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Data protection

Privacy policy

Introduction

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

The terms used are not gender-specific.

Status:28.01.2021

Table of contents

Person responsible

EQUANIMITY ESTATE LLC
DAVID EKWE EBOBISSE, SOLE MBR

Address of the LLC:
30 N Gould St Ste N
Sheridan, WY 82801
USA

Organizer of the LLC:
Northwest Registered Agent Service Inc
30 N Gould St Ste N
Sheridan, WY 82801
USA

Contact information:
Phone: +49 160 2412 760
E-mail: shop@drraw.de
Internet: https://drraw.de/

Sales tax identification number (EIN):
37-2151604

Responsible for the content:
David Ekwe Ebobisse

Contact data protection officer

Responsible for the content of this website according to § 5 TMG:

EQUANIMITY ESTATE LLC
DAVID EKWE EBOBISSE, SOLE MBR

Address of the LLC:
30 N Gould St Ste N
Sheridan, WY 82801
USA

Organizer of the LLC:
Northwest Registered Agent Service Inc
30 N Gould St Ste N
Sheridan, WY 82801
USA

Repräsentanz/Postadresse:
Atzelbergstr. 92
60389 Frankfurt am Main
Deutschland

Contact information:
Phone: +49 160 2412760
E-mail: shop@drraw.de
Internet: https://drraw.de/

Sales tax identification number (EIN):
37-2151604

Responsible for the content:
David Ekwe Ebobisse

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

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

Categories of affected persons

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

Purposes of the processing

  • Assessment of creditworthiness and credit standing.
  • Provision of our online offer and user-friendliness.
  • Visit action evaluation.
  • Office and organizational procedures.
  • Cross-device tracking (cross-device processing of user data for marketing purposes).
  • Direct marketing (e.g. by email or post).
  • Interest-based and behavioral marketing.
  • Contact requests and communication.
  • Conversion measurement (measuring the effectiveness of marketing measures).
  • Profiling (creation of user profiles).
  • Remarketing.
  • Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures.
  • Tracking (e.g. interest/behavioral profiling, use of cookies).
  • Provision of contractual services and customer service.
  • Managing and responding to inquiries.
  • Target group formation (determination of target groups relevant for marketing purposes or other output of content).

Automated decisions in individual cases

  • Credit report (decision based on a credit check).

Relevant legal bases

In the following, we inform you of the legal basis of the General Data Protection Regulation (GDPR), on the basis of which we process personal data. Please note that, in addition to the provisions of the GDPR, the national data protection regulations in your or our country of residence and domicile may apply. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR) – The data subject has given their consent to the processing of their personal data for one or more specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 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 sentence 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 sentence 1 lit. f. GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Security 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 nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses 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): We use SSL encryption to protect your data transmitted via our online offering. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Transfer and disclosure of personal data

As part of our processing of personal data, the data may be transferred to other bodies, companies, legally independent organizational units or persons or disclosed to them. The recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and in particular conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.

Data processing in third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this will only take place 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 recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

Use of cookies

Cookies are text files that contain data from websites or domains visited and are stored 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 service. The information stored may include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was watched. The term “cookies” also includes other technologies that perform the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also 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 an online service and closed their browser.
  • Permanent cookies: Permanent cookies remain stored even after the browser is closed.
    For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again.
    The interests of users that are used for reach measurement or marketing purposes can also be stored in such a cookie.
  • First-party cookies: First-party cookies are set by us.
  • Third-party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • 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 input or for security reasons).
  • Statistical, marketing and personalization cookies: Cookies are also generally used to measure reach and when a user’s interests or behaviour (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile.
    Such profiles are used, for example, to show users content that matches their potential interests.
    This process is also referred to as “tracking”, i.e. tracing the potential interests of users.
    .
    If we use cookies or “tracking” technologies, we will inform you separately in our privacy policy 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 you for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offering and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.

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

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent you have given 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 your browser settings, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared using a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. You can also obtain further information on how to object 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 in the context of the use of cookies, we ask users for their consent, which can be revoked at any time. Before consent has not been given, cookies that are absolutely necessary for the operation of our online offer will be used.

Cookie settings / objection option:

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

When you visit this website for the first time, you will have seen a consent dialog. You can use the following links to view the settings made there and to change or revoke your consent:

Your UUID (unique identification number): [rcb-consent-print-uuid fallback=””Noch” keine Einwilligung gegeben”]

[rcb-consent type=””change”” tag=””a”” text=””Privacy settings” ändern”]

[rcb-consent type=””history”” tag=””a”” text=””History” der Privatsphäre-Einstellungen”]

[rcb-consent type=”revoke” tag=”a” text=”Revoke consent” successmessage=”You have successfully revoked your consent. The page will now be reloaded.”]

