Alles legal

Privacy Policy

 

This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the associated websites, functions and content as well as external online presences, such as our social media profile (hereinafter referred to collectively as “online offer”). With regard to the terms used, such as “processing” or “person responsible”, we refer you to the definitions in Art. 4 of the Data Protection Basic Regulation (GDPR).

 

Responsible party and service provider
drive by mobility GmbH

Directors:
Timo Nührich, Florian Haus

Location:
Kantstraße 54, 10627 Berlin

Postal address:
Kemperplatz 1, 10785 Berlin

E-Mail:
hello@miles-mobility.com

Link to our company imprint:
https://www.miles-mobility.com/impressum

Contact data protection officer:
hello@miles-mobility.com

 

Types of data processed

– Inventory data (e.g., names, addresses).
– Contact data (e.g., e-mail, telephone numbers).
– Content data (e.g., text input, photographs, videos).
– Usage data (e.g., websites visited, interest in content, access times).
– Meta/communication data (e.g., device information, IP addresses).

Categories of data subjects

Visitors and users of the online offer (hereinafter referred to collectively as “users”).

 

Purpose of processing

– Provision of the online offer, its functions and contents.
– Answering contact requests and communicating with users.
– Security measures.
– Range measurement/Marketing

 

Terms used

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier (e.g., a cookie) or to one or more specific characteristics which express the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, is regarded as identifiable.

“Processing,” means any operation or set of operations, which is carried out with or without the aid of automated processes and which involves personal data. The term is broad and covers practically every handling of data.

“Pseudonymization” means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the provision of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures ensuring that the personal data are not attributed to an identified or identifiable natural person.

“Profiling” means any automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to the work performance, economic situation, health, personal preferences, interests, reliability, conduct, whereabouts or movements of that natural person.

“Person in charge“ means any natural or legal person, public authority, agency or 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 person in charge.

 

Legal basis for the processing of personal data

In accordance with Art. 13 GDPR we inform you about the legal basis of our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR; the legal basis for processing in order to fulfill our services and carry out contractual measures as well as answer inquiries is Art. 6 para. 1 lit. b GDPR; the legal basis for processing in order to fulfill our legal obligations is Art. 6 para. 1 lit. c GDPR; and the legal basis for processing in order to safeguard our legitimate interests is Art. 6 para. 1 lit. f GDPR. In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 para. 1 lit. d GDPR serves as the legal basis.

 

Security measures

In accordance with Art. 32 GDPR, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, the implementation costs and the nature, extent, circumstances and purposes of the processing as well as the different probability of occurrence and severity of the risk to the rights and freedoms of natural persons.

Measures shall include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access, inputting, disclosure, securing and separation of data. In addition, we have established procedures to ensure the protection of data subjects’ rights, deletion of data and reaction to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and data protection-friendly default settings (Art. 25 GDPR).

 

Cooperation with contract processors and third parties

Insofar as we disclose data to other persons and companies (contract processors or third parties) within the scope of our processing, transfer them to them or otherwise grant them access to the data, this shall only take place on the basis of legal permission (e.g., if a transfer of the data to third parties, such as payment service providers, pursuant to Art. 6 para. 1 lit. b GDPR is necessary for the performance of the contract), if you have consented to this, if a legal obligation provides for this or on the basis of our legitimate interests (e.g., when using agents, web hosts, etc.).

If we commission third parties with the processing of data on the basis of a so-called “order-processing contract”, this is done on the basis of Art. 28 GDPR.

 

Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of the use of third-party services or disclosure or transfer of data to third parties, this will only occur if it is done to fulfill our (pre-)contractual obligations, on the basis of your consent, a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or allow the data to be processed in a third country only if the special requirements of Art. 44 et seq. GDPR are met. This means that the processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to the EU (e.g., for the USA by the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).

 

Rights of data subjects

You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with Art. 15 GDPR.

In accordance with Art. 16 GDPR, you have the right to request the completion of data concerning you or the rectification of incorrect data concerning you.

