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Privacy policy

Introduction

With the following data protection declaration, 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 data protection declaration applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter also referred to collectively as "online offer").

The terms used are not gender-specific.

Stand: 4. April 2020

Contents overview

responsible person

Peppermint GmbH
Roman Luyken
Fasanenweg 4
82335 Berg
Germany

E-Mail address: contact1@peppermintproducts.com

Imprint: peppermintproducts.com

Overview of the processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

types of data processed

  • stock data (e.g. names, addresses).
  • content data (e.g. text entries, photographs, videos).
  • 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).
  • location data (data indicating the location of an end user's terminal device).
  • Contract data (e.g. subject matter of the contract, duration, customer category).
  • Payment data (e.g. bank details, invoices, payment history).

Categories of affected persons

  • Employees (e.g. employees (e.g. employees, applicants, former employees).
  • business and contractual partners.
  • interested parties.
  • communication partners.
  • customers.
  • users (e.g. website visitors, users of online services).
  • lottery and competition participants.

purposes of processing.

  • affiliate tracking.
  • provision of our online offer and user-friendliness.
  • visitor promotion evaluation.
  • Office and organisational procedures.
  • Cross-device tracking (cross-device processing of user data for marketing purposes).
  • Direct marketing (e.g. by e-mail or post).
  • Conducting prize draws and competitions.
  • Feedback (e.g. collecting feedback via online form).
  • Interest based and behavioral marketing.
  • Contact inquiries and communication.
  • Conversion measurement (measurement of effectiveness of marketing measures).
  • Profiling (creation of user profiles).
  • Remarketing.
  • Range measurement (e.g. access statistics, recognition of recurring visitors).
  • security measures.
  • tracking (e.g. interest/behaviour-related profiling, use of cookies).
  • contractual services.
  • Administration and answering of inquiries.
  • Target group formation (determination of target groups relevant for marketing purposes or other output of content).

Dependant legal bases

In the following we inform you about the legal bases of the Basic Data Protection Regulation (DSGVO), on the basis of which we process personal data. Please note that in addition to the regulations of the DSGVO, national data protection regulations may apply in your or our country of residence and domicile. If, furthermore, more specific legal bases are applicable in individual cases, we will inform you of these in the Data Protection Declaration.

  • Consent (Art. 6 Para. 1 S. 1 lit. a DSGVO) - The data subject has given his or her consent to the processing of personal data relating to him or her for one or more specific purposes.
  • Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1, sent. 1, letter b. DPA) - Processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the request of the data subject.
  • Legal obligation (Art. 6 para. 1, sent. 1, letter c. DPA) - Processing is necessary for the performance of a legal obligation to which the controller is subject. - The processing is necessary to protect the vital interests of the data subject or of another natural person.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO) - The processing is necessary to protect the legitimate interests of the controller or of a third party unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data outweigh those of the data subject.

National data protection regulations in Germany: In addition to the data protection regulations in the Basic Data Protection Regulation, national data protection regulations apply in Germany. These include in particular the law on protection against misuse of personal data in data processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to deletion, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision making in individual cases including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may be applicable.

security measures

In accordance with the legal requirements, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk, 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.

transmission and disclosure of personal data

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

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 is carried out in the context of using the services of third parties or in order to disclose or transfer data to other persons, bodies or companies, this will only be done in accordance with the legal requirements.

Subject to express consent or transfer required by contract or by law, we will only process or keep the data in third countries with a recognised level of data protection, including the US processors certified under the "Privacy Shield", or on the basis of special guarantees, such as contractual obligation through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec. europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en ).

use of cookies

Cookies are text files which contain data from visited websites or domains and are stored by a browser on the user's computer. 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 location where a video was viewed. The term "cookies" also includes other technologies that perform the same functions as cookies (e.g, if user information is stored using pseudonymous online identifiers, also known as "user IDs")

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed his browser.
  • Permanent cookies: Permanent 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 can be stored in such a cookie.
  • First-party cookies: First-party cookies are set by us.
  • Third party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information. Cookies can be absolutely necessary for the operation of a website (e.g. to store logins or other user entries or for security reasons).

