Privacy Policy

Introduction

With the following data protection declaration we would like to explain to you which types of your personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer").

The terms used are not gender specific.

As of November 23, 2020

Contents overview

  • Introduction
  • Responsible person
  • Overview of processing
  • Relevant legal basis
  • Safety measures
  • Transmission and disclosure of personal data
  • Data processing in third countries
  • Use of cookies
  • Commercial and business services
  • Payment service provider
  • Provision of the online offer and web hosting
  • Special notes on applications (apps)
  • Registration, login and user account
  • Single sign-on registration
  • Contact
  • Push messages
  • Newsletters and electronic notifications
  • Advertising communication via email, post, fax or telephone
  • Sweepstakes and competitions
  • Polls and surveys
  • Web analysis, monitoring and optimisation
  • Online marketing
  • Presence in social networks (social media)
  • Plugins and embedded functions as well as content
  • Deletion of data
  • Change and update of the data protection declaration
  • Data Subject Rights
  • Definitions of terms

 

Responsible Person:

Ously Games GmbH

Berger Str. 188-190 
60385 Frankfurt am Main 
info@ouslygames.com

 

Authorised representatives: Jens Kleemann, Managing Director

Email address: jens@ously.de

Overview of processing

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

 

Types of data processed

  • Event data (Facebook) ("event data" is data that can be transmitted from us to Facebook, for example via Facebook pixels (via apps or in other ways) and relate to people or their actions; Data includes, for example, information about visits to websites, interactions with content, functions, installation of apps, purchases of products, etc; the event data is processed for the purpose of creating target groups for content and advertising information (custom audiences ); event data does not contain the actual content (such as written comments), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data will be deleted by Facebook after a maximum of two years. The target groups formed from the data are deleted when our Facebook account is deleted.

 

  • Inventory data (e.g. names, addresses)
  • Content data (e.g. entries in online forms)
  • Contact details (e.g. email, telephone numbers)
  • Meta / communication data (e.g. device information, IP addresses)
  • Usage data (e.g. websites visited, interest in content, access times)
  • Image and / or video recordings (e.g. photographs or video recordings of a person)
  • Location data (information on the geographical position of a device or a person)
  • Contract data (e.g. subject of the contract, duration, customer category)
  • Payment data (e.g. bank details, invoices, payment history)

 

Categories of data subjects

  • Business and contractual partners
  • Interested persons
  • Communication partners
  • Customers
  • Users (e.g. website visitors, users of online services)
  • Sweepstakes and competition participants

 

Purposes of processing

  • Affiliate Tracking
  • Registration process
  • Quality of our online offer and user-friendliness
  • Conversion measurement (measurement of marketing effectiveness)
  • Office and organisational procedures
  • Click tracking
  • Cross-device tracking (cross-device processing of user data for marketing purposes)
  • Direct marketing (e.g. by email or post)
  • Conducting sweepstakes and competitions
  • Feedback (e.g. collecting feedback via an online form)
  • Interest-based and behavioural marketing
  • Contact requests and communication
  • Profiling (creation of user profiles)
  • Remarketing
  • Range measurement (e.g. access statistics, recognition of returning visitors)
  • Safety measures
  • Tracking (e.g. interest / behavioural profiling, use of cookies)
  • Server monitoring and error detection
  • Provision of contractual services and customer service
  • Management and answering of inquiries
  • Target group formation (determination of target groups relevant for marketing purposes or other output of content)

 

Relevant legal basis

In the following we share the legal basis of the General Data Protection Regulation (GDPR), which controls how we process personal data. Please note that in addition to the regulations of the GDPR, the national data protection requirements in your or our country of residence and domicile may apply. If a more specific legal basis is relevant in individual cases, we will inform you of this in the data protection declaration.

 

  • Consent (Art. 6 para. 1 lit. a. GDPR) - the data subject has given consent to the processing of his or her personal data for one or more specific purposes
  • Contract and pre-requests (Art. 6 para. 1 lit. b. GDPR) - processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
  • Legal obligation (Art. 6 para. 1  lit. c. GDPR) - processing is necessary for compliance with a legal obligation to which the controller is subject
  • Legitimate interests (Art. 6 para. 1 S. 1 lit. f. GDPR) - The processing is necessary to protect the legitimate interests of the controller or a third party, not as long as the interests or fundamental rights and freedoms of the data subject, the personal protection Data require, predominate.

 

National data protection regulations in Germany : In addition to the data protection regulations of the General Data Protection Regulation, national data protection regulations apply in Germany. This includes the law on the protection against misuse of personal data during data processing (Federal Data Protection Act - BDSG). The BDSG contains special regulations on the right to information, the right to erasure, 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. It also 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 can be applied.

 

Safety measures

We take appropriate technical and organisational measures in accordance with legal requirements, taking into account current best practices, implementation costs and the type, scope, circumstances and purposes of processing as well as the risk level and the extent of the threat to the rights and freedoms of natural persons to ensure an appropriate level of protection.

The measures include securing the confidentiality, integrity and availability of data by controlling physical and electronic access to the data. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to the threat to the data. We promote the protection of personal data in the development or selection of hardware, software and procedures through technology design and data protection-friendly default settings.

Transmission and disclosure of personal data

As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organisational units or persons. The recipients of this data can 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 a case, we observe the legal requirements and in particular conclude corresponding contracts or agreements that serve to protect your data with the recipients of 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 data is processed by third party services or the disclosure or transfer of data to other persons, offices or companies takes place, this is only done in accordance with the legal requirements. 