Commercial and business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships and associated 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 safeguard our rights and for the purposes of the administrative tasks associated with this information as well as for business organization. We only pass on the data of contractual partners to third parties within the framework of the applicable law insofar as this is necessary for the aforementioned purposes or to fulfill legal obligations or with the consent of the persons concerned (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, as part of this privacy policy.

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 marking (e.g. colors) 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, e.g. as long as it must be retained for legal archiving reasons (e.g. for tax purposes, generally 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.

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 of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. As part of the registration process and subsequent logins and use of the customer account, we store the IP addresses of customers together with the access times in order to be able to prove registration and prevent any misuse of the customer account.

If customers have terminated their customer account, the data relating to the customer account will be deleted, unless their retention is required for legal reasons. It is the customer’s responsibility to back up their data when the customer account is terminated.

Economic analyses and market research: For economic reasons and in order to be able to identify market trends, wishes of contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc., whereby the group of data subjects may include contractual partners, interested parties, customers, visitors and users of our online offer.

The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). If available, we may take into account the profiles of registered users, including their details, e.g. on services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarized, i.e. anonymized values. Furthermore, we take the privacy of users into consideration and process the data for analysis purposes as pseudonymously as possible and, where feasible, anonymously (e.g. as summarized data).

Store and e-commerce: We process the data of our customers to enable them to select, purchase or order the selected products, goods and associated services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution for our customers. We use the services of banks and payment service providers to process payment transactions. The required information 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 consultations.

  • Processed data types: 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. contract object, duration, customer category), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Interested parties, business and contractual partners, customers.
  • Purposes of Processing: Provision of contractual services and customer support, Contact requests and communication, Office and organizational procedures, Managing and responding to inquiries, Security measures, Conversion tracking, Interest-based and behavioral marketing, Profiling (Creating user profiles).
  • Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Payment service provider

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

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

Payment transactions are subject to the terms and conditions and data protection notices of the respective payment service providers, which can be accessed on the respective websites or transaction applications. We also refer to these for further information and the assertion of rights of revocation, information and other rights of data subjects.

  • 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).
  • Affected persons: Customers, interested parties.
  • Purposes of processing: Provision of contractual services and customer service.
  • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services used and service providers:

Credit check

If we make advance payments or enter into comparable economic risks (e.g. when ordering on account), we reserve the right to obtain identity and creditworthiness information for the purpose of assessing the credit risk on the basis of mathematical-statistical procedures from specialized service companies (credit agencies) in order to safeguard our legitimate interests.

We process the information received from the credit agencies on the statistical probability of a payment default as part of an appropriate discretionary decision on the establishment, execution and termination of the contractual relationship. We reserve the right to refuse payment on account or any other advance payment in the event of a negative result of the credit check.

The decision as to whether we make advance payments is made in accordance with Art. 22 GDPR solely on the basis of an automated decision in individual cases, which our software makes on the basis of the information provided by the credit agency.

If we obtain express consent from contractual partners, the legal basis for the credit report and the transmission of the customer’s data to the credit agencies is consent. If no consent is obtained, the credit information is provided on the basis of our legitimate interests in the security of our payment claims.

  • Processed data types: Inventory data (e.g. names, addresses), Payment data (e.g. bank details, invoices, payment history), Contact data (e.g. email, telephone numbers), Contract data (e.g. subject matter of the contract, duration, customer category).
  • Affected persons: Customers, interested parties.
  • Purposes of processing: Assessment of creditworthiness and credit standing.
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
  • Automated decisions in individual cases: Credit information (decision based on a credit check).

Services used and service providers:

Provision of the online offer and web hosting

In order to provide our online offering securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offering 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 service may include all information relating to the users of our online service that is generated during 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.

E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as other information relating to the sending of e-mails (e.g. the providers involved) and the content of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received (unless an end-to-end encryption method is used). We can therefore accept no responsibility for the transmission path of e-mails between the sender and receipt on our server.

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

The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the utilization of the servers and their 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).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Contact us

When contacting us (e.g. by contact form, e-mail, telephone or via social media), the data of the inquiring persons are processed insofar as this is necessary to answer the contact inquiries and any requested measures.

The response to contact requests in the context of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to respond to (pre)contractual inquiries and otherwise on the basis of the legitimate interests in responding to the inquiries.

  • 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: Communication partners, interested parties.
  • Purposes of processing: contact requests and communication, managing and responding to requests.
  • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services used and service providers:

Newsletter and electronic notifications

We only send newsletters, emails and other electronic notifications (hereinafter “newsletter”) with the consent of the recipient or with legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user’s consent. Otherwise, our newsletters contain information about our services and us.

