We also place the greatest importance on transparency when it comes to data protection. Therefore, we store as little user data as possible.
This privacy policy informs you about the type, scope and purpose of the processing of personal data (hereinafter referred to as "Data") in the context of the provision of our services and within our online offering and the websites, functions and content connected to it as well as external online presences, such as our social media profiles (hereinafter collectively referred to as "Online Offering"). With regard to the terminology used, such as "Processing" or "Controller", we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Leeway
Daberkowstraße 12
13593 Berlin
Represented by:
Lars Wißler
kontakt@leeway.tech
- Inventory data (e.g., personal master data, names or addresses).
- Contact data (e.g., email).
- Content data (e.g., text entries).
- Usage data (e.g., websites visited, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).
Visitors and users of the online offering (hereinafter we also refer to the data subjects collectively as "Users").
- Provision of the online offering, its functions and content.
- Answering contact requests and communicating with users.
- Security measures.
- Reach measurement/Marketing
"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., cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
"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 virtually any handling of data.
"Pseudonymization" means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
"Profiling" means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
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.
"Processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. For users from the scope of the General Data Protection Regulation (GDPR), i.e., the EU and the EEA, the following applies, unless the legal basis is stated in the privacy policy:
The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR;
The legal basis for processing for the fulfillment of our services and implementation of contractual measures as well as answering inquiries is Art. 6 para. 1 lit. b GDPR;
The legal basis for processing for the fulfillment of our legal obligations is Art. 6 para. 1 lit. c GDPR;
In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.
The legal basis for the necessary processing for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Art. 6 para. 1 lit. e GDPR.
The legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f GDPR.
The processing of data for purposes other than those for which they were collected is determined by the provisions of Art. 6 para. 4 GDPR.
The processing of special categories of data (in accordance with Art. 9 para. 1 GDPR) is determined by the provisions of Art. 9 para. 2 GDPR.
We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk in accordance with legal requirements, taking into account the state of the art, implementation costs and the nature, scope, circumstances and purposes of processing, as well as the different probabilities of occurrence and severity of the risk to the rights and freedoms of natural persons.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access, input, disclosure, ensuring availability and separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, deletion of data and response to data threats. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software and procedures in accordance with the principle of data protection through technology design and through privacy-friendly default settings.
If we disclose data to other persons and companies (processors, joint controllers or third parties), transmit it to them or otherwise grant them access to the data within the framework of our processing, this is only done on the basis of a legal permission (e.g., if transmission of the data to third parties, such as payment service providers, is necessary for contract fulfillment), users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g., when using agents, web hosts, etc.).
If we disclose, transmit or otherwise grant access to data to other companies in our corporate group, this is done in particular for administrative purposes as a legitimate interest and beyond that on a basis corresponding to legal requirements.
If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or this happens in the context of using third-party services or disclosing or transferring data to other persons or companies, this is only done if it is necessary to fulfill our (pre)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to express consent or contractually required transfer, we process or have the data processed only in third countries with a recognized level of data protection, which include US processors certified under the "Privacy Shield" or on the basis of special guarantees, such as contractual obligations through so-called standard contractual clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, EU Commission information page).
Right to information: You have the right to request confirmation as to whether data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with legal requirements.
Right to rectification: You have the right, in accordance with legal requirements, to request the completion of data concerning you or the rectification of incorrect data concerning you.
Right to erasure and restriction of processing: You have the right, in accordance with legal requirements, to demand that data concerning you be deleted immediately, or alternatively, in accordance with legal requirements, to demand restriction of processing of the data.
Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with legal requirements or to request its transmission to another controller.
Complaint to supervisory authority: You also have the right, in accordance with legal requirements, to file a complaint with the competent supervisory authority.
You have the right to revoke consents given with effect for the future.
Right of objection: You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you that is carried out on the basis of Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising; this also applies to profiling insofar as it is related to such direct marketing.
"Cookies" are small files that are stored on users' computers. Different information can be stored within cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit within an online offering. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online offering and closes their browser. In such a cookie, for example, the contents of a shopping cart in an online store or a login status can be stored. Cookies are described as "permanent" or "persistent" if they remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. Likewise, the interests of users can be stored in such a cookie, which are used for reach measurement or marketing purposes. "Third-party cookies" are cookies that are offered by providers other than the controller who operates the online offering (otherwise, if it is only the controller's cookies, they are referred to as "first-party cookies").
We may use temporary and permanent cookies and clarify this within the framework of our privacy policy.
If we ask users for consent to the use of cookies (e.g., in the context of a cookie consent), the legal basis for this processing is Art. 6 para. 1 lit. a. GDPR. Otherwise, the personal cookies of users are processed in accordance with the following explanations within the framework of this privacy policy on the basis of our legitimate interests (i.e., interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f. GDPR) or if the use of cookies is necessary for the provision of our contract-related services, in accordance with Art. 6 para. 1 lit. b. GDPR, or if the use of cookies is necessary for the performance of a task that is in the public interest or is carried out in the exercise of official authority, in accordance with Art. 6 para. 1 lit. e. GDPR.
If users do not want cookies to be stored on their computer, they are asked to disable the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offering.
A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by disabling them in the browser settings. Please note that not all functions of this online offering may then be available.
The data processed by us will be deleted or restricted in its processing in accordance with legal requirements. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and no legal retention obligations prevent deletion.
If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. That is, the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
We ask you to regularly inform yourself about the content of our privacy policy. We 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 an action on your part (e.g., consent) or other individual notification.
Additionally, we process
- Contract data (e.g., subject matter of contract, term, customer category).
- Payment data (e.g., bank details, payment history)
from our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
We use external payment service providers, on whose platforms users and we can carry out payment transactions. These payment service providers may include, each with
Stripe (https://stripe.com/de/privacy).
In the context of contract fulfillment, we use payment service providers on the basis of Art. 6 para. 1 lit. b. GDPR. Otherwise, we use external payment service providers on the basis of our legitimate interests in accordance with Art. 6 para. 1 lit. f. GDPR in order to offer our users effective and secure payment options.
The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed and stored by the payment service providers. That is, 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. This transmission is for the purpose of identity and credit checks. For this, we refer to the terms and conditions and privacy notices of the payment service providers.
The terms and conditions and privacy notices of the respective payment service providers apply to payment transactions, which can be accessed within the respective websites or transaction applications. We also refer to these for further information and assertion of revocation, information and other data subject rights.
We process data in the context of administrative tasks as well as organization of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the context of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers, prospects, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in administration, financial accounting, office organization, archiving of data, i.e., tasks that serve to maintain our business activities, perform our tasks and provide our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information mentioned in these processing activities.
We disclose or transfer data to the tax authorities, advisors such as tax advisors or auditors as well as other fee offices and payment service providers.
Furthermore, we store information on suppliers, organizers and other business partners on the basis of our business interests, e.g., for the purpose of later contact. We generally store these mostly company-related data permanently.
Users can create a user account. As part of the registration, the required mandatory information is communicated to users and processed on the basis of Art. 6 para. 1 lit. b GDPR for the purpose of providing the user account. The data processed includes, in particular, login information (name, password and an email address). The data entered during registration is used for the purposes of using the user account and its purpose.
Users can be informed by email about information relevant to their user account, such as technical changes. If users have canceled their user account, their data will be deleted with regard to the user account, subject to a legal retention obligation. It is the users' responsibility to back up their data before the end of the contract if they have canceled. We are entitled to irretrievably delete all data stored by the user during the contract period.
In the context of using our registration and login functions as well as using the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user's protection against misuse and other unauthorized use. A transfer of this data to third parties does not generally take place, unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Art. 6 para. 1 lit. c. GDPR. IP addresses are anonymized or deleted after 7 days at the latest.
When contacting us (e.g., via contact form, email, telephone or via social media), the user's information is processed for the purpose of handling the contact request and its processing in accordance with Art. 6 para. 1 lit. b. (within the framework of contractual/pre-contractual relationships), Art. 6 para. 1 lit. f. (other inquiries) GDPR. The user's information may be stored in a Customer Relationship Management System ("CRM System") or comparable inquiry organization.
We delete the inquiries if they are no longer required. We review the necessity every two years; furthermore, the legal archiving obligations apply.
With the following information, we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.
Newsletter content: We send newsletters, emails and other electronic notifications with promotional information (hereinafter "Newsletter") only with the consent of the recipients or a legal permission. If the contents of the newsletter are specifically described within the framework of a registration, they are decisive for the consent of the users. Otherwise, our newsletters contain information about our services and us.
Double-Opt-In and Logging: Registration for our newsletter takes place in a so-called double-opt-in procedure. That is, you will receive an email after registration asking you to confirm your registration. This confirmation is necessary so that no one can register with foreign email addresses. Newsletter registrations are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the registration and confirmation time, as well as the IP address. Changes to your data stored with the shipping service provider are also logged.
Registration data: To register for the newsletter, it is sufficient if you provide your email address. Optionally, we ask you to provide a name for personal address in the newsletter.
The sending of the newsletter and the success measurement associated with it are based on the consent of the recipients in accordance with Art. 6 para. 1 lit. a, Art. 7 GDPR in conjunction with § 7 para. 2 no. 3 UWG or, if consent is not required, on the basis of our legitimate interests in direct marketing in accordance with Art. 6 para. 1 lit. f. GDPR in conjunction with § 7 para. 3 UWG.
The logging of the registration process is based on our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR. Our interest is directed towards the use of a user-friendly and secure newsletter system that serves both our business interests and meets the expectations of users and also allows us to prove consent.
Cancellation/Revocation - You can cancel the receipt of our newsletter at any time, i.e., revoke your consents. A link to cancel the newsletter can be found at the end of each newsletter. We may store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of a consent is confirmed at the same time.
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. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval, are first collected.
This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or access times. The statistical surveys also include determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our aim nor, if used, that of the shipping service provider to observe individual users. The evaluations serve us much more 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.
A separate revocation of the success measurement is unfortunately not possible, in this case the entire newsletter subscription must be canceled.
The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, email delivery, security services and technical maintenance services that we use for the purpose of operating this online offering.
In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, prospects and visitors to this online offering on the basis of our legitimate interests in an efficient and secure provision of this online offering in accordance with Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of order processing contract).
We, or our hosting provider, collect data on every access to the server on which this service is located (so-called server log files) on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR. The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, message about successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Log file information is stored for security reasons (e.g., to investigate abuse or fraud) for a maximum of 7 days and then deleted. Data whose further retention is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
Google Tag Manager is a solution with which we can manage so-called website tags via an interface (and thus integrate Google Analytics and other Google marketing services into our online offering). The Tag Manager itself (which implements the tags) does not process any personal data of users. With regard to the processing of personal data of users, reference is made to the following information on Google services. Terms of use: https://www.google.com/intl/de/tagmanager/use-policy.html.
We use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). Google uses cookies. The information generated by the cookie about the use of the online offering by users is usually transmitted to a Google server in the USA and stored there.
Google will use this information on our behalf to evaluate the use of our online offering by users, to compile reports on the activities within this online offering and to provide us with further services related to the use of this online offering and internet usage. Pseudonymous user profiles of users can be created from the processed data.
We only use Google Analytics with IP anonymization enabled. This means that the IP address of users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user's browser is not merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of data generated by the cookie and related to their use of the online offering to Google as well as the processing of this data by Google by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
If we ask users for consent (e.g., in the context of a cookie consent), the legal basis for this processing is Art. 6 para. 1 lit. a. GDPR. Otherwise, the personal data of users is processed on the basis of our legitimate interests (i.e., interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f. GDPR).
Insofar as data is processed in the USA, we point out that Google is certified under the Privacy Shield Agreement and thereby assures compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Further information on data use by Google, settings and objection options can be found in Google's privacy policy (https://policies.google.com/privacy) as well as in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
The personal data of users will be deleted or anonymized after 14 months.
We use Google Analytics in the form of "Universal Analytics". "Universal Analytics" refers to a method of Google Analytics in which user analysis is performed on the basis of a pseudonymous user ID and thus a pseudonymous profile of the user is created with information from the use of various devices (so-called "Cross-Device-Tracking").
We use Google Analytics to display the ads placed within Google's advertising services and those of its partners only to users who have also shown an interest in our online offering or who have certain characteristics (e.g., interests in certain topics or products determined by the websites visited) that we transmit to Google (so-called "Remarketing" or "Google Analytics Audiences"). With the help of remarketing audiences, we also want to ensure that our ads correspond to the potential interest of users.
We use the online marketing method Google "AdWords" 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 have a presumed interest in the ads. This allows us to display ads for and within our online offering more targeted in order to present users only ads that potentially correspond to their interests. If a user is shown ads for products, for example, that he has shown interest in on other online offerings, this is referred to as "Remarketing". For these purposes, when our and other websites on which the Google advertising network is active are accessed, a code from Google is executed immediately by Google and so-called (re)marketing tags (invisible graphics or code, also referred to as "Web Beacons") are integrated into the website. With their help, an individual cookie, i.e., a small file, is stored on the user's device (instead of cookies, comparable technologies can also be used). This file notes which websites the user has visited, what content he is interested in and which offers the user has clicked on, as well as technical information about the browser and operating system, referring websites, visit time and further information about the use of the online offering.
Furthermore, we receive an individual "Conversion Cookie". The information collected with the help of the cookie is used by Google to create conversion statistics for us. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page tagged with a conversion tracking tag. However, we do not receive any information that can be used to personally identify users.
The data of users is processed pseudonymously within the Google advertising network. That is, Google does not store and process, for example, the name or email address of users, but processes the relevant data cookie-related within pseudonymous user profiles. That is, from Google's perspective, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymization. The information collected about users is transmitted to Google and stored on Google's servers in the USA.
If we ask users for consent (e.g., in the context of a cookie consent), the legal basis for this processing is Art. 6 para. 1 lit. a. GDPR. Otherwise, the personal data of users is processed on the basis of our legitimate interests (i.e., interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f. GDPR).
Insofar as data is processed in the USA, we point out that Google is certified under the Privacy Shield Agreement and thereby assures compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Further information on data use by Google, settings and objection options can be found in Google's privacy policy (https://policies.google.com/technologies/ads) as well as in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
Within our online offering, the so-called "Facebook Pixel" of the social network Facebook, which is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"), is used.
With the help of the Facebook Pixel, Facebook is able to determine the visitors of our online offering 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 Facebook users who have also shown an interest in our online offering or who have certain characteristics (e.g., interests in certain topics or products determined by 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 do not appear annoying. With the help of the Facebook Pixel, we can also track the effectiveness of Facebook advertisements for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook advertisement (so-called "Conversion").
The processing of data by Facebook takes place within the framework of Facebook's data usage policy. Accordingly, general information on the display of Facebook Ads can be found in Facebook's data usage policy: https://www.facebook.com/policy. Specific information and details about the Facebook Pixel and how it works can be found in Facebook's help section: https://www.facebook.com/business/help/651294705016616.
If we ask users for consent (e.g., in the context of a cookie consent), the legal basis for this processing is Art. 6 para. 1 lit. a. GDPR. Otherwise, the personal data of users is processed on the basis of our legitimate interests (i.e., interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f. GDPR).
Facebook is certified under the Privacy Shield Agreement and thereby assures compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
You can object to the collection by the Facebook Pixel and use of your data to display Facebook Ads. To set which types of advertisements are shown to you within Facebook, you can visit the page set up by Facebook and follow the instructions there on settings for usage-based advertising: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e., they are applied to all devices, such as desktop computers or mobile devices.
You can also object to the use of cookies used for reach measurement and advertising purposes via the deactivation page of the Network Advertising Initiative (http://optout.networkadvertising.org/) and additionally the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).
We use the conversion and tracking services "Microsoft Advertising" of Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA, within our online offering. In doing so, Microsoft stores cookies on users' devices to enable an analysis of the use of our online offering by users, provided that users have reached our online offering via a Microsoft ad (so-called "Conversion Measurement"). Microsoft and we can recognize in this way that someone has clicked on an ad, was redirected to our online offering and reached a previously determined target page (so-called "Conversion Page"). We only learn the total number of users who clicked on a Microsoft ad and were then redirected to the conversion page. No IP addresses are stored. No personal information about the identity of users is communicated.
If we ask users for consent (e.g., in the context of a cookie consent), the legal basis for this processing is Art. 6 para. 1 lit. a. GDPR. Otherwise, the personal data of users is processed on the basis of our legitimate interests (i.e., interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f. GDPR).
Microsoft is certified under the Privacy Shield Agreement and thereby assures compliance with European and Swiss data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active).
If users do not want to participate in the tracking procedure of Microsoft Advertising, they can also disable the setting of a cookie required for this via browser settings or use Microsoft's opt-out page: http://choice.microsoft.com/de-DE/opt-out.
Further information on data protection and the cookies used at Microsoft Advertising can be found in Microsoft's privacy policy: https://privacy.microsoft.com/de-de/privacystatement.
We maintain online presences within social networks and platforms in order to communicate with customers, prospects and users active there and to inform them about our services.
We point out that data of users may be processed outside the European Union. This can result in risks for users because, for example, the enforcement of users' rights could be made more difficult. With regard to US providers certified under the Privacy Shield, we point out that they thereby commit themselves to comply with EU data protection standards.
