data protection
Introduction
With the following data protection declaration, we would like to inform you about which types of your personal data (hereinafter also referred to as "data") we process for which purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both within the framework 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 March 26, 2020
Responsible
Dolitha Ranchagoda
Sri Lanka Agency: Ceylon's Best Tours (Pvt) Ltd
No. 406A Katukoliya
80510 Induruwa, Bentota
Sri Lanka
Email address: info@ceylonsbest.com
Overview of 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
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Inventory data (e.g. names, addresses).
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Content data (e.g. text input, photographs, videos).
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Contact information (e.g. email, phone numbers).
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Meta/communication data (e.g. device information, IP addresses).
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Usage data (e.g. websites visited, interest in content, access times).
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Location data (data indicating the location of an end user's end device).
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Contract data (e.g. subject of the contract, term, customer category).
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Payment data (e.g. bank details, invoices, payment history).
Categories of data subjects
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Employees (e.g. employees, applicants, former employees).
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business and contractual partners.
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Interested persons.
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communication partner.
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Customers.
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Users (e.g. website visitors, users of online services).
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Sweepstakes and Contest Entrants.
purposes of processing
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Provision of our online offer and user-friendliness.
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visit action evaluation.
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office and organizational procedures.
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Cross-device tracking (processing of user data across devices for marketing purposes).
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Direct marketing (e.g. by e-mail or post).
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Conducting sweepstakes and competitions.
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Feedback (e.g. collecting feedback via online form).
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Interest-Based and Behavioral Marketing.
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Contact Requests and Communication.
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Conversion measurement (measurement of the effectiveness of marketing measures).
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Profiling (creating user profiles).
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remarketing.
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Range measurement (e.g. access statistics, recognition of returning visitors).
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Safety measures.
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Tracking (e.g. interest/behavioural profiling, use of cookies).
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Contractual Benefits and Service.
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Management and response to inquiries.
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Target group formation (determination of target groups relevant for marketing purposes or other output of content).
Relevant legal bases
In the following we inform you about the legal basis of the General Data Protection Regulation (GDPR), on the basis of which we process the personal data. Please note that in addition to the regulations of the GDPR, the national data protection regulations in your or our country of residence and domicile may apply. If more specific legal bases are relevant in individual cases, we will inform you of them in the data protection declaration.
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Consent (Art. 6 Para. 1 S. 1 lit. a GDPR) - The person concerned has given their consent to the processing of their personal data for a specific purpose or several specific purposes.
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Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. DSGVO) - The processing is necessary for the fulfillment of a contract to which the data subject is a party, or for the implementation of pre-contractual measures, which are required at the request of the data subject take place.
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Legal obligation (Art. 6 Para. 1 S. 1 lit. c. GDPR) - The processing is necessary to fulfill a legal obligation to which the person responsible is subject.
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Protection of vital interests (Art. 6 Para. 1 S. 1 lit. d. GDPR) - Processing is necessary to protect vital interests of the data subject or another natural person.
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Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR) - Processing is necessary to safeguard the legitimate interests of the person responsible or a third party, unless the interests or fundamental rights and freedoms of the data subject, which protect personal Data require prevail.
Safety measures
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, 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 to ensure a level of protection appropriate to the risk.
The measures include, in particular, securing the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, disclosure, securing availability and their separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to data threats. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
SSL encryption (https): In order to protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.
Transfer 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 organizational units or persons or that it is disclosed to them. 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 appropriate contracts or agreements with the recipients of your data that serve to protect your data.
Data transfers within the organization: We may transfer personal data to other entities within our organization or allow them access to this data. If this transfer takes place for administrative purposes, the transfer of the data is based on our legitimate entrepreneurial and business interests or takes place if it is necessary to fulfill our contractual obligations or if the consent of the person concerned or legal permission is available.
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 the processing within the framework of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies takes place, this is only done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transmission, we only process or pass the data in third countries with a recognized level of data protection, which includes US processors certified under the "Privacy Shield", or on the basis of special guarantees, such as contractual obligations 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 containing 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 their visit to an online offer. The stored information can include, for example, the language settings on a website, the login status, a shopping cart or the place where a video was viewed. The term cookies also includes other technologies that fulfill the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also referred to as "user IDs").
