We manage our websites according to the principles regulated below:
We undertake to comply with the legal provisions on data protection and strive to always take into account the principles of data avoidance and data minimization.
1. name and address of the responsible person
The responsible party within the meaning of the General Data Protection Regulation and other national data protection laws of the member states of the European Union as well as other data protection regulations is:
Mr. Klemens Höbing
Doncaster Square 5-7
2. explanations of terms
3. legal basis for the processing of personal data
We only process your personal data, such as your surname and first name, your e-mail address and IP address, etc., if there is a legal basis for doing so. Here, according to the General Data Protection Regulation, three regulations in particular come into consideration:
a) You have given us your consent to the processing of your personal data for one or more purposes, Art. 6 (1) p. 1 lit. a DSGVO. In this context, you will be informed by us in detail about the purpose(s) of the processing and your explicit consent will be documented with us.
b) The processing of your personal data is necessary for the performance of a contract or for the implementation of pre-contractual measures with you, Art. 6 para. 1 p. 1 lit. b DSGVO.
c) The processing of personal data is necessary for the protection of our legitimate interests, unless your interests or fundamental rights and freedoms prevail, Art. 6 para. 1 p. 1 lit. f DSGVO.
However, we will always point out to you again at the respective points on which legal basis the processing of your personal data takes place.
4. transfer of personal data
A transfer of your personal data to third parties for purposes other than those listed below does not take place. We will only disclose your personal data to third parties if:
(a) you have given your express consent to do so in accordance with Art. 6 (1) p. 1 lit. a DSGVO,
b) the disclosure according to Art. 6 para. 1 p. 1 lit. f DSGVO is necessary for the assertion, exercise or defense of legal claims and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data,
c) there is a legal obligation for the disclosure according to Art. 6 para. 1 p. 1 lit. c DSGVO.
d) this is legally permissible and necessary for the processing of contractual relationships with you according to Art. 6 para. 1 p. 1 lit. b DSGVO.
5. storage period and deletion
We store all personal data that you transmit to us only as long as they are needed to fulfill the purposes for which these data were transmitted or as long as this is required by law. Upon fulfillment of the purpose and/or expiration of the legal storage periods, the data will be deleted or blocked by us.
6. SSL Encryption
This website uses SSL encryption for security reasons and to protect the transmission of confidential content, such as the inquiries you send to us as the website operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line.
If SSL encryption is activated, the data you transmit to us cannot be read by third parties.
7. collection and storage of personal data as well as their type and purpose of use
a) When visiting the website
When you call up our website, information is automatically sent to the server of our website by the browser used on your end device. This information is temporarily stored in a so-called log file. The following information is collected without your intervention and stored until automated deletion:
- IP address of the requesting computer
- Date and time of access
- Name and URL of the accessed file
- Website from which the access was made (referrer URL)
- Browser used and, if applicable, the operating system of your computer as well as the name of your access provider.
The aforementioned data is processed by us for the following purposes:
- Ensuring a comfortable use of our website
- Evaluation of system security and stability
Data that allow a conclusion to your person, such as the IP address, will be deleted after 7 days at the latest. If we store the data beyond this period, this data will be pseudonymized so that an assignment to you is no longer possible.
The legal basis for the data processing is Art. 6 para. 1 p. 1 lit. f DSGVO. In no case do we use the collected data for the purpose of drawing conclusions about your person.
b) Tracking to evaluate the use of the newsletter.
Double opt-in and logging
For security reasons, we use the so-called double opt-in procedure to register for our newsletter, so that no one can register with other people's e-mail addresses. Therefore, after you have registered for our newsletter, you will first receive an e-mail asking you to confirm your registration. Only with the confirmation of the registration it becomes effective.
Furthermore, your registration for the newsletter will be logged. The logging includes the storage of the registration and confirmation time, your specified data and your IP address. If you make changes to your data, these changes will also be logged.
If you no longer wish to receive our newsletter, you can revoke your consent at any time for the future. To do so, you can click on the unsubscribe link at the end of each newsletter or send us an e-mail to the following e-mail address: email@example.com.
The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
Content of the newsletter and registration data
We will only send you a newsletter if you order it from us and have given your consent in accordance with Art. 6 (1) p. 1 lit. a DSGVO. The contents of the newsletter will be specifically described when you register for the newsletter. For the registration of the newsletter, it is sufficient to provide your e-mail address. If you provide further voluntary information, such as your name and/or gender, this will be used exclusively for the personalization of the newsletter addressed to you.
Dispatch via Mailgun
Emails are sent via the registration portal using "Mailgun", an email sending platform of the US provider Mailgun Technologies, Inc., 535 Mission St., San Francisco, CA 94105. The provider is designated as Privacy Shield-certified (https://www.privacyshield.gov/participant?id=a2zt0000000PCbmAAG&status=Active ), which guarantees compliance with the EU GDPR as well as all other data protection laws or provisions of a data protection nature applicable in the member states of the EU. Users can find more information on data processing by the provider at https://www.mailgun.com/privacy-policy.