Notice on legal bases: The legal basis on which we process your personal data with the aid of cookies depends on whether we ask you for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing 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 a business operation of our online offer and its improvement) are processed or, if the use of cookies is necessary to fulfil our contractual obligations.

General information on revocation and objection (Opt-Out): Depending on whether the processing is based on consent or legal permission, you have the possibility at any time to revoke a granted consent or to object to the processing of your data by cookie technologies (collectively referred to as "Opt-Out"). You can initially declare your objection by means of the settings of your browser, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online service). 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 notices of objection within the framework of the information on the service providers and cookies used.

Processing of cookie data on the basis of consent: Before we process data within the framework of the use of cookies or have them processed, we ask the users for consent that can be revoked at any time. Before consent has not been given, cookies are used if necessary, which are necessary for the operation of our online offer. Their use is based on our interest and the interest of the users in the expected functionality of our online offer.

  • Processed data types: Usage data (e.g. visited websites, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: users (e.g. website visitors, users of online services).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

commercial and business services

We process data of our contractual and business partners, e.g. Customers and interested parties (collectively referred to as "Contractual Partners") within the scope of contractual and comparable legal relationships and related measures and within the scope of communication with the Contractual Partners (or pre-contractual), e.g, in order 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 data and for the purposes of the company organisation. Within the framework of the applicable law, we only pass on the data of the contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations or with the consent of the contractual partners (e.g. to participating telecommunication, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.

What data is required for the above-mentioned purposes will be communicated to the contractual partners before or within the scope of data collection, e.g. e.g. in online forms, by means of special marking (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 4 years, unless the data is stored in a customer account, e.g. as long as it must be kept for legal archiving reasons (e.g. for tax purposes usually 10 years). We delete data that has been disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, generally after the end of the order.

If we use third-party providers or platforms to provide our services, the terms and conditions and data protection information of the respective third-party provider or platform apply in the relationship between the users and the providers.

Economic analyses and market research: For business management reasons and in order to be able to recognise market trends, wishes of the contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc, whereby in the group of persons concerned may include contractual partners, interested parties, customers, visitors and users of our online offer.

The analyses are carried out for the purpose of business management evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we can take into account the profiles of registered users, if available, including their details, e.g. on services used. The analyses serve solely to serve us and are not disclosed externally, unless they are anonymous analyses with summarised, i.e. anonymised, values. Furthermore, we respect the privacy of the users and process the data for the analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as summarised data).

Shop and E-Commerce: We process the data of our customers in order to enable them to make the selection, purchase or the order of the selected products, goods and related services, as well as their payment and delivery, or execution.

The necessary information is marked as such in the context of the order or comparable acquisition process and includes the data required for delivery, or

  • Processed data types: Stock 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. object of contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Interested parties, business and contractual partners, customers.
  • Purposes of processing: Contractual services and service, contact requests and communication, office and organisational procedures, administration and answering of requests, visitation evaluation, interest based and behaviour related marketing, profiling (creation of user profiles), security measures.
  • Legal basis: Fulfilment of contract and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b. DSGVO), Legal obligation (Art. 6 Para. 1 S. 1 lit. c. DSGVO), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. DSGVO).

payment service provider

In the context of contractual and other legal relationships, due to legal obligations or otherwise based on our legitimate interests, we offer the persons concerned efficient and secure payment options and use other payment service providers in addition to banks and credit institutions (collectively "payment service providers").

The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient related data. These details are required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored by them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the payment service providers may transfer the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. For this purpose we refer to the General Terms and Conditions and the data protection information of the payment service providers.

For payment transactions the terms and conditions and the data protection information of the respective payment service providers apply, which can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and assertion of revocation, disclosure and other rights of affected persons.

