Privacy Policy – wobie fav
preamble
With the following privacy policy, we would like to inform you about which types of your personal data (hereinafter also referred to as "data") we process, for what purposes, and to what extent. This 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, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offering").
The terms used are not gender-specific.
As of: August 25, 2023
Table of Contents
- preamble
- Person responsible
- Relevant legal bases
- Overview of processing
- Transmission of personal data
- International data transfers
- Rights of data subjects
- Business services
- Use of online platforms for offer and sales purposes
- Providers and services used in the course of business activities
- Special notes on applications (apps)
- Registration, login and user account
- Single sign-on login
- Cloud services
- Newsletters and electronic notifications
- Advertising communication via email, post, fax or telephone
- Presences in social networks (social media)
- Plugins and embedded functions and content
- Changes and updates to the privacy policy
- Definitions of terms
Person responsible
wobie GmbH
At the Alster 6
20099 Hamburg
Germany
+4940 237 24 33 312
Authorized representatives:
Karsten Fröiland
E-mail address:
kontakt@wobie.de
Imprint:
www.wobie.de/imprint
Relevant legal bases
Relevant legal bases under the GDPR: Below you will find an overview of the legal bases under the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases apply in individual cases, we will inform you of these in the privacy policy.
- Consent (Article 6 (1) (a) GDPR) - The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
- Contractual performance and pre-contractual inquiries (Article 6 (1) (b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the request of the data subject.
- Legal obligation (Article 6 (1) (c) GDPR) - Processing is necessary to fulfill a legal obligation to which the controller is subject.
- Legitimate interests (Article 6 (1) (f) GDPR) - Processing is necessary to protect the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject which require protection of personal data prevail.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. This includes, in particular, the Federal Data Protection Act (BDSG). The BDSG contains, in particular, special provisions on the right to information, the right to erasure, the right of objection, the processing of special categories of personal data, processing for other purposes, and transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may apply.
Note on the applicability of the GDPR and the Swiss Data Protection Act: This privacy policy serves to provide information in accordance with both the Swiss Federal Data Protection Act (Swiss DSG) and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that, due to their broader geographical application and clarity, the terms used in the GDPR are used instead of the terms "processing" of "personal data," "overriding interest," and "particularly sensitive personal data" used in the Swiss Data Protection Act. However, the legal meaning of these terms will continue to be determined by the Swiss Data Protection Act within the scope of the Swiss Data Protection Act.
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.
- Payment details.
- Contact details.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and procedural data.
- Event data (Facebook).
Categories of data subjects
- Customers.
- Employees.
- Interested parties.
- Communication partner.
- Users.
- Business and contractual partners.
Purposes of processing
- Provision of contractual services and fulfillment of contractual obligations.
- Contact requests and communication.
- Security measures.
- Direct marketing.
- Reach measurement.
- Office and organizational procedures.
- Conversion measurement.
- Managing and responding to inquiries.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Registration procedure.
- Provision of our online offering and user-friendliness.
- Information technology infrastructure.
Transmission of personal data
As part of our processing of personal data, it may happen that the data is transmitted to or disclosed to other bodies, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.
International data transfers
Data processing in third countries: If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if the processing takes place as part of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies, this will only be done in accordance with the legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers only take place if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 (2) (c) GDPR), express consent or in the case of contractually or legally required transfer (Art. 49 (1) GDPR). Otherwise, we will inform you of the basis for third-country transfers from the individual providers from the third country, whereby the adequacy decisions take precedence. Information on third country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de .
EU-US Trans-Atlantic Data Privacy Framework: Within the framework of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognized the level of data protection for certain US companies as secure within the framework of the adequacy decision of July 10, 2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). In our privacy policy, we inform you which service providers we use are certified under the Data Privacy Framework.
Rights of data subjects
Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:
- Right of objection: You have the right to object at any time to the processing of personal data concerning you based on Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; 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 the purposes of such advertising; this also applies to profiling insofar as it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw consent at any time.