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

 

Use of cookies

Cookies are text files that contain data from websites or domains that are visited which are stored on the user's computer by a browser. A cookie is primarily used to store information about a user during or after their visit to a website. The stored information can include, for example, the language settings on a website, login status, a shopping cart or the location at which 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")

 

A distinction is made between the following cookie types and functions:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left a website and closed their browser
  • Permanent cookies: Permanent cookies are saved even after the browser is closed. For example, login status can be saved or preferred content can be displayed directly when the user visits a website again. The interests of users which are used to measure reach or for marketing purposes can also be stored in such a cookie
  • First-party cookies: First-party cookies are set by ourselves
  • Third-party cookies: Third-party cookies are mainly used by advertisers (so-called third parties) to process user information
  • Necessary (also: essential or absolutely necessary) cookies: Cookies that are absolutely necessary for the operation of a website (e.g. to save logins or other user input or for security reasons).
  • Statistics, marketing and personalisation cookies : In addition, cookies are also used for range measurement and when the interests of a user or his behaviour (e.g. viewing certain content, using functions, etc.) on individual websites in a user profile get saved. Such profiles are used to show users content that corresponds to their potential interests in example. This process is also known as "tracking", i.e. following up the potential interests of users. Insofar as we use cookies or "tracking" technologies, we will inform you separately in our data protection declaration or while obtaining consent.

Notes on legal basis: The legal basis on which we process your personal data with the help of cookies depends on whether we ask for your consent. If this is the case and you consent to the use of cookies, the legal basis for 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 the commercial operation of our online offer and its improvement) or, if the use of cookies is necessary, in order to fulfil our contractual obligations.

Storage duration If we do not provide you with any explicit information on the storage duration of permanent cookies (e.g. in the context of a so-called cookie opt- in), please assume that the storage duration can be up to two years.

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

Processing of cookie data on the basis of consent : Before we process or have data processed from the use of cookies, we ask the users for consent that can be revoked at any time. If consent has not been given, cookies may be used that are absolutely necessary for the operation of our online offer.

  • Processed data types: 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)
  • Legal basis: (Art. 6. para. 1 lit. a. GDPR), authorised interests (Art. 6 para. 1 lit. f. GDPR)

 

Commercial and business services

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

We process this data to fulfil our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as the business organisation. We only pass on the data of the contractual partners to third parties within the scope of applicable law to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations or with the consent of the persons concerned (e.g. to telecommunications, transport and other auxiliary services involved as well 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.

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

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

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

Customer account : Contractual partners can create an account within our online offer (e.g. customer or user account, "customer account" for short). If the registration of a customer account is required, contractual partners will be informed of this as well as the information required for registration. The customer accounts are not public and cannot be indexed by search engines. As part of the registration as well as subsequent logins and uses of the customer account, we save the IP addresses of the customers along with the access times in order to be able to prove the registration and prevent any misuse of the customer account.

If customers have cancelled their customer account, the data relating to the customer account will be deleted, subject to their retention being required for legal reasons. It is the responsibility of the customer to save their data if the customer account is terminated.

Shop : We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and related services, as well as their payment and delivery or execution. We use the services of banks and payment service providers to process payment transactions. The information required is marked as such in the context of the order or comparable purchase process and includes the information required for delivery or provision and billing as well as contact information in order to be able to hold any consultation.

 

Joint Controllership English

 

Games services from Evoplay Entertainment BV: We are jointly responsible together with Evoplay Entertainment BV, Fransche Bloemweg 4, Curaçao, website: https://evoplay.com/ (“Evoplay”) for the processing of your data for the use of the games offered by Evoplay Services on our platform. We have concluded an agreement with Evoplay in accordance with Art. 26 GDPR, which in particular regulates which legal Obligations and which security measures each responsible person assumes.  In this agreement, the responsible persons also declare that they will process personal data in accordance with the data protection regulations applicable in the European Union, i.e. in particular the GDPR. The agreement relates to data processing that is associated with the use of the Games-Services offered by Evoplay:

 

  1. If you use Games-Services of Evoplay via our platform, following data is being transmitted from us to Evoplay for further processing: Your user ID (i.e., a pseudonymous identifier with which you are identified as users of our services in our system) information about your gaming activity and game balance. The purpose of the transmission and processing of this data to and by Evoplay is to provide the Games-Services offered by Evoplay and to provide other contractual services such as billing for the Evoplay Games-Services used by the user. The legal basis of this data processing is Art. 6 para. 1 sentence 1 lit. b. GDPR.

 

Since Evoplay is based in Curaçao and as result the aforementioned data is transferred to a country outside the EEA, we have also concluded an agreement with Evoplay in accordance with the EU standard contractual clauses within the meaning of Art. 46 para. 2 lit. c. GDPR, in which Evoplay guarantees to ensure and comply with the level of data protection guaranteed by the GDPR when processing your data.

 

  1. Furthermore, Evoplay collects and processes following data of the user on their website and their interfaces while using the Evoplay offered Games-Services: a) information on the web browser of the user so-called "browser data. "(e.g. browser type), b) information about the devices used by the user, so-called" device data "(e.g. IP addresses, operating system) and c) the user's user country code. Browser and device data are collected and processed exclusively for the provision of technical support services (in particular to correct error messages and faults with regard to the software) in relation to the Games-Services offered by Evoplay. Evoplay needs the User Country Code in order to be able to adapt the offered Games-Services to the legal provisions of the user's country of residence and domicile and to be able to check whether technical problems with the software on which the Games-Services are based were caused by geographical factors. Legal basis of this data processing is Art. 6 para. 1 sentence 1 lit. b. and lit. c. GDPR.

