Data protection declaration
Responsible person: Arturs Popovics
WW Trade GmbH
Types of data processed:
– Inventory data (e. g. names, addresses).
– Contact details (e. g. E-mail, telephone numbers).
– Content data (e. g. text entries, photographs, videos).
– Contract data (e. g. subject matter of the contract, duration, customer category).
– payment data (e. g. bank details, payment history).
– Usage data (e. g. websites visited, interest in content, access times).
– meta/communication data (e. g. device information, IP addresses).
Processing of special categories of data (Art. 9 para. 1 GDPR):
No special categories of data are processed.
Categories of data subjects:
– Customers, interested parties, business partners.
– Visitors and users of the online offer.
In the following, we also refer to the persons concerned as “users”.
Purpose of the processing
– Provision of the online offer, its contents and shop functions.
– Provision of contractual services, general service and customer care.
– Responding to contact requests and communicating with users.
– Marketing, advertising and market research.
– Security measures.
Situation at: 17.04.2020
1. Terms used
1.1. „Personal data“ means any information relating to an identified or identifiable natural person (in the following referred to as the “data subject”); a natural person who, directly or indirectly, is considered identifiable, in particular by reference to an identifier such as a name, identification number, location data, an online identifier (e. g. cookie) or to one or more specific characteristics that express the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
1.2. „Processing” means any operation carried out with or without the aid of automated procedures or any series of such operations relating to personal data. The term goes far and covers practically every handling of data.
1.3. Als „Verantwortlicher“ wird die natürliche oder juristische Person, Behörde, Einrichtung oder andere Stelle, die allein oder gemeinsam mit anderen über die Zwecke und Mittel der Verarbeitung von personenbezogenen Daten entscheidet, bezeichnet.
Nach Maßgabe des Art. 13 DSGVO teilen wir Ihnen die Rechtsgrundlagen unserer Datenverarbeitungen mit. Sofern die Rechtsgrundlage in der Datenschutzerklärung nicht genannt wird, gilt Folgendes: Die Rechtsgrundlage für die Einholung von Einwilligungen ist Art. 6 Abs. 1 lit. a und Art. 7 DSGVO, die Rechtsgrundlage für die Verarbeitung zur Erfüllung unserer Leistungen und Durchführung vertraglicher Maßnahmen sowie Beantwortung von Anfragen ist Art. 6 Abs. 1 lit. b DSGVO, die Rechtsgrundlage für die Verarbeitung zur Erfüllung unserer rechtlichen Verpflichtungen ist Art. 6 Abs. 1 lit. c DSGVO, und die Rechtsgrundlage für die Verarbeitung zur Wahrung unserer berechtigten Interessen ist Art. 6 Abs. 1 lit. f DSGVO. Für den Fall, dass lebenswichtige Interessen der betroffenen Person oder einer anderen natürlichen Person eine Verarbeitung personenbezogener Daten erforderlich machen, dient Art. 6 Abs. 1 lit. d DSGVO als Rechtsgrundlage.
3. Changes and updated of the data protection declaration
We ask you to inform yourself regularly about the content of our data protection decleration. We adapt the data protection declaration as soon as changes to our data processing make this necessary. We will inform you as soon as an act of participation on your part (e. g. Consent) or any other individual notification is required.
4. Security measures
4.1. We shall meet in accordance with Art. 32 GDPR, taking into account the state of the technology, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different likelihood and severity of the risk to the rights and freedoms of natural persons, appropriate technical and organisational measures to ensure a level of protection appropriate to the risk. Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, transfer, security of availability and separation. In addition, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data and the reaction to the risk of data being compromised. In addition, we take into account the protection of personal data already during the development or selection of hardware, software and procedures, in accordance with the principle of data protection by means of technical design and data protection-friendly presettings (Art. 25 GDPR).
4.2. The security measures include in particular the encrypted transmission of data between your browser and our server.
5. Disclosure and transmission of data
5.1. If we, as part of our processing, disclose data to other persons and companies (processors or third parties), transmit data to them or otherwise grant them access to the data, this is only done on the basis of a legal permission (e. g. if a transmission of the data to third parties, such as payment service providers, acc. Art. 6 para. 1 lit. b GDPR is necessary for the fulfilment of the contract), if you have consented, if a legal obligation provides for this or on the basis of our legitimate interests (e. g. when using agents, hosting providers, tax, economic and legal advisors, customer care, accounting, billing and similar services that allow us to efficiently and effectively fulfil our contractual obligations, administrative tasks and obligations).
