Privacy Policy
.This privacy statement informs you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the websites, functions and content associated with it, as well as external online presences, such as our social media profiles. (hereinafter collectively referred to as “online offer”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
.Management and responsible:
Nico Nolte, Katharina Ilker GbR
Eschenrain 21/1
74199 Untergruppenbach, Germany
+49 172 58 99 285
nico.nolte@papavintage.com
Types of data processed:
– Inventory data
– Contact data
– Content data
– Contract data
– Payment data
– Usage data
– Meta-/Communication data
Processing of special categories of data (Art. 9(1) DSGVO):
.No special categories of data are processed.
Categories of persons concerned by the processing:
.– Customers, interested parties, visitors and users of the online offer, business partners.
– Visitors and users of the online offer.
In the following, we also refer to the data subjects collectively as “users”.
Purpose of processing:
.– Provision of the online offer, its content and store functions.
– Provision of contractual services, service and customer care.
– Answering contact requests and communication with users.
– Marketing, advertising and market research.
– Security measures.
As of 12/ 2019
.1. Terminology Used
1.1. “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e. e.g. cookie) or to one or more particular characteristics that are an expression of that natural person’s physical, physiological, genetic, mental, economic, cultural or social identity.
1.2 “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data.
1.3 “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.
2.Applicable legal bases
In accordance with Art. 13 DSGVO, we inform you of the legal bases of our data processing. If the legal basis is not mentioned in the privacy policy, the following applies: The legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 DSGVO, the legal basis for processing to fulfill our services and perform contractual measures and respond to inquiries is Art. 6(1)(b) DSGVO, the legal basis for processing to fulfill our legal obligations is Art. 6(1)(c) DSGVO, and the legal basis for processing to protect our legitimate interests is Art. 6(1)(f) DSGVO. In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) lit. d DSGVO serves as the legal basis.
3. Changes and updates to the privacy policy
We ask you to regularly inform yourself about the content of our privacy policy. We will adjust the Privacy Policy as soon as the changes in the data processing operations carried out by us make it necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
4. Security Measures
4.1 We take appropriate technical and organizational measures in accordance with Article 32 GDPR, 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 varying likelihood and severity of the risk to the rights and freedoms of natural persons.
4.2 The security measures include in particular the encrypted transmission of data between your browser and our server.
.5. Disclosure and transfer of data
5.1. If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transfer it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if a transfer of data to third parties, such as payment service providers, according to Art. 6 para. 1 lit. b DSGVO is necessary for the performance of a contract), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, hosting providers, tax, business and legal advisors, customer care, accounting, billing and similar services that allow us to efficiently and effectively fulfill our contractual obligations, administrative tasks and duties).
5.2.
5.2 If we entrust third parties with the processing of data on the basis of a so-called “order processing agreement”, this is done on the basis of Art. 28 DSGVO.
.6. Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or do so in the context of using third-party services or disclosing, or transferring data to third parties, this will only be done if it is done to fulfill 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 legal or contractual permissions, we process or allow the processing of data in a third country only if the special requirements of Art. 44 et seq. DSGVO are met. I.e. the processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU (e.g. for the USA by the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).
7. Rights of data subjects
7.1 You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with Art. 15 of the GDPR.
7.2 You have according to. Art. 16 DSGVO the right to request the completion of the data concerning you or the correction of incorrect data concerning you.
.7.3. you have in accordance with Art. 17 DSGVO the right to request that data concerning you be deleted without undue delay, or alternatively in accordance with Art. 18 DSGVO to request restriction of the processing of the data.
7.4 You have the right to request that the data concerning you that you have provided to us be received in accordance with Art. 20 of the GDPR and to request that it be transferred to other data controllers.
.7.5 You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 DSGVO.
8. right of withdrawal
You have the right to revoke consent granted pursuant to Art. 7 (3) DSGVO with effect for the future.
9. Right of objection
You may object to future processing of the data concerning you in accordance with Art. 21 DSGVO at any time. The objection may be made in particular against the processing for purposes of direct marketing.