 

Further information about the processing of personal data by Evoplay can be found here: https://evoplay.com/

 

Although you can assert your rights (especially access, cancellation, opposition etc.)  against either of the two responsible bodies, we have set up following central point for your questions and comments:

 

Ously Games GmbH

Berger Str. 188-190

60385 Frankfurt am Main

Germany

Tel: + 49 69 944 111 80

Email: info@ouslygames.com

 

As part of our joint responsibility for the processing of your data by us and Evoplay, we have committed ourselves to fulfil the information obligations in accordance with Art. 13, 14 GDPR, to be the point of contact for your rights and to take over communication and cooperation with the data protection authorities responsible under the GDPR.

 

Offer of software and platform services : We process the data of our users using registered or test account (hereinafter uniformly referred to as "users") in order to be able to provide them with our contractual services and on the basis of legitimate interests to ensure the security of our offer and to be able to develop it further. The information required is identified as such in the context of the conclusion of the order or comparable contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations.

Further information on commercial services : We process the data of our customers and clients (hereinafter collectively referred to as "customers") in order to enable them to select, purchase or commission the selected services or works as well as related activities as well as their payment and delivery or to enable execution or provision.

The information required is identified as such when entering into an order, order or comparable contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations.

  • Processed data types: inventory data (e.g. names, addresses), payment data(e.g. bank details, invoices, payment history), contact details (e.g. e-mail, telephone numbers), contract data (e.g. subject of the contract, term, 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: Provision of contractual services and customer service, contact inquiries and communication, office and organisational procedures, administration and answering of inquiries, security measures
  • Legal basis: contract and pre-requests (Art. 6 para. 1 lit b. GDPR) Legal obligation (Art. 6 para. 1 lit c. GDPR), Legitimate interests (Art. 6 para. 1 lit. f. GDPR)

 

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 including banks and credit institutions and other payment service providers (collectively "payment service providers").

The data processed by the payment service provider includes inventory data such as name and address, bank data such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient-related information. The information is required to carry out the transactions. However, the data entered will only be processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, only whether the payment was approved or rejected. Under certain circumstances, the data will be transmitted to credit agencies by the payment service provider. The purpose of this transmission is to check your identity and creditworthiness. For this purpose, we refer to the terms and conditions and the data protection information of the payment service providers.

The terms and conditions and data protection notices of the respective payment service providers, which can be called up on the respective websites or transaction applications, apply to payment transactions. We refer to this also for the purpose of further information and assertion of revocation, information and other rights of data subject.

 

  • Processed data types: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data(e.g. subject matter of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. Device information, IP addresses), contact data (e.g. e-mail, telephone numbers)
  • Affected persons: customers, interested parties
  • Purposes of processing: Provision of contractual services and customer service, contact inquiries and communication, affiliate tracking
  • Legal basis: contract and pre-requests (Art. 6 para 1. lit b GDPR), Authorised interests (Art. 6 para. 1 lit. f. GDPR)

Used services and service providers:

 

Provision of the online offer 

In order to be able to provide our online offer safely 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 can use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.

The data processed as part of the provision of the hosting service can include all information relating to the users of our online offer that is generated in the context of use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or from websites.

Collection of access data and log files: We (or our web hosting provider ) collect data on every access to the server (server log files). The server log files can include the address and name of the websites and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and IP Addresses.

The server log files can be used for security purposes, e.g. to avoid overloading the server (especially in the case of abusive attacks such as DDoS attacks) and to ensure server stability.

  • Processed data types: content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information, IP addresses).
  • Affected persons: users (e.g. website visitors, users of online services).
  • Legal basis: authorised interests (Art. 6 para.1 lit f GDPR)

Used services and service providers:

 

Special notes on applications (apps)

We process the data of the users of our application insofar as this is necessary in order to provide users with the application and its functionalities, monitor its security and be able to develop it further. We can also contact users in compliance with the legal requirements, provided that communication is necessary for purposes of administration or use of the application. For the rest, we refer to the data protection information in this document with regard to the processing of user data.

Legal basis: The processing of data, which is necessary for the provision of the functionalities of the application, serves the fulfilment of contractual obligations. This also applies if the provision of the functions requires user authorisation (e.g. enabling device functions). If the processing of data is not required for the provision of the functionalities of the application, but serves the security of the application or our business interests (e.g. collection of data for the purpose of optimising the application or security purposes), it is carried out on the basis of our legitimate interests. If users are expressly asked for their consent to the processing of their data, the processing of the data takes place on the basis of the consent.

Commercial use :

We process the data of the users of our application, registered and any test users (hereinafter uniformly referred to as "users") in order to be able to provide them with our contractual services and on the basis of legitimate interests to ensure the security of our application and to further develop it. 

Storage of a universal and unique identifier (UUID) :

The application stores a universal and unique identifier (" Universal Unique Identifier", UUID) for the purpose of analysing the use and functionality of the application and for storing user settings . This identifier is used when installing the application.

Storage of a pseudonymous identifier :

We use a pseudonymous identifier so that we can provide the application and ensure its functionality. 

Device permissions for access to functions and data :

The use of our application or its functionalities may require user authorisations for access to certain functions of the devices used or to the data stored on the devices or accessible with the help of the devices. 

Access to the camera and saved recordings :

When using our application, image and / or video recordings (including audio recordings) of the user (and of other persons recorded by the recordings) are processed by accessing the camera functions or saved recordings. 

No location history and no movement profiles :

The location data is only used selectively and not to create a location history 

  • Processed data types: inventory data (e.g. names, addresses), meta / communication data (e.g. device information, IP addresses), image and / or video recordings (e.g. photographs or video recordings of a person), location data (information on geographical position a device or a person).
  • Purpose of processing: Provision of contractual services and customer service.
  • Legal basis: Consent (Art. 6 para. 1 lit. a. GDPR), Performance and pre-requests (Art. 6 para. 1 lit. b. GDPR), Legitimate interests (Art.  6 para. 1 lit. f. GDPR)

 

Registration, login and user account

Users can create a user account. As part of the registration, the mandatory information is communicated to the users and processed for the purpose of providing the user account on the basis of contractual obligations. The processed data includes the login information (name, password and an email address). The data entered during registration will be used for the purpose of maintaining the user account.