5.2. As we process third parties with the data on the basis of a so-called “Contract processing contract”, this is done on the basis of Art. 28 GDPR.
6. Transfers to third countries
If we collect data in a third country (i. e. outside the European Union (EU) or the European Economic Area (EEA)) or do so in the context of the use of third-party services or disclosure and transmission of data to third parties, this takes place only if it is done for the fulfilment of our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or leave the data in a third country only if the special conditions of Art. 44 et seq. GDPR. are available i. e. the processing takes place e. g. on the basis of specific safeguards, such as the official recognition of a level of data protection equivalent to that of the EU (e. g. for the USA through the “Privacy Shield”) or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).
7. Rights of data subjects
7.1. You have the right to request confirmation as if data is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR.
7.2. You have accordingly Art. 16 GDPR the right to request the completion of the data concerning you or the correction of inaccurate data concerning you.
7.3. You have in accordance with Art. 17 GDPR the right to demand that the data in question be deleted immediately, or as an alternative, in accordance with Art. 18 GDPR to demand a restriction of the processing of the data.
7.4. You have the right to demand that the data concerning you, which you have provided to us, be processed in accordance with Art. 20 GDPR and to request their transmission to other responsible persons.
7.5. You have furthermore acc. Art. 77 GDPR the right to submit a complaint at the competent supervisory authority.
8. Powers of revocation
You have the right to revoke your given consents according to Art. 7 para. 3 GDPR with effect for the future.
9. Right of objection
You may contradict the future processing of your data in accordance with Art. 21 GDPR at any time. The objection may in particular be made against the processing for direct marketing purposes.
10. Cookies und right of objection in the case of direct advertisement
10.1. “Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store the information of a user (or the device on which the cookie is stored) during or after its visit within an online offer. As temporary cookies, “Session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, e. g. the contents of a shopping cart in an online shop or a login status are stored. “Permanent” or “persistent” cookies remain stored even after the browser is closed. For example, it is possible that the login status is stored when users visit it after several days. Likewise, the interests of the users, which are used for reach measurement or marketing purposes, can be stored in such a cookie. “Third-party cookies” are cookies from providers other than the responsibles for operating the online offer (otherwise, if they are only their cookies, they are referred to as “First-party cookies”).
10.2. We use temporary and permanent cookies and clarify this in the context of our data protection declaration. If users do not want cookies to be stored on their computer, they are asked to deactivate 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 limitations of this online offer.
11. Deletion of data
11.1. The data processed by us will be, in accordance with Art. 17 and 18 GDPR, deleted or restricted in their processing. Unless expressly stated in the context of this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their purpose and the deletion does not conflict with any statutory storage obligations. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted. I. e. the data is blocked and not processed for other purposes. This is the case e. g. for data that must be retained for commercial or tax reasons.
11.2. Germany: According to legal requirements, the storage takes place in particular for 6 years in accordance with § 257 para. 1 HGB (trading books, inventories, opening balance sheets, annual accounts, commercial letters, accounting documents, etc.) as well as for 10 years according to § 147 para. 1 AO (books, records, management reports, accounting documents, trade and business letters, documents relevant for taxation, etc.
12. Order processing in the online shop and customer account
12.1. We process the data of our customers in the context of the ordering processes in our online shop, in order to provide them the selection and order of the selected products and services, as well as their payment and delivery, respectively to allow execution.
12.2. The processed data includes inventory data, communication data, contract data, payment data and the data subjects of our customers, interested parties and other business partners. The processing takes place for the purpose of providing contractual services within the scope of operating an online shop, billing, delivery and customer services. Here we use session cookies for the storage of the shopping cart content and permanent cookies for the storage of the login status.
12.3. The processing is carried out on the basis of Art. 6 para. 1 lit. b (implementation of ordering processes) and c (legally required archiving) GDPR. The information marked as necessary are required for the establishment and fulfilment of the contract. We disclose the data to third parties only within the scope of delivery, payment or within the scope of legal permissions and obligations towards legal advisors and authorities. The data will only be processed in third countries if this is necessary for the fulfilment of the contract (e. g. at the customer’s request for delivery or payment).
