, we store information relating to suppliers, event organisers and other business partners, z.B. so that we can contact you at a later date. We generally store this data, most of which relates to companies, on a permanent basis.

Business Analysis and Market Research

In order to run our business efficiently and to identify market trends and the needs of our contractual partners and users, we analyse the data available to us relating to business transactions, contracts, enquiries, etc. In doing so, we process customer data, communication data, contractual data, payment data, usage data and metadata on the basis of Article 6(1)(f) of the GDPR, whereby the data subjects include contractual partners, prospective customers, customers, visitors and users of our online services.

The analyses are carried out for the purposes of business analysis, marketing and market research. In doing so, we may combine the profiles of registered users with information, z.B. regarding the services they have used. We use these analyses to improve user-friendliness, optimise our offering and enhance operational efficiency. The analyses are for our use only and are not disclosed externally, unless they are anonymous analyses containing aggregated data.

Where these analyses or profiles relate to specific individuals, they will be deleted or anonymised upon termination of the user’s account; otherwise, they will be deleted or anonymised two years after the conclusion of the contract. Furthermore, analyses of overall business performance and general trend assessments are carried out anonymously wherever possible.

Participation in affiliate programmes

Within our online services, we process data on the basis of our legitimate interests (d.h. In the interests of analysing, optimising and ensuring the cost-effective operation of our online service, we use industry-standard tracking measures in accordance with Article 6(1)(f) of the GDPR, insofar as these are necessary for the operation of the affiliate system. Below, we explain the technical background to users.

The services offered by our contractual partners may also be advertised and linked to on other websites (so-called affiliate links or after-purchase systems, if z.B. (links or third-party services offered after a contract has been concluded). The operators of the respective websites receive a commission if users follow the affiliate links and subsequently take up the offers.

In summary, it is necessary for our online service that we are able to track whether users who are interested in affiliate links and/or the offers available on our site subsequently take advantage of those offers as a result of the affiliate links or our online platform. To this end, the affiliate links and our offers are supplemented with certain identifiers, which form part of the link or are included in some other way, z.B. can be stored in a cookie. These values include, in particular, the referring website (referrer), the time, an online identifier for the operator of the website on which the affiliate link was located, an online identifier for the relevant offer, an online identifier for the user, as well as tracking-specific values such as z.B. Advertising material ID, partner ID and categorisations.

The online user identifiers we use are pseudonymous values. D.h. The online identifiers do not themselves contain any personal data such as names or email addresses. They merely help us to determine whether the same user who clicked on an affiliate link or expressed an interest in an offer via our website has actually taken up that offer, d.h. z.B. has entered into a contract with the provider. However, the online identifier is personal insofar as both the partner company and we have access to it, together with other user data. This is the only way the partner company can inform us whether that user has taken up the offer, and we z.B. can pay out the bonus.

Privacy Notice for the Recruitment Process

We process applicants’ data solely for the purposes of and within the scope of the recruitment process, in accordance with legal requirements. The processing of applicants’ data is carried out to fulfil our (pre-)contractual obligations as part of the recruitment process within the meaning of Article 6(1)(b) and Article 6(1)(f) of the GDPR, provided that the data processing z.B. if it becomes necessary for us in the context of legal proceedings (in Germany, Section 26 of the BDSG also applies).

The application process requires applicants to provide us with their application details. The necessary applicant details are indicated where we provide an online form; otherwise, they are set out in the job descriptions and generally include personal details, postal and contact addresses, and the documents required for the application, such as a covering letter, CV and certificates. In addition, applicants may voluntarily provide us with further information.

By submitting their application to us, applicants consent to the processing of their data for the purposes of the recruitment process in accordance with the manner and scope set out in this privacy policy.

Where, as part of the application process, special categories of personal data within the meaning of Article 9(1) of the GDPR are provided on a voluntary basis, their processing is also carried out in accordance with Article 9(2)(b) of the GDPR (z.B. Health data, such as z.B. (severe disability or ethnic origin). Where, as part of the recruitment process, applicants are asked to provide special categories of personal data within the meaning of Article 9(1) of the GDPR, the processing of such data is also carried out in accordance with Article 9(2)(a) of the GDPR (z.B. Health data, where this is necessary for the purposes of professional practice).