Pursuant to Art. 17 GDPR, you have the right to demand that the data concerned be deleted immediately or, alternatively, to demand that the processing of the data be restricted pursuant to Art. 18 GDPR.

You have the right to receive the data concerning you that you have provided to us in accordance with Art. 20 GDPR and to demand that it be passed on to other persons responsible.

Pursuant to Art. 77 GDPR, you also have the right to file a complaint with the competent supervisory authority.

 

Right of withdrawal

You have the right to revoke consents granted pursuant to Art. 7 para. 3 GDPR with effect for the future.

 

Right of objection

You may object at any time to the future processing of the data concerning you in accordance with Art. 21 GDPR. In particular, you may object to the processing of your data for the purposes of direct marketing.

 

Cookies and right to object to direct advertising

“Cookies” are small files that are stored on the user’s computer. Different data can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after the user’s visit to an online service. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. The content of a shopping basket in an online shop or a login status, for example, can be stored in such a cookie. Cookies are referred to as “permanent” or “persistent” and remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. The interests of the users who are used for range measurement or marketing purposes can also be stored in such a cookie. “Third party cookies” are cookies that are offered by providers other than the person responsible for operating the online service (otherwise, if they are only the latter’s cookies, they are referred to as “first party cookies”).

We may use temporary and permanent cookies and explain this in our privacy policy.

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 your browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general objection to the use of cookies used for online marketing purposes can become the EU website http://www.youronlinechoices.com/erklärt for a large number of services, especially in the case of tracking, via the US American website http://www.aboutads.info/choices/oder . In addition, cookies can be saved by deactivating them in the browser settings. Please note that in this case not all functions of this online offer can be used.

 

Deletion of data

The data processed by us will be deleted or their processing restricted in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and there are no legal obligations to retain them. If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons.

According to legal requirements in Germany, the storage takes place in particular for 10 years according to §§ 147 (1) AO, 257 (1) Nr. 1 and 4, (4) HGB (books, records, management reports, accounting documents, commercial books, for taxation of relevant documents, etc.) and 6 years according to § 257 (1) Nr. 2 und 3, (4) HGB (commercial letters).

According to legal requirements in Austria, the storage is carried out in particular for 7 years in accordance with § 132 (1) BAO (accounting documents, receipts/invoices, accounts, receipts, business papers, list of income and expenses, etc.), for 22 years in connection with real estate and for 10 years for documents in the context with electronically provided services, telecommunications, radio and television services which are provided to non-entrepreneurs in EU member states and for which the Mini One Stop Shop (MOSS) is used.

 

Order processing in the online shop and customer account

We process the data of our customers within the course of order processes in our online shop, in order to enable them to select and order the selected products and services, as well as their payment and delivery, or execution.

The processed data includes inventory data, communication data, contract data, payment data and the persons affected by the processing include our customers, interested parties and other business partners. Processing is carried out for the purpose of providing contractual services within the framework of operating an online shop, billing, delivery and customer services. We use session cookies to store the contents of the shopping basket and permanent cookies to store the login status.

Processing takes place on the basis of Art. 6 para. 1 lit. b (execution of order processes) and c (legally required archiving) GDPR. The information marked as necessary is required for the justification and fulfillment of the contract. We disclose the data to third parties only within the course of delivery, payment or within the framework of the legal permissions and obligations to legal advisors and authorities. The data will only be processed in third countries if this is necessary for the fulfillment of the contract (e.g., at the customer’s request upon delivery or payment).

Users can optionally create a user account by viewing their orders in particular. During the registration process, the necessary mandatory information will be provided 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 its retention for commercial or tax reasons pursuant to Art. 6 para. 1 lit. c GDPR. Data in the customer account shall remain until it is deleted with subsequent archiving in the event of a legal obligation. It is the responsibility of the users to back up their data before the end of the contract in the event of termination.

During registration and renewed registrations as well as use of our online services, 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. These data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation pursuant to Art. 6 para. 1 lit. c GDPR.