- Right to information: You have the right to request confirmation as to whether data concerning you is being processed and to request information about this data as well as further information and a copy of the data in accordance with the legal requirements.
- Right to rectification: You have the right, in accordance with the statutory provisions, to request that the data concerning you be completed or that inaccurate data concerning you be corrected.
- Right to erasure and restriction of processing: You have the right, in accordance with the statutory provisions, 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 that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transmitted to another controller.
- Complaint to a supervisory authority: In accordance with the statutory provisions and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State in which you habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
Business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners") within the framework of contractual and comparable legal relationships as well as related measures and within the framework of communication with the contractual partners (or pre-contractually), e.g. to answer inquiries.
We process this data to fulfill our contractual obligations. This includes, in particular, the obligation to provide the agreed services, any update obligations, and remedy in the event of warranty and other service disruptions. Furthermore, we process the data to protect our rights and for the purposes of the administrative tasks associated with these obligations, as well as company organization. Furthermore, we process the data based on our legitimate interests in proper and efficient business management and in security measures to protect our contractual partners and our business operations from misuse and the endangerment of their data, secrets, information, and rights (e.g., the involvement of telecommunications, transport, and other auxiliary services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Within the framework of applicable law, we only pass on contractual partners' data to third parties to the extent necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed of other forms of processing, e.g., for marketing purposes, in this privacy policy.
We will inform our 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 in person.
We delete the data after statutory warranty and similar obligations have expired, i.e. generally after four years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal archiving reasons. The statutory retention period is ten years for documents relevant for tax law as well as for commercial books, inventories, opening balance sheets, annual financial statements, the work instructions necessary to understand these documents and other organizational documents and accounting documents, and six years for received commercial and business letters and reproductions of sent commercial and business letters. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, opening balance sheet, annual financial statements or management report was prepared, the commercial or business letter was received or sent, the accounting document was created, the recording was made or the other documents were created.
To the extent that 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 to the relationship between users and the providers.
- Types of data processed: 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., contract subject matter, term, customer category); usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
- Data subjects: customers; prospective customers; business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; security measures; contact requests and communication; office and organizational procedures; administration and response to inquiries.
- Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Legal obligation (Art. 6 (1) (c) GDPR); Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
Customer account: Customers can create an account within our online offering (e.g., customer or user account, "customer account" for short). If registration of a customer account is required, customers will be informed of this, as well as the information required for registration. Customer accounts are not public and cannot be indexed by search engines. During registration, as well as subsequent logins and use of the customer account, we store the customer's IP addresses along with the access times in order to verify registration and prevent any misuse of the customer account. If the customer account is terminated, the customer account data will be deleted after the termination date, unless it is retained for purposes other than providing the customer account or must be retained for legal reasons (e.g., internal storage of customer data, order processes, or invoices). It is the customer's responsibility to secure their data upon termination of the customer account; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
Use of online platforms for offer and sales purposes
We offer our services on online platforms operated by other service providers. In this context, the privacy policies of the respective platforms apply in addition to our privacy policy. This applies in particular with regard to the execution of the payment process and the methods used on the platforms for reach measurement and interest-based marketing.
- Types of data processed: 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. contract subject, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
- Data subjects: customers.
- Purposes of processing: provision of contractual services and customer service; marketing.
- Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Amazon: Online marketplace for e-commerce; service provider: Amazon EU S.à rl (Société à responsabilité limitée), 38 avenue John F. Kennedy, L-1855 Luxembourg; legal basis: legitimate interests (Art. 6 (1) (f) GDPR); website: https://www.amazon.de/ ; privacy policy: https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010 .
Providers and services used in the course of business activities
In the course of our business activities, we use additional services, platforms, interfaces, or plug-ins from third-party providers (hereinafter "Services") in compliance with legal requirements. Their use is based on our interest in the proper, lawful, and economical management of our business operations and our internal organization.