12.4. Users can optionally create a user account in particular to view their orders. As part of the registration, the required mandatory information will be communicated to the users. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data with regard to the user account will be deleted, subject to their retention for commercial or tax reasons according Art. 6 para. 1 lit. c GDPR. Information in the customer account remains until its deletion with subsequent archiving in the case of a legal obligation. It is the responsibility of the users to secure their data before the end of the contract.
12.5. As part of the registration and re-registration as well as the use of our online services, we store the IP address and the time of the respective user action. The storage takes place on the basis of 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 take place, unless it is necessary to pursue our claims or there is a legal obligation to do so according to Art. 6 para. 1 lit. c GDPR.
12.6. The deletion takes place after expiry of legal warranty and comparable obligations, the necessity of the storage of the data is checked every three years; in the case of legal archiving obligations, the deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) retention obligation); Information in the customer account remains until its deletion.
13. Business analysis and market research
13.1. In order to be able to operate our business economically, identify market trends, customer and user wishes, we analyse the data available of business transactions, contracts, enquiries, etc. We process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. GDPR, whereby the data subjects include customers, interested parties, business partners, visitors and users of the online offer. The analyses are carried out for the purpose of economic evaluations, marketing and market research. In doing so, we can provide the profiles of registered users with information, e. g. for their purchase transactions. The analyses are made to increase the user-friendliness, for the optimization of our offer and the economic efficiency. The analyses are solely for us and will not be disclosed externally, unless they are anonymous analyses with summarized values.
13.2. If these analyses or profiles are personal, they will be deleted or anonymized upon termination of the users, otherwise after two years from the conclusion of the contract. Furthermore, as far as possible, the economic analyses and general trend determinations are compiled anonymously.
Checking the creditworthiness of a customer is permissible if the risk of payment default is otherwise imminent, i. e. when the goods are delivered without payment have been received (i. e. if the customer chooses the purchase on account). There is no risk of default if the customer e. g. chooses pre-payment or payment via third-party providers such as e.g. Paypal.
It should also be noted that the collection of an automatic credit information is an “Automated Decisions in Individual Cases” according to Art. Art. 22 GDPR, i. e. a legal decision without human participation. This is permissible if the customer has consented or if this decision is necessary for the conclusion of the contract. It is not conclusively clarified yet if a conclusion is necessary, but is often represented as given, also by the author of this declaration. However, if you wish to exclude any risk, you should obtain consent.
Consent is also necessary if the credit information is already used to decide at all whether the option “on account” should be displayed, because it could have been that the customer would have decided in any case for the advance payment or Paypal and the credit check would not have been necessary.
Such consent could, e.g. be read as follows:
I agree that a credit check will be carried out in an automated procedure (Art. 22 GDPR) to decide whether the option of purchase on account is offered. Further information on the credit check, the credit bureaus used and the procedure as well as the options for objection can be found in our data protection declaration.
14. Credit rating information
14.1. If the option of advance payment is chosen, we reserve the right to obtain identity and credit information for the purpose of assessing credit risk on the basis of mathematical-statistical procedures from specialist service providers (credit agencies) in order to safeguard legitimate interests.
14.2. As part of the credit information, we transmit the following personal data of the customer (name, address, date of birth, information on the type of contract, bank details) to the following credit agencies:
SCHUFA-Gesellschaft (SCHUFA Holding AG, Kormoranweg 5, DE-65201 Wiesbaden), data protection information: https://www.schufa.de/de/ueber-uns/daten-scoring/.
14.3. We process the information received from credit agencies about the statistical probability of a payment default in the context of an appropriate discretionary decision on the establishment, implementation and termination of the contractual relationship. In the event of a negative result of the credit check, we reserve the right to refuse payment on account or any other advance payment.
14.4. The decision of whether we make advance payment is made in accordance with Art. 22 GDPR solely on the basis of an automated decision in individual cases, which our software makes on the basis of the information provided by the credit agency.