The deletion takes place after expiration of legal warranty and comparable obligations, the necessity of the retention of data is reviewed every three years; in the case of legal archiving obligations, the deletion takes place after their expiration (end of commercial (6 years) and tax (10 years) retention obligation).

 

Business-related processing

Additionally we process

– Contract data (e.g., contract object, duration, customer category).

– Payment data (e.g., bank details, payment history)

by our customers, interested parties and business partners for the purpose of providing contractual performances, service and customer care, marketing, advertising and market research.

 

Contractual services

We process the data of our contractual partners and interested parties as well as other clients, customers, principals or contractual partners (uniformly referred to as “contractual partners”) in accordance with Art. 6 para. 1 lit. b. GDPR in order to provide them with our contractual or pre-contractual services. The data processed, the type, scope and purpose and the necessity of their processing are determined by the underlying contractual relationship.

The processed data includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g. e-mail addresses and telephone numbers) as well as contract data (e.g., services used, contract contents, contractual communication, names of contact persons) and payment data (e.g., bank details, payment history).

We do not process any special categories of personal data, unless these are components of a commissioned or contractual processing.

We process data which are necessary for the justification and fulfillment of the contractual services and point out the necessity of their indication, if this is not evident for the contracting parties. Disclosure to external persons or companies will only take place if it is necessary within the framework of a contract. When processing the data provided to us within the framework of an order, we act in accordance with the instructions of the client and the legal requirements.

Within the framework of using our online services, we can store the IP address and the time of the respective user action. The storage takes place on the basis of our justified interests, as well as the interests of the users in the protection against abuse and other unauthorized use. A passing on of these data to third parties does not take place in principle, unless it is necessary for the pursuit of our claims according to Art. 6. 1 lit. f. GDPR is necessary or there is a legal obligation to do so pursuant to Art. 6 para. 1 lit. c. GDPR.

The data will be deleted when the data is no longer required for the fulfillment of contractual or statutory welfare obligations and for the handling of any warranty and comparable obligations, whereby the necessity of data retention is reviewed every three years; otherwise the statutory retention obligations apply.

 

External payment service providers

We use external payment service providers, through whose platforms the users and we can carry out payment transactions (e.g., in each case with link to the data protection declaration,

Paypal (https://www.paypal.com/de/webapps/mpp/ua/privacy-full),

Klarna (https://www.klarna.com/de/datenschutz/),

Skrill (https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/), Giropay (https://www.giropay.de/rechtliches/datenschutz-agb/), Visa (https://www.visa.de/datenschutz),

Mastercard (https://www.mastercard.de/de-de/datenschutz.html), American Express (https://www.americanexpress.com/de/content/privacy-policy-statement.html).

Within the framework of the fulfillment of contracts, we shall appoint payment service providers on the basis of Art. 6 para. 1 lit. b. GDPR. In addition, we use external payment service providers on the basis of our legitimate interests pursuant to 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 or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient details. The information is required to complete the transactions. However, the data entered will only be processed and stored by the payment service providers. This means that we do not receive any account- or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the data may be transmitted by the payment service provider to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the general terms and conditions and data Private Policies of the payment service providers.

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

 

Administration, financial accounting, office organisation, contact management

We process data in the context of administrative tasks as well as the organization of our business, financial accounting and compliance with legal obligations, such as archiving. Here we process the same data that we process within the course of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, for example, tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of the data with regard to contractual services and contractual communication corresponds to the data specified in these processing activities.

We disclose or transmit data to the tax administrations, consultants, such as tax consultants or auditors, as well as other fee offices and payment service providers.

Furthermore, based on our business interests, we store information on suppliers, organizers and other business partners, for example, for the purpose of establishing contact at a later date. This data, which is mainly company-related, is stored permanently.

 

Economic analyses and market research

In order to run our business economically, to be able to recognize market trends, wishes of our contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., in order to identify the most suitable and appropriate solutions for your needs. 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 persons concerned include contractual partners, interested parties, customers, visitors and users of our online services.