The following cookie types and functions are distinguished:
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Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
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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, which are used to measure reach or for marketing purposes, can be stored in such a cookie.
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First party cookies: First party cookies are set by ourselves.
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Third-party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
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Necessary (also: essential or absolutely necessary) cookies: Cookies can be absolutely necessary for the operation of a website (e.g. to save logins or other user entries or for security reasons).
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Statistics, marketing and personalization cookies: Cookies are also usually used to measure range and when the interests of a user or his behavior (e.g. viewing certain content, using functions, etc.) on individual websites in a user profile get saved. Such profiles are used to show users, for example, content that corresponds to their potential interests. This procedure is also referred to as "tracking", ie tracking the potential interests of users. . If we use cookies or "tracking" technologies, we will inform you separately in our data protection declaration or when obtaining consent.
Notes on legal bases: The legal basis on which we process your personal data with the help of cookies depends on whether we ask for your consent. If this is the case and you consent to the use of cookies, the legal basis for the processing of your data is the declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offer and its improvement) or if the use of cookies is necessary to fulfill 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 option at any time to revoke your 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 using the settings in 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 online marketing purposes can also be raised using a variety of services, especially in the case of tracking, via the websiteshttps://optout.aboutads.infoandhttps://www.youronlinechoices.com/be explained. In addition, you can receive further objection notices as part of the information on the service providers and cookies used.
Processing of cookie data based on consent: Before we process or have data processed as part of the use of cookies, we ask users to give their consent, which can be revoked at any time. Before the consent has not been given, cookies that are required for the operation of our online offer will be used. They are used on the basis of our interest and the interest of the user in the expected functionality of our online offer.
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Types of data processed: usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
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Affected persons: users (e.g. website visitors, users of online services).
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Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Commercial and Business Services
We process the data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners") within the framework of contractual and comparable legal relationships and related measures and within the framework of communication with the contractual partners (or pre-contractual), e.g respond.
We process this data to fulfill our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with this information and the corporate organization. We only pass on the data of the contractual partners to third parties within the framework of the applicable law to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations or with the consent of the contractual partners (e.g. to telecommunications, transport and other auxiliary services involved 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.
We inform the contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special markings (e.g. colours) or symbols (e.g. asterisks or similar), or personally.
We delete the data after statutory warranty and comparable obligations have expired, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. for as long as it has to be kept for legal archiving reasons (e.g. for tax purposes usually 10 years). We delete data disclosed to us by the contractual partner as part 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.
Travel-related services: We process the data of our customers and interested parties (uniformly referred to as "customers") in accordance with the underlying contractual relationship. We can also process information about the characteristics and circumstances of people or their belongings if this is necessary within the framework of the contractual relationship This can be, for example, information about personal living conditions, movable property and the financial situation.
As part of our assignment, it may be necessary for us to process special categories of data within the meaning of Art. 9 Para. 1 GDPR, in particular information on a person's health. The processing takes place in order to protect the health interests of the customers and otherwise only with the consent of the customers.
If necessary for the fulfillment of the contract or by law, or if the customer has given our consent or based on our legitimate interests, we disclose or transmit the customer's data, for example to the service providers involved in the fulfillment of the travel services.
Events: We process the data of the participants of the events, events and similar activities offered or organized by us (hereinafter referred to as “participants” and “events”) in order to enable them to participate in the events and use the services associated with participation enable services or actions.
If we process health-related data, religious, political or other special categories of data in this context, then this is done within the scope of obviousness (e.g. in the case of thematically oriented events or is used for health care, security or with the consent of those affected).
The information required is marked as such within the framework of the conclusion of the contract, order or comparable contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations. Insofar as we have access to information from end customers, employees or other persons, we process this in accordance with the legal and contractual requirements.
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Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of contract, term, customer category).
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Affected persons: interested parties, business and contractual partners, customers.