Furthermore, user data is usually processed for market research and advertising purposes. For example, usage profiles can be created from the usage behavior and resulting interests of users. The usage profiles can in turn be used to place advertisements inside and outside the platforms that presumably correspond to the interests of users. For these purposes, cookies are usually stored on users' computers in which the usage behavior and interests of users are stored. Furthermore, data can also be stored in the usage profiles regardless of the devices used by users (especially if users are members of the respective platforms and are logged in to them).
The processing of personal data of users is based on our legitimate interests in effective information of users and communication with users in accordance with Art. 6 para. 1 lit. f. GDPR. If users are asked by the respective platform providers for consent to the data processing described above, the legal basis for processing is Art. 6 para. 1 lit. a., Art. 7 GDPR.
For a detailed presentation of the respective processing and the options for objection (opt-out), we refer to the information linked below from the providers.
Also in the case of information requests and the assertion of user rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the data of users and can directly take appropriate measures and provide information. If you still need help, you can contact us.
- Facebook, -Pages, -Groups, (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) on the basis of an Agreement on Joint Processing of Personal Data - Privacy Policy: https://www.facebook.com/about/privacy/, specifically for pages: https://www.facebook.com/legal/terms/information_about_page_insights_data, Opt-Out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.
- Google/ YouTube (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) – Privacy Policy: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – Privacy Policy/ Opt-Out: http://instagram.com/about/legal/privacy/.
- Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) - Privacy Policy: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.
- Pinterest (Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA) – Privacy Policy/ Opt-Out: https://about.pinterest.com/de/privacy-policy.
- LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland) - Privacy Policy https://www.linkedin.com/legal/privacy-policy, Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active.
- Xing (XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany) - Privacy Policy/ Opt-Out: https://privacy.xing.com/de/datenschutzerklaerung.
We use external "Typekit" fonts from the provider Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Republic of Ireland on the basis of our legitimate interests (i.e., interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f. GDPR). Adobe is certified under the Privacy Shield Agreement and thereby offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000TNo9AAG&status=Active).
Contact Management and Message Sending
This type of service enables the management of a database of email contacts, phone numbers or any other contact information to communicate with the user. The services may also collect data about the date and time when the message was read by the user, as well as when the user interacted with incoming messages, such as by clicking on links contained therein.
SendinBlue Email (SendinBlue SAS)
SendinBlue is a service provided by SendinBlue SAS for managing email addresses and sending messages.
Personal data collected: Cookie; Email; Usage data.
Place of processing: France
Privacy Policy: https://de.sendinblue.com/legal/privacypolicy/
User Database Management
This type of service allows the provider to create user profiles by first using the email address, name or other information that the user has provided to this application, as well as tracking user activities through analytics functionality. This personal data may also be matched with publicly available information about the user (such as profiles on social media) and used to build a personal profile that the provider can display and use to improve this application. Some of these services may also provide for sending time-synchronized messages to the user, such as emails linked to specific actions in this application.
SendinBlue Marketing Automation (SendinBlue SAS)
SendinBlue is a user database management service from SendinBlue SAS.
Personal data collected: Cookie; Email; Usage data.
Place of processing: France
Privacy Policy: https://de.sendinblue.com/legal/privacypolicy/
We use Hotjar to better understand our users' needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users' experiences (e.g., how much time they spend on which pages, which links they click, what users like and don't like, etc.) and enables us to build and maintain our service based on user feedback. Hotjar uses cookies and other technologies to collect data about our users' behavior and their devices. This includes a device's IP address (processed and stored in anonymized form during your session), device screen size, device type (unique device identifiers), browser information, geographic location (country only) and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually prohibited from selling the data collected on our behalf.
For more details, see the 'About Hotjar' section on Hotjar's support page.
This page uses an integration of the liability seal of Exali AG. The graphic element of the seal is loaded from the servers of Exali AG. For this purpose, your IP address is processed due to the technical design of the Internet in order to transmit the graphic to your browser.
If you click on this seal, you leave our page and are redirected to the servers of Exali AG.
More information can be found in Exali's privacy policy: Privacy Policy
The legal basis for data processing is Art. 6 para. 1 lit. f) GDPR (legitimate interest).
The data processing serves the purpose of providing the legally required mandatory information on professional liability insurance in accordance with § 2 para. 11 DL-InfoV) in an appealing visual manner.
Our legitimate interest in data processing arises from the purpose of offering an appealing online offering and fulfilling our information obligations in a design-appealing manner.
Created with Datenschutz-Generator.de by RA Dr. Thomas Schwenke