The analyses are carried out for the purpose of economic evaluations, marketing and market research. We can consider the profiles of the registered users with information, for example, about their used services. The analyses serve us to increase user friendliness, to optimise our range of services and to improve business efficiency. The analyses serve us alone and are not disclosed externally unless they are anonymous analyses with summarized values.

If these analyses or profiles are person-related, they will be deleted or anonymised upon termination by the user, otherwise after two years from the conclusion of the contract. In all other respects, the macroeconomic analyses and general trend determinations shall be prepared anonymously wherever possible.

 

Data protection information in the application process

We process the applicant data only for the purpose and within the framework of the application procedure in accordance with the legal requirements. The processing of the applicant data is carried out to fulfill our (pre-)contractual obligations in the course of the application procedure in the sense of Art. 6 para. 1 lit. b. GDPR Art. 6 para. 1 lit. f. GDPR insofar as data processing becomes necessary for us, for example, within the framework of legal proceedings (in Germany, § 26 GDPR additionally applies).

The application procedure requires that applicants provide us with the applicant data. If we offer an online form, the necessary applicant data is marked, otherwise it results from the job descriptions and basically includes the personal details, postal and contact addresses and the documents belonging to the application, such as cover letter, curriculum vitae and certificates. In addition, applicants may voluntarily provide us with additional information.

By submitting their application to us, applicants consent to the processing of their data for the purposes of the application procedure in accordance with the type and scope set out in this Privacy Policy.

If special categories of personal data within the meaning of Art. 9 para. 1 GDPR are voluntarily provided within the framework of the application procedure, they will also be processed in accordance with Art. 9 para. 2 lit. b GDPR (e.g., health data, such as severe disability or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are requested from applicants as part of the application procedure, their processing will also be carried out in accordance with Art. 9 para. 2 lit. a GDPR (e.g., health data if they are required for the professional practice).

If available, applicants may submit their applications via an online form on our website. The data will be transmitted to us encrypted according to the state of the art.

Applicants can also send us their applications by e-mail. Please note, however, that e-mails are generally not sent in encrypted form and the applicants themselves must ensure that they are encrypted. We therefore cannot assume any responsibility for the transmission path of the application between the sender and the reception on our server and therefore recommend using an online form or postal dispatch. Instead of applying using the online form and e-mail, applicants still have the option of sending their application by post.

In the event of a successful application, the data provided by the applicants may be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicant’s data will be deleted. Applicant data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time.

Subject to justified revocation by the applicants, the data will be deleted after a period of six months so that we can answer any follow-up questions regarding the application and meet our obligations to provide evidence under the Equal Treatment Act. Invoices for any reimbursement of travel expenses will be archived in accordance with the provisions of tax law.

 

Talent pool

As part of the application process, we offer applicants the opportunity to be included in our “talent pool” for a period of two years on the basis of consent as defined in Art. 6 para. 1 lit. b. and Art. 7 GDPR.

The application documents in the talent pool will be processed solely within the course of future job advertisements and the employee search and will be destroyed at the latest after expiry of the deadline. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the current application procedure and that they can revoke this consent at any time for the future and declare objections within the meaning of Art. 21 GDPR.

 

Registration function

Users can create a user account. During registration, the required mandatory data will be communicated to the users and processed on the basis of Art. 6 para. 1 lit. b GDPR for the purpose of providing the user account. The processed data includes in particular the login information (name, password and an e-mail address). The data entered during registration will be used for the purposes of using the user account and its purpose.

Users may be informed by e-mail of information relevant to their user account, such as technical changes. If users have terminated their user account, their data will be deleted with regard to the user account, subject to a statutory retention obligation. It is the responsibility of the users to secure their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract.

Within the scope of using our registration and login functions as well as the use of 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 passing on of these data to third parties does not take place in principle, unless it is necessary for the pursuit of our claims or there is a legal obligation according to Art. 6 para. 1 lit. c. GDPR. The IP addresses will be anonymized or deleted after 7 days at the latest.