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Purposes of processing: Contractual services and services, contact requests and communication, office and organizational procedures, administration and answering requests.
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Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), Legal obligation (Art. 6 Para. 1 S. 1 lit. c. GDPR), Legitimate interests (Art. 6 Para. 1 p. 1 lit. f. GDPR).
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). The data of the readers are processed for the purposes of the publication medium only insofar as it is necessary for its presentation and the communication between authors and readers or for reasons of security. 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 Posts: When users leave comments or other posts, their IP addresses may be stored based on our legitimate interests. This is for our security if someone leaves illegal content in comments and posts (insults, forbidden political propaganda, etc.). In this case, we can be prosecuted for the comment or contribution and are therefore interested in the identity of the author.
Furthermore, we reserve the right to process user information for the purpose of spam detection on the basis of our legitimate interests.
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 votes.
The personal information provided in the comments and posts, any contact and website information as well as the content will be stored by us permanently until the user objects.
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Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text input, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g device information, IP addresses).
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Affected persons: users (e.g. website visitors, users of online services).
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Purposes of processing: contractual services and services, feedback (e.g. collecting feedback via online form), security measures, administration and answering of inquiries.
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Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR), consent (Art. 6 Para. 1 S. 1 lit. a GDPR), protection of vital interests (Art. 6 Para. 1 S. 1 lit. d. GDPR).
contact
When contacting us (e.g. via contact form, e-mail, telephone or via social media), the details of the requesting person will be processed to the extent that this is necessary to answer the contact request and any requested measures.
The answering of contact inquiries within the framework of contractual or pre-contractual relationships takes place to fulfill our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of the legitimate interests in answering the inquiries.
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Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text input, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g device information, IP addresses).
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Affected persons: communication partners.
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Purposes of processing: contact requests and communication.
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Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Communication via Messenger
We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messenger, on encryption, on the use of the metadata of the communication and on your options to object.
You can also contact us in alternative ways, e.g. by telephone or e-mail. Please use the contact options provided to you or the contact options specified within our online offer.
In the case of end-to-end encryption of content (ie the content of your message and attachments), please note that the communication content (ie 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 messenger with activated encryption to ensure that the message content is encrypted.
However, we also point out to our communication partners that the providers of the messengers cannot see the content, but can find out that and when communication partners communicate with us as well as technical information on the device used by the communication partner and, depending on the settings of their device, also location information ( so-called metadata) are processed.
Notes on legal bases: If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for your consent and you contact us, for example, we use Messenger in relation to our contractual partners and in the context of contract initiation 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 fulfillment of the needs of our communication partners in communication via messenger. We would also like to point out that we will not transmit the contact data you have given us to Messenger for the first time without your consent.
Revocation, objection and deletion: You can revoke your 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 (ie, 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 partner, if no reference to a previous conversation is to be expected and the deletion does not conflict with any statutory retention requirements.
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, for example, when internal contract details require particular secrecy or an answer via messenger does not meet the formal requirements. In such cases, we will refer you to more appropriate communication channels.
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Types of data processed: contact data (e.g. e-mail, telephone numbers), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), content data (e.g. text entries, photographs, videos) .
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Affected persons: communication partners.
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Purposes of processing: contact requests and communication, direct marketing (e.g. by email or post).
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Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Services and service providers used:
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Facebook Messenger: Facebook Messenger with end-to-end encryption (the end-to-end encryption of Facebook Messenger requires activation if it is not activated by default); Service provider:https://www.facebook.com, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; site:https://www.facebook.com; Data protection:https://www.facebook.com/about/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA):https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Possibility of objection (opt-out):https://www.facebook.com/settings?tab=ads.
Provision of the online offer and web hosting
In order to be able to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services.
The data processed as part of the provision of the hosting offer may include all information relating to the users of our online offer that arises 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 on websites.
Collection of access data and log files: We ourselves (or our web hosting provider) collect data for every access to the server (so-called server log files). The address and name of the retrieved websites and files, date and time of retrieval, amounts of data transferred, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP Addresses and the requesting provider belong.