  • Processed data types: Stock data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of the contract, term, customer category), usage data (e.g. e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: customers, interested parties.

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data are processed for the purposes of the publication medium only to the extent that it is necessary for its presentation and communication between authors and readers or for security reasons. In addition, we refer to the information on the processing of visitors to our publication medium in the context of this data protection notice.

Comments and contributions: If users leave comments or other contributions, their IP addresses may be stored on the basis of our legitimate interests. This is done for our security in case someone leaves illegal content in comments and contributions (insults, prohibited political propaganda, etc.) In this case we can be prosecuted ourselves for the comment or contribution and are therefore interested in the identity of the author.

Furthermore, based on our legitimate interests, we reserve the right to process the information provided by users for the purpose of spam detection.

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

  • Affected persons: users (e.g. website visitors, users of online services).
  • Purposes of processing: Contractual performance and service, feedback (e.g. collecting feedback via online form), security measures, administration and answering of inquiries.
  • Legal bases: Fulfilment of contract and pre-contractual enquiries (Art. 6 Paragraph 1 S. 1 lit. b. DSGVO), legitimate interests (Art. 6 Paragraph 1 S. 1 lit. f. DSGVO), consent (Art. 6 Paragraph 1 S. 1 lit. a DSGVO), protection of vital interests (Art. 6 para. 1 sentence 1 lit. d. DSGVO).
  • contact us

    When contacting us (e.g. by contact form, e-mail, telephone or via social media), the details of the inquiring persons are processed to the extent necessary to answer the contact enquiries and any measures requested.

    The answering of contact enquiries within the framework of contractual or pre-contractual relationships is carried out in order to fulfil our contractual obligations or to answer (pre)contractual enquiries and otherwise on the basis of the legitimate interest in answering the enquiries.

    • Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos).
    • Persons concerned: Communication partners.
    • Purposes of processing: Contact requests and communication.
    • Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

    communication via Messenger

    We use Messenger for communication purposes and therefore ask you to observe the following information on the functionality of the Messenger, on encryption, on the use of metadata of the communication and on your right to object.

    You can also contact us by alternative means, e.g. by telephone or e-mail. Please use the contact details provided to you or the contact details provided within our online offer.

    In the case of end-to-end encryption of content (i.e. the content of your message and attachments), please note that the communication content (i.e. the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messengers with activated encryption, so that the encryption of the message content is guaranteed.

    However, we would like to point out to our communication partners that although the messenger providers cannot view the content, they can find out that and when communication partners communicate with us, as well as technical information about the communication partner's device used and, depending on the settings of their device, also location information (so-called metadata) is processed.

    Notes on legal bases: If we ask communication partners for permission before communicating with them via Messenger, the legal basis of our processing of their data is their consent. Otherwise, if we do not ask for your consent and you contact us, e.g. on your own initiative, we will use Messenger in relation to our contractual partners as well as in the context of contract preparation as a contractual measure and in the case of other interested parties and communication partners on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners for communication via Messenger. Furthermore, we would like to point out that we will not transmit the contact data provided to us to Messenger for the first time without your consent.

    Cancellation, objection and deletion: You can revoke a given consent at any time and object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete the messages in accordance with our general deletion guidelines (i.e, as described above, after the end of contractual relationships, in the context of archiving requirements etc.) and otherwise as soon as we can assume that we have answered any information from the communication partners, if no reference to a previous conversation is to be expected and no legal storage obligations stand in the way of deletion.

    Reservation of the reference to other communication channels: Finally, we would like to point out that for reasons of your security we reserve the right not to answer inquiries via Messenger. This is the case if, for example, internal contractual matters require special secrecy or if an answer via Messenger does not meet the formal requirements. In such cases we refer you to more adequate communication channels.