 

CRM System Zendesk

We use the CRM system “Zendesk”, of the provider Zendesk, Inc., 989 Market Street #300, San Francisco, CA 94102, USA, in order to be able to process user inquiries faster and more efficiently (legitimate interest according to Art. 6 para. 1 lit. f. GDPR).

Zendesk is certified under the Privacy Shield Agreement, providing an additional guarantee of compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt0000000TOjeAAG&status=Active).

Zendesk uses user data only for the technical processing of requests and does not pass them on to third parties. In order to use Zendesk, it is necessary to provide at least a correct e-mail address.

A pseudonymous use is possible. In the course of processing service requests, it may be necessary to collect further data (name, address).

If users do not agree with the collection and storage of data by Zendesk’s external system, we will provide them with alternative contact options for submitting service requests by e-mail, telephone, fax or mail. For more information, please see Zendesk’s Privacy Policy: https://www.zendesk.de/company/customers-partners/privacy-policy/.

 

Newsletter

With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures and your rights of objection. By subscribing to our newsletter, you declare your agreement with the receipt and the described procedures.

Content of the newsletter: We send newsletters, e-mails and other electronic notifications containing advertising information (hereinafter “newsletter”) only with the consent of the recipient or a legal permission. If the contents of the newsletter are specifically described during registration, they are decisive for the consent of the user. Furthermore, our newsletters contain information about our services and us.

Double-Opt-In and logging: The registration to our newsletter takes place in a so-called Double-Opt-In procedure. This means that you will receive an e-mail after your registration in which you will be asked to confirm your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address. Also, the changes of your data stored with the shipping providers are logged.

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 addressing you personally.

The dispatch of the newsletter and the performance measurement associated with it are based on the consent of the recipients pursuant to 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 our legitimate interests in direct marketing pursuant to Art. 6 para. 1 lt. f. GDPR in connection with § 7 para. 3 UWG.

The registration procedure is recorded on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR. Our interest is directed towards the use of a user-friendly and secure newsletter system that serves our business interests as well as the expectations of the users and furthermore allows us to provide evidence of consent.

Cancellation/revocation – You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to provide evidence of a previously given consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time.

 

Newsletter – Mailchimp

The newsletters are sent by the mail service “MailChimp”, a newsletter dispatch platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view the privacy policy of the shipping service provider here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC d/b/a MailChimp is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with the European data protection level (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active). The shipping service provider is responsible for the delivery of our products on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. GDPR and an order processing contract in accordance with Art. 28 para. 3 S. 1 GDPR.

The dispatch service provider can use the recipient’s data in pseudonymous form, i.e. without allocation to a user, to optimise or improve its own services, e.g. for technical optimisation of dispatch and the presentation of the newsletter or for statistical purposes. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.

 

Newsletter – measuring success

The newsletters contain a so-called “web-beacon”, i.e. a file the size of a pixel, which is retrieved from our server when the newsletter is opened or, if we use a dispatch service provider, from its server. In the course 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 to technically improve the services on the basis of technical data or target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or access times. The 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. It is, however, neither our endeavor nor, if used, that of the dispatch 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. A separate cancellation of the performance measurement is unfortunately not possible, in which case the entire newsletter subscription must be cancelled.

Hosting and e-mailing

The hosting services used by us serve the provision of the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services which we use for the purpose of operating this online service.

Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors to this online service on the basis of our legitimate interests in the efficient and secure provision of this online service in accordance with Art. 6 para. 1 lit. f GDPR in connection with Art. 28 GDPR (conclusion of an order processing contract).

 

Collection of access data and log files

We, and/or our hosting supplier, raise on basis of our entitled interests in the sense of Art. 6 para. 1 lit. f. GDPR collects data on each access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, 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., for the clarification of abuse or fraud actions) for the duration of maximally 7 days and deleted afterwards. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.

 

Google Tag Manager

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 user data. With regard to the processing of users’ personal data, reference is made to the following information on Google services. Terms of use: https://www.google.com/intl/de/tagmanager/use-policy.html.

 

Google Analytics

On the basis of our legitimate interests (i.e., interest in the analysis, optimisation and economic operation of our online offer in the sense of Art. 6 para. 1 lit. f. GDPR), we act in accordance with the following principles GDPR) Google Analytics, a web analysis service of Google LLC (“Google”). Google uses cookies. The information generated by the cookie about users’ use of the website is generally transmitted to and stored by Google on servers in the United States.

Google 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=a2zt000000001L5AAI&status=Active).

Google will use this information on our behalf to evaluate the use of our online services by users, to compile reports on the activities within this online service and to provide us with other services associated with the use of this online service and the Internet. Pseudonymous user profiles can be created from the processed data.

We use Google Analytics only with activated IP anonymization. This means that the IP address of the user 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 is the full IP address 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 may refuse the use of cookies by selecting the appropriate settings on their browser, they may also refuse the use of cookies by selecting the appropriate settings on their browser, they may refuse the use of cookies by selecting the appropriate settings on their browser, and they may refuse the processing of cookies by selecting the appropriate settings on Google, and they may refuse the processing of cookies by selecting the appropriate settings on Google, and they may refuse the processing of cookies by Google, by downloading and installing the browser plugin available from the following link: http://tools.google.com/dlpage/gaoptout?hl=en. You can also prevent the use of Google Analytics by clicking on this link: deactivate Google Analytics.

Further information on the use of data by Google, setting and objection options can be found in Google’s data protection declaration (https://policies.google.com/technologies/ads) and in the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).

The personal data of the users will be deleted or anonymized after 14 months.

 

Google Universal Analystics

We use Google Analytics in the form of “universal analytics”. “Universal Analytics” refers to a Google Analytics procedure in which user analysis is performed on the basis of a pseudonymous user ID and a pseudonymous profile of the user is thus created with information from the use of various devices (so-called “cross-device tracking”).

 

Google AdWords and Conversion Measurement

On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer in the sense of Art. 6 Para. 1 lit. f. of the German Civil Code), we make use of the information provided on this website. GDPR) the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).

Google 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=a2zt000000001L5AAI&status=Active).

 

We use the Google “AdWords” online marketing process to place ads on the Google advertising network (e.g., in search results, videos, websites, etc.) so that they are displayed to users who have a suspected interest in the ads. This allows us to display ads for and within our online offerings in a more targeted manner in order to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products in which he or she is interested in other online offers, this is referred to as “remarketing”. For these purposes, when our and other websites on which the Google Advertising Network is active are called up, 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, for example, a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). This file records which websites the user visits, what content he is interested in and what offers the user has clicked, as well as technical information on the browser and operating system, referring websites, visit times and other information on the use of the online service.

Furthermore we receive an individual “Conversion-Cookie”. The information collected with the help of the cookie is used by Google to compile conversion statistics for us. However, we only know the anonymous total number of users who clicked on our ad and were directed to a page with a conversion tracking tag. However, we do not receive any personally identifiable information.

User information is processed pseudonymously within the Google Advertising Network. This means, for example, that Google does not store and process the user’s name or e-mail address, but processes the relevant data cookie-related within pseudonymous user profiles. This means that, from Google’s point of view, the ads are not administered 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 permitted Google to process the data without this pseudonymisation. The information collected about users is transmitted to Google and stored on Google’s servers in the United States.

Further information on the use of data by Google, setting and objection options can be found in Google’s data protection declaration (https://policies.google.com/technologies/ads) and in the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).

 

 

 

 

Facebook Pixel, Custom Audiences and Facebook Conversion

Due to our legitimate interests in the analysis, optimisation and economic operation of our online service, the so-called “Facebook pixel” of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are resident in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), is used within our online service.

Facebook 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=a2zt0000000GnywAAC&status=Active).

With the help of the Facebook pixel, Facebook is on the one hand able to determine the visitors of our online offer as a target group for the presentation of ads (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to Facebook users who have shown an interest in our online offering or who have certain 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”). Using Facebook pixels, we also want to ensure that our Facebook ads match the potential interest of users and are not annoying. Using Facebook pixels, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing if users were referred to our website after clicking on a Facebook ad (known as “conversion”).