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

Double opt-in procedure: Registration for our newsletter is always carried out in a so-called double opt-in procedure. This means that after registering you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with other people’s e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the mailing service provider are also logged.

Deletion and restriction of processing: We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a blacklist solely for this purpose.

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

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

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

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

This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor, if used, that of the mailing service provider to observe individual users. Rather, we use the evaluations to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the user, on the basis of our legitimate interests for the purposes of using a user-friendly and secure newsletter system that serves both our business interests and meets the expectations of users.

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

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

Services used and service providers:

Web analysis, monitoring and optimization

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

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

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

The IP addresses of users are also stored. However, we use an IP masking procedure (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimization, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. 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 privacy policy.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of Processing: Web Analytics (e.g. access statistics, recognition of returning visitors), Targeting (e.g. profiling based on interests and behavior, use of cookies), Conversion Tracking, Profiling (Creating user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services used and service providers:

  • etracker: Web analysis/reach measurement; Service provider: etracker GmbH, Erste Brunnenstraße 1 20459 Hamburg, Germany; Website: https://www.etracker.com; Privacy Policy: https://www.etracker.com/datenschutz/; Opt-Out: https://www.etracker.de/privacy?et=[BITTE-EINSETZEN-IHRE-Account-ID].
  • Matomo (without cookies): Matomo is a data protection-friendly web analysis software that is used without cookies and in which returning users are recognized with the help of a so-called “digital fingerprint”, which is stored anonymously and changed every 24 hours; With the “digital fingerprint”, user movements within our online offer are recorded with the help of pseudonymized IP addresses in combination with user-side browser settings in such a way that it is not possible to draw conclusions about the identity of individual users; Service provider: Web analytics/ reach measurement in self-hosting; Website: https://matomo.org/.

Online marketing

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

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which the information about the user relevant for the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical 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 users are also stored. However, we use available IP masking procedures (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that neither we nor the providers of the online marketing processes know the actual identity of the users, but only the information stored in their profiles.

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

In exceptional cases, 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 processes we use and the network links the user profiles with the aforementioned data. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.

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

Unless otherwise stated, we ask you to assume that cookies used are stored for a period of two years.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. 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 privacy policy.

Facebook pixel: With the help of the Facebook pixel, it is possible for Facebook to determine the visitors of our online offer as a target group for the display of ads (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only 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”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of users and are not annoying. With the help of the Facebook pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook ad (so-called “conversion measurement”).

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographical position of a device or person).
  • Data subjects: Users (e.g. website visitors, users of online services), interested parties.
  • Purposes of Processing: Targeting (e.g. profiling based on interests and behavior, use of cookies), Remarketing, Conversion Tracking, Interest-based and behavioral marketing, Profiling (Creating user profiles), Conversion tracking (Measurement of the effectiveness of marketing activities), Web Analytics (e.g. access statistics, recognition of returning visitors), Custom Audiences (Selection of relevant target groups for marketing purposes or other output of content), Cross-Device Tracking (Device-independent processing of user data for marketing purposes).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
  • Possibility of objection (opt-out): We refer you to the data protection notices of the respective providers and the opt-out options specified for the providers (so-called “opt-out”). If no explicit opt-out option has been specified, you have the option of deactivating cookies in your browser settings. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered summarized 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-territory: https://optout.aboutads.info.

Services used and service providers:

  • Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offering.
    The Tag Manager itself (which implements the tags) does not process any personal user data.
    With regard to the processing of users’ personal data, please refer to the following information on Google services.
    Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy.
  • Google Analytics: Online marketing and web analytics; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Opt-Out: Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de; Settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • Google Ads and conversion measurement: We use the online marketing process “Google Ads” to place ads in the Google advertising network (e.g. in search results, in videos, on websites, etc.) so that they are displayed to users who are presumed to be interested in the ads.
    We also measure the conversion of the ads.
    However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page with a so-called “conversion tracking tag”.
    However, we ourselves do not receive any information that can be used to identify users.
    Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy.
  • Google Ad Manager: We use the “Google Marketing Platform” (and services such as “Google Ad Manager”) to place ads in the Google advertising network (e.g. in search results, in videos, on websites, etc.).
    The Google Marketing Platform is characterized by the fact that ads are displayed in real time based on the presumed interests of users.
    This allows us to display ads for and within our online offering in a more targeted manner in order to present users only with ads that potentially match their interests.
    If, for example, a user is shown ads for products that they have shown an interest in on other online offers, this is referred to as “remarketing”.
    Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy.
  • 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; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Opt-Out: https://www.facebook.com/settings?tab=ads.