    • Processed data types:Contact data (e.g. e-mail, telephone numbers), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. e.g. device information, IP addresses).
    • Persons concerned: communication partners.
    • purposes of processing: contact requests and communication, direct marketing (e.g. e-mail or by post).
    • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

    provision of the online offer and web hosting

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

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

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

    The server log files may be used 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 capacity utilisation of the servers and their stability.

    • Processed data types: Content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. e.g. device information, IP addresses).
    • Affected persons: users (e.g. website visitors, users of online services).
    • legal basis: Justified interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

    Cloud services

    We use software that is accessible via the Internet and executed on the servers of their providers. Software services (so-called "cloud services", also referred to as "software as a service") for the following purposes: document storage and management, calendar management, e-mailing, spreadsheets and presentations, exchanging documents, content and information with specific recipients or publishing websites, forms or other content and information, as well as chatting and participating in audio and video conferences.

    In this context, personal data may be processed and stored on the servers of the providers, provided that they are part of communication processes with us or otherwise processed by us as set out in this privacy policy. This data may include, in particular, master data and contact details of users, data on procedures, contracts, other processes and their contents. The providers of the cloud services also process usage data and meta data that they use for security purposes and for service optimization.

    If we use the cloud services to process forms or the like for other users or publicly accessible websites. provide documents and content, the providers may store cookies on the users' devices for web analysis purposes or to remember user settings (e.g. in the case of media control).

    Notes on legal bases:If we ask for consent to use the cloud services, the legal basis for processing is consent. Furthermore, their use can be a component of our (pre-)contractual services, provided that the use of the cloud services has been agreed in this context. Otherwise, user data will be processed on the basis of our legitimate interests (i.e, interest in efficient and secure administration and collaboration processes), processed data types:

    • Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
    • Affected persons: customers, employees (e.g. employees, applicants, former employees), interested parties, communication partners.
    • Purposes of processing: Office and organisational procedures.
    • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a DSGVO), Fulfilment of contract and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. FADP).

    newsletter and broad communication

    We send newsletters, e-mails and other electronic communications (hereinafter "newsletters") only with the consent of the recipients or with a legal permit. If the contents of the newsletter are specifically described in the context of a registration for the newsletter, they are decisive for the consent of the users. In addition, our newsletters contain information about our services and us.

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

    Double-Opt-In-Procedure: The registration for our newsletter is always done in a so-called Double-Opt-In-Procedure. This means that you will receive an e-mail after registration in which you are asked to confirm your registration. This confirmation is necessary so that nobody can register with foreign e-mail addresses. The newsletter registrations are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored with the dispatch service provider are also logged.

    Deletion and limitation of processing: We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove that we have previously given our 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 a consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a blacklist for this purpose alone.

    The logging of the registration procedure is based on 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 mailing system.

    Notes on legal bases:The sending of newsletters is based on the consent of the recipients or, if consent is not required, on our legitimate interests in direct marketing, if and insofar as this is permitted by law, e.g. in the case of advertising to existing customers. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests in order to prove that it has been carried out in accordance with the law.

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

    measurement of success: 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 mailing service provider, from their server. Within the scope of this retrieval, technical information, such as information on the browser and your system, as well as your IP address and the time of retrieval, is initially 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 behaviour on the basis of their retrieval locations (which can be determined by means 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. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor, if used, that of the mailing service provider to observe individual users. Rather, the evaluations serve us to recognise 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 evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system, which both serves our business interests and meets the expectations of the users.

    • Processed data types: 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. visited websites, interest in content, access times).
    • Persons concerned: communication partners.
    • purposes of processing: direct marketing (e.g. e-mail or by post).
    • legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
    • Opt-out: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably e-mail.

    advertising communication via e-mail, post, fax or telephone

    We process personal data for the purposes of advertising communication, which is carried out via various channels such as e-mail, telephone, post or fax, in accordance with the legal requirements.

    The recipients have the right to revoke any consent given or to object to the promotional communication at any time.

    After revocation or objection, we may store the data required to prove consent for up to three years on the basis of our legitimate interests before deleting it. 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 a consent is confirmed at the same time.