Users can be informed by email about processes that are relevant to their user account, such as technical changes. If users have cancelled their user account, their data will be deleted subject to a statutory retention requirement. It is up to the users to save their data in the event of termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the contract period.

As part of the use of our registration and login functions and the use of the user account, we save the IP address and the time of the respective user action. The storage takes place on the basis of our legitimate interests as well as those of the users in protection against misuse and other unauthorised use. This data is not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.

Two-factor authentication : Two-factor authentication offers an additional layer of security for your user account and ensures that only you can access your account, even if someone else knows your password.

For this purpose, in addition to your password, you must carry out a further authentication measure (e.g. enter a code sent to a mobile device). We will inform you about the procedure we use.

  • Processed data types: inventory data (e.g. first name, last name, address, date of birth, gender), contact information (e.g. e-mail, phone numbers), content data (e.g. input into online forms), meta / communications data (e.g., device information, IP addresses)
  • Affected persons: users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and customer service, security measures, administration and answering inquiries.
  • Legal basis: Consent (Art.6 para. 1 lit. a GDPR), Performance and pre-requests (Art. 6 para. 1 lit. b. GDPR) , Legitimate interests (Art. 6 para 1. lit. f. GDPR).

 

Single sign-on registration

"Single sign-on" or "single sign-on registration” or" authentication" are processes that allow users to register with a provider of single sign-on processes (e.g. a social network), also to register with our online offer. Condition of single sign -On -Authentication is that the users are registered with the respective single sign -on provider and enter the required access data in the online form provided, or are already registered with the single sign -on provider and confirm on registration via the appropriate button. 

The authentication takes place directly with the respective single sign -on provider. As part of such authentication, we receive a user ID with the information that the user is logged in to the respective single sign -on provider under this user ID and an ID that cannot be used for other purposes (so-called "user handle") Whether additional data is transmitted to us depends solely on the single sign -on procedure used, the selected data releases as part of the authentication and also on which data users in the privacy or other settings of the user account for single - Sign -On provider. Depending on the single sign -on provider and the choice of user, different data can be used, usually the email address and the username. The password entered in the sign -on procedure with the single sign -on provider is neither visible to us, nor is it stored by us.

Users are asked to note that the information we store can be automatically compared with their user account with the single sign -on provider, but this is not always possible or actually takes place. If, for example, the users' email addresses change, they have to change them manually in their user account with us.

If agreed with the users, we can use the single sign -on registration within the framework of or before the fulfilment of the contract, insofar as the users have been asked to do so, process it within the framework of a consent and otherwise set it on the basis of the legitimate interests on our part and the Interests of users in an effective and secure login system.

Should users ever decide that they no longer want to use the link to their user account with the single sign -on provider for the single sign -on procedure, they must cancel this connection within their user account with the single sign -on provider. If users want to delete their data with us, they have to cancel their registration with us.

Facebook Single Sign -On : We work with Facebook Ireland Ltd. for the collection or receipt as part of a transmission (but not the further processing) of "event data" that Facebook collects using the Facebook single sign -on registration process that is carried out on our online offer or as part of a Transmission for the following purposes: a) Display of content advertising information that corresponds to the presumed interests of the users; b) Delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) Improving the delivery of advertisements and personalising functions and content (e.g. improving the recognition of which content or advertising information presumably corresponds to the interests of the users). We have concluded a special agreement with Facebook ("Addition for those responsible", https://www.facebook.com/legal/controller_addendum ), which regulates in particular which security measures Facebook must observe ( https: //www.facebook. com / legal / terms / data_security_terms ) and in which Facebook has agreed to fulfil the rights of the data subject (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with measured values, analysis and reports (which are aggregated, i.e. they do not receive any information about individual users and are anonymous to us), then this processing does not take place within the framework of joint responsibility, but on the basis of an order processing contract ("data processing conditions" , https://www.facebook.com/legal/terms/dataprocessing ), the "data security conditions" ( https://www.facebook.com/legal/terms/data_security_terms ) and with regard to processing in the USA based on of standard contractual clauses ("Facebook-EU-data transfer addendum, https://www.facebook.com/legal/EU_data_transfer_addendum ). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are covered by the agreements with Facebook.

Instagram Single Sign -On : We work with Facebook Ireland Ltd. for the collection or receipt as part of a transmission (but not the further processing) of "event data" that Facebook collects using the Instagram single sign -on registration process that is carried out on our online offer or as part of a Transmission for the following purposes: a) Display of content advertising information that corresponds to the presumed interests of the users; b) Delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) Improving the delivery of advertisements and personalising functions and content (e.g. improving the recognition of which content or advertising information presumably corresponds to the interests of the users). We have concluded a special agreement with Facebook ("Addition for those responsible", https://www.facebook.com/legal/controller_addendum ), which regulates in particular which security measures Facebook must observe ( https: //www.facebook. com / legal / terms / data_security_terms ) and in which Facebook has agreed to fulfil the rights of the data subject (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with measured values, analysis and reports (which are aggregated, i.e. they do not receive any information about individual users and are anonymous to us), then this processing does not take place within the framework of joint responsibility, but on the basis of an order processing contract ("data processing conditions") , https://www.facebook.com/legal/terms/dataprocessing ), the "data security conditions" ( https://www.facebook.com/legal/terms/data_security_terms ) and with regard to processing in the USA based on of standard contractual clauses ("Facebook-EU-Datenübermittlungszusatz, https://www.facebook.com/legal/EU_data_transfer_addendum ). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are covered by the agreements with Facebook.

  • Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), event data (Facebook) ("event data" are data, e.g. via Facebook pixels (via apps or on other ways) can be transmitted by us to Facebook and relate to people or their actions; the data includes, for example, information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc .; The event data is processed for the purpose of creating target groups for content and advertising information (custom audiences ); event data does not contain the actual content (such as written comments), no login information and no contact information (i.e. no names, e- Mail addresses and telephone numbers). Event data will be deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account)
  • Affected persons: users (e.g. website visitors, users of online services)
  • Purposes of processing: Provision of contractual services and customer service, registration process
  • Legal basis: Consent (Art. 6 para. 1 lit. a GDPR), Performance and pre-requests (Art. 6 para. 1 lit. b. GDPR) , Legitimate interests (Art. 6 para. 1. lit. f. GDPR)

Used services and service providers:

 

Contact

When you contact us (e.g. via the contact form, email, telephone or via social media), the details of the inquiring person are processed, insofar as this is necessary to answer the contact inquiries and any requested measures.

The answering of contact inquiries in the context of contractual or pre-contractual relationships is carried out to fulfil our contractual obligations or to answer (pre) contractual inquiries and otherwise on the basis of legitimate interests in answering the inquiries.

  • Processed data types: inventory data (e.g. names, addresses), contact details (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms).
  • Affected persons: communication partner.
  • Purposes of processing: contact requests and communication.
  • Legal basis: contract and pre-requests (Art. 6 para. 1 lit. b. GDPR), Authorised interests (Art. 6 para. 1. lit. f. GDPR)

 

Push messages

With the consent of the user, we can send so-called "push notifications" to the users. These are messages that are displayed on the screens, devices or in the browsers of the users, even when our online service is not actively used.

In order to register for the push notifications, users must confirm the query on their browser or device to receive the push notifications. This approval process is documented and saved. The storage is necessary in order to recognise whether users have agreed to receive the push messages and to be able to prove their consent. For this purpose, a pseudonymous browser identifier (so-called "push token") or the device ID of a device is saved.

Push notifications may be required to fulfil contractual obligations (e.g. technical and organisational information relevant to the use of our online offer ) and are otherwise, unless specifically mentioned below, sent on the basis of the consent of the user. Users can change the receipt of push messages at any time using the notification settings of their respective browser or device.

Push messages with advertising content :

The push notifications we send can contain promotional information. The promotional push messages are processed based on the consent of the user.

Analysis and success measurement :

We evaluate push messages statistically and can thus recognise whether and when push messages were displayed and clicked. This information is used to technically improve our push messages based on the technical data or the target groups and their retrieval behaviour or retrieval times. This analysis also includes determining whether the push messages are opened, when they are opened and whether users interact with their content or buttons. For technical reasons, this information can be assigned to the individual push message recipients. However, it is neither our aim nor, if used, that of the shipping service provider to observe individual users.

 

  • Processed data types: usage data (e.g. websites visited, interest in content, access times).
  • Purposes of processing: Provision of contractual services and customer service, direct marketing (e.g. by email or post), range measurement (e.g. access statistics, recognition of returning visitors)
  • Legal basis (Art. 6  para. 1 lit. a. GDPR), Contract and pre-requests (Art. 6 para. 1 lit. b. GDPR)

Used services and service providers:

Newsletters and electronic notifications

We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter "newsletter") only with the consent of the recipient or a legal permission. Insofar as the contents of a newsletter are concretely described, they are authoritative for the consent of the users. Incidentally, our newsletters contain information about Spinarena and its programs and events, as well as programs and events relevant to our target groups.

In order to register for our newsletters, it is generally sufficient to provide your email address. However, we can ask you to provide a name for the purpose of addressing you personally in the newsletter, or to provide further information if this is necessary for the purposes of the newsletter.

Double- Opt -In-process: The subscription to our newsletter is a double- Opt -In process. In other words, after registering you will receive an email asking you to confirm your registration. This confirmation is necessary so that nobody can register with someone else's email address. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider are also logged.

Deletion and restriction of processing: We can save the unsubscribed email addresses for up to three years on the basis of our legitimate interests (in order to be able to prove a previously given consent) before we delete them. 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 previous existence of consent is confirmed at the same time. In the event of obligations to permanently observe contradictions, we reserve the right to store the email address in a block list for this purpose alone.

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving that it has proceeded properly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure mailing system.

Notes on legal bases: The newsletter is sent on the basis of the recipient's consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of advertising to existing customers. Insofar as we commission a service provider to send emails, this is done on the basis of our legitimate interests. The registration process is recorded based on our legitimate interests to prove that it was carried out in accordance with the law.

Analysis and success 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 its server. Technical information, such as information about the browser and your system, as well as your IP address and the time of access, is collected.

This information is used to improve our newsletter on the basis of the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our endeavour nor, if used, that of the shipping service provider to observe individual users. Rather, the evaluations help 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 take place, subject to the express consent of the user, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves both our business interests and the expectations of the users.

A separate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled.

Requirement for the use of free services : Consent to the sending of mailings can be made dependent as a condition for the use of free services (e.g. access to certain content or participation in certain campaigns). If users want to use the free service without registering for the newsletter, we ask you to contact us.