14.5 If we obtain explicit consent from you, the legal basis for the credit information and the transmission of the customer’s data to the credit bureaus is a consent acc. Art. 6 para. 1 lit. a, 7 GDPR. If no consent is obtained, our legitimate interests in the default security of your payment claim are the legal basis according to Art. 6 para. 1 lit. f. GDPR.
15. Contact and customer service
15.1. When contacting us (via contact form or e-mail), the information of the user is used to process the contact request in accordance with Art. 6 para. 1 lit. b) GDPR.
15.2. The information of the users can be stored in our Customer Relationship Management System (“CRM System”) or comparable request organization.
15.3. We will delete the requests if they are no longer required. We check the necessity every two years; inquiries from customers who have a customer account are stored permanently and refer to the details of the customer account for deletion. Furthermore, the statutory archiving obligations apply.
16. Collection of access data and log files
16.1. We raise on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the retrieved website, file, date and time of the retrieval, amount of data transferred, notification of successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
16.2. Logfile information is stored for security reasons (e. g. for the investigation of abuses or fraud) for a maximum period of seven days and will be deleted afterwards. Data whose further retention is required for evidence purposes are excluded from deletion until the final clarification of the respective incident.
17. Online presence on social media
17.1. We maintain on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR online presence within social networks and platforms in order to communicate with the customers, interested parties and active users and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and the data processing guidelines of the respective operators apply.
If the “remarketing” or “Google Analytics Audiences” functions are used, the following passage to these functions must be added as a second point:
17.3. We use Google Analytics to display the ads placed within Google’s advertising services and its partners only to those users who have shown an interest in our online offer or who have specific characteristics (e. g. Interests in certain topics or products that are determined on the basis of 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 the users and do not have an annoying effect.
18. Google Analytics
18.2. Google is certified under the Privacy Shield Agreement which offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
18.3. Google will use this information on our behalf to evaluate the use of our online offer by the users, to compile reports on the activities within this online offer and to provide us with further services related to the use of this online offer and the internet use. Pseudonymous user profiles can be created from the processed data.
18.4. We only use Google Analytics with activated IP anonymization. This means that the IP address of the users is abbreviated by Google within member states of the European Union or in other signatory states of the European Economic Area. Only in exceptional cases the full IP address will be transmitted to a Google server in the USA and shortened there.
18.5. The IP address transmitted by the user’s browser will not be merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; in addition, users can prevent the collection of the data generated by the cookie and related to their use of the online offer to Google and the processing of this data by Google by downloading and installing the browser plugin available here: https://tools.google.com/dlpage/gaoptout?hl=de.
18.6. For more information about Google’s use of data, settings and objection options, please visit Google’s websites: https://www.google.com/intl/de/policies/privacy/partners (“Google’s use of data when you use our partners’ websites or apps”), https://policies.google.com/technologies/ads (“Data use for advertising purposes”), https://adssettings.google.com/authenticated (“Manage information that Google uses to show you advertisements”).
19.1. We use on the basis of our legitimate interests (i. e. Interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) the marketing and remarketing services (“Google Marketing Services”) of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, („Google“).
19.2. Google is certified under the Privacy Shield Agreement which offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
19.3. The Google Marketing Services allow us to display advertisements for and on our website in a more targeted manner in order to only present advertisements to users that potentially correspond to their interests. For example ads for products he has been interested in on other websites are referred to as “remarketing”. For these purposes, when our website and other websites on which Google marketing services are active are accessed, a Google code is executed directly 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 is created on the user’s device, i. e. a small file is saved (comparable technologies can also be used instead of cookies). The cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file notes which websites the user visits, which content he is interested in and which offers he has clicked on, as well as technical information on the browser and operating system, referring websites, visit time and other information on the use of the online offer. The IP address of the users is also recorded, whereby we inform you within the framework of Google Analytics that the IP address is shortened within member states of the European Unionand in other signatory states of the European Economic Area and only in exceptional cases completely transmitted to a Google server in the USA and shortened there. The IP address is not merged with the user’s data of other Google offers. The above-mentioned information may also be linked by Google to such information from other sources. If the user subsequently visits other websites, the ads tailored to him can be displayed to him according to his interests.
19.4. The data of the users are processed pseudonymously within the scope of Google marketing services. I. e. Google stores and processes e. g. not the name or e-mail address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. I. e. from Google’s point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie owner, regardless of who this cookie owner is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymization. The information collected by Google marketing services about the users is transmitted to Google and stored on Google’s servers in the USA.