The server log files can be used on the one hand for security purposes, e.g. to avoid overloading the server (especially in the case of abusive attacks, so-called DDoS attacks) and on the other hand to ensure server utilization and stability.
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Types of data processed: content data (e.g. text input, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
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Affected persons: users (e.g. website visitors, users of online services).
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Purposes of processing: Contractual services and services.
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Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
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Services and service providers used:
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Wix: hosting platform for websites; Service Provider: Wix.com ltd., Tel Aviv, 500 Terry A. Francois Boulevard, San Francisco, California 94158, USA; site:https://www.wix.com; Data protection:https://www.wix.com/about/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA):https://www.privacyshield.gov/participant?id=a2zt0000000GnbGAAS&status=Active.
cloud services
We use software services accessible via the Internet and running on the servers of their providers (so-called "cloud services", also referred to as "software as a service") for the following purposes: document storage and management, calendar management, email sending, spreadsheets and presentations, exchanging documents, content and information with designated recipients or posting web pages, forms or other content and information, as well as chatting and participating in audio and video conferences.
In this context, personal data can be processed and stored on the servers of the providers, insofar as these are part of communication processes with us or are otherwise processed by us, as set out in this data protection declaration. This data can include, in particular, master data and contact details of users, data on transactions, contracts, other processes and their content. The providers of the cloud services also process usage data and metadata, which they use for security purposes and to optimize the service.
If we use the cloud services to provide forms or similar documents and content for other users or publicly accessible websites, the providers can store cookies on the users' devices for web analysis purposes or to change user settings (e.g. in the case of media control). remember, save.
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 part of our (pre)contractual services, provided that the use of cloud services has been agreed in this context. Otherwise, user data is processed on the basis of our legitimate interests (ie interest in efficient and secure administration and collaboration processes).
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Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text input, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g device information, IP addresses).
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Affected persons: customers, employees (e.g. employees, applicants, former employees), interested parties, communication partners.
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Purposes of processing: office and organizational procedures.
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Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a GDPR), fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S . 1 lit. f. GDPR).
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Services and service providers used:
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Dropbox: cloud storage services; Service Provider: Dropbox, Inc., 333 Brannan Street, San Francisco, California 94107, USA; site:https://www.dropbox.com/de; Data protection:https://www.dropbox.com/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA):https://www.privacyshield.gov/participant?id=a2zt0000000GnCLAA0&status=Active; Standard contractual clauses (ensuring the level of data protection when processing in a third country):https://www.dropbox.com/terms/business-agreement-2016.
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Google Cloud Services: cloud storage services; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; site:https://cloud.google.com/; Data protection:https://www.google.com/policies/privacy, Safety instructions:https://cloud.google.com/security/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA):https://www.privacyshield.gov/participant?id=a2zt0000000000001L5AAI&status=Active; Standard contractual clauses (ensuring the level of data protection when processing in a third country):https://cloud.google.com/terms/data-processing-terms; Additional information on data protection:https://cloud.google.com/terms/data-processing-terms.
Sweepstakes and Contests
We process the personal data of 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 processing 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 from misuse by possible collection of IP addresses when submitting competition entries).
If entries by participants are published as part of the competition (e.g. as part of a voting or presentation of the competition entries or the winners or reporting on the competition), we would like to point out that the names of the participants may 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 usage and data protection provisions 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 context of the competition and inquiries regarding the competition are to be addressed to us.
The participants' data will be deleted as soon as the sweepstakes or competition has ended and the data is no longer required to inform the winners or because queries about the sweepstakes are to be expected. In principle, the data of the participants will be deleted no later than 6 months after the end of the competition. Winners' data may be retained for a longer period of time, for example in order to be able to answer questions about the prizes or to be able to fulfill the prizes; in this case, the retention period depends on the type of prize and is, for example, up to three years for items or services in order to be able to process warranty cases, for example. Furthermore, the data of the participants can be stored longer, for example in the form of reporting on the competition in online and offline media.