 

  • Processed data types: usage data (e.g. websites visited, interest in content, access times).
  • Purposes of processing: Provision of contractual services and customer service, direct marketing (e.g. by email or post), range measurement (e.g. access statistics, recognition of returning visitors).
  • Legal basis (Art. 6. para. 1 lit. a. GDPR), Contract and pre-requests (Art. 6 para. 1 lit. b. GDPR)

Used services and service providers:

  • Customer.io : Service Provider : Customer.io , 921 SW Washington Street 
    Suite 820 Portland, Oregon, 97205 ; Website: https://customer.io ; Data protection declaration: https://customer.io/legal/privacy-policy/

 

Advertising communication via email, post, fax or telephone

We process personal data for the purposes of advertising communication, which can take place via various channels, such as email, telephone, post or fax, in accordance with legal requirements.

The recipients have the right to revoke their consent at any time or to object to advertising communication at any time.

After revocation or objection, we can store the data required to prove consent for up to three years on the basis of our legitimate interests before we delete them. 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: inventory data (e.g. names, addresses), contact details (e.g. e-mail, telephone numbers).
  • Affected persons: communication partner.
  • Purposes of processing: direct marketing (e.g. by email or post).
  • Legal basis: (Art. 6 para. 1 lit. a. GDPR), authorised interests (Art. 6 para. 1 lit. f. GDPR)

 

Sweepstakes and competitions

We process personal data of the participants in sweepstakes and competitions only in compliance with the relevant data protection regulations, insofar as the processing is contractually required for the provision, implementation and handling of the sweepstakes, the participants have consented to the processing or the processing serves our legitimate interests (e.g. in the Security of the competition or the protection of our interests against misuse through the possible collection of IP addresses when submitting competition entries).

If contributions by the participants are published as part of the competition (e.g. in the context of a vote or presentation of the competition contributions or the winners or reporting on the competition), we point out that the names of the participants can also be published in this context. 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 usage and data protection provisions of the respective platforms also apply. In these cases, we point out that we are responsible for the information provided by the participants in the context of the competition and inquiries regarding the competition are to be directed to us.

The data of the participants will be deleted as soon as the competition is over and the data is no longer required to inform the winners. In principle, the data of the participants will be deleted no later than 6 months after the end of the competition. The winners' data can be retained for longer, for example to answer questions about the prizes or to be able to fulfil the prizes. In this case, the retention period depends on the type of profit and is, for example, up to three years for items or services, in order to be able to process warranty cases. Furthermore, the data of the participants can be stored for a longer time, for example in the form of reporting on the competition in online and offline media.

If data was also collected for other purposes within the framework of the competition, its processing and retention period are based on the data protection information for this use (e.g. in the case of registering for the newsletter as part of a competition).

  • Processed data types: inventory data (e.g. names, addresses), content data (e.g. entries in online forms).
  • Affected persons: Contest and competition participants.
  • Purposes of processing: Carrying out sweepstakes and competitions.
  • Legal basis (Art. 6 para. 1 lit. a. GDPR), authorised interests (Art. 6 para. 1 lit. b. GDPR) Polls and surveys

The polls and surveys carried out by us (hereinafter "surveys") are evaluated anonymously. Personal data are only processed to the extent that this is necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address in order to display the survey in the user's browser or to allow the survey to be resumed using a temporary cookie (session cookie) enable) or users have consented.

Notes on legal bases: If we ask the participants for consent to the processing of their data, this is the legal basis for the processing, otherwise the processing of the participants' data is based on our legitimate interests in carrying out an objective survey.

  • Processed data types: contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information, IP addresses).
  • Affected persons: communication partners , users (e.g. website visitors, users of online services).
  • Purposes of processing: Contact inquiries and communication, direct marketing (e.g. by e-mail or post), tracking (e.g. interest / behavioural profiling , use of cookies), feedback (e.g. collecting feedback via online form).
  • Legal basis: (Art. 6 para. 1 lit. a. GDPR), authorised interests (Art 6 para.1 lit. f. GDPR)

 

Web analysis, monitoring and optimisation

Web analysis (also known as "range measurement") is used to evaluate the flow of visitors to our online offer and can include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the range analysis, we can, for example, recognise at which time our online offer or its functions or content are used most often or invite you to reuse. We can also understand which areas need optimisation.

In addition to web analysis, we can also use test procedures, for example, to test and optimise different versions of our online offer or its components.

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

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

Notes on legal basis: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would 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. device information, IP addresses).

  • Affected persons: users (e.g. website visitors, users of online services).
  • Purposes of processing: Range measurement (e.g. access statistics , recognition of returning visitors , server monitoring and error recognition
  • Security measures: IP masking (pseudonymisation of the IP address).
  • Legal basis: (Art. 6 para.1 lit. a GDPR), authorised interests (Art. 6 para. 1 lit. f. GDPR)

Used services and service providers:

  • Google Analytics: range measurement and web analysis; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/ ; Data protection declaration: https://policies.google.com/privacy .
  • Google Optimise : Use of Google Analytics data for the purpose of improving areas of our online offer and improving the alignment of our marketing measures with the potential interests of users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://optimize.google.com ; Data protection declaration: https://policies.google.com/privacy ; Opposition option ( opt- out): opt -out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de , settings for displaying advertisements: https://adssettings.google.com/authenticated .
  • Google Tag Manager: Google Tag Manager is a solution with which we manage so-called website tags via an interface and thus integrate other services into our online offer (for more information, please refer to this data protection declaration). With the Tag Manager itself (which implements the tags) z. B. has not yet created any user profiles or saved cookies. Google only learns the IP address of the user, which is necessary to run the Google Tag Manager. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com ; Data protection declaration: https://policies.google.com/privacy

 

Advertising / Online marketing

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

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

The IP addresses of the users are also saved. However, we use available IP masking processes (i.e., pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) are stored in the online marketing process, but pseudonyms. In other words, neither we nor the providers of online marketing processes 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 processes. These cookies can later generally also be read out on other websites that use the same online marketing process, analysed for the purpose of displaying content and supplemented with additional data and stored on the server of the online marketing process provider.