Statistical surveys and analyses
The newsletters sent via Mailgun contain a so-called "web-beacon", i.e. a pixel-sized file that is retrieved from Mailgun's server when the newsletter is opened. As part of this retrieval, the following technical information is initially collected:
- Information about the browser
- Information about your system
- Your IP address
- Time of the retrieval
This information is used to improve the services based on the technical data, the target groups and their reading behavior, based on the retrieval locations (which can be determined with the help of the IP address) and the access times.
The statistical surveys also include the determination of whether and when the newsletters are opened and which links in the newsletter are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients, but it is neither our intention nor that of Mailgun 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.
The use of the Mailgun newsletter service, the performance of statistical surveys and analyses as well as the logging of the registration process, are carried out on the basis of our legitimate interests pursuant to Art. 6 para. p. 1 lit. f DSGVO. Our interest is directed towards the use of a user-friendly as well as secure newsletter system that serves our business interests as well as meets the expectations of the users.
c) Contact form / e-mail contact
We provide a contact form on our website so that you have the opportunity to contact us at any time. For the use of the contact form, it is necessary to provide a name for a personal salutation and a valid e-mail address to contact us, so that we know from whom the request originates and can also process it.
If you send us inquiries via the contact form, your information from the inquiry form, including the contact data you provide there, as well as your IP address, will be processed pursuant to Art. 6 (1) p. 1 lit. b and f DSGVO for the purpose of carrying out pre-contractual measures that take place in response to your inquiry or for the exercise of our legitimate interest, namely to carry out our business activities.
Please note that to protect the data transmitted in your request, the message is provided with https transport encryption. You can achieve a higher level of security by contacting us by telephone or fax during the specified opening hours using the above telephone or fax number, or by visiting us in person.
You are also welcome to send us an e-mail instead using the e-mail address provided on our website. In this case, we will store and process your e-mail address and the information you provide in the e-mail in accordance with Art. 6 (1) p. 1 lit. b and f DSGVO to process your message.
The inquiries as well as the associated data will be deleted no later than 3 months after receipt, unless they are required for a further contractual relationship.
d) Google Fonts
We use Google Fonts on our Internet pages. This enables the display of fonts. Google Fonts is a service of Google Inc. (Gordon House, Barrow Street, Dublin 4, Ireland). The integration of these web fonts is done by a server call, usually a Google server in the USA. Through this, the following may be transmitted to the server and stored by Google:
- Name and version of the browser used
- Website from which the request was initiated (referrer URL)
- Operating system of your computer
- Screen resolution of your computer
- IP address of requesting computer
- Language settings of the browser or operating system used by the user
The use of Google Fonts serves to make it easier for you to read our website and to make it more graphically pleasant, and is thus based on our legitimate interests pursuant to Art. 6 (1) p. 1 lit. f DSGVO.
The data processed by cookies is necessary for the aforementioned purposes to protect our legitimate interests as well as those of third parties in accordance with Art. 6 (1) p. 1 lit. f DSGVO.
Most browsers automatically accept cookies based on the browser default setting. However, you can configure your browser so that either no cookies are stored on your end device or at least a notice is displayed before a new cookie is stored. If you completely deactivate the cookie function in your browser, you may not be able to use all the functions of our website.
Below we explain the different types of cookies we use.
a) Session cookies
In order to make the use of our offer more pleasant for you, we use so-called session cookies to recognize that you have already visited individual pages of our website. These session cookies are automatically deleted after you leave our site.
b) Temporary cookies
These temporary cookies are stored on your terminal device for a certain fixed period of time.
c) Cookies for marketing and optimization purposes.
These cookies are automatically deleted after a defined period of time.
9. analysis and tracking tools
We use the analysis and tracking tools listed below on our website. These serve to ensure the continuous optimization of our website and to design it according to requirements.
These interests are to be regarded as legitimate in the sense of Art. 6 para. 1 p. 1 lit. f DSGVO. The respective data processing purposes and data categories can be found in the corresponding tools.
a) Google Analytics
- Name and version of the browser used
- Operating system of your computer
- Website from which the access is made (referrer URL)
- IP address of the requesting computer
- Time of the server request
are usually transferred to a Google server in the USA and stored there.
However, since we have activated IP anonymization on our website, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there.
On our behalf, Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity and providing other services relating to website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google.
You can prevent the storage of cookies by selecting the appropriate settings on your browser software. However, we would like to point out that in this case you may not be able to use all functions of our website to their full extent.
You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and 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.
You can prevent the collection of your data by Google Analytics by rejecting the cookies.
b) Use of Google reCaptcha
We use on our websites at our contact form the service reCAPTCHA of the company Google Inc (Gordon House, Barrow Street, Dublin 4, Ireland) to be able to distinguish the input by a human or by automated, abusive, machine processing. We have a legitimate interest in protecting our web offerings from abusive automated spying and from SPAM.
When queried by the reCAPTCHA service, both your IP address and any other data required by Google for the reCAPTCHA service are forwarded to Google and processed there.