If data was also collected for other purposes as part of the competition, its processing and storage period are based on the data protection notices for this use (e.g. in the case of registration for the newsletter as part of a competition).
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Types of data processed: Inventory data (e.g. names, addresses), content data (e.g. text entries, photographs, videos).
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Affected persons: Sweepstakes and competition participants.
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Purposes of processing: conducting sweepstakes and competitions.
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Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR).
Online marketing
We process personal data for online marketing purposes, which may include the marketing of advertising space or the presentation of advertising and other content (collectively referred to as "content") based on the potential interests of users and the measurement of their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar processes are used, by means of which the information about the user relevant to the presentation of the aforementioned content is stored. This information can include, for example, 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 the collection of their location data, this can also be processed.
The IP addresses of the users are also saved. However, we use available IP masking procedures (ie pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) are stored as part of the online marketing process, but pseudonyms. This means that we and the providers of the online marketing process do not know the actual identity of the users, 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 on other websites that use the same online marketing process and analyzed for the purpose of displaying content, as well as supplemented with further 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, for example, if the users are members of a social network whose online marketing process we use and the network connects the user's profile with the aforementioned information. We kindly 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 receive access to summarized information about the success of our advertisements. However, we can use so-called conversion measurements to check which of our online marketing processes have led to a so-called conversion, ie, to a contract with us, for example. The conversion measurement is only used to analyze the success of our marketing measures.
Unless otherwise stated, please 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, user data is processed on the basis of our legitimate interests (ie interest in efficient, economical 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.
Facebook pixel: With the help of the Facebook pixel, Facebook is able to determine the visitors of our online offer as a target group for the display of advertisements (so-called "Facebook ads"). Accordingly, we use the Facebook pixel so that the Facebook ads placed by us are only available to 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 use the Facebook pixel to ensure that our Facebook ads are relevant to users' potential interests and are not annoying.The Facebook pixel also allows us to understand the effectiveness of Facebook ads for statistical and market research purposes by seeing who whether users were redirected to our website after clicking on a Facebook ad (so-called "conversion measurement").
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Types of data processed: usage data (e.g. websites visited, 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 end device).
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Affected persons: users (e.g. website visitors, users of online services), interested parties.
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Purposes of processing: tracking (e.g. interest/behaviour-related profiling, use of cookies), remarketing, evaluation of visits, interest-based and behavioral marketing, profiling (creating user profiles), conversion measurement (measurement of the effectiveness of marketing measures), range measurement (e.g. access statistics, detection 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).
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Security measures: IP masking (pseudonymization of the IP address).
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Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
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Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the possibilities of objection specified for the providers (so-called \"opt-out\"). If no explicit opt-out option has been specified, you can turn off cookies in your browser settings. However, this can limit 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) United States:https://www.aboutads.info/choices. d) Inter-territorial:https://optout.aboutads.info.
Services and service providers used:
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Google Analytics: online marketing and web analytics; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; site:https://marketingplatform.google.com/intl/de/about/analytics/; Data protection:https://policies.google.com/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA):https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; Possibility of objection (opt-out): Opt-out plugin:https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements:https://adssettings.google.com/authenticated.
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Facebook pixel: Facebook pixel; Service provider:https://www.facebook.com, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; site:https://www.facebook.com; Data protection:https://www.facebook.com/about/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA):https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Possibility of objection (opt-out):https://www.facebook.com/settings?tab=ads.
rating platforms
We participate in evaluation processes to evaluate, optimize and advertise our services. If users rate us via the rating platforms or methods involved or give us feedback in any other way, the general terms and conditions of business or terms of use and the data protection notices of the providers also apply. As a rule, the evaluation also requires registration with the respective providers.
In order to ensure that the reviewers have actually used our services, we transmit the data required for this with regard to the customer and the service used to the respective rating platform (including name, e-mail address and order number or article number). This data is only used to verify the authenticity of the user.