As an exception, clear data can be assigned to the profiles. This is the case if the users are, for example, members of a social network whose online marketing process we use and the network connects the profiles of the users with the aforementioned information. We ask you to note that users can make additional agreements with the providers, e.g. by giving their consent during registration.

In principle, we only get access to summarised information about the success of our advertisements. However, within the scope of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e., for example, to a contract with us. The conversion measurement is used solely to analyse the success of our marketing measures.

Unless otherwise stated, assume that the cookies used will be stored for a period of two years.

Notes on legal basis: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would 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. device information, IP addresses).

  • Affected persons: users (e.g. website visitors, users of online services).
  • Purposes of processing: Range measurement (e.g. access statistics , recognition of returning visitors), tracking (e.g. interest / behaviour-based profiling , use of cookies), conversion measurement (measurement of the effectiveness of marketing measures ), profiling (creation of user profiles), server monitoring and error detection, interest-based and behavioural marketing.
  • Security measures: IP masking (pseudonymisation of the IP address).
  • Legal basis: (Art. 6 para. 1 lit. a. GDPR), authorised interests (Art. 6 para. 1 lit. f. GDPR)

 

Used services and service providers:

 

Facebook pixels and target group formation (Custom Audiences ) :

With the help of the Facebook pixel (or comparable functions for the transmission of event data or contact information using interfaces in apps), Facebook is able to target the visitors of our online offer as a target group for the display of advertisements (so-called "Facebook ads" ) to be determined. Accordingly, we use the Facebook pixel to only send the Facebook ads to those users on Facebook and within the services of the partners cooperating with Facebook (so-called " Audience Network" https://www.facebook.com/audiencenetwork/) ) who have also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products that can be seen from the websites visited) that we transmit to Facebook (so-called "Custom Audiences "). We also want to ensure that our Facebook ads correspond to the potential interest of the user and are not annoying. With the help of the Facebook pixel we can also understand the effectiveness of the Facebook ads for statistical and market research purposes.

 

  • Processed data types: 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), interested parties.
  • Purposes of processing: Tracking (e.g. interest / behaviour-based profiling , use of cookies), remarketing , conversion measurement (measurement of the effectiveness of marketing measures), interest-based and behaviour-related marketing, profiling (creation of user profiles), range measurement (e.g. access statistics, recognition of returning visitors) , Click tracking, 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 basis: (Art. 6 para. 1 lit. a. GDPR), authorised interests (Art. 6 para. 1 lit. f. GDPR)
  • Opposition option ( opt- out): We refer to the data protection informationof the respective provider and the options for objection given to the provider (so-called " opt- out"). If no explicit opt -out option has been specified, there is the option of switching off cookies in your browser settings. However, this can restrict the functions of our online offer. We therefore also recommend the following opt -out options, which are offered in summary for the respective areas : a ) Europe: https://www.youronlinechoices.eu . b) Canada: https://www.youradchoices.ca/choices . c) USA: https://www.aboutads.info/choices . d) Cross-regional: https://optout.aboutads.info .

Used services and service providers:

  • Google Tag Manager: Google Tag Manager is a solution with which we manage so-called website tags via an interface and thus integrate other services into our online offer (for more information, please refer to this data protection declaration). With the Tag Manager itself (which implements the tags) z. B. has not yet created any user profiles or saved cookies. Google only learns the IP address of the user, which is necessary to run the Google Tag Manager. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com ; Data protection declaration: https://policies.google.com/privacy .
  • Google Analytics: online marketing and web analysis; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/ ; Data protection declaration: https://policies.google.com/privacy ; Opposition option ( opt- out): opt -out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de , settings for displaying advertisements: https://adssettings.google.com/authenticated .

We maintain an online presence 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 can be processed outside of the European Union. This can result in risks for the user because it could make it more difficult to enforce the users' rights, for example.

In addition, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created on the basis of user behaviour and the interests of the user resulting from this. The usage profiles can in turn be used, for example, to place advertisements inside 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 the interests of the users are stored. Furthermore, data can be stored in the usage profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).

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

In the case of requests for information and the assertion of rights of data subjects, we point out that these can be most effectively asserted with the providers. Only the providers have access to the data of the users and can take appropriate measures and provide information. If you still need help, you can contact us.

Facebook : We work with Facebook Ireland Ltd. who are responsible for the collection (but not the further processing) of data from visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see “Things You and Others Do and Provide” in the Facebook Data Policy: https: // www.facebook.com/policy ), as well as information about the devices used by the users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under "Device information" in the Facebook data policy declaration: https://www.facebook.com/policy ). As explained in the Facebook data guideline under "How do we use this information?", Facebook also collects and uses information to provide analysis services, so-called "Page Insights ", for website operators so that they can obtain information about how people use their pages and interact with the content associated with them. We have concluded a special agreement with Facebook ("Information on Page Insights ", https://www.facebook.com/legal/terms/page_controller_addendum ), which regulates in particular which security measures Facebook must observe and which Facebook itself has agreed to fulfil the rights of the data subject (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information on Page Insights " ( https://www.facebook.com/legal/terms/information_about_page_insights_data ).

  • Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device Information, IP addresses).
  • Affected persons: users (e.g. website visitors, users of online services).
  • Purposes of processing: Contact inquiries and communication, tracking (e.g. interest / behaviour-related profiling , use of cookies), remarketing , range measurement (e.g. access statistics, recognition of returning visitors).
  •  Legal basis: authorised interests (Art. 6 para. 1 lit. f. GDPR)

Used services and service providers:

 

Plugins and embedded functions as well as content

We incorporate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These can be graphics, videos or social media buttons and articles (hereinafter uniformly referred to as "content").