Presence in social networks (social media)

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

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

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

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

  • 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).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of Processing: Contact requests and communication, Tracking (e.g. profiling based on interests and behavior, use of cookies), Remarketing, Web Analytics (e.g. access statistics, recognition of returning visitors).
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services used and service providers:

Plugins and embedded functions and 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 may be, for example, graphics, videos or social media buttons and posts (hereinafter uniformly referred to as “content”).

The integration always requires that the third-party providers of this content process the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content or function. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags can be used to analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as being 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 the processing of data is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. 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 privacy policy.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses), Location data (Information on the geographical position of a device or person), Content data (e.g. entries in online forms), Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers).
  • Data subjects: Users (e.g. website visitors, users of online services), communication partners.
  • Purposes of Processing: Provision of our online services and usability, Provision of contractual services and customer support, Contact requests and communication, Targeting (e.g. profiling based on interests and behavior, use of cookies), Interest-based and behavioral marketing, Profiling (Creating user profiles), Security measures, Managing and responding to inquiries.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR), consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR).

Services used 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 given for processing is revoked or other permissions cease to apply (e.g. if the purpose for 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 and legally permissible purposes, its processing is restricted to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for the assertion, exercise or defense of 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 notices of this privacy policy.

Amendment and updating of the privacy policy

We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

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

Rights of the data subjects

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

  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Art. 6 para.
    1 lit.
    e or f GDPR; this also applies to profiling based on these provisions.
    If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw your consent at any time.
  • Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed and to obtain access to this data and further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: In accordance with the statutory provisions, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
  • Right to data portability: You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request its transmission to another controller.
  • Complaint to the supervisory authority: You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

Definitions of terms

This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined above all in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are listed in alphabetical order.

  • Visit action evaluation: “Visit action evaluation” (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 websites on which the marketing measures take place and then retrieved again on the target website.
    For example, this allows us to track whether the ads we placed on other websites were successful).
  • Credit information: Automated decisions are based on automatic data processing without human intervention (e.g. in the case of an automatic rejection of a purchase on account, an online credit application or an online application procedure without any human intervention.
    According to Art. 22 GDPR, such automated decisions are only permitted if the data subject consents, if they are necessary for the performance of a contract or if national laws permit these decisions.
  • Cross-device tracking: Cross-device tracking is a form of tracking in which user behavior and interest information is recorded across devices in so-called profiles by assigning users an online identifier.
    This allows user information to be analyzed for marketing purposes, regardless of the browsers or devices used (e.g. cell phones or desktop computers).
    For most providers, the online identifier is not linked to clear data such as names, postal addresses or email addresses.
  • IP masking: “IP masking” refers to a method in which the last octet, i.e. the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person.
    IP masking is therefore a means of pseudonymizing processing procedures, particularly in online marketing
  • Interest-based and behavioral marketing: Interest-based and/or behavioral marketing is when users’ potential interests in ads and other content are predetermined as precisely as possible.
    This is done on the basis of information about their previous behavior (e.g. visiting certain websites and spending time on them, purchasing behavior or interaction with other users), which is stored in a so-called profile.
    Cookies are generally used for these purposes.
  • Conversion measurement: Conversion measurement is a process 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 websites on which the marketing measures take place and then retrieved again on the target website.
    For example, this allows us to track whether the ads we have placed on other websites have been successful.
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiling: “Profiling” means any form of automated processing of personal data consisting of the use of personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this includes information relating to age, gender, location data and movement data, interaction with websites and their content, shopping behavior, social interactions with other people) (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.
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, such as website content.
    With the help of reach analysis, website owners can, for example, recognize at what time visitors visit their website and what content they are interested in.
    This allows them to better adapt the content of the website to the needs of their visitors, for example.
    For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Remarketing: The term “remarketing” or “retargeting” is used when, for example, it is noted for advertising purposes 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.
  • Location data: Location data is generated when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, a WLAN or similar technical means and functions of location determination.
    Location data is used to indicate the geographically determinable position on earth at which the respective device is located.
    Location data can be used, for example, to display map functions or other location-dependent information.
  • Tracking: The term “tracking” is used when the behavior of users can be traced across several online offers.
    As a rule, behavioral and interest information is stored in cookies or on the servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling).
    This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
  • Controller: The “controller” is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means.
    The term is broad and covers practically every handling of data, be it collection, analysis, storage, transmission or deletion.
  • Target group formation: Target group formation (or “custom audiences”) is when target groups are determined for advertising purposes, e.g. the display of advertisements.
    For example, based on a user’s interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online store in which they viewed the products.
    In turn, we speak of “lookalike audiences” (or similar target groups) if the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created.
    Cookies and web beacons are generally used for the purpose of creating custom audiences and lookalike audiences.