    • Processed data types: Stock data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
    • Communication partners.
    • Purposes of processing: Direct marketing (e.g. by e-mail or by post).
    • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

      If contributions of the participants are published in the context of the competition (e.g. in the context of a vote or presentation of the competition contributions or the winners or the reporting on the competition), we point out that the names of the participants can also be published in this context. The participants can object to this at any time.

      If the competition takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as "online platform"), the terms of use and data protection regulations of the respective platforms also apply. In these cases, we would like to point out that we are responsible for the information provided by the participants in the course of the competition and that any enquiries regarding the competition should be addressed to us.

      The participants' data will be deleted as soon as the competition or contest has ended and the data is no longer required to inform the winners or because queries regarding the competition can be expected. In principle, the participants' data will be deleted at the latest 6 months after the end of the competition. Winners' data may be retained for longer, e.g. in order to be able to answer questions about the prizes or to fulfil the prize services; in this case the retention period depends on the type of prize and is up to three years in the case of items or services, for example, in order to be able to process warranty claims. Furthermore, the participants' data may be stored for a longer period of time, e.g. in the form of reports on the competition in online and offline media.

      If data has also been collected for other purposes within the framework of the competition, its processing and the period of storage are governed by the data protection information on this use (e.g. in the case of registration for the newsletter within the framework of a competition).

      • Types of data processed: Inventory data (e.g. names, addresses), content data (e.g. text entries, photographs, videos).
      • Persons concerned: Participants in competitions and competitions.
      • Purposes of processing: Conducting competitions and contests
      • Legal bases: Fulfilment of contract and pre-contractual enquiries (Art. 6 Paragraph 1 S. 1 lit. b. DSGVO).

      online marketing

      We process personal data for the purposes of online marketing, 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 its effectiveness.

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

      The IP addresses of users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect the users. In general, the online marketing procedure does not store any clear data of the users (such as e-mail addresses or names), 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 the cookies or by means of similar procedures. These cookies can later generally also be read out on other websites that use the same online marketing procedure and analysed for the purpose of presenting content and supplemented with further data and stored on the server of the online marketing procedure provider.

      As an exception, 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 procedure we use and the network links the user profiles with the aforementioned data. Please note that users can make additional agreements with the providers, e.g. by giving their consent during the registration process.

      In principle, we only gain access to summarized information on the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyse the success of our marketing measures.

      Unless otherwise stated, 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 processing data is consent. Otherwise, the users' data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-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.

      Facebook pixel: On the one hand, the Facebook pixel enables Facebook to determine the visitors to our online offer as a target group for the display of ads (so-called "Facebook ads"). Accordingly, we use the Facebook pixel to ensure that the Facebook Ads placed by us are only shown to those users on Facebook and within the services of partners cooperating with Facebook (so-called "Audience Network" https://www. facebook.com/audiencenetwork/ ) who have also shown an interest in our online offering or who exhibit certain characteristics (e.g. interest in certain topics or products, which can be seen from 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 the users and are not annoying. With the help of the Facebook Pixel, we can also track the effectiveness of 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 measurement").

      • Processed data types: Usage data (e.g. visited websites, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (data indicating the location of an end user's terminal equipment).
      • Affected persons: users (e.g. website visitors, users of online services), interested parties.
      • purposes of processing: tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, visitor action evaluation, interest-based and behaviour-based marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of recurring visitors), target group formation (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes)
      • security measures:IP masking (pseudonymisation of the IP address).
      • legal bases:consent (Art. 6 Para. 1 S. 1 lit. a DSGVO), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. DSGVO).
      • Opt-out: We refer to the data protection information of the respective providers and the opt-out options provided for the providers. If no explicit opt-out possibility has been indicated, there is, on the one hand, the possibility that you switch off cookies in the settings of your browser. However, this can restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which together be offered in summary form for the following territories: (a) Europe: https://www.youronlinechoices.eu. (b) Canada: https://www.youradchoices.ca/choices. (c) USA: https://www.aboutads.info/choices. (d) Canada: https://optout. aboutads.info.