10. Cookies and right to object to direct advertising
10.1. “Cookies” are small files that are stored on users’ computers. Within the cookies, different information can be stored. A cookie is primarily used to store the details of a user (or the device on which the cookie is stored) during or even after his visit within an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. Such a cookie may store, for example, the contents of a shopping cart in an online store or a login status. Cookies that remain stored even after the browser is closed are referred to as “permanent” or “persistent”. For example, the login status can be stored if users visit them after several days. Likewise, the interests of users can be stored in such a cookie, which is used for range measurement or marketing purposes. Cookies from providers other than the responsible party operating the online offer are referred to as “third-party cookies” (otherwise, if it is only its cookies, it is referred to as “first-party cookies”).
10.2 We use temporary and permanent cookies and explain this in our privacy policy.
If users do not want cookies to be stored on their computer, they are asked to disable the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies may lead to functional restrictions of this online offer.
10.3 A general objection to the use of cookies used for online marketing purposes can be declared for a large number of the services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by means of their deactivation in the browser settings. Please note that then not all functions of this online offer can be used if necessary.
.11. Deletion of data
11.1. The data processed by us will be deleted or restricted in its processing in accordance with Articles 17 and 18 DSGVO. Unless expressly stated in the context of this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.
11.2 Germany: According to legal requirements, the storage is carried out in particular for 6 years according to § 257 para. 1 HGB (commercial books, inventories, opening balances, annual financial statements, commercial letters, accounting vouchers, etc.) and for 10 years according to § 147 para. 1 AO (books, records, management reports, accounting vouchers, commercial and business letters, documents relevant for taxation, etc
.11.3. Austria: According to legal requirements, the storage is carried out in particular for 7 years in accordance with § 132 para 1 BAO (accounting records, vouchers/invoices, accounts, receipts, business papers, statement of income and expenditure, etc.), for 22 years in connection with real estate and for 10 years for documents in connection with electronically provided services, telecommunications, radio and television services provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.
.12. Order processing in the online store and customer account
12.1. We process the data of our customers in the context of the ordering process in our online store to enable them to select and order the selected products and services, as well as their payment and delivery, or execution.
12.2 The processed data includes inventory data, communication data, contract data, payment data and the data subjects are our customers, prospective customers and other business partners. The processing is carried out for the purpose of providing contractual services in the context of the operation of an online store, billing, delivery and customer services. Here, we use session cookies to store the shopping cart content and permanent cookies to store the login status.
.12.3 The processing is based on Art. 6 para. 1 lit. b (execution of order transactions) and c (legally required archiving) DSGVO. In this context, the information marked as required is necessary for the justification and fulfillment of the contract. We disclose the data to third parties only in the context of delivery, payment or in the context of legal permissions and obligations to legal advisors and authorities. The data is processed in third countries only if this is necessary for the fulfillment of the contract (e.g. at the request of the customer for delivery or payment).
12.4 Users can optionally create a user account, in particular by viewing their orders. As part of the registration, the required mandatory information will be provided to users. User accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data with regard to the user account will be deleted, subject to their retention is necessary for commercial or tax reasons in accordance with Art. 6 para. 1 lit. c DSGVO. Information in the customer account remains until its deletion with subsequent archiving in the event of a legal obligation. It is incumbent on users to back up their data in the event of termination before the end of the contract.
.12.5 In the context of registration and renewed registrations and use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the users in protection against abuse and other unauthorized use. In principle, this data is not passed on to third parties, unless it is necessary for the pursuit of our claims or there is a legal obligation to do so pursuant to Art. 6 para. 1 lit. c DSGVO.
.12.6 Deletion takes place after the expiry of statutory warranty and comparable obligations, the necessity of storing the data is reviewed every three years; in the case of statutory archiving obligations, deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) retention obligation); information in the customer account remains until its deletion.
.13. Business analyses and market research
13.1. In order to operate our business economically, to be able to recognize market trends, customer and user wishes, we analyze the data available to us on business transactions, contracts, inquiries, etc.. In doing so, we process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. DSGVO, whereby the data subjects include customers, interested parties, business partners, visitors and users of the online offer. The analyses are carried out for the purpose of business management evaluations, marketing and market research. In doing so, we may take into account the profiles of registered users with details of, for example, their purchase transactions. The analyses serve us for the increase of the user friendliness, the optimization of our offer and the business management. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with aggregated values.