Facebook processes the data in accordance with Facebook’s data usage policy. Accordingly, general information on the presentation of Facebook ads is provided in Facebook’s data usage policy: https://www.facebook.com/policy. Specific information and details about Facebook pixels and how they work can be found in the Facebook:https://www.facebook.com/business/help/651294705016616.

You may opt out of Facebook pixel collection and use of your information to display Facebook ads. To set what types of ads you see within Facebook, you can go to the page set up by Facebook and follow the instructions on the settings for usage-based ads: 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 may also object to the use of cookies to measure reach and for advertising purposes, via the Network Advertising Initiative’s opt-out page (http://optout.networkadvertising.org/) and additionally via the U.S. website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).

 

Online presences in social media

We maintain online presences within social networks and platforms in order to be able to communicate with customers, interested parties and users active there and to inform them about our services.

We would like to point out that user data may be processed outside the European Union. This can result in risks for users, as it could, for example, make it more difficult to enforce the rights of users. With regard to US providers that are certified under the Privacy Shield, we would like to point out that by doing so they commit themselves to comply with EU data protection standards.

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

The processing of the personal data of the users takes place on the basis of our legitimate interests in effective information of the users and communication with the users in accordance with Art. 6 para. 1 letter f. GDPR. If the users are asked by the respective providers for their consent to data processing (i.e. declare their consent e.g. by ticking a checkbox or confirming a button), the legal basis for processing is Art. 6 para. 1 lit. a., Art. 7 GDPR.

For a detailed description of the respective processing operations and the opt-out options, please refer to the following linked information provided by the providers.

Also in the case of requests for information 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 the users and can directly take appropriate measures and give information. Should you nevertheless need help, you can contact us.

– Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) – Privacy Policy: https://www.facebook.com/about/privacy/, Opt-Out: https://www.facebook.com/settings?tab=adsund http://www.youronlinechoices.com, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.

– Google (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – Privacy Statement: 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 Statement / Opt-Out: http://instagram.com/about/legal/privacy/.

– Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) – Privacy Statement: 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 Statement / Opt-Out: https://about.pinterest.com/de/privacy-policy.

– LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland) – Privacy Statement 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 Statement / Opt-Out: https://privacy.xing.com/de/datenschutzerklaerung.

 

Integration of third-party services and content

Within the scope of our online offer, we act 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. of the German Civil Code). GDPR) content or service offers from third parties in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).

This always presupposes that the third-party providers of this content perceive the IP address of the user, since they would not be able to 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 those contents whose respective providers only use the IP address to deliver the contents. Third party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. “Pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring web pages, visit times and other information about the use of our online services, as well as may be linked to such information from other sources.

 

Youtube

We integrate the videos of the platform “YouTube” of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

 

Google Maps

We integrate the maps of the service “Google Maps” of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Processed data may include, but is not limited to, IP addresses and location data of users without their consent (usually performed as part of the settings of their mobile devices). The data can be processed in the USA.

Privacy Policy: https://www.google.com/policies/privacy/,

Opt-Out: https://adssettings.google.com/authenticated.

 

Twitter

Functions and contents of the Twitter service offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, can be integrated into our online offer. This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online service within Twitter.

If the users are members of the Twitter platform, Twitter can assign the call of the above-mentioned contents and functions to the profiles of the users there. 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). Privacy policy:https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization.

 

Instagram

Within our online offer, functions and contents of the service Instagram, offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA, can be integrated. This may include, for example, content such as images, videos or text and buttons with which users can share content from this online offering within Instagram. If the users are members of the Instagram platform, Instagram can assign the call of the above contents and functions to the user profiles there. Instagram Privacy Policy: http://instagram.com/about/legal/privacy/

 

 

 

 

This Privacy Policy shall be issued in German and English. In the event of any discrepancies, the German version shall take precedence.