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Privacy policy

Introduction

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of our services and, in particular, on our websites, in mobile applications as well as within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offering”).

The terms used are not gender-specific.

Last updated: 22.02.2024

 

Outline

  • Introduction
  • Person in charge
  • Overview of processing operations
  • Relevant legal bases
  • Security Measures
  • Transfer of personal data
  • Data processing in third countries
  • Use of cookies
  • Business Services
  • Provision of the online offer and web hosting
  • Application Procedure
  • Newsletters and electronic notifications
  • Web Analysis, Monitoring and Optimization
  • Online Marketing
  • Presence in social networks (social media)
  • Plugins and embedded functions as well as content
  • Deletion of data
  • Changes and updates to the Privacy Policy
  • Rights of data subjects
  • Definitions

 

Person in charge

Green Game GmbH Atelierstr. 1081671 Munich

Authorized representatives: Marc Socher.

E-mail address: info@greengame.de.

Imprint: www.greengame.de/impressum/.

 

Overview of processing operations

The following table summarises the types of data processed and the purposes for which they are processed, and refers to the data subjects.

Types of data processed

  • Inventory data (e.g. names, addresses).
  • Applicant data (e.g. personal details, postal and contact addresses, the documents associated with the application and the information contained therein, such as cover letter, curriculum vitae, certificates and other information about the person or qualifications provided by applicants with regard to a specific position or voluntarily).
  • Content data (e.g. entries in online forms).
  • Contact details (e.g. e-mail, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Contract data (e.g. subject matter of the contract, duration, customer category).
  • Payment data (e.g. bank details, invoices, payment history).

 

Categories of data subjects

  • Applicant.
  • Business and contractual partners.
  • Interested parties.
  • Communication.
  • Customers.
  • Users (e.g. website visitors, users of online services).

 

Purposes of processing

  • Provision of our online offer and user-friendliness.
  • Conversion measurement (measuring the effectiveness of marketing efforts).
  • Application procedure (justification and possible subsequent implementation as well as possible later termination of the employment relationship).
  • Office and organizational procedures.
  • Direct marketing (e.g. by e-mail or post).
  • Feedback (e.g. collecting feedback via online form).
  • Marketing.
  • Contact requests and communication.
  • Profiles with user-related information (creating user profiles).
  • Remarketing.
  • Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Provision of contractual services and customer service.
  • Manage and respond to requests.
  • Target grouping (identification of relevant target groups for marketing purposes or other output of content).

 

Relevant legal bases

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

  • Consent (Art. 6 para. 1 sentence 1 lit. 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 for several specific purposes.
  • Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR) – The 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 (Art. 6 para. 1 sentence 1 lit. c. GDPR) – The processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR) – The processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
  • Application procedure as a pre-contractual or contractual relationship (Art. 9 para. 2 lit. b GDPR)  – Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants as part of the application process, so that the controller or the data subject can provide him or her with the benefits of labour law and social security law and social security law. rights arising from social protection and fulfils his or her obligations in this regard, their processing is carried out in accordance with Art. 9 (2) (b) GDPR, in the case of the protection of vital interests of applicants or other persons pursuant to Art. 9 (2) (c) GDPR or for the purposes of health care or occupational medicine, for the assessment of the employee’s ability to work,  for medical diagnostics, care or treatment in the health or social sector or for the administration of systems and services in the health or social sector in accordance with Art. 9 (2) (h) GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 (2) (a) GDPR.

 

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

 

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 organizational measures to ensure a level of protection appropriate to the risk.

The measures shall include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, availability and segregation of data. Furthermore, we have put in place procedures to ensure the exercise of data subject rights, the deletion of data and reactions to the risk of data being compromised. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes in accordance with the principle of data protection, through technical design and through privacy-friendly default settings.

Shortening of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not necessary, the IP address will be shortened (also referred to as “IP masking”). In this case, the last two digits, or the last part of the IP address, are removed after a period, or replaced by placeholders. The abbreviation of the IP address is intended to prevent or make it much more difficult to identify a person by his or her IP address.

SSL encryption (https): In order to protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

 

Transfer of personal data

In the course of our processing of personal data, it happens that the data is transmitted to other bodies, companies, legally independent organisational units or persons or that it is disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

Data transfer within the group of companies: We may transfer personal data to other companies within our group of companies or provide them with access to this data. Insofar as this disclosure takes place for administrative purposes, the disclosure of the data is based on our legitimate entrepreneurial and business interests or takes place insofar as it is necessary for the fulfilment of our contract-related obligations or if the consent of the data subject or legal permission has been obtained.

 

Data processing in third countries

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

Subject to explicit consent or contractually or legally required transfer, we process or have the data processed only in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

 

Use of cookies

Cookies are text files that contain data from websites or domains visited and are stored on the user’s computer by a browser. A cookie is primarily used to store information about a user during or after his visit within an online offer. The stored information may include, for example, the language settings on a website, the login status, a shopping cart or the place where a video was watched. The term “cookies” also includes other technologies that perform the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also referred to as “user IDs”)

A distinction is made between the following types of cookies and functions:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
  • Persistent cookies: Persistent cookies remain stored even after the browser 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, the interests of users used for reach measurement or marketing purposes may be stored in such a cookie.
  • First-party cookies: First-party cookies are set by ourselves.
  • Third-party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or strictly necessary) cookies: Cookies can be absolutely necessary for the operation of a website (e.g. to store logins or other user input or for security reasons).
  • Statistical, marketing and personalisation cookies: Furthermore, cookies are usually also used in the context of reach measurement and when a user’s interests or behaviour (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that corresponds to their potential interests. This method is also known as “tracking”, i.e. tracking the potential interests of users. If we use cookies or “tracking” technologies, we will inform you separately in our privacy policy or in the context of obtaining consent.

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

Storage period: Unless we provide you with explicit information on the storage period of permanent cookies (e.g. as part of a so-called cookie opt-in), please assume that the storage period can be up to two years.

General information on revocation and objection  (opt-out): Depending on whether the processing  is based on consent or legal permission, you have the option at any time to withdraw your consent or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can first declare your objection using the settings of your browser, e.g. by deactivating the use of cookies (whereby this may also limit the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further objection notices as part of the information on the service providers and cookies used.

Processing of cookie data on the basis of consent: We use a cookie consent management procedure within the framework of which the consent of users to the use of cookies, or the processing and providers mentioned in the context of the cookie consent management procedure, can be obtained, as well as managed and revoked by the users. In this case, the declaration of consent is stored so that it does not have to be requested again and in order to be able to prove the consent in accordance with the legal obligation. The data can be stored on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. In this case, a pseudonymous user identifier is formed and stored 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.

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

Services and service providers used:

 

Business Services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with the contractual partners (or pre-contractual), e.g. to answer enquiries.

We process this data in order to fulfil our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as the business organisation. Within the scope of applicable law, we only pass on the data of the contractual partners to third parties insofar as this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or is carried out with the consent of the data subjects (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners are informed about further forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.

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

We delete the data after expiry of statutory warranty and comparable obligations, i.e., generally after the expiry of 4 years, unless the data is stored in a customer account, e.g. as long as it must be stored for legal reasons of archiving (e.g. for tax purposes usually 10 years). We delete data that has been disclosed to us by the contractual partner in the context of an order in accordance with the specifications of the order, generally after the end of the order.

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

Consulting: We process the data of our clients, clients as well as interested parties and other clients or contractual partners (collectively referred to as “clients”) in order to be able to provide them with our consulting services. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship.

If it is necessary for the fulfilment of our contract, for the protection of vital interests or by law, or if the consent of the clients has been obtained, we disclose or transmit the data of the clients to third parties or agents, such as authorities, subcontractors or in the field of IT, office or comparable services, in compliance with the professional requirements.

Events and events: We process the data of the participants of the events, events and similar activities offered or hosted by us (hereinafter collectively referred to as “participants” and “events”) in order to enable them to participate in the events and to take advantage of the services or promotions associated with their participation.

Insofar as we process health-related, religious, political or other special categories of data in this context, then this is done within the scope of public knowledge (e.g. at thematically oriented events or serves health care, safety or takes place with the consent of the data subject).

The required information is marked as such in the context of the conclusion of the order, order or comparable contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations. Insofar as we have access to information from end customers, employees or other persons, we process it in accordance with legal and contractual requirements.

  • Types of data processed: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of the contract, duration, customer category).
  • Data subjects: interested parties, business and contractual partners, customers.
  • Purposes of processing: Provision of contractual services and customer service, contact requests and communication, office and organizational procedures, management and response to requests.
  • Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR  ), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

 

Provision of the online offer and web hosting

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

The data processed in the context of the provision of the hosting offer may include all information concerning the users of our online offer that arises in the context of use and communication. This usually includes the IP address, which is necessary to be able to deliver the content of online offers to browsers, and all entries made within our online offer or from websites.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on each access to the server (so-called server log files). The server log files may include the address and name of the websites and files accessed, date and time of access, data volumes transferred, notification of successful retrieval, 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.

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

  • Types of data processed: Content data (e.g. entries in online forms), usage data (e.g.  websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

 

Services and service providers used:

  • Server professionals: services  in the field of provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider:
    Serverprofis GmbH representing the managing directors Maximilian Cerveny, Martin Müller, Andreas Rademacher

Mondstraße 2-4

85622 Feldkirchen

Germany; Website: https://www.serverprofis.de/Datenschutzerklärung: https://www.serverprofis.de/datenschutz/

 

Application Procedure

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

Basically, the required information includes information about the person, such as name, address, a contact option and proof of the qualifications necessary for a job. On request, we will also be happy to provide you with information that is required.

If provided, applicants can submit their applications to us using an online form. The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications via e-mail. However, please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received. Therefore, we cannot assume any responsibility for the transmission path of the application between the sender and the receipt on our server.

For the purposes of searching for applicants, submitting applications and selecting applicants, we may make use of applicant management or recruitment software and platforms and services of third-party providers in compliance with the legal requirements.

Applicants are welcome to contact us about the method of submitting the application or send us the application by post.

Processing of special categories of data:  Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants in the context of the application process, so that the controller or the data subject can exercise the rights arising from labour law and social security and social protection law and to exercise his or her rights under labour law and social security and social protection law.  can fulfil its obligations in this regard, their processing is carried out in accordance with Art. 9 (2) (b) GDPR, in the case of the protection of vital interests of applicants or other persons pursuant to Art. 9 (2) (c) GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnostics, for care or treatment in the health or social sector or for the administration of systems and Services in the health or social sector in accordance with Art. 9 (2) (h) GDPR. In the case of a notification of the special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 (2) (a) GDPR.

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

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

  • Types of data processed: Applicant data (e.g. personal details, postal and contact addresses, the documents associated with the application and the information contained therein, such as cover letter, curriculum vitae, certificates and other personal or qualification information provided by applicants with regard to a specific position or voluntarily).
  • Data subjects: Applicants.
  • Purposes of processing: Application procedure (justification and possible subsequent implementation as well as possible subsequent termination of the employment relationship).
  • Legal basis: Application procedure as a pre-contractual or contractual relationship (Art. 9 para. 2 lit. b GDPR).

 

Newsletters and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter referred to as “newsletters”) only with the consent of the recipients or a legal permission. Insofar as the contents of the newsletter are specifically described as part of a subscription, they are decisive for the consent of the user. In addition, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to enter your e-mail address. However, we may ask you to provide a name for the purpose of addressing you personally in the newsletter or other information if this is necessary for the purposes of the newsletter.

Double opt-in procedure:  Registration for our newsletter is generally carried out in a so-called double opt-in procedure, i.e. you will receive an e-mail after registration in which you will be asked to confirm your registration. This confirmation is necessary so that no one can log in with someone else’s email addresses. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider will also be logged.

Deletion and restriction of processing:  We may store the 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 a previously given consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe contradictions, we reserve the right to store the e-mail address in a blacklist (so-called “blocklist”) solely for this purpose.

The registration process is logged on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system.

Notes on legal bases: The newsletter is sent on the basis of the consent of the  recipients or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of existing customer advertising. To the extent that we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration procedure is recorded on the basis of our legitimate interests to prove that it has been carried out in accordance with the law.

Contents: Information about us, our services, promotions and offers.

Measurement of opening and click-through rates: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server or, if we use a mailing service provider, from its server when the newsletter is opened. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of access, is first collected.

This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behavior on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. The evaluations serve us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The measurement of the opening rates and the click rates as well as the storage of the measurement results in the profiles of the users as well as their further processing are carried out on the basis of the user’s consent.

Unfortunately, it is not possible to revoke the performance measurement separately, in which case the entire newsletter subscription must be cancelled or objected to. In this case, the saved profile information will be deleted.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g. by e-mail or post).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit.  a. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
  • Opt-out: You can cancel your subscription to our newsletter at any time, i.e. revoke your consent or object to further receipt. You will either find a link to unsubscribe from the newsletter at the end of each newsletter or you can use one of the contact options listed above, preferably e-mail.

 

Web Analysis, Monitoring and Optimization

Web analysis (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the reach analysis, we can, for example, identify at what time our online offer or its functions or content are most frequently used or invite them to reuse. We can also understand which areas need to be optimized.

In addition to web analysis, we can also use test procedures, e.g. to test and optimize different versions of our online offer or its components.

For these purposes, so-called user profiles can be created and stored in a file (so-called “cookie”) or similar processes with the same purpose can be used. This information may include, for example, content viewed, websites visited and elements used there, and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed, depending on the provider.

The IP addresses of the users are also stored. However, we use an IP masking process (i.e., pseudonymization by shortening the IP address) to protect users. In general, in the context of web analysis, A/B testing and optimization, no clear user data (such as e-mail addresses or names) is stored, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, the user’s data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economical and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors), profiles with user-related information (creation of user profiles).
  • Security measures: IP  masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit.  a. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

 

Services and service providers used:

  • Google Analytics: reach measurement and web analytics; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy.
  • Google Tag Manager: Google Tag Manager is a solution that allows us to manage so-called website tags via an interface and thus integrate other services into our online offer (see further information on this in this privacy policy). For example, the Tag Manager itself (which implements the tags) does not yet create user profiles or store cookies. Google only learns the user’s IP address, which is necessary to run Google Tag Manager. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy policy: .

Online Marketing

We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the presentation of advertising and other content (collectively referred to as “Content”) based on the potential interests of users and the measurement of their effectiveness.

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

The IP addresses of the users are also stored. However, we use available IP masking methods (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that we, as well as the providers of the online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in cookies or by means of similar processes. These cookies can later generally be read on other websites that use the same online marketing method and analysed for the purpose of displaying content, as well as supplemented with further data and stored on the server of the online marketing process provider.

Exceptionally, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing process we use and the network connects the profiles of the users with the aforementioned information. Please note that users can make additional arrangements with the providers, e.g. by giving their consent as part of the registration process.

As a matter of principle, we only have access to aggregated information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e. e.g. to the conclusion of a contract with us. Conversion measurement is used solely to analyze the success of our marketing efforts.

Unless otherwise specified, we ask you to assume that cookies used will be stored for a period of two years.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, the user’s data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economical and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

Services and service providers used:

  • Google Analytics: online marketing and web analytics; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Possibility of objection (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • Google Ads and conversion measurement: We use the online marketing process “Google Ads” to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads. We also measure the conversion of the ads. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page with a so-called “conversion tracking tag”. However, we do not receive any information that can be used to identify users. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy.
  • Google Ad Manager: We use the “Google  Marketing Platform” (and services such as “Google Ad Manager”) to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.). Google Marketing Platform excels at displaying ads in real-time based on users’ presumed interests. This allows us to display ads for and within our online offering in a more targeted manner in order to only present users with ads that potentially correspond to their interests. If, for example, a user is shown ads for products that he or she has been interested in on other online offers, this is referred to as “remarketing”. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy.
  • LinkedIn: Insights tag/conversion measurement; Service Provider: LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA; Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy, Cookie Policy: https://www.linkedin.com/legal/cookie_policy; Possibility of objection (opt-out): .

 

Presence in social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with users who are active there or to offer information about us.

We would like to point out that user data may be processed outside the area of the European Union. This may result in risks for users, e.g. because it could make it more difficult to enforce users’ rights.

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

For a detailed description of the respective forms of processing and the options for objection (opt-out), we 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 also like to point out that these can be most effectively asserted with the providers. Only the providers have access to the user’s data and can directly take appropriate measures and provide information. If you still need help, you can contact us.

  • Types of data processed: Contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g.  websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: contact requests and communication, feedback (e.g. collecting feedback via online form), marketing.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services and service providers used:

 

Plugins and embedded functions as well as content

We integrate functional and content elements into our online offering, which are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). This may include, for example, graphics, videos or city maps (hereinafter referred to collectively as “Content”).

The integration always presupposes that the third-party providers of this content process the IP address of the users, as without the IP address they would not be able to send the content to their browser. The IP address is therefore required for the display of this content or functions. We make every effort to only use content whose respective providers only use the IP address to deliver the content. Third parties may also use 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 on the browser and operating system, referring websites, time of visit and other information on the use of our online offering, as well as be combined with such information from other sources.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, the user’s data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economical and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), inventory data (e.g. names, addresses), contact data (e.g.  e-mail, telephone numbers), content data (e.g. entries in online forms).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness, provision of contractual services and customer service, marketing, profiles with user-related information (creation of user profiles).
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR), consent (Art. 6 para. 1 sentence 1 lit. a. GDPR  ), performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR).

Services and service providers used:

 

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents to processing are revoked or other permissions cease to apply (e.g. if the purpose of the processing of this data has ceased to exist or if they are not required for the purpose).

Unless the data is erased because it is necessary for other purposes permitted by law, its processing will be limited to these purposes. This means that the data will be blocked and will not be processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.

As part of our privacy policy, we may provide users with further information on the deletion as well as on the retention of data that applies specifically to the respective processing processes.

 

Changes and updates to the Privacy Policy

We ask you to regularly inform yourself about the content of our privacy policy. We will amend the Privacy Policy as soon as the changes to the data processing we carry out make it necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or another individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting us.

 

Rights of data subjects

As a data subject, you are entitled to various rights under the GDPR, which result in particular from Art. 15 to 21 GDPR:

  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data based on Art. 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions. If your personal data is processed for the purpose of direct marketing, you have the right to object at any time to the processing of your personal data for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw your consent at any time.
  • Right of access: 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 legal requirements.
  • Right to rectification: In accordance with the law, you have the right to request the completion of the data concerning you or the correction of the inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that  data concerning you be erased without undue delay or, alternatively, to demand that the processing of the data be restricted in accordance with the legal requirements.
  • Right to data portability: You have the  right to receive data concerning you that you have provided to us in a structured, commonly used 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: In accordance with the  legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State in which you habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of your personal data violates the GDPR.

Supervisory authority responsible for us:

Bavarian State Office for Data Protection Supervision (BayLDA)Promenade 1891522 Ansbach

Definitions

This section provides an overview of the terminology used in this Privacy Policy. Many of the terms are taken from the law and are defined primarily in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to serve the purpose of understanding. The terms are sorted alphabetically.

  • IP masking: “IP  masking” is a method in which the last octet, i.e. the last two digits of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymising processing methods, especially in online marketing
  • Conversion measurement: Conversion measurement (also known as “visit action evaluation”) is a method used to determine the effectiveness of marketing efforts. For this purpose, a cookie is usually stored on the user’s devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, it allows us to understand whether the ads we serve on other websites have been successful.
  • Personal data: “Personal data”  means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is defined as one who identifies directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to it which are an expression of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any type of automated processing of personal data consisting in the use of such personal data to identify certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information relating to demographics, behaviour and interests,  such as interacting with websites and their content, etc.) analyze, evaluate, or predict them (e.g., interest in certain content or products, click behavior on a website, or location). Cookies and web beacons are often used for profiling purposes.
  • Reach measurement: Reach measurement (also referred to as web analytics) is used to evaluate the flow of visitors to an online offer and can include the behavior or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, see at what time visitors visit their website and what content they are interested in. This allows them to better adapt the content of the website to the needs of their visitors, for example. For the purpose of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Remarketing: “Remarketing” or “retargeting” is used when, for example, for advertising purposes, it is noted which products a user has been interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Controller: “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and encompasses practically any handling of data, be it collection, evaluation, storage, transmission or deletion.
  • Target group formation: Target group formation (or “custom audiences”) is when target groups are determined for advertising purposes, e.g. the display of advertisements. For example, based on a user’s interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which he or she viewed the products. In turn, “lookalike audiences” (or similar target groups) are when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were formed. Cookies and web beacons are usually used for the purpose of creating Custom Audiences and Lookalike Audiences.