Where available, applicants can submit their applications to us via an online form on our website. The data is transmitted to us in encrypted form using state-of-the-art technology.
Furthermore, applicants may submit their applications to us by email. However, please note that emails are not encrypted by default and applicants must ensure encryption themselves. We are therefore unable to accept any responsibility for the transmission of the application between the sender and our server, and we therefore recommend using the online form or sending your application by post. This is because, as well as applying via the online form or by email, applicants still have the option of sending their application to us by post.

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 vacancy is unsuccessful, 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 valid withdrawal by the applicant, the data will be deleted after a period of six months has elapsed, so that we can answer any follow-up questions regarding the application and fulfil our obligations to provide evidence under the Equal Treatment Act. Invoices relating to any travel expense reimbursements are archived in accordance with tax regulations.

Registration function

Users can create a user account. During the registration process, users are informed of the required mandatory details, which are processed on the basis of Article 6(1)(b) of the GDPR for the purpose of providing the user account. The data processed includes, in particular, login details (name, password and an email address). The data entered during registration is used for the purposes of using the user account and for the purposes for which it was created.

Users can access information relevant to their user account, such as z.B. technical changes; users will be notified by email. Once users have cancelled their user account, their data relating to that account will be deleted, subject to any statutory retention obligations. It is the users’ responsibility to back up their data prior to the end of the contract period following cancellation. We are entitled to irrevocably delete all of the user’s data stored during the term of the contract.

When you use our registration and login functions, as well as when you use your user account, we store your IP address and the time of the respective user action. This data is stored on the basis of our legitimate interests, as well as the users’ interests in protection against misuse and other unauthorised use. This data is not, as a matter of principle, disclosed to third parties, unless this is necessary to pursue our claims or there is a legal obligation to do so in accordance with Article 6(1)(c) of the GDPR. IP addresses are anonymised or deleted after 7 days at the latest.

Comments and posts

When users leave comments or other posts, their IP addresses may be stored for 7 days on the basis of our legitimate interests within the meaning of Article 6(1)(f) of the GDPR. This is for our own protection in the event that someone posts unlawful content in comments or posts (insults, prohibited political propaganda, etc.). In such cases, we ourselves may be held liable for the comment or post and are therefore interested in the author’s identity.

Furthermore, we reserve the right to process users’ data for the purpose of spam detection on the basis of our legitimate interests pursuant to Article 6(1)(f) of the GDPR.

On the same legal basis, we reserve the right, in the case of surveys, to store users’ IP addresses for the duration of the survey and to use cookies to prevent multiple votes.

We store the personal information provided in comments and posts, any contact and website details, as well as the content of these posts, on a permanent basis until the user objects.

Comment subscriptions

Users may subscribe to follow-up comments with their consent in accordance with Article 6(1)(a) of the GDPR. Users will receive a confirmation email to verify that they are the owners of the email address provided. Users may unsubscribe from ongoing comment subscriptions at any time. The confirmation email will contain information on how to withdraw consent. For the purposes of providing evidence of the users’ consent, we store the time of registration together with the users’ IP address and delete this information when users unsubscribe.

You can cancel your subscription at any time, d.h. Withdraw your consent. We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them, in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of potentially defending against claims. An individual request for erasure may be made at any time, provided that the prior existence of consent is confirmed at the same time.

Getting in touch

When contacting us (z.B. (via the contact form, email, telephone or social media), the user’s details are processed for the purpose of handling the contact enquiry and its follow-up in accordance with Article 6(1)(b) (in the context of contractual or pre-contractual relationships), Article 6(1)(f) (other enquiries) of the GDPR. Users’ details may be stored in a customer relationship management system (“CRM system”) or a comparable enquiry management system.

We delete enquiries once they are no longer required. We review their necessity every two years; furthermore, statutory archiving obligations apply.

The newsletters are sent via the mailing service provider “MailChimp”, a newsletter distribution platform operated by the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view the mailing service provider’s privacy policy here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC, trading as MailChimp, is certified under the Privacy Shield Framework and thereby guarantees compliance with European data protection standards (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active). The delivery service provider is engaged on the basis of our legitimate interests pursuant to Article 6(1)(f) of the GDPR and a data processing agreement pursuant to Article 28(3), first sentence, of the GDPR.

The delivery service provider may process the recipients’ data in pseudonymous form, d.h. without linking it to a user, to optimise or improve our own services, z.B. to optimise the technical aspects of sending and displaying the newsletter, or for statistical purposes. However, the mailing service provider does not use the data of our newsletter subscribers to contact them directly or to pass the data on to third parties.

The newsletters contain what is known as a ‘web beacon’, d.h. A file the size of a single pixel, which is retrieved from our server – or, if we use a mailing service provider, from their server – when the newsletter is opened. When this file is retrieved, technical information – such as details about your browser and system, as well as your IP address and the time of retrieval – is collected.

This information is used to improve the services technically, based on technical data, or to analyse target groups and their reading behaviour based on their location (which can be determined using their IP address) or the times at which they access the site. Statistical analysis also includes determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be traced back to individual newsletter recipients. However, it is neither our intention, nor – where applicable – that of the mailing service provider, to monitor individual users. Rather, the analyses serve to help us identify our users’ reading habits and tailor our content accordingly, or to send different content based on our users’ interests.

Unfortunately, it is not possible to cancel the performance tracking separately; in this case, the entire newsletter subscription must be cancelled.

Web hosting and email delivery

The hosting services we use are intended to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, email delivery, security services and technical maintenance services, which we utilise for the purpose of operating this online service.

In this context, we – or our hosting provider – process personal details, contact details, content data, contractual data, usage data, meta and communication data relating to customers, prospective customers and visitors to this online service on the basis of our legitimate interests in providing this online service efficiently and securely, in accordance with Article 6(1)(f) of the GDPR i.V.m. Article 28 of the GDPR (Conclusion of a data processing agreement).

Collection of access data and log files

We, or rather our hosting provider, collect data on every access to the server on which this service is hosted (so-called server log files) on the basis of our legitimate interests within the meaning of Article 6(1)(f) of the GDPR. The access data includes the name of the webpage accessed, the file, the date and time of access, the amount of data transferred, confirmation of successful access, the browser type and version, the user’s operating system, the referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is collected for security reasons (z.B. (for the purpose of investigating cases of misuse or fraud) are stored for a maximum of 7 days and then deleted. Data which must be retained for evidential purposes are exempt from deletion until the incident in question has been fully resolved.

Google Tag Manager

Google Tag Manager is a solution that allows us to manage so-called website tags via a user interface (and thus z.B. (Integrating Google Analytics and other Google marketing services into our website). Tag Manager itself (which implements the tags) does not process any of users’ personal data. With regard to the processing of users’ personal data, please refer to the following information on Google’s services. Terms of Use: https://www.google.com/intl/de/tagmanager/use-policy.html.

Google Analytics

We process data on the basis of our legitimate interests (d.h. In order to analyse, optimise and ensure the cost-effective operation of our online service (within the meaning of Article 6(1)(f) of the GDPR), we use Google Analytics, a web analytics service provided by Google LLC (“Google”). Google uses cookies. The information generated by the cookie regarding users’ use of the online service is usually transmitted to a Google server in the USA and stored there.

Google is certified under the Privacy Shield Agreement and thereby guarantees compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Google will use this information on our behalf to analyse how users use our online service, to compile reports on activity within this online service, and to provide us with other services relating to the use of this online service and internet usage. In doing so, pseudonymous user profiles may be created from the processed data.

We only use Google Analytics with IP anonymisation enabled. This means that users’ IP addresses are truncated by Google within Member States of the European Union or in other States party to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and truncated there.

The IP address transmitted by the user’s browser is not combined with any other data held by Google. Users can prevent cookies from being stored by adjusting the settings in their browser software; users can also prevent Google from collecting the data generated by the cookie and relating to their use of the online service, as well as from processing this data, by downloading and installing the browser plug-in available via the following link:http://tools.google.com/dlpage/gaoptout?hl=de.

For further information on Google’s use of data, as well as options for adjusting settings and opting out, please refer to Google’s Privacy Policy (https://policies.google.com/technologies/ads) and in the settings for the display of adverts by Google (https://adssettings.google.com/authenticated).

Users’ personal data is deleted or anonymised after 14 months.

Google AdWords and Conversion Tracking

We process data on the basis of our legitimate interests (d.h. In the interests of analysing, optimising and ensuring the cost-effective operation of our online service (within the meaning of Article 6(1)(f) of the GDPR), we use the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (‘Google’).

Google is certified under the Privacy Shield Agreement and thereby guarantees compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

We use Google’s online marketing service ‘AdWords’ to place adverts on the Google Display Network (z.B., in search results, in videos, on websites, etc.), so that they are shown to users who are likely to be interested in the adverts. This enables us to display adverts for and within our online service in a more targeted manner, so as to present users only with adverts that potentially match their interests. If a user z.B. When adverts are displayed for products in which the user has shown an interest on other websites, this is referred to as ‘remarketing’. For these purposes, when you visit our website or other websites where the Google advertising network is active, a Google code is executed directly by Google, and so-called (re)marketing tags (invisible graphics or code, also known as ‘web beacons’) are embedded in the website. With the help of these, an individual cookie is placed on the user’s device, d.h. a small file is stored (comparable technologies may also be used instead of cookies). This file records which web pages the user has visited, what content they are interested in and which offers the user has clicked on, as well as technical information about the browser and operating system, referring web pages, the time of the visit and further details regarding the use of the online service.

We also receive an individual ‘conversion cookie’. Google uses the information collected via this cookie to compile conversion statistics for us. However, we are only provided with the anonymous total number of users who clicked on our advert and were redirected to a page tagged with a conversion tracking tag. We do not, however, receive any information that could be used to personally identify users.

User data is processed pseudonymously within the Google advertising network. D.h. Google stores and processes z.B. It does not process users’ names or email addresses, but instead processes the relevant data on a cookie-by-cookie basis within pseudonymous user profiles. D.h. From Google’s perspective, the adverts are not managed and displayed for a specifically identified individual, but for the cookie holder, regardless of who that cookie holder is. This does not apply if a user has expressly authorised Google to process the data without this pseudonymisation. The information collected about users is transmitted to Google and stored on Google’s servers in the USA.

For further information on Google’s use of data, as well as options for adjusting settings and opting out, please refer to Google’s Privacy Policy (https://policies.google.com/technologies/ads) and in the settings for the display of adverts by Google (https://adssettings.google.com/authenticated).

Facebook Pixel, Custom Audiences and Facebook Conversion

Within our online service, and in accordance with our legitimate interests in the analysis, optimisation and commercial operation of our online service, we use the so-called “Facebook Pixel” provided by the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), is used.

Facebook is certified under the Privacy Shield Agreement and thereby guarantees compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

With the help of the Facebook Pixel, Facebook is able, firstly, to identify visitors to our website as a target audience for the display of adverts (so-called ‘Facebook Ads’). Accordingly, we use the Facebook Pixel to ensure that the Facebook Ads we place are shown only to those Facebook users who have demonstrated an interest in our online offering or who share certain characteristics (z.B. who show an interest in specific topics or products, as determined by the websites they have visited), which we transmit to Facebook (so-called ‘Custom Audiences’). We also use the Facebook Pixel to ensure that our Facebook adverts are tailored to users’ potential interests and do not come across as intrusive. Furthermore, the Facebook Pixel enables us to track the effectiveness of Facebook adverts for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook advert (known as a ‘conversion’).

Facebook processes the data in accordance with its Data Use Policy. Accordingly, general information on the display of Facebook adverts can be found in Facebook’s Data Use Policy:https://www.facebook.com/policy. You can find specific information and details about the Facebook Pixel and how it works in the Facebook Help Centre: https://www.facebook.com/business/help/651294705016616.

You can object to the collection of data by the Facebook Pixel and the use of your data to display Facebook adverts. To control the types of adverts shown to you on Facebook, you can visit the page set up by Facebook and follow the instructions there regarding the settings for usage-based advertising:https://www.facebook.com/settings?tab=ads. The settings are platform-independent, d.h. They are applied to all devices, such as desktop computers or mobile devices.

You can also opt out of the use of cookies for audience measurement and advertising purposes via the Network Advertising Initiative’s opt-out page (http://optout.networkadvertising.org/) and, in addition, the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/) contradict.

Online presence on social media

We maintain an online presence on social media networks and platforms so that we can communicate with customers, prospective customers and users who are active on these platforms and keep them informed about our services.

We would like to point out that this may involve the processing of users’ data outside the European Union. This may entail risks for users, because z.B. this could make it more difficult to enforce users’ rights. With regard to US providers certified under the Privacy Shield, we would point out that they thereby undertake to comply with EU data protection standards.

Furthermore, users’ data is generally processed for market research and advertising purposes. This enables z.B. usage profiles are created based on users’ behaviour and their resulting interests. These usage profiles can in turn be used to z.B. To display advertisements both on and off the platforms that are presumed to match users’ interests. For these purposes, cookies are usually stored on users’ computers, in which their usage behaviour and interests are recorded. Furthermore, data may also be stored in user profiles regardless of the devices used by users (particularly if users are members of the respective platforms and are logged in to them).

The processing of users’ personal data is carried out on the basis of our legitimate interests in providing users with effective information and communicating with them, in accordance with Article 6(1)(f) of the GDPR. If users are asked by the respective providers to consent to the processing of their data (d.h. their consent z.B. (explained by ticking a box or clicking a button) the legal basis for the processing is Article 6(1)(a) and Article 7 of the GDPR.

For a detailed explanation of the respective processing activities and the options for objecting (opt-out), please refer to the information provided by the providers via the links below.

In the case of requests for information and the exercise of user rights, we would also like to point out that these can most effectively be exercised by contacting the service providers directly. Only the service providers have access to users’ data and can take appropriate action and provide information directly. Should you nevertheless require assistance, please do not hesitate to contact us.

- Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) - Privacy Policy: https://www.facebook.com/about/privacy/, Opt-out: https://www.facebook.com/settings?tab=ads andhttp://www.youronlinechoices.com, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.

- Google/YouTube (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – Privacy Policy:https://policies.google.com/privacy, Opt-out: https://adssettings.google.com/authenticated, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.

- Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – Privacy Policy / Opt-out: http://instagram.com/about/legal/privacy/.

- Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) - Privacy Policy: https://twitter.com/de/privacy, Opt-out: https://twitter.com/personalization, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.

- Pinterest (Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA) – Privacy policy / Opt-out: https://about.pinterest.com/de/privacy-policy.

- LinkedIn (LinkedIn Ireland Unlimited Company) Wilton Place, Dublin 2, Ireland) – Privacy Policy https://www.linkedin.com/legal/privacy-policy ,Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out, Privacy Shield:https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active.

- Xing (XING AG, Dammtorstraße 29–32, 20354 Hamburg, Germany) – Privacy policy / Opt-out: https://privacy.xing.com/de/datenschutzerklaerung.

- Wakalet (Wakelet Limited, 76 Quay Street, Manchester, M3 4PR, United Kingdom) - Privacy policy / Opt-out: https://wakelet.com/privacy.html.

- SoundCloud (SoundCloud Limited, Rheinsberger Str. 76/77, 10115 Berlin, Germany) - Privacy policy / Opt-out: https://soundcloud.com/pages/privacy.

Integration of third-party services and content

Within our online services, we rely on our legitimate interests (d.h. In the interests of analysing, optimising and ensuring the cost-effective operation of our online offering within the meaning of Article 6(1)(f) of the GDPR, we incorporate content or services from third-party providers in order to display their content and services, such as z.B. Embedding videos or fonts (hereinafter collectively referred to as “content”).

This always presupposes that the third-party providers of this content collect users’ IP addresses, as they would be unable to send the content to users’ browsers without them. The IP address is therefore necessary for the display of this content. We endeavour to use only such content where the respective providers use the IP address solely for the purpose of delivering the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as ‘web beacons’) for statistical or marketing purposes. These ‘pixel tags’ enable information, such as visitor traffic on the pages of this website, to be analysed. This pseudonymous information may also be stored in cookies on the user’s device and may include, amongst other things, technical information about the browser and operating system, referring websites, time of visit and further details regarding the use of our online service, as well as being linked to such information from other sources.

Vimeo

We can embed videos from the “Vimeo” platform, provided by Vimeo Inc., Attention: Legal Department, 555 West 18th Street, New York, New York 10011, USA. Privacy policy: https://vimeo.com/privacy. Please note that Vimeo may use Google Analytics; for further information, please refer to the privacy policy (https://policies.google.com/privacy) as well as opt-out options for Google Analytics (http://tools.google.com/dlpage/gaoptout?hl=de) or Google’s settings for the use of data for marketing purposes (https://adssettings.google.com/).

YouTube

We embed videos from the “YouTube” platform provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-out: https://adssettings.google.com/authenticated.

Google Fonts

We incorporate fonts (“Google Fonts”) provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-out: https://adssettings.google.com/authenticated.

Google reCAPTCHA

We are integrating the bot detection feature, z.B. when entering data into online forms (“ReCaptcha”) provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-out: https://adssettings.google.com/authenticated.

Google Maps

We incorporate maps from the “Google Maps” service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The data processed may include, in particular, users’ IP addresses and location data; however, this data is not collected without their consent (which is usually given via the settings on their mobile devices). The data may be processed in the USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-out: https://adssettings.google.com/authenticated.

Use of Facebook Social Plugins

We process data on the basis of our legitimate interests (d.h. In the interests of analysing, optimising and ensuring the cost-effective operation of our online service within the meaning of Article 6(1)(f) of the GDPR, social plugins (“plugins”) from the social network facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”).
To this end, you can z.B. This includes content such as images, videos or text, as well as buttons that allow users to share content from this website on Facebook. The list and appearance of the Facebook social plugins can be viewed here:https://developers.facebook.com/docs/plugins/.

Facebook is certified under the Privacy Shield Agreement and thereby guarantees compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

When a user accesses a feature of this online service that contains such a plug-in, their device establishes a direct connection to Facebook’s servers. The content of the plug-in is transmitted directly from Facebook to the user’s device and integrated into the online service. In the process, user profiles may be created from the data processed. We therefore have no influence over the scope of the data that Facebook collects via this plug-in and are therefore informing users in accordance with the information available to us.

By integrating the plugins, Facebook receives information that a user has accessed the relevant page of the website. If the user is logged into Facebook, Facebook can associate the visit with their Facebook account. When users interact with the plugins – for example, by clicking the ‘Like’ button or posting a comment – the relevant information is transmitted directly from their device to Facebook and stored there. Even if a user is not a member of Facebook, it is still possible for Facebook to obtain and store their IP address. According to Facebook, only an anonymised IP address is stored in Germany.

Users can find details of the purpose and scope of data collection, as well as the further processing and use of data by Facebook, and the relevant rights and settings options for protecting users’ privacy, in Facebook’s privacy policy:https://www.facebook.com/about/privacy/.

If a user is a Facebook member and does not wish Facebook to collect data about them via this website and link it to their membership data stored on Facebook, they must log out of Facebook and delete their cookies before using our website. Further settings and the option to object to the use of data for advertising purposes are available within the Facebook profile settings:https://www.facebook.com/settings?tab=ads or via the US websitehttp://www.aboutads.info/choices/ or the EU websitehttp://www.youronlinechoices.com/. The settings are platform-independent, d.h. They are applied to all devices, such as desktop computers or mobile devices.

Twitter

Our website may incorporate features and content from the Twitter service, provided by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. To this end, z.B. Content such as images, videos or text, as well as buttons that allow users to share content from this website on Twitter.
Provided that users are members of the Twitter platform, Twitter may track access to the o.g. Assign content and functions to users’ profiles on that platform. Twitter is certified under the Privacy Shield Agreement and thereby guarantees compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active). Privacy policy: https://twitter.com/de/privacy, Opt-out: https://twitter.com/personalization.

Instagram

Our online platform may incorporate features and content from the Instagram service, provided by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA. To this end, z.B. Content such as images, videos or text, as well as buttons that allow users to share content from this website on Instagram. Provided that users are members of the Instagram platform, Instagram may track access to the o.g. Assign content and features to users’ profiles on that platform. Instagram’s Privacy Policy: http://instagram.com/about/legal/privacy/.

Our website may incorporate features and content from the Pinterest service, provided by Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA. To this end, z.B. Content such as images, videos or text, as well as buttons that allow users to share content from this website on Pinterest. Provided that users are members of the Pinterest platform, Pinterest may track access to the o.g. Assign content and features to users’ profiles on that platform. Pinterest’s Privacy Policy: https://about.pinterest.com/de/privacy-policy.

We use the privacy-friendly “Shariff” buttons. “Shariff” was developed to enhance online privacy and replace the standard “Share” buttons used by social media platforms. In this process, it is not the user’s browser but the server hosting this website that establishes a connection with the server of the respective social media platforms and requests z.B. the number of likes, etc. The user remains anonymous. You can find more information about the Shariff project from the developers at c't magazine: www.ct.de.

Vouchers and special offers

As a thank you for placing orders, we offer you access to vouchers and special offers for shopping and purchasing other services from other online providers via Profity, a service provided by our partner adfocus GmbH, based in Zug, Switzerland. To provide you with this access, when you complete an order on our website, we integrate a corresponding notice from adfocus via an encrypted connection, whereby data – in particular your Internet Protocol (IP) address, which may constitute personal data – is exchanged with adfocus. Any personal data exchanged in this context is used exclusively to enable us to provide Profity on a permanent, secure and reliable basis (legal basis in accordance with the GDPR, where applicable: Article 6(1)(b) and (f) of the GDPR). Further details on the nature, scope and purpose of data processing can be found in Profity’s privacy policy. ss