13.2 If these analyses or profiles are personal, they will be deleted or anonymized upon termination of the users, otherwise after two years from the conclusion of the contract. Otherwise, the overall business analyses and general tendency determinations are created anonymously whenever possible.
2. The check of a customer’s creditworthiness is permissible if there is otherwise a risk of non-payment, i.e. if the goods are delivered without payment having been received (i.e. if the customer chooses to purchase on account). In contrast, there is no risk of non-payment if the customer chooses the prepayment option, for example, or makes the payment via third-party providers, such as Paypal.
It should also be noted that obtaining an automatic credit report is an “Automated Decisions in Individual Cases” pursuant to Art. 22 DSGVO, i.e. a legal decision without human involvement. This is permissible if the customer has consented or if this decision is necessary for the conclusion of the contract. Whether the decision is necessary has not yet been conclusively clarified, but is widely held to be a given, including by the author of this sample. However, if you want to exclude any risk, you should obtain consent.
.A consent is also necessary if the credit report is already then used to decide at all whether the option “on account” should be displayed. Because it could have been that the customer would have decided anyway for the advance payment or Paypal and the credit check would not have been necessary.
.Such consent could, for example, read as follows:
I agree that a credit check is carried out in order to decide in an automated procedure (Art. 22 DSGVO) whether the option of purchase on account is offered. For more information on the credit check, the credit reporting agencies used and the procedure, as well as the objection options, please refer to our objection statement.
.14. credit information
14.1. insofar as we act in advance (eg purchase on account), we reserve the right to protect the legitimate interests of an identity and credit information for the purpose of assessing the credit risk on the basis of mathematical-statistical methods of specialized service companies (credit agencies) to obtain.
14.2. in the context of the credit report, we transmit the following personal data of the customer (name, postal address, date of birth, information on the type of contract, bank details [please specify additional data if necessary]) to the following credit agencies:
[please specify the credit agencies here, e.g.:] SCHUFA company (SCHUFA Holding AG, Kormoranweg 5, 65201 Wiesbaden), data protection information: https://www.schufa.de/de/ueber-uns/daten-scoring/.
14.3 We process the information received from the credit agencies about the statistical probability of a payment default within the framework of an appropriate discretionary decision on the establishment, implementation and termination of the contractual relationship. We reserve the right, in the event of a negative result of the credit check, to refuse payment on account or any other advance payment.
.14.4 The decision as to whether we provide advance performance is made in accordance with Art. 22 DSGVO solely on the basis of an automated decision in individual cases, which our software takes on the basis of the information from the credit agency.
.14.5 If we obtain explicit consent from you, the legal basis for the credit report and the transmission of the customer’s data to the credit agencies is consent pursuant to Art. 6 para. 1 lit. a, 7 DSGVO. If no consent is obtained, our legitimate interests in the default security of their payment claim is the legal basis pursuant to Art. 6 para 1 lit. f. DSGVO.
15. Contacting and Customer Service
15.1. When contacting us (via contact form or email), the user’s details are processed for the purpose of handling the contact request and its processing pursuant to Art. 6 para. 1 lit. b) DSGVO.
15.2. the user’s details may be stored in our customer relationship management system (“CRM system”) or comparable inquiry organization.
15.3 We delete the inquiries if they are no longer necessary. We review the necessity every two years; we store inquiries from customers who have a customer account permanently and refer to the information on the customer account for deletion. Furthermore, the legal archiving obligations apply.
16. collection of access data and log files
16.1. we collect on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO data about each access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
16.2 Log file information is stored for security reasons (e.g. to clarify acts of abuse or fraud) for a maximum of seven days and then deleted. Data whose further storage is required for evidentiary purposes is exempt from deletion until the final clarification of the respective incident.
.17. Online presences in social media
17.1. We maintain online presences on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO, we maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services there. When calling up the respective networks and platforms, the terms and conditions and data processing policies of their respective operators apply.