19.5. Among other things, the Google marketing services we use include: the online advertising program “Google AdWords”. In the case of Google AdWords, each AdWords customer receives a different “conversion cookie”. Cookies can therefore not be tracked via the websites of AdWords customers. The information collected with the help of the cookie is used to create conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers learn the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not receive any information with which users can be personally identified.
19.8. We can also use the service “Google Optimizer”. Google Optimizer allows us to understand the effects of various changes to a website (e. g. Changes in the input fields, the design, etc.). For these test purposes, cookies are stored on the user’s devices. Only pseudonymous data of the users are processed.
19.9. We may also use the “Google Tag Manager” to integrate and manage Google’s analytics and marketing services into our website.
19.11. If you wish to object to interest-based advertising through Google Marketing Services, you can change the settings and opt-out options provided by Google.
Furthermore, when using the Facebook pixel, we use the additional function “extended comparison” in which data such as telephone numbers, e-mail addresses or Facebook IDs of the users are transmitted to Facebook (encrypted) for the formation of target groups (“Custom Audiences” or “Look Alike Audiences”). Further information on “extended comparison”: https://www.facebook.com/business/help/611774685654668).
We also use the “Custom Audiences from File” procedure of the social network Facebook Inc. In this case, the email addresses of the newsletter recipients are uploaded to Facebook. The upload process is encrypted. The upload is used solely to determine the recipients of our Facebook ads. We want to ensure that the ads are only displayed to users who have an interest in our information and services.
In the case of your opt-out, please add the following:
To prevent the collection of your data by Facebook pixel on our website, please click on the following link: Facebook opt-out Note: If you click on the link, an “opt-out” cookie is stored on your device. If you delete the cookies in this browser, you will need to click the link again. Furthermore, the opt-out only applies within the browser you are using and only within our web domain on which the link was clicked.
20. Facebook-, Custom Audiences and Facebook-Marketing-Services
20.1. Due to our legitimate interests in the analysis, optimisation and economic operation of our online offer, “Facebook-Pixel” of the social network Facebook is used, which is operated by Facebook Inc. , 1 Hacker Way, Menlo Park, CA 94025, USA, respectively if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”).
20.2. Facebook is certified under the Privacy Shield Agreement which offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
20.3. Mit Hilfe des Facebook-Pixels ist es Facebook zum einen möglich, die Besucher unseres Onlineangebotes als Zielgruppe für die Darstellung von Anzeigen (sog. “Facebook-Ads”) zu bestimmen. Dementsprechend setzen wir das Facebook-Pixel ein, um die durch uns geschalteten Facebook-Ads nur solchen Facebook-Nutzern anzuzeigen, die auch ein Interesse an unserem Onlineangebot gezeigt haben oder die bestimmte Merkmale (z.B. Interessen an bestimmten Themen oder Produkten, die anhand der besuchten Webseiten bestimmt werden) aufweisen, die wir an Facebook übermitteln (sog. „Custom Audiences“). Mit Hilfe des Facebook-Pixels möchten wir auch sicherstellen, dass unsere Facebook-Ads dem potentiellen Interesse der Nutzer entsprechen und nicht belästigend wirken. Mit Hilfe des Facebook-Pixels können wir ferner die Wirksamkeit der Facebook-Werbeanzeigen für statistische und Marktforschungszwecke nachvollziehen, in dem wir sehen ob Nutzer nachdem Klick auf eine Facebook-Werbeanzeige auf unsere Website weitergeleitet wurden (sog. „Conversion“).
With the help of Facebook pixel, Facebook is on the one hand able to target visitors to our online offer as a target group for the display of ads (so-called “Facebook-Ads”). Accordingly, we use Facebook pixel to display the Facebook ads placed by us only to Facebook users who have also shown an interest in our online offer or who have specific characteristics (e. g. Interests in certain topics or products that are determined on the basis of the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of the users and do not have an annoying effect. With the help of Facebook pixel, we can also understand the effectiveness of Facebook ads for statistical and market research purposes, in which we see whether users were redirected to our website after clicking on a Facebook ad (“Conversion” ).