      Services and service providers:

      affiliate programs and affiliate links

      In our online offer we include so-called affiliate links or other references (which may include discount codes, for example) to the offers and services of third parties (collectively referred to as "affiliate links"). If users follow the affiliate links or subsequently take advantage of the offers, we may receive a commission or other benefits from these third party providers (collectively referred to as "commission").

      In order to track whether users have taken advantage of the offers of an affiliate link we have set up, it is necessary for the respective third party providers to learn that users have followed an affiliate link set up within our online offer. The assignment of the affiliate links to the respective business transactions or other actions (e.g. purchases) serves the sole purpose of the commission settlement and is cancelled as soon as it is no longer necessary for the purpose.

      For the purposes of the aforementioned assignment of the affiliate links, the affiliate links can be supplemented by certain values which are a component of the link or can be stored in another way, e.g. in a cookie. These values can include in particular the initial website (referrer), the time, an online identification of the operator of the website on which the affiliate link was located, an online identification of the respective offer, the type of link used, the type of offer and an online identification of the user.

      Notes on legal bases: If we ask users for their consent to the use of the third-party providers, the legal basis for processing data is consent. Furthermore, their use can be a component of our (pre-)contractual services, so far as the use of third parties has been agreed in this context. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.

      • Processed data types: Contract data (e.g. subject matter of the contract, duration, customer category), usage data (e.g. visited websites, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
      • Affected persons: Users (e.g. website visitors, users of online services).
      • Purposes of processing: Affiliate tracking.
      • legal bases: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

      Presences in social networks

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

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

      Remotely, users' data within social networks are generally processed for market research and advertising purposes. Thus, for example, user profiles can be created based on user behaviour and the resulting interests of the users. The user profiles can in turn 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 the users' computers, in which the usage behaviour and interests of the users are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to these).

      For a detailed presentation of the respective forms of processing and the possibilities of objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.

      Also in the case of requests for information and the assertion of rights of the persons concerned, we point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can take appropriate measures and provide information directly. Should you nevertheless require assistance, you can contact us.

      • Processed data types: Stock data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
      • Affected persons: Users (e.g. website visitors, users of online services).
      • Purposes of processing: Contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
      • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. DSGVO).

      Used services and service providers:

      Plugins and embedded functions as well as content

      We integrate function and content elements into our online offer, which are obtained from the servers of their respective providers (hereinafter referred to as "third party providers"). These can be, for example, graphics, videos or social media buttons and contributions (hereinafter uniformly referred to as "content").

      The integration always requires 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 to display these contents or functions. We make every effort to use only such content whose respective providers use the IP address only to deliver the content. Third party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information on the browser and the operating system, websites to be referred to, the time of visit and other information on the use of our online offer, as well as being linked to such information from other sources.

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

      • Processed data types:Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. (e.g. device information, IP addresses), location data (data indicating the location of an end user's terminal equipment), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos).
      • Affected persons: Users (e.g. (e.g. website visitors, users of online services).
      • purposes of processing: provision of our online offer and user-friendliness, contractual services and service, security measures, administration and answering of enquiries.
      • undefined: legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO), Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO).

      Used services and service providers:

      Deletion of data

      The data processed by us will be deleted in accordance with the legal requirements as soon as their consent permitted for processing is revoked or other permissions cease to apply (e.g..,

      If the data are not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or that must be stored for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.

      Further information on the deletion of personal data can also be found in the individual data protection notes of this data protection declaration.

      Change and update of the data protection declaration

      We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes make it necessary for you to take action to cooperate (e.g. consent) or to receive other individual notification.

      If we provide addresses and contact information of companies and organisations in this data protection declaration, please note that the addresses may change over time and please check the information before contacting us.