There are three variants of the query:
- No CAPTCHA reCAPTCHA: Only a checkbox with the content "I am not a robot" must be clicked.
- Image reCAPTCHA: 9 image sections are displayed and then similar elements are selected (e.g. all images with street signs).
- Text reCAPTCHA: You have to enter a text, which is mostly hard to read and is displayed as image(s).
On our behalf, Google will use this information to evaluate your use of this service. The IP address transmitted by your browser as part of reCaptcha will not be merged with other data from Google. The deviating data protection provisions of the Google company apply to this data.
10. video integration
We integrate the videos of the platform "YouTube" of the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
If you activate the YouTube plugin during your visit, a connection to the YouTube servers is established and the YouTube server is informed which of our pages you have visited. This allows YouTube to assign your surfing behavior directly to your personal profile. You can prevent this by logging out of your member account before visiting our website.
The legal basis results from Art. 6 para. 1 p. 1 lit. f DSGVO. The underlying promotional purpose is to be regarded as a legitimate interest within the meaning of the DSGVO.
11. rights of the data subject
You are entitled to the following rights:
In accordance with Art. 15 DSGVO, you have the right to request information about your personal data processed by us. This right to information includes information about
- the purposes of processing
- the categories of personal data
- the recipients or categories of recipients to whom your data have been or will be disclosed
- the planned storage period or at least the criteria for determining the storage period
- the existence of a right to rectification, erasure, restriction of processing or objection
- the existence of a right of appeal to a supervisory authority
- the origin of your personal data, if it was not collected by us
- the existence of automated decision-making, including profiling, and, if applicable, meaningful information on the details of such.
Pursuant to Art. 16 DSGVO, you have a right to prompt correction of incorrect or incomplete personal data stored by us.
Pursuant to Art. 17 DSGVO, you have the right to request that we delete your personal data without delay, unless further processing is necessary for one of the following reasons:
- to exercise the right to freedom of expression and information
- for compliance with a legal obligation which requires processing under the law of the European Union or the Member States to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
- for reasons of public interest in the area of public health pursuant to Art. 9(2)(h) and (i) and Art. 9(3) of the GDPR
- for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes pursuant to Art. 89(1) DSGVO, insofar as the right referred to in section a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing
- for the assertion, exercise or defense of legal claims
d) Restriction of processing
In accordance with Art. 18 DSGVO, you may request the restriction of the processing of your personal data for one of the following reasons:
- You dispute the accuracy of your personal data.
- The processing is unlawful and you object to the erasure of the personal data.
- We no longer need the personal data for the purposes of processing, but you need it to assert, exercise or defend legal claims.
- You object to the processing in accordance with Article 21 (1) DSGVO.
If you have requested the rectification or erasure of your personal data or a restriction of processing pursuant to Art. 16, Art. 17 (1) and Art. 18 DSGVO, we will inform all recipients to whom your personal data have been disclosed, unless this proves impossible or involves a disproportionate effort. You may request that we inform you of these recipients.
You have the right to receive your personal data that you have provided to us in a structured, common and machine-readable format.
You also have the right to request that this data be transferred to a third party, provided that the processing was carried out with the help of automated processes and is based on consent pursuant to Art. 6 (1) sentence 1 lit. a or Art. 9 (2) lit. a or on a contract pursuant to Art. 6 (1) sentence 1 lit. b DSGVO.
In accordance with Art. 7 (3) DSGVO, you have the right to revoke your consent at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation. In the future, we may no longer continue the data processing that was based on your revoked consent.
In accordance with Article 77 of the GDPR, you have the right to lodge a complaint with a supervisory authority if you believe that the processing of your personal data violates the GDPR.
If your personal data is processed on the basis of legitimate interests pursuant to Art. 6 (1) p. 1 lit. f DSGVO, you have the right to object to the processing of your personal data pursuant to Art. 21 DSGVO, provided that there are grounds for doing so that arise from your particular situation or if the objection is directed against direct marketing. In the latter case, you have a general right of objection, which will be implemented by us without specifying the particular situation. If you would like to exercise your right of revocation or objection, an e-mail to firstname.lastname@example.org is sufficient.
j) Automated decision in individual cases including profiling
You have the right not to be subjected to a decision based solely on automated processing - including profiling - which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision
- is necessary for the conclusion or performance of a contract between you and us
- is permissible on the basis of legal provisions of the European Union or the Member States to which we are subject and these legal provisions contain appropriate measures to protect your rights and freedoms as well as your legitimate interests
- is made with your express consent
However, these decisions must not be based on special categories of personal data pursuant to Article 9(1) of the GDPR, unless Article 9(2)(a) or (g) of the GDPR applies and appropriate measures have been taken to protect your rights and freedoms and your legitimate interests.
With regard to the above-mentioned cases, we take appropriate measures to safeguard the rights and freedoms as well as your legitimate interests, including at least the right to obtain the intervention of a person from our side, to express your point of view and to contest the decision.