Evaluation widget: We integrate so-called "evaluation widgets" into our online offer. A widget is a function and content element integrated into our online offer that displays variable information. It can, for example, take the form of a seal or comparable element, sometimes also " Badge". The corresponding content of the widget is displayed within our online offer, but it is retrieved from the servers of the respective widget provider at that moment. This is the only way to always show the current content, especially the respective Current rating. To do this, a data connection must be established from the website called up within our online offer to the widget provider's server and the widget provider receives certain technical data (access data, including IP address) that are necessary for the content of the widget to be displayed can be delivered to the user's browser.
Furthermore, the widget provider receives information that users have visited our online offer. This information can be stored in a cookie and used by the widget provider to identify which online offers that participate in the evaluation process have been visited by the user. The information may be stored in a user profile and used for advertising or market research purposes.
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Types of data processed: contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
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Affected persons: customers, users (e.g. website visitors, users of online services).
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Purposes of processing: Feedback (e.g. collecting feedback via online form), range measurement (e.g. access statistics, recognition of returning visitors), evaluation of visits, interest-based and behavioral marketing, profiling (creating user profiles).
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Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
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 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 user's rights, for example. 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 undertake to comply with the data protection standards of the EU.
Furthermore, 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 usage behavior and the resulting interests of users. 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 user. For these purposes, cookies are usually stored on the users' computers, in which the usage behavior and the interests of the users are stored. Furthermore, data can also be stored in the usage profiles independently 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 possibility 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 data subject rights, we would like to 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. If you still need help, you can contact us.
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Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text input, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g device information, IP addresses).
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Affected persons: users (e.g. website visitors, users of online services).
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Purposes of processing: contact requests and communication, tracking (e.g. interest/behavioral profiling, use of cookies), remarketing, range measurement (e.g. access statistics, recognition of returning visitors).
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Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Services and service providers used:
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Instagram : social network; Service Provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; site:https://www.instagram.com; Data protection:https://instagram.com/about/legal/privacy.
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Facebook: social network; Service provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; site:https://www.facebook.com; Data protection:https://www.facebook.com/about/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA):https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Possibility of objection (opt-out): Settings for advertisements:https://www.facebook.com/settings?tab=ads; Additional information on data protection: Agreement on joint processing of personal data on Facebook pages:https://www.facebook.com/legal/terms/page_controller_addendum, Data protection information for Facebook pages:https://www.facebook.com/legal/terms/information_about_page_insights_data.
Plugins and embedded functions and content
We integrate functional and content elements into our online offer that 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 articles (hereinafter collectively 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 could not send the content to their browser. The IP address is therefore required for the display of this content or functions. We endeavor to only 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 about the browser and the operating system, websites to be referred to, the time of the visit and other information on the use of our online offer and can also be linked to such information from other sources.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed on the basis of our legitimate interests (ie interest in efficient, economical 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.
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Types of data processed: usage data (e.g. websites visited, 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 end device).
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Affected persons: users (e.g. website visitors, users of online services).
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Purposes of processing: Provision of our online offer and user-friendliness, contractual services and services.
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Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
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Services and service providers used:
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Google Fonts: We integrate the fonts ("Google Fonts") from the provider Google, whereby the user data is used solely for the purpose of displaying the fonts in the user's browser. The integration takes place on the basis of our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform representation and taking into account possible licensing restrictions for their integration. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; site:https://fonts.google.com/; Data protection:https://policies.google.com/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA):https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
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Google Maps: We integrate the maps of the service “Google Maps” from the provider Google. The processed data may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually as part of the settings on their mobile devices); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; site:https://cloud.google.com/maps-platform; Data protection:https://policies.google.com/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA):https://www.privacyshield.gov/participant?id=a2zt0000000TRkEAAW&status=Active; Possibility of objection (opt-out): Opt-out plugin:https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements:https://adssettings.google.com/authenticated.
deletion of data
The data processed by us will be deleted in accordance with the legal requirements as soon as your consent to processing is revoked or other permissions are no longer applicable (e.g. if the purpose of processing this data no longer applies or it 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 stored for commercial or tax 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 provided in the context of the individual data protection information in this data protection declaration.
Change and update of the privacy policy
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 in the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this data protection declaration, please note that the addresses can change over time and ask you to check the information before contacting us.