      Rights of the persons concerned

      As a data subject, you are entitled to various rights under the DSGVO, which are derived in particular from Art. 15 to 18 and 21 DPA:

      • right to object: you have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data relating to you that is carried out pursuant to Art. 6, paragraph 1, letters e or f DPA; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing, including profiling, insofar as it is linked to such direct marketing.
      • Right to withdraw consent: You have the right to withdraw consent at any time.

      Definitions of terms

      This section gives you an overview of the terms used in this Data Protection Declaration. Many of the terms are taken from the law and are defined above all in Art. 4 DSGVO. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.

      • Affiliate tracking:In the context of affiliate tracking, links are logged by means of which the linking websites refer users to websites with product or other offers. The operators of the respective linking websites can receive a commission if users follow these so-called affiliate links and then take advantage of the offers (e.g. buy goods or services). To this end, it is necessary for the providers to be able to track whether users who are interested in certain offers subsequently take notice of them at the instigation of the affiliate links. Therefore, for affiliate links to work, it is necessary for them to be supplemented with certain values that become part of the link or are otherwise stored, e.g. in a cookie. These values include in particular the initial website (referrer), the time, an online identification of the operator of the website on which the affiliate link was located, an online identification of the respective offer, an online identification of the user as well as tracking specific values such as, e.g. ad media ID, partner ID and categorizations.
      • visit tracking: "Conversion Tracking" is a method to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user's device within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, we can track whether the ads we placed on other websites were successful).
      • Cross-Device Tracking: Cross-Device Tracking is a form of tracking in which user behavioral and interest information is recorded across devices in so-called profiles by assigning users an online ID. This allows the user information to be analyzed for marketing purposes, regardless of the browser or device used (e.g. mobile phones or desktop computers). With most providers, the online identification is not linked to clear data, such as names, postal addresses or e-mail addresses.
      • IP-Masking: IP-Masking is a method in which the last octet, i.e. the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. IP-Masking is therefore a means of pseudonymising processing methods, especially in online marketing >/li>
      • Interest-based and behaviour-based marketing: One speaks of interest-based and/or behaviour-based marketing when potential interests of users in advertisements and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behaviour (e.g. visiting and staying on certain websites, buying behaviour or interaction with other users), which is stored in a so-called profile. Cookies are usually used for these purposes.
      • Conversion measurement: Conversion measurement is a method by which the effectiveness of marketing measures can be determined. 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, this enables us to track whether the ads we have placed on other websites have been successful.
      • Personal Data: "Personal Data" is any information relating to an identified or identifiable natural person (hereinafter referred to as "Data Subject"); a natural person is deemed identifiable if he or she is directly or indirectly, in particular by means of association with an identifier such as a name, an identification number, location data, online identification (e.g., a website address, telephone number, e-mail address, etc.), or a website address. (e.g. cookie) or one or more special features which reveal the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
      • Range measurement:Range measurement (also known as web analytics) is used to evaluate the streams of visitors to an online offering and can include the behaviour or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, identify at what time visitors visit their website and what content they are interested in. This enables them to better adapt the contents of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis purposes in order to recognise returning visitors and thus obtain more precise analyses of the use of an online offering.
      • Remarketing: Remarketing" or "retargeting" is the term used when, for example, it is noted for advertising purposes in which products a user on a website is interested, in order to remind the user of these products on other websites, e.g. in advertisements.
      • Tracking: Tracking is the term used when the behaviour of users can be traced across several online offers. As a rule, behavioral and interest information regarding the online offers used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
      • responsible: "Responsible person" is the natural or legal person, authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data.
      • Target group formation: The term "target group formation" (or "custom audiences") is used when target groups are defined for advertising purposes, e.g. insertion 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 where he/she viewed the products. Lookalike Audiences" (or similar target groups) are, in turn, when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating custom audiences and lookalike audiences.
      • terms: personal data, person responsible, processing.

      Created with free data protection generator.de von Dr. Thomas Schwenke


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