- Types of data processed: Inventory data (e.g., names, addresses); payment data (e.g., bank details, invoices, payment history); contact data (e.g., email, telephone numbers); content data (e.g., entries in online forms); contract data (e.g., contract subject matter, term, customer category).
- Data subjects: customers; interested parties; users (e.g., website visitors, users of online services); business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Office and organizational procedures.
- Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- TuneIn: TuneIn is an online service and mobile app for Android, Apple iOS, Blackberry, Microsoft Windows Phone, Fire OS, and Samsung that enables streaming of radio stations and internet radio; Service provider: TuneIn, Inc.
- Spotify: Spotify (from the English words "to spot" and "to identify") is a publicly traded audio streaming service based in Stockholm. In addition to music, audiobooks and podcasts can also be streamed. Service provider: Spotify AB.
Special notes on applications (apps)
We process the data of our application users to the extent necessary to provide the application and its functionalities to users, to monitor its security, and to further develop it. We may also contact users in compliance with legal requirements if communication is necessary for the purposes of administering or using the application. Furthermore, with regard to the processing of user data, we refer to the data protection information in this privacy policy.
Legal basis: The processing of data required to provide the application's functionalities serves to fulfill contractual obligations. This also applies if the provision of the functions requires user authorization (e.g., approval of device functions). If the processing of data is not necessary to provide the application's functionalities, but serves the security of the application or our business interests (e.g., collecting data for the purpose of optimizing the application or security purposes), it is based on our legitimate interests. If users are expressly asked for their consent to the processing of their data, the data covered by the consent will be processed on the basis of their consent.
- Types of data processed: Inventory data (e.g., names, addresses); metadata, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status); payment data (e.g., bank details, invoices, payment history); contract data (e.g., contract subject matter, term, customer category).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations.
- Legal basis:
- Consent (Art. 6 (1) (a) GDPR); Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Commercial use: We process the data of our application users, registered users, and any test users (hereinafter collectively referred to as "users") in order to provide them with our contractual services, as well as on the basis of legitimate interests, to ensure the security of our application and to further develop it. The required information is marked as such within the scope of the user agreement, order, or similar contract conclusion and may include the information required for service provision and any billing, as well as contact information for any follow-up consultations. Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
- Storage of a universal and unique identifier (UUID):
The application stores a so-called universally unique identifier (UUID) for the purposes of analyzing application usage and functionality, as well as storing user preferences. This identifier is generated when the application is installed (but is not linked to the device, so it is not a device identifier in this sense), remains stored between the application launch and its updates, and is deleted when users uninstall the application from their device.
Registration, login and user account
Users can create a user account. During registration, users are provided with the required mandatory information and processed for the purpose of providing the user account based on contractual obligations. The processed data includes, in particular, login information (username, password, and email address).
When you use our registration and login functions, as well as your user account, we store your IP address and the time of each user action. This storage is based on our legitimate interests and those of the users in protecting against misuse and other unauthorized use. This data is generally not shared with third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users may be informed by email about events relevant to their user account, such as technical changes.
- Types of data processed: Inventory data (e.g., names, addresses); contact data (e.g., email, telephone numbers); content data (e.g., entries in online forms); metadata, communication data, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; security measures; administration and response to inquiries; provision of our online offering and user-friendliness.
- Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Registration with pseudonyms: Users may use pseudonyms as usernames instead of real names; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
Single sign-on login
"Single sign-on" or "single sign-on registration or authentication" refers to procedures that allow users to log in to our online offering using a user account with a provider of single sign-on procedures (e.g., a social network). The prerequisite for single sign-on authentication is that users are registered with the respective single sign-on provider and enter the required access data in the online form provided for this purpose, or are already logged in with the single sign-on provider and confirm the single sign-on registration via a button.
Authentication takes place directly with the respective single sign-on provider. As part of such authentication, we receive a user ID with the information that the user is logged in to the respective single sign-on provider using this user ID, as well as an ID (so-called "user handle") that we cannot use for other purposes. Whether additional data is transmitted to us depends solely on the single sign-on process used, the data releases selected during authentication, and also on which data users have released in the privacy or other settings of their user account with the single sign-on provider. Depending on the single sign-on provider and the user's choice, this may be different data; typically, it is the email address and user name. The password entered during the single sign-on process with the single sign-on provider is neither visible to us nor is it stored by us.
Users are asked to note that the information we store can be automatically compared with their user account with the single sign-on provider, but this is not always possible or actually done. If, for example, users' email addresses change, they must manually update them in their user account with us.
We can use single sign-on registration, if agreed with the users, as part of or before the fulfillment of the contract, if the users have been asked to do so, process it within the scope of their consent and otherwise use it on the basis of our legitimate interests and the interests of the users in an effective and secure registration system.
If users decide they no longer wish to use the link between their user account and the single sign-on provider for the single sign-on process, they must cancel this connection within their user account with the single sign-on provider. If users wish to delete their data from us, they must cancel their registration with us.
- Types of data processed: Inventory data (e.g., names, addresses); contact data (e.g., email, telephone numbers); usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status); Event Data (Facebook) ("Event Data" is data that can be transmitted by us to Facebook, e.g., via Facebook Pixel (via apps or other means) and relates to individuals or their actions. This data includes, for example, information about visits to websites, interactions with content, functions, app installations, product purchases, etc.; the event data is processed for the purpose of creating target groups for content and advertising information (custom audiences). Event Data does not contain the actual content (such as comments written), login information, or contact information (i.e., no names, email addresses, or phone numbers). Event Data is deleted by Facebook after a maximum of two years; the target groups created from it are deleted when our Facebook account is deleted.
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; security measures. Registration procedures.
- Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Apple Single Sign-On: Authentication service; Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.apple.com/de/ ; Privacy policy: https://www.apple.com/legal/privacy/de-ww/ .
- Facebook Single Sign-On: Authentication service of the Facebook platform; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.facebook.com ; Privacy Policy: https://www.facebook.com/about/privacy ; Data processing agreement: https://www.facebook.com/legal/terms/dataprocessing ; Standard contractual clauses (guaranteeing data protection levels when processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum .
- Google Single Sign-On: Authentication service; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Opt-out option: Settings for the display of advertisements: https://adssettings.google.com/authenticated; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Website: https://www.google.de ; Privacy policy: https://policies.google.com/privacy .
- Spotify: Spotify - music hosting and widget; Service provider: Spotify AB, Regeringsgatan 19, SE-111 53 Stockholm, Sweden; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.spotify.com/de ; Privacy policy: https://www.spotify.com/de/legal/privacy-policy/ .
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 storage and management of content (e.g. document storage and management, exchange of documents, content and information with specific recipients or publication of content and information).
Within this framework, personal data may be processed and stored on the providers' servers if it is part of communication with us or is otherwise processed by us as set out in this privacy policy. This data may include, in particular, user master data and contact details, data on transactions, contracts, other processes, and their content. The providers of cloud services also process usage data and metadata, which they use for security purposes and to optimize their services.
If we use cloud services to provide forms, documents, and content to other users or publicly accessible websites, the providers may store cookies on users' devices for the purposes of web analysis or to remember users' settings (e.g., in the case of media control).
- Types of data processed: Inventory data (e.g., names, addresses); contact data (e.g., email, telephone numbers); content data (e.g., entries in online forms); usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
- Data subjects: Customers; employees (e.g., employees, applicants, former employees); interested parties; communication partners.
- Purposes of processing: Office and organizational procedures. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.).
- Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Amazon Drive: Cloud storage service; Service provider: Amazon EU S.à rl (Société à responsabilité limitée), 38 avenue John F. Kennedy, L-1855 Luxembourg; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.amazon.de ; Privacy Policy: https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010 . Basis for third-country transfer: EU-US Data Privacy Framework (DPF).
Newsletters and electronic notifications
We send newsletters, emails, and other electronic notifications (hereinafter "newsletters") only with the recipient's consent or legal permission. If the newsletter's content is specifically described when registering for the newsletter, it is decisive for the user's consent. Furthermore, our newsletters contain information about our services and us.
To subscribe to our newsletter, it is generally sufficient to provide your email address. However, we may ask you to provide a name for the purpose of addressing you personally in the newsletter, or other information if this is necessary for the purposes of the newsletter.
Double opt-in process: Registration for our newsletter is generally carried out using a so-called double opt-in process. This means that after registration, you will receive an email asking you to confirm your registration. This confirmation is necessary to ensure that no one can register using someone else's email address. Newsletter registrations are logged to provide evidence of 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 shipping service provider are also logged.
Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address on a block list (so-called "block list") for this purpose alone.
The registration process is logged based on our legitimate interests for the purpose of demonstrating its proper execution. If we commission a service provider to send emails, this is done based on our legitimate interests in an efficient and secure delivery system.
Contents:
Information about us, our services, promotions and offers.
- Types of data processed: Inventory data (e.g., names, addresses); contact data (e.g., email, telephone numbers); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status); usage data (e.g., websites visited, interest in content, access times).
- Data subjects: communication partners.
- Purposes of processing: direct marketing (e.g. by email or post).
- Legal basis: Consent (Art. 6 (1) (a) GDPR).
- Opt-out: You can unsubscribe from 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 by using one of the contact options listed above, preferably email.
Further information on processing procedures, methods and services:
- Measuring open and click rates: The newsletters contain a so-called "web beacon," i.e., a pixel-sized file that is retrieved from our server when the newsletter is opened, or, if we use a shipping service provider, from its server. During 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 to technically improve our newsletter based on technical data or target groups and their reading behavior based on their access 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. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. The evaluations allow us to recognize the reading habits of our users and adapt our content to them, or to send different content based on our users' interests.
The measurement of opening rates and click rates as well as the storage of the measurement results in the user profiles and their further processing are based on the user's consent.
Unfortunately, a separate revocation of performance measurement is not possible. In this case, the entire newsletter subscription must be canceled or revoked. In this case, the stored profile information will be deleted.
Legal basis: Consent (Art. 6 (1) (a) GDPR).
Advertising communication via email, post, fax or telephone
We process personal data for the purposes of advertising communication, which can be carried out via various channels, such as email, telephone, mail or fax, in accordance with legal requirements.
Recipients have the right to revoke consent given or to object to advertising communication at any time.
After revocation or objection, we will store the data required to prove previous authorization for contacting or sending for up to three years after the end of the year of revocation or objection based on our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. Based on our legitimate interest in permanently respecting the user's revocation or objection, we also store the data required to avoid further contact (e.g., depending on the communication channel, the email address, telephone number, name).
- Types of data processed: Inventory data (e.g., names, addresses). Contact data (e.g., email, telephone numbers).
- Data subjects: communication partners.
- Purposes of processing: direct marketing (e.g. by email or post).
- Legal basis: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Presences in social networks (social media)
We maintain online presences within social networks and, in this context, process user data 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 could pose risks for users, for example, because it could make it more difficult to enforce their 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 the users. These user profiles can then be used, for example, to place advertisements within and outside the networks that presumably correspond to the users' interests. For these purposes, cookies are generally stored on users' computers in which the user behavior and interests are saved. Furthermore, user profiles can also store data independent of the devices used by the users (particularly if the users are members of the respective platforms and are logged in to them).
For a detailed description of the respective processing methods and the opt-out options, please refer to the privacy policies 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 like to point out that these can be most effectively asserted with the providers. Only the providers have access to the user data and can directly take appropriate measures and provide information. Should you still need assistance, please contact us.
- Types of data processed: Contact data (e.g., email, telephone numbers); content data (e.g., entries in online forms); usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Contact requests and communication; feedback (e.g., collecting feedback via online form). Marketing.
- Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.instagram.com . Privacy policy: https://instagram.com/about/legal/privacy .
- Facebook Pages: Profiles within the social network Facebook - We, together with Meta Platforms Ireland Limited, are responsible for collecting (but not further processing) data from visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see "Things you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/policy ), as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see "Device Information" in the Facebook Data Policy: https://www.facebook.com/policy ). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services called "Page Insights" to page operators so that they can gain insights into how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook ("Information on Page Insights", https://www.facebook.com/legal/terms/page_controller_addendum ), which specifically regulates the security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of those affected (i.e. users can, for example, direct information or deletion requests directly to Facebook). The rights of users (in particular the right to information, deletion, objection and complaint to the responsible supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information on Page Insights" https://www.facebook.com/legal/terms/information_about_page_insights_data ); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.facebook.com ; Privacy Policy: https://www.facebook.com/about/privacy ; Basis for third-country transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses ( https://www.facebook.com/legal/EU_data_transfer_addendum ). Further information: Joint Controller Agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data Joint controllership is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular the transmission of data to its parent company, Meta Platforms, Inc., in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
Plugins and embedded functions and content
We integrate 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 include, for example, graphics, videos, or city maps (hereinafter collectively referred to as "content").
Integration always requires that the third-party providers of this content process the user's IP address, as without the IP address they would not be able to send the content to their browser. The IP address is therefore required to display 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 may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. These "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, the time of visit, and other information about the use of our online offering, as well as be linked to such information from other sources.
- Types of data processed: Usage data (e.g., websites visited, interest in content, access times). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offering and user-friendliness; reach measurement (e.g., access statistics, recognition of returning visitors); conversion measurement (measurement of the effectiveness of marketing measures); profiles with user-related information (creation of user profiles).
- Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Spotify: Spotify - music hosting and widget; Service provider: Spotify AB, Regeringsgatan 19, SE-111 53 Stockholm, Sweden; Legal basis: legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.spotify.com/de . Privacy policy: https://www.spotify.com/de/legal/privacy-policy/ .
- TuneIn: TuneIn is an online service and mobile app for Android, Apple iOS, Blackberry, Microsoft Windows Phone, Fire OS, and Samsung that enables streaming of radio stations and internet radio; Service provider: TuneIn, Inc.
- Notes on the fonts used: Only Google Fonts are used ( https://fonts.google.com/ ).
Changes and updates to 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 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 privacy policy, we ask you to note that the addresses may change over time and ask you to check the information before contacting us.
Definitions of terms
This section provides an overview of the terms used in this privacy policy. To the extent that the terms are defined by law, the legal definitions apply. The following explanations, however, are intended primarily to facilitate understanding.
- Conversion measurement: Conversion measurement (also known as "visit action analysis") is a method used to determine the effectiveness of marketing measures. This typically involves storing a cookie on users' devices within the websites where the marketing measures are carried out and then retrieving it on the target website. For example, this allows us to understand whether the ads we place on other websites were successful.
- 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 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.
- Profiles with user-related information: The processing of "profiles with user-related information," or "profiles" for short, includes any type of automated processing of personal data consisting of the use of this personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information relating to demographics, behavior, and interests, such as interaction with websites and their content, etc.). Cookies and web beacons are often used for profiling purposes.
- Reach measurement: Reach measurement (also known as web analytics) is used to evaluate visitor traffic to an online offering and can include visitor behavior or interest in specific information, such as website content. With the help of reach analysis, website owners can, for example, identify when visitors visit their website and what content they are interested in. This allows them to, for example, better adapt the website content to the needs of their visitors. 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 offering.
- Controller: The “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of the processing of personal data.
- Processing: "Processing" is any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and encompasses virtually every type of data handling, including collection, analysis, storage, transmission, or deletion.