20.4. The processing of the data by Facebook is carried out within the framework of Facebook’s data use policy. Accordingly, general information on the depiction of Facebook ads, in the data use policy of Facebook: https://www.facebook.com/policy.php. For specific information and details on Facebook pixel and how it works, please visit the Facebook help area: https://www.facebook.com/business/help/651294705016616.
20.5. You can object to the data collection by Facebook pixel and to the use of your data for displaying Facebook ads. To set the types of ads you see within Facebook, you can go to the page set up by Facebook and follow the instructions on the settings of usage-based advertising: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i. e. they are adopted for all devices, such as desktop computers or mobile devices.
21. Facebook Social Plugins
21.1. We use Social plugins (“plugins”) on the basis of our legitimate interests (i. e. Interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) of the social network facebook.com, which is operated by Facebook Ireland Ltd. , 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The plugins can be used for interaction elements or content (e. g. videos, graphics or text contributions) and are recognizable by one of the Facebook logos (white “f” on a blue tile, the term “Like” or the sign “Thumbs up”) or are marked with the addition “Facebook Social Plugin”. The list and the appearance of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
21.2. Facebook is certified under the Privacy Shield Agreement which offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
21.3. If a user calls up a function of this online offer that contains such a plugin, his device establishes a direct connection with the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated into the online offer. From the processed data user profiles of the users can be created. We therefore have no influence on the extent of the data that Facebook collects with the help of this plugin and therefore inform the users according to our level of knowledge.
21.4. By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to his Facebook account. If users interact with the plugins, for example by clicking the Like button or posting a comment, the corresponding information is transmitted from your device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook finds out and stores his IP address. According to Facebook, only an anonymised IP address is stored in Germany.
21.6. If a user is a Facebook member and does not want Facebook to collect data about him or her and link it to his or her member data stored on Facebook via this online offer, he or she must log out of Facebook and delete his or her cookies before using our online offer. Further settings and contradictions regarding the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US page http://www.aboutads.info/choices/ or the EU page http://www.youronlinechoices.com/. The settings are platform-independent, i. e. they are adopted for all devices, such as desktop computers or mobile devices.
22 Communication by mail, e-mail, fax oder telephone
22.1 We use means of distance communication, such as: Mail, telephone or e-mail, for business and marketing purposes. We process inventory data, address and contact data as well as contract data of customers, participants, interested parties and communication partners.
22.2 The processing is carried out on the basis of Art. 6 para. 1 lit. a, Art. 7 GDPR, Art. 6 para. 1 lit. f GDPR in conjunction with legal requirements for advertising communications. The contact is made only with the consent of the contact partners or within the scope of the legal permissions and the processed data will be deleted as soon as they are not necessary and otherwise with objection, revocation or elimination of the authorization bases or legal archiving obligations.
23.1. With the following information, we inform you about the contents of our newsletter as well as the registration, dispatch, statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to the receipt and the procedures described.
23.2. Content of the newsletter: We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. Insofar as the content of the newsletter is specifically described in the context of a registration, it is decisive for the consent of the users. In addition, our newsletters contain information about our products, offers, promotions and our company.
23.3. Double opt-in and logging: The registration for our newsletter takes place in double-opt-in-procedure. I. e. After registering, you will receive an e-mail in which you will be asked to confirm your registration. This confirmation is necessary so that no one can register with third-party e-mail addresses. The subscriptions to the newsletter are logged to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the login and confirmation time, as well as the IP address. Changes to your data stored by the shipping service provider will also be logged.
23.5. Insofar as we use a shipping service provider, the shipping service provider can use this data in pseudonymous form, i. e. without assignment to a user to optimize or improve their own services, e. g. to technically optimise the sending and presentation of newsletters or for statistical purposes to determine which countries the recipients come from. However, the shipping service provider does not use the data of our newsletter recipients to write to them themselves or to pass them on to third parties.
23.6. Registration data: To subscribe to the newsletter, it is sufficient to enter your e-mail address. Optionally, we ask you to enter a name in the newsletter for the purpose of personal contact.
23.7. Measurement of success – The newsletters contain a so-called “web-beacon”, i. e. a pixel-sized file, which is stored when the newsletter is opened from our server or if we use a shipping service provider from whose server it is retrieved. As part 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 initially 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. Statistical surveys also include determining whether the 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 contents to them or to send different contents according to the interests of our users.