17.2 Unless otherwise stated in our privacy policy, we process the data of users insofar as they communicate with us within the social networks and platforms, e.g. write posts on our online presences or send us messages.
If the “Remarketing”, or “Google Analytics Audiences” functions are used, the following passage on these functions must be included in addition, as a second point:
.17.2 We use Google Analytics to display the ads placed by within advertising services of Google and its partners, only to those users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the visited web pages), which we transmit to Google (so-called “Remarketing-“, or “Google Analytics Audiences”). With the help of Remarketing Audiences, we also want to ensure that our ads correspond to the potential interest of users and do not have a harassing effect.
18. Google Analytics
18.1. We use on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) Google Analytics, a web analytics service provided by Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by users is usually transmitted to a Google server in the U.S. and stored there.
18.2. Google is certified under the Privacy Shield Agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
18.3 Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with other services related to the use of this online offer and Internet use. In doing so, pseudonymous usage profiles of the users can be created from the processed data.
.18.4 We use Google Analytics only with IP anonymization enabled. This means that the IP address of the user is shortened by Google within Member States of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
.18.5 The IP address transmitted by the user’s browser is not merged with other data from Google. Users can prevent the storage of cookies by selecting the appropriate settings on their browser software; users can also prevent the collection of data generated by the cookie and related to their use of the online offer to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
.18.6 For more information about Google’s data use, settings and opt-out options, please visit Google’s websites: https://www.google.com/intl/de/policies/privacy/partners (“Data Use by Google When You Use Our Partners’ Websites or Apps”), https://policies.google.com/technologies/ads (“Data Use for Advertising Purposes”), https://adssettings.google.com/authenticated (“Manage Information Google Uses to Show You Advertising”).
19. Google Re/Marketing Services
19.1. We use on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) the marketing and remarketing services (in short “Google marketing services”) of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).
19.2 Google is certified under the Privacy Shield Agreement and thereby provides a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
19.3 The Google marketing services allow us to display advertisements for and on our website in a more targeted manner, in order to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products in which he was interested on other websites, this is referred to as “remarketing”. For these purposes, when our website and other websites on which Google marketing services are active are called up, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as “web beacons”) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). The cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file records which websites the user has visited, which content he is interested in and which offers he has clicked on, as well as technical information on the browser and operating system, referring websites, time of visit and other information on the use of the online offer. The IP address of the user is also recorded, whereby we inform Google Analytics that the IP address is shortened within Member States of the European Union or in other contracting states to the Agreement on the European Economic Area and only in exceptional cases is transferred in full to a Google server in the USA and shortened there. The IP address will not be merged with data of the user within other offers of Google. The aforementioned information may also be linked on the part of Google with such information from other sources. If the user subsequently visits other websites, the ads tailored to him can be displayed according to his interests.
.19.4 The data of the users are processed pseudonymously within the framework of the Google marketing services. I.e. Google does not store and process, for example, the name or email address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. I.e. from Google’s perspective, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymization. The information collected by Google marketing services about users is transmitted to Google and stored on Google’s servers in the U.S.
.19.5 The Google marketing services used by us include, among others, the online advertising program “Google AdWords”. In the case of Google AdWords, each AdWords customer receives a different “conversion cookie”. Cookies can therefore not be tracked across the websites of AdWords customers. The information obtained using the cookie is used to create conversion statistics for AdWords customers who have opted in to conversion tracking. The AdWords customers learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive information that personally identifies users.
19.6 We may integrate third-party advertisements based on the Google marketing service “DoubleClick”. DoubleClick uses cookies, with which Google and its partner websites, the placement of ads based on users’ visits to this website or other websites on the Internet is enabled.
.19.7. we can integrate third-party advertisements based on the Google marketing service “AdSense”. AdSense uses cookies, with which Google and its partner websites, the placement of ads based on users’ visits to this website or other websites on the Internet is enabled.
.19.8 Likewise, we may use the service “Google Optimizer”. Google Optimizer allows us to track the effect of various changes to a website (e.g. changes to input fields, design, etc.) as part of so-called “A/B testing”. Cookies are placed on users’ devices for these testing purposes. Only pseudonymous user data is processed in the process.
19.9. Furthermore, we may use the “Google Tag Manager” to integrate and manage Google analytics and marketing services on our website.
.19.10. For more information about Google’s use of data for marketing purposes, please see the overview page: https://policies.google.com/technologies/ads, Google’s privacy policy is available at https://adssettings.google.com/authenticated.
Furthermore, when using the Facebook Pixel, we use the additional function “extended matching” (here, data such as phone numbers, email addresses or Facebook IDs of the users) to form target groups (“Custom Audiences” or “Look Alike Audiences”) are transmitted to Facebook (encrypted). Further notes on “advanced matching”:https://www.facebook.com/business/help/611774685654668).
We also use the procedure “Custom Audiences from File” of the social network Facebook, Inc. In this case, the email addresses of the newsletter recipients are uploaded to Facebook. The upload process is encrypted. The upload is used solely to determine recipients of our Facebook ads. In this way, we want to ensure that the ads are only displayed to users who have an interest in our information and services.
Note about opting out: please note that Facebook does not offer opt-out at the time of writing this sample and you will need to implement it yourself. If you do not, you will need to remove this passage. The implementation can be done, for example, using Javascript (setting the opt-out link) and when loading the page via PHP (which checks whether the opt-out cookie has been set and only loads the Facebook pixel if the result is negative). If a user visits the website, it must be checked whether the “opt-out” cookie is set. If so, the “Facebook pixel” must not be loaded.
.Please include the following addition in the case of your own opt-out:
.To prevent the collection of your data using the Facebook pixel on our website, please click the following link: Facebook Opt-Out Note: When you click the link, an “opt-out” cookie will be stored on your device. If you delete the cookies in this browser, then you must click the link again. Furthermore, the opt-out only applies within the browser you are using and only within our web domain on which the link was clicked.
20. Facebook, Custom Audiences and Facebook Marketing Services
20.1. Within our online offer, due to our legitimate interests in analysis, optimization and economic operation of our online offer and for these purposes, the so-called “Facebook Pixel” of the social network Facebook, which is operated by Facebook Inc, 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are a resident of the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”).
20.2 Facebook is certified under the Privacy Shield Agreement, thereby providing a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
20.3 With the help of the Facebook Pixel, it is possible for Facebook, on the one hand, to determine the visitors to our online offer as a target group for the display of advertisements (so-called “Facebook Ads”). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of users and do not have a harassing effect. With the help of the Facebook pixel, we can further track the effectiveness of the Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion”).
.20.4 The processing of data by Facebook takes place within the framework of Facebook’s data use policy. Accordingly, general guidance on the display of Facebook Ads, in Facebook’s Data Use Policy: https://www.facebook.com/policy.php. Specific information and details about the Facebook Pixel and how it works can be found in Facebook’s help section: https://www.facebook.com/business/help/651294705016616.
20.5 You can object to the collection by the Facebook Pixel and use of your data to display Facebook Ads. To adjust which types of ads are displayed to you within Facebook, you can visit the page set up by Facebook and follow the instructions there for the settings of usage-based advertising: https://www.facebook.com/settings?tab=ads. The settings are done in a platform-independent manner, i.e. they are applied to all devices, such as desktop computers or mobile devices.
.20.6. You can further object to the use of cookies that serve reach measurement and advertising purposes via the deactivation page of the network advertising initiative (http://optout.networkadvertising.org/) and additionally the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).
21. Facebook Social Plugins
21.1. We use on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) social plugins (“plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The plugins can display interaction elements or content (e.g. videos, graphics or text contributions) and are recognizable by one of the Facebook logos (white “f” on blue tile, the terms “Like”, “Like” or a “thumbs up” sign) or are marked with the addition “Facebook Social Plugin”. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
21.2. Facebook is certified under the Privacy Shield agreement, thereby providing a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
21.3 When a user calls up a function of this online offer that contains such a plugin, his device establishes a direct connection with the servers of Facebook. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated by it into the online offer. In the process, usage profiles of the users can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects with the help of this plugin and therefore informs users according to our level of knowledge.
.21.4 By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user is logged into Facebook, Facebook can assign the visit to his Facebook account. If users interact with the plugins, for example by clicking the Like button or posting a comment, the corresponding information is transmitted from your device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will learn and store his or her IP address. According to Facebook, only an anonymized IP address is stored in Germany.
21.5. the purpose and scope of data collection and the further processing and use of data by Facebook, as well as the relevant rights and settings options for protecting the privacy of users, can be found in Facebook’s privacy policy: https://www.facebook.com/about/privacy/.
21.6 If a user is a Facebook member and does not want Facebook to collect data about him/her via this online offer and link it to his/her membership data stored with Facebook, he/she must log out of Facebook and delete his/her cookies before using our online offer. Further settings and objections to the use of data for advertising purposes, are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
.22. reach analysis with Matomo
22.1. within the scope of the reach analysis of Matomo, on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO)the following data is processed: the browser type and version you use, the operating system you use, your country of origin, the date and time of the server request, the number of visits, the time you spend on the website and the external links you click. The IP address of users is anonymized before it is stored.
22.2 Matomo uses cookies that are stored on the user’s computer and that enable an analysis of the use of our online offer by the user. In the process, pseudonymous user profiles can be created from the processed data. The cookies have a storage period of one week. The information generated by the cookie about your use of this website will only be stored on our server and will not be disclosed to third parties.
.22.3 Users can object to the anonymized data collection by the Matomo program at any time with future effect by clicking on the link below. In this case, a so-called opt-out cookie will be stored in their browser, with the result that Matomo will no longer collect any session data. If users delete their cookies, however, this has the effect that the opt-out cookie is also deleted and must therefore be reactivated by users.
.23. Jetpack (WordPress Stats)
23.1. We use on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) the plugin Jetpack (here the sub-function “WordPress Stats”), which embeds a tool for statistical analysis of visitor traffic and is provided by Automattic, Inc. 132 Hawthorne Street San Francisco, CA 94107, USA. Jetpack uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site.
23.2 Automattic is certified under the Privacy Shield agreement, thereby providing a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000CbqcAAC&status=Active).
.23.3 The information generated by the cookie about your use of this online service is stored on a server in the USA. Thereby, usage profiles of the users can be created from the processed data, whereby these are only used for analysis purposes and not for advertising purposes. For more information, please see Automattic’s privacy policy:https://automattic.com/privacy/ and notes on Jetpack cookies: https://jetpack.com/support/cookies/.
24. etracker
24.1. We use on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) the analysis service “etracker” of etracker GmbH, Erste Brunnenstraße 1 20459 Hamburg.
24.2 From the data processed by etracker, user profiles can be created under a pseudonym. Cookies can be used for this purpose. The cookies make it possible to recognize your browser. The data collected with the etracker technologies will not be used to personally identify visitors to our website without the separately granted consent of the person concerned and will not be merged with personal data about the bearer of the pseudonym. Furthermore, the personal data will only be processed for us, i.e. will not be merged with personal data collected within other online offerings.
24.4 Opt-out will set an opt-out cookie named “cntcookie” from etracker. Please do not delete this cookie as long as you wish to maintain your opt-out. For more information, please see etracker’s privacy policy: http://www.etracker.com/de/datenschutz.html.
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25. Criteo
25.1. We use on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) the services of the provider Criteo GmbH, Gewürzmühlstr. 11, 80538 Munich, Germany.
25.2 The services of Criteo allow us to display advertisements for and on our website in a more targeted manner in order to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products in which he was interested on other websites, this is referred to as “remarketing”. For these purposes, when our website and other websites on which Criteo is active are called up, Criteo immediately executes code from Criteo and so-called (re)marketing tags (invisible graphics or code, also referred to as “web beacons”) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). This file records which web pages the user has visited, which content the user is interested in and which offers the user has clicked on, as well as technical information about the browser and operating system, referring web pages, time of visit and other information about the use of the online offer. The aforementioned information may also be combined by Criteo with such information from other sources. If the user subsequently visits other websites, he can be shown ads tailored to his interests.
.25.3. further information as well as objection options to the collection by Criteo can be found in the privacy policy of Criteo: https://www.criteo.com/de/privacy/.
.26. Amazon Affiliate Program
26.1. We are based on our legitimate interests (i.e. interest in the economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f. DSGVO) participant of the affiliate program of Amazon EU, which was designed to provide a medium for websites, by means of which through the placement of advertisements and links to Amazon.de advertising fees can be earned. Amazon uses cookies to track the origin of orders. Among other things, Amazon can recognize that you have clicked the affiliate link on this website.
26.2 For more information about Amazon’s use of data, please see the company’s privacy policy: http://www.amazon.de/gp/help/customer/display.html/ref=footer_privacy?ie=UTF8&nodeId=3312401.
27. Communication via mail, e-mail, fax or telephone
27.1 We use means of remote communication, such as mail, telephone or e-mail, for business processing and marketing purposes. In doing so, we process inventory data, address and contact data as well as contract data of customers, participants, interested parties and communication partners.
27.2 The processing is based on Art. 6 para. 1 lit. a, Art. 7 DSGVO, Art. 6 para. 1 lit. f DSGVO in conjunction with legal requirements for promotional communications. Contact will only be made with the consent of the contact partners or within the scope of legal permissions and the processed data will be deleted as soon as they are not necessary and otherwise with objection/ revocation or discontinuation of the authorization bases or legal archiving obligations.
.Note: Please point out already in the context of registration, i.e. in the registration form, the contents of the newsletter and the evaluation of the opening as well as the click behavior, e.g.:
Our newsletter contains information about our products, offers, promotions and our company. Information on data protection, revocation, logging as well as the performance measurement covered by the consent, you will find in our [LINK]Privacy Policy[/Link].
.If you use a shipping service provider, you must supplement information about them and can be guided by these examples (use of a service provider from the EU and one from a third country):
Shipping service provider: The newsletter is sent by means of CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede, hereinafter referred to as “shipping service provider”. You can view the privacy policy of the shipping service provider here: https://www.cleverreach.com/de/datenschutz/.
Sending service provider: The newsletter is sent using “MailChimp”, a newsletter sending platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view the privacy policy of the shipping service provider here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC d/b/a MailChimp is certified under the Privacy Shield agreement, thereby providing a guarantee of compliance with the European level of data protection (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active).
Note on the legal basis: Please select the variant for Germany or Austria in the information on the legal basis.
Please take into account that in Austria, due to a provision of the E-Commerce Act (ECG), the so-called “ECG list” must be taken into account. This list is maintained by the Regulatory Authority for Telecommunications and Broadcasting (RTR): https://www.rtr.at/de/tk/TKKS_Spam. It contains those e-mail addresses to which no e-mails may be sent.
28. Newsletter
28.1 With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to the receipt and the described procedures.
28.2 Content of the newsletter: We send newsletters, e-mails and other electronic notifications with promotional information (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. Insofar as the contents of the Newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. Otherwise, our newsletters contain information about our products, offers, promotions and our company.
.28.3 Double opt-in and logging: The registration for our newsletter is carried out in a so-called double opt-in procedure. That is, after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address. Likewise, the changes to your data stored with the shipping service provider are logged.
28.4 Dispatch service provider: The newsletter is dispatched using “MailChimp”, a newsletter dispatch platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view the privacy policy of the shipping service provider here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC d/b/a MailChimp is certified under the Privacy Shield agreement, thereby providing a guarantee of compliance with the European level of data protection (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active).
28.5 Insofar as we use a shipping service provider, the shipping service provider may, according to its own information, use this data in pseudonymous form, i.e. without assignment to a user, to optimize or improve its own services, e.g. to technically optimize the shipping and display of the newsletter or for statistical purposes to determine from which countries the recipients come. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass them on to third parties.
28.6 Registration Data: To sign up for the newsletter, it is sufficient to provide your email address. Optionally, we ask you to provide a name, for the purpose of personal address in the newsletter.
.28.7 Performance measurement – The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened, or if we use a shipping service provider, from their server. In the course of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the retrieval are collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. The statistical surveys also include the determination of whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor, if used, that of the dispatch service provider to observe individual users. The evaluations serve us much more 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.
28.8. Germany: The dispatch of the newsletter and the measurement of success are based on the consent of the recipients according to Art. 6 para. 1 lit. a, Art. 7 DSGVO in conjunction with § 7 para. 2 No. 3 UWG or on the basis of the legal permission according to § 7 para. 3 UWG.
.28.9. Austria: The dispatch of the newsletter and the measurement of success are based on the consent of the recipients according to Art. 6 para. 1 lit. a, Art. 7 DSGVO in conjunction with § 107 para. 2 TKG or on the basis of the legal permission according to § 107 para. 2 u. 3 TKG.
28.10. The logging of the registration process is based on our legitimate interests pursuant to Art. 6 para. 1 lit. f DSGVO and serves as proof of consent to receive the newsletter.
.28.11. Newsletter recipients can cancel the receipt of our newsletter at any time, i.e. revoke their consents. They will find a link to cancel the newsletter at the end of each newsletter. At the same time, their consent to the performance measurement will expire. A separate cancellation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled. With the unsubscription from newsletter, the personal data will be deleted, unless their retention is legally required or justified, in which case their processing will be limited only to these exceptional purposes. In particular, we may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them for newsletter sending purposes, in order to be able to prove consent formerly given. The processing of this data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.
29. integration of services and content of third parties
29.1. we use within our online offer on the basis of our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para 1 lit. f. DSGVO) to integrate content or services offered by third-party providers, such as videos or fonts (hereinafter uniformly referred to as “content”). This always requires that the third-party providers of this content are aware of the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content. We endeavor to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.
29.2 The following presentation provides an overview of third-party providers and their content, along with links to their privacy statements, which contain further information on the processing of data and, in part, already mentioned here, objection options (so-called opt-out)
– If our customers use the payment services of third parties (eg PayPal or Sofortüberweisung), the terms and conditions and privacy notices of the respective third party providers, which are available within the respective websites, or transaction applications.
– External fonts from Google, LLC., https://www.google.com/fonts (“Google Fonts”). The integration of Google Fonts is done by a server call at Google (usually in the USA). Privacy policy: https://policies.google.com/privacy, Opt-out: https://adssettings.google.com/authenticated.
– Maps provided by the service “Google Maps” of the third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
– Videos from the “YouTube” platform of the third-party provider Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
– Within our online offer, functions of the service Google+ are integrated. These functions are offered by the third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. If you are logged in to your Google+ account, you can link the content of our pages to your Google+ profile by clicking on the Google+ button. This allows Google to associate the visit to our pages with your user account. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by Google+. Privacy policy: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated.
– Within our online offer, functions of the service Instagram are integrated. These functions are offered by Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA integrated. If you are logged into your Instagram account, you can link the content of our pages to your Instagram profile by clicking on the Instagram button. This allows Instagram to associate the visit to our pages with your user account. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by Instagram. Privacy policy: http://instagram.com/about/legal/privacy/.
– We use social plugins of the social network Pinterest, which is operated by Pinterest Inc, 635 High Street, Palo Alto, CA, 94301, USA (“Pinterest”). When you call up a page that contains such a plugin, your browser establishes a direct connection to the Pinterest servers. The plugin transmits log data to the Pinterest server in the USA. This log data may contain your IP address, the address of the visited websites that also contain Pinterest functions, type and settings of the browser, date and time of the request, your usage of Pinterest as well as cookies. Privacy Policy: https://about.pinterest.com/de/privacy-policy.
– Within our online offer, functions of the service, or the platform Twitter can be integrated (hereinafter referred to as “Twitter”). Twitter is an offer of Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The functions include the display of our posts within Twitter within our online offer, the link to our profile on Twitter as well as the possibility to interact with the posts and the functions of Twitter, as well as to measure whether users reach our online offer via the advertisements placed by us on Twitter (so-called conversion measurement). Twitter is certified under the Privacy Shield agreement and thereby offers a guarantee of 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.