Rights of data subjects
As a data subject, you are entitled to various rights under the GDPR, which result in particular from Articles 15 to 18 and 21 GDPR:
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Right of objection: You have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data, which is based on Article 6 Paragraph 1 lit. e or f GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed in order to operate direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct advertising.
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Right of withdrawal for consent: You have the right to withdraw your consent at any time.
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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 legal requirements.
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Right to rectification: In accordance with legal requirements, you have the right to request the completion of the data concerning you or the correction of incorrect data concerning you.
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Right to deletion and restriction of processing: You have the right, in accordance with the legal requirements, to request that data concerning you be deleted immediately, or alternatively to request a restriction of the processing of the data in accordance with the legal requirements.
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Right to data portability: You have the right to receive the data 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.
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Complaint to the supervisory authority: In accordance with the statutory provisions, you also have the right to lodge a complaint with a supervisory authority, in particular in the member state of your usual place of residence, your place of work or the place of the alleged infringement, if you believe that the processing of data concerning you personal data violates the GDPR.
definitions of terms
This section provides you with an overview of the terms used in this data protection declaration. Many of the terms are taken from the law and defined above all in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended primarily for understanding. The terms are sorted alphabetically.
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Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special features, are an expression of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
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Responsible: The "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.
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Processing: "Processing" is any process or series of processes carried out with or without the aid of automated processes in connection with personal data. The term goes far and covers practically every handling of data, be it collection, evaluation, storage, transmission or deletion.
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Visit action evaluation: "Visit action evaluation" (English "Conversion Tracking") refers to a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the user's device within the website on which the marketing measures take place and then called up again on the target website. For example, we can use this to understand whether the ads we placed on other websites were successful).
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Cross-device tracking: Cross-device tracking is a form of tracking in which information on the behavior and interests of users is recorded across devices in so-called profiles by assigning an online identifier to the user. This allows 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 identifier is not linked to clear data such as names, postal addresses or e-mail addresses.
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Interest-based and behavioral marketing: One speaks of interest- and/or behavioral marketing when the potential interests of users in ads and other content are predetermined as precisely as possible. This is done using information about their previous behavior (e.g. visiting certain websites and staying on them, purchasing behavior or interaction with other users), which is stored in a so-called profile. Cookies are usually used for these purposes.
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Conversion measurement: Conversion measurement is a method that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user's device within the website on which the marketing measures take place and then called up again on the target website. For example, this allows us to understand whether the ads we placed on other websites were successful.
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Profiling: "Profiling" means any type of automated processing of personal data, which consists in using this personal data to obtain certain personal aspects relating to a natural person (depending on the type of profiling, this includes information relating to the Age, gender, location data and movement data, interaction with websites and their content, shopping behavior, social interactions with other people) to analyze, evaluate or predict them (e.g. interests in certain content or products, click behavior on a website or location) Cookies and web beacons are often used for profiling purposes.
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Remarketing: We speak of "remarketing" or "retargeting" when, for advertising purposes, for example, it is noted which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
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Range measurement: The range measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offer and can include the behavior or interests of visitors in certain information, such as website content. With the help of the range analysis, website owners can, for example, see at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for range analysis purposes in order to recognize returning visitors and thus obtain more precise analyzes of the use of an online offer.
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Tracking: One speaks of "tracking" when the behavior of users can be traced across several online offers. As a rule, behavior and interest information with regard to 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 show users advertisements that are likely to match their interests.
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Target group formation: One speaks of target group formation (or "custom audiences") when target groups are determined for advertising purposes, e.g. display of advertisements. For example, based on the interest of a user in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which he viewed the products. In turn, one speaks of "lookalike audiences" (or similar target groups) if the content assessed as suitable is displayed to users whose profiles or interests are presumably correspond to the users for whom the profiles were created. Cookies and web beacons are usually used for the purpose of creating custom audiences and lookalike audiences.
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IP masking: "IP masking" is a method in which the last octet, ie the last two digits of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing methods, especially in online marketing