The integration always presupposes that the third-party providers of this content process the IP address of the user, since without the IP address they would not be able to send the content to their browser. The IP address is therefore required for the display of this content or functions. We strive to use content whose respective providers only use the IP address to deliver the content. Third-party providers can 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 can also be stored in cookies on the user's device and contain, among other things, technical information on the browser and operating system, the 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.

Facebook plugins and content : We work with Facebook Ireland Ltd. for the collection or receipt as part of a transmission (but not further processing) of "event data" that Facebook collects using the Facebook social plugins (and embedding functions for content) that are carried out on our online offer for the following purposes: a) Display of content and advertising information that corresponds to the presumed interests of the users; b) Delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) Improving the delivery of advertisements and personalising functions and content (e.g. improving the recognition of which content or advertising information presumably corresponds to the interests of the users). We have concluded a special agreement with Facebook ("Addition for those responsible", https://www.facebook.com/legal/controller_addendum ), which regulates in particular which security measures Facebook must observe ( https: //www.facebook. com / legal / terms / data_security_terms ) and in which Facebook has agreed to fulfil the rights of the data subject (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with measured values, analysis and reports (which are aggregated, i.e. they do not receive any information about individual users and are anonymous to us), then this processing does not take place within the framework of joint responsibility, but on the basis of an order processing contract ("data processing conditions") , https://www.facebook.com/legal/terms/dataprocessing ), the "data security conditions" ( https://www.facebook.com/legal/terms/data_security_terms ) and with regard to processing in the USA based on of standard contractual clauses ("Facebook-EU-data transfer addendum, https://www.facebook.com/legal/EU_data_transfer_addendum ). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are covered by the agreements with Facebook.

Instagram plugins and content : We work with Facebook Ireland Ltd. for the collection or receipt as part of a transmission (but not the further processing) of "event data" that Facebook collects using functions of Instagram (e.g. embedding functions for content) that are carried out on our online offer: a) Display of content and advertising information that corresponds to the presumed interests of the users; b) Delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) Improving the delivery of advertisements and personalising functions and content (e.g. improving the recognition of which content or advertising information presumably corresponds to the interests of the users). We have concluded a special agreement with Facebook ("Addition for those responsible", https://www.facebook.com/legal/controller_addendum ), which regulates in particular which security measures Facebook must observe ( https: //www.facebook. com / legal / terms / data_security_terms ) and in which Facebook has agreed to fulfil the rights of the data subject (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with measured values, analysis and reports (which are aggregated, i.e. they do not receive any information about individual users and are anonymous to us), then this processing does not take place within the framework of joint responsibility, but on the basis of an order processing contract ("data processing conditions") , https://www.facebook.com/legal/terms/dataprocessing ), the "data security conditions" ( https://www.facebook.com/legal/terms/data_security_terms ) and with regard to processing in the USA based on of standard contractual clauses ("Facebook-EU-data transfer addendum, https://www.facebook.com/legal/EU_data_transfer_addendum ). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are covered by the agreements with Facebook.

  • Processed data types: usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information, IP addresses), event data (Facebook) ("event data" are data that e.g. . can be transmitted from us to Facebook via Facebook pixels (via apps or in other ways) and relate to people or their actions; the data includes, for example, information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc .; the event data is processed for the purpose of creating target groups for content and advertising information (custom audiences ); event data does not contain the actual content (e.g. written comments), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data is deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook-accounts), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), inventory data (e.g. names, addresses).
  • Affected persons: users (e.g. website visitors, users of online services), communication partners .
  • Purposes of processing: Provision of our online offer and user-friendliness, provision of contractual services and customer service, contact inquiries and communication, direct marketing (e.g. by e-mail or post), tracking (e.g. interest / behavioural profiling , use of cookies), interest-based and behavioural marketing, Profiling (creation of user profiles), security measures, administration and answering inquiries.
  • : Legal basis Legitimate interests (Art. 6 para. 1 lit. f. GDPR) Consent (Art. 6 para. 1 lit. a. GDPR) Performance and pre-requests (Art. 6 para. 1 lit. b. GDPR)

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 the consent allowed for processing is revoked or other permissions are no longer applicable (e.g. if the purpose of processing this data is no longer applicable or is not required for the purpose).

If the data is not deleted because it is required for other legally permissible purposes, its processing will be limited to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be kept for commercial or tax law reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect 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 information 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 the changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your participation (e.g. consent) or other individual notification.

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

 

Data Subject Rights

As the data subject, you have various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

  • Right to object: You have the right, for reasons arising from your particular situation at any time to the processing of personal data concerning that according to Art. 6, para 1. lit. e. or f. GDPR takes place to object; this also applies to profiling based on these provisions . If the personal data concerning you are processed in order to operate direct mail, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such advertising; this also applies to profiling insofar as it is connected to such direct advertising.
  • Right of revocation for consent: You have the right to revoke your consent at any time.
  • Right to information: You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to correction: In accordance with the legal requirements, you have the right to request the completion of the data concerning you or the correction of incorrect data concerning you.
  • Right to deletion and restriction of processing: In accordance with the legal requirements, you have the right to request that the data relating to you be deleted immediately or, alternatively, to request that the processing of the data be restricted in accordance with the legal requirements.
  • Right to data portability: You have the right to receive data relating to you that you have provided to us in accordance with the legal requirements in a structured, common and machine-readable format or to request that it be transmitted to another person responsible.
  • Complaint to the supervisory authority: In accordance with the legal requirements, you also have the right to lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, your place of work or the place of the alleged infringement, if you are of the opinion that the processing of the data concerning your personal data violates the GDPR.