23.8. Germany: The dispatch of the newsletter and the measurement of success are based on the consent of the recipients acc. Art. 6 para. 1 lit. a, Art. 7 GDPR in connection with § 7 para. 2 No. 3 UWG respectively on the basis of the legal permission according to § 7 para. 3 UWG.
23.9. Austria: The dispatch of the newsletter and the measurement of success are based on the consent of the recipients acc. Art. 6 para. 1 lit. a, Art. 7 GDPR in connection with § 107 para. 2 TKG respectively on the basis of the legal permission according to § 107 para. 2 and 3 TKG.
23.10. The logging of the registration procedure takes place on the basis of our legitimate interests acc. Art. 6 para. 1 lit. f GDPR and serves as proof of consent to the receipt of the newsletter.
23.11. Newsletter recipients can cancel the receipt of our newsletter at any time, i. e. Revoke their consent. They will find a link to cancel the newsletter at the end of each newsletter. At the same time, their consent to the measurement of success expires. A separate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled. With the unsubscription of newsletters, the personal data will be deleted, unless their storage is legally required or justified, in which case their processing is limited to these exceptional purposes only. In particular, we may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests in order to be able to prove previously given consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for cancellation is possible at any time, provided that the former existence of a consent is confirmed at the same time.
24. Integration of third-party services and content
24.1. We use in our online offer on the basis of our legitimate interests (i. e. Interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) content or services offered by third-party providers e. g. videos or fonts (hereinafter referred to as “content”). This always presupposes that the third-party providers of the content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We make every effort to use only content whose respective providers use the IP address only to deliver the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may, among other things, contain technical information about the browser and operating system, referring websites, visit time and other information about the use of our online offer, as well as be linked to such information from other sources.
24.2. The following presentation provides an overview of third-party providers and their contents, as well as links to their privacy statements, which provide further information on the processing of data and, in some parts already mentioned here, possibilities of contradiction (so-called Opt-out).
– If our customers use the payment services of third parties (e. g. Paypal or Sofortüberweisung), the terms and conditions and the data protection notices of the respective third-party providers, which are available within the respective websites or Transaction applications, apply.
– External fonts from Google, LLC., https://www.google.com/fonts („Google Fonts“). The integration of Google fonts takes place through a server call at Google (usually in the USA). Data protection declaration: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated.
– Maps of the service “Google Maps”, provided by the third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Data protection declaration:https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
– Videos of the platform “YouTube” of the third-party provider Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Data protection declaration: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
– Within our online offer, functions of the service Google+ are integrated. These functions are offered by the third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. If you are logged in to your Google+ account, you can link the content of our pages to your Google+ profile by clicking the Google+ button. This allows Google to associate your visit to our pages with your user account. We would like to point out that, as the provider of the pages, we have no knowledge of the content of the transmitted data or its use by Google+. Data protection declaration:https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated.
– Functions of the service Instagram are integrated into our online offer. These functions are offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA. If you are logged in to your Instagram account, you can link the content of our pages to your Instagram profile by clicking the Instagram button. This allows Instagram to associate your visit to our pages with your user account. We would like to point out that, as the provider of the pages, we have no knowledge of the content of the transmitted data or its use by Instagram. Data protection declaration: http://instagram.com/about/legal/privacy/.
– We use social plugins of the social network Pinterest, which is operated by Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA (“Pinterest”). When you visit a page that contains such a plugin, your browser establishes a direct connection to the servers of Pinterest. The plugin transmits protocol data to the Pinterest server in the USA. This log data may contain your IP address, the address of the websites visited, which also contain Pinterest functions, the type and settings of the browser, the date and time of the request, your use of Pinterest and cookies. Data protection declaration: https://about.pinterest.com/de/privacy-policy.
– Our online offer includes functions of the service or the platform Twitter (hereinafter referred to as “Twitter”;). Twitter is a service of Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The functions include the presentation of our posts within Twitter within our online offer, the link to our profile on Twitter as well as the possibility to interact with the posts and the functions of Twitter and to measure whether users access our online offer via the advertisements we place on Twitter (so-called Conversion measurement). Twitter is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active). Data protection declaration: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization.