Privacy Policy - FollowerPilot

This privacy policy explains the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) in the context of the provision of our services and within our online offer and the associated websites, functions and content as well as external online presences, such as our social media profile (hereinafter collectively referred to as “online offer”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Person responsible

FollowerX GmbH
At the Mühren 1
20457 Hamburg
Germany

Phone: +49 160 4522230
E-mail: business(at)followerpilot.de

Link to the imprint: https://www.followerpilot.de/impressum/

Please note that we do NOT offer customer service or support at these addresses, telephone numbers or this e-mail address!

Note: To avoid spam e-mails, we have replaced the “@” in our e-mail address with “(at)”. Please use the “@” again if you would like to contact us.

Types of data processed

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

Categories of affected persons

Visitors and users of the online offer (hereinafter we also refer to the data subjects collectively as “users”).

Purpose of the processing

– Provision of the online offer, its functions and content.
– Answering contact requests and communicating with users.
– Safety measures.
– Reach measurement/marketing

Terminology used

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

“Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically any handling of data.

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

“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

The “controller” is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Relevant legal bases

In accordance with Art. 13 GDPR, we inform you of the legal basis of our data processing. For users from the area of application of the General Data Protection Regulation (GDPR), i.e. the EU and the EEC, the following applies if the legal basis is not mentioned in the data protection declaration:
The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR;
The legal basis for processing to fulfill our services and carry out contractual measures as well as answering inquiries is Art. 6 para. 1 lit. b GDPR;
The legal basis for processing for the fulfillment of our legal obligations is Art. 6 para. 1 lit. c GDPR;
In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.
The legal basis for the processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Art. 6 para. 1 lit. e GDPR.
The legal basis for processing to safeguard our legitimate interests is Art. 6 para. 1 lit. f GDPR.
The processing of data for purposes other than those for which they were collected is governed by the provisions of Art. 6 para. 4 GDPR.
The processing of special categories of data (in accordance with Art. 9 para. 1 GDPR) is governed by the provisions of Art. 9 para. 2 GDPR.

Security measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, 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, to ensure a level of protection appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures that guarantee the exercise of data subject rights, the deletion of data and the response to data threats. Furthermore, we take the protection of personal data into account as early as the development and selection of hardware, software and processes, in accordance with the principle of data protection through technology design and data protection-friendly default settings.

Cooperation with processors, joint controllers and third parties

If we disclose data to other persons and companies (processors, joint controllers or third parties) as part of our processing, transfer it to them or otherwise grant them access to the data, this is only done on the basis of legal permission (e.g. if the transfer of data to third parties, such as payment service providers, is necessary to fulfill the contract), users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we disclose, transfer or otherwise grant access to data to other companies in our group of companies, this is done in particular for administrative purposes as a legitimate interest and, in addition, on a basis corresponding to the legal requirements.

Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to other persons or companies, this will only take place if it is done to fulfill 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 only process or leave the data in a third country if the legal requirements are met. This means, for example, that the processing takes place on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations.

Rights of the data subjects

You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with the legal requirements.

In accordance with the legal requirements, you have the right to request the completion of data concerning you or the correction of incorrect data concerning you.

In accordance with the legal requirements, you have the right to demand that the data in question be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the legal requirements.

You have the right to request to receive the data concerning you that you have provided to us in accordance with the legal requirements and to request its transfer to other responsible parties.

You also have the right to lodge a complaint with the competent supervisory authority in accordance with the statutory provisions.

Right of withdrawal

You have the right to withdraw your consent with effect for the future.

Right of objection

You can object to the future processing of data concerning you at any time in accordance with the legal requirements. In particular, you may object to processing for direct marketing purposes.

Cookies and right to object to direct advertising

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 information about a user (or the device on which the cookie is stored) during or after their visit to an online service. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes their browser. The content of a shopping cart in an online store or a login status, for example, can be stored in such a cookie. Cookies that remain stored even after the browser is closed are referred to as “permanent” or “persistent”. For example, the login status can be saved if the user visits the website after several days. The interests of users can also be stored in such a cookie and used for reach measurement or marketing purposes. “Third-party cookies” are cookies that are offered by providers other than the controller who operates the online service (otherwise, if they are only the controller’s cookies, they are referred to as “first-party cookies”).

We may use temporary and permanent cookies and provide information about 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 the 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 be declared for a large number of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that you may then not be able to use all the functions of this website.

Deletion of data

The data processed by us will be deleted or its processing restricted in accordance with the legal requirements. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations.

If the data is not deleted because it is required for other and legally permissible purposes, its processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

Changes and updates to the privacy policy

We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

Business-related processing

In addition, we process
– contract data (e.g., subject matter of the contract, term, customer category).
– payment data (e.g., bank details, payment history)
from our customers, interested parties and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.

Order processing in the online store and customer account

We process our customers’ data as part of the ordering process in our online store 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. The processing is carried out for the purpose of providing contractual services in the context of operating an online store, billing, delivery and customer services. We use session cookies to store the contents of the shopping cart and permanent cookies to store the login status.

The processing is carried out for the fulfillment of our services and implementation of contractual measures (e.g. execution of order processes) and insofar as it is required by law (e.g. legally required archiving of business transactions for commercial and tax purposes). The information marked as necessary is required to justify and fulfill the contract. We only disclose the data to third parties in the context of delivery, payment or within the scope of legal permissions and obligations, as well as if this is done on the basis of our legitimate interests, about which we inform you in the context of this data protection declaration (e.g. to legal and tax advisors, financial institutions, freight companies and authorities).

Users can optionally create a user account in which they can view their orders in particular. As part of the registration process, users are provided with the required mandatory information. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, unless their retention is necessary for commercial or tax law reasons. Information in the customer account remains until its deletion with subsequent archiving in the event of a legal obligation or our legitimate interests (e.g. in the event of legal disputes). It is the responsibility of users to back up their data before the end of the contract in the event of termination.

We store the IP address and the time of the respective user action as part of the registration and renewed logins as well as the use of our online services. This data is stored on the basis of our legitimate interests and those of the user in protection against misuse and other unauthorized use. This data is not passed on to third parties unless it is necessary to pursue our legal claims as a legitimate interest or there is a legal obligation to do so.

The deletion takes place after the expiry of statutory warranty and other contractual rights or obligations (e.g., payment claims or performance obligations from contracts with customers), whereby the necessity of storing the data is reviewed every three years; in the case of storage due to statutory archiving obligations, the deletion takes place after their expiry.

External payment service providers

We use external payment service providers via whose platforms the users and we can carry out payment transactions (e.g., each with a link to the privacy policy, 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)

As part of the fulfillment of contracts, we use the 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. 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 the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored by them. 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 providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the terms and conditions and data protection information 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 on the respective websites or transaction applications. We also refer to these for further information and the assertion of rights of revocation, information and other rights of data subjects.

Administration, financial accounting, office organization, contact management

We process data in the context of administrative tasks and the organization of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process as part of the provision of 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, i.e. tasks that serve to maintain our business activities, perform our tasks and provide our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information specified in these processing activities.

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

We also store information on suppliers, event organizers and other business partners on the basis of our business interests, e.g. for the purpose of contacting them at a later date. We generally store this data, most of which is company-related, permanently.

Business analyses and market research

In order to operate our business economically, identify market trends and the wishes of contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc. In doing so, we process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. GDPR. GDPR, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offering.

The analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we can take into account the profiles of registered users with information, e.g. on the services they have used. The analyses help us to increase user-friendliness, optimize our offer and 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 personal, they will be deleted or anonymized upon termination by the user, otherwise after two years from the conclusion of the contract. Otherwise, the overall business analyses and general trend determinations are created anonymously where possible.

Participation in affiliate partner programs

Within our online offer, we use industry-standard tracking measures on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer) in accordance with Art. 6 para. 1 lit. f GDPR, insofar as these are necessary for the operation of the affiliate system. Below we explain the technical background to users.

The services offered by our contractual partners may also be advertised and linked on other websites (so-called affiliate links or after-buy systems, e.g. if links or third-party services are offered after a contract has been concluded). The operators of the respective websites receive a commission if users follow the affiliate links and subsequently take advantage of the offers.

In summary, it is necessary for our online offer that we can track whether users who are interested in affiliate links and/or the offers available from us subsequently take advantage of the offers at the instigation of the affiliate links or our online platform. For this purpose, the affiliate links and our offers are supplemented by certain values that can be set as part of the link or otherwise, e.g. in a cookie. The values include, in particular, the source website (referrer), time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as tracking-specific values such as advertising material ID, partner ID and categorizations.

The online identifiers we use for users are pseudonymous values. This means that the online identifiers themselves do not contain any personal data such as names or e-mail addresses. They only help us to determine whether the same user who clicked on an affiliate link or was interested in an offer via our online offer took up the offer, i.e. concluded a contract with the provider, for example. However, the online identifier is personal to the extent that the partner company and we have the online identifier together with other user data. Only in this way can the partner company inform us whether the user has taken up the offer and we can, for example, pay out the bonus.

Registration function

Users can create a user account. As part of the registration process, the required mandatory information is 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 email address). The data entered during registration is used for the purposes of using the user account and its purpose.

Users may be informed by email about information relevant to their user account, such as technical changes. If users have terminated their user account, their data relating to the user account will be deleted, subject to a statutory retention obligation. It is the responsibility of users to back up 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.

As part of the use of 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. This data is stored on the basis of our legitimate interests as well as those of the user in protection against misuse and other unauthorized use. This data is not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Art. 6 para. 1 lit. c. GDPR. The IP addresses are anonymized or deleted after 7 days at the latest.

Comments and contributions

If users leave comments or other contributions, their IP addresses may be stored on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR for 7 days. GDPR for 7 days. This is done for our security in case someone leaves illegal content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves may be prosecuted for the comment or post and are therefore interested in the identity of the author.

Furthermore, we reserve the right, on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. GDPR, to process user data for the purpose of spam detection.

On the same legal basis, we reserve the right to store the IP addresses of users for the duration of surveys and to use cookies in order to avoid multiple votes.

The personal information provided as part of the comments and contributions, any contact and website information as well as the content information will be stored permanently by us until the user objects.

Akismet anti-spam check

Our website uses the “Akismet” service, which is provided by Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA. It is used on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f) GDPR. This service is used to distinguish comments from real people from spam comments. For this purpose, all comments are sent to a server in the USA, where they are analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data is stored beyond this period. This data includes the name entered, the email address, the IP address, the comment content, the referrer, details of the browser used and the computer system and the time of the entry.

Further information on the collection and use of data by Akismet can be found in Automattic’s privacy policy: https://automattic.com/privacy/.

Users are welcome to use pseudonyms or refrain from entering their name or email address. You can completely prevent the transfer of data by not using our comment system. That would be a shame, but unfortunately we do not see any other alternatives that work just as effectively.

Retrieval of profile pictures from Gravatar

We use the Gravatar service of Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA, within our online offering and in particular in the blog.

Gravatar is a service where users can register and store profile pictures and their email addresses. If users leave posts or comments on other online presences (especially in blogs) with the respective e-mail address, their profile pictures can be displayed next to the posts or comments. For this purpose, the e-mail address provided by users is transmitted to Gravatar in encrypted form for the purpose of checking whether a profile is stored for it. This is the sole purpose of transmitting the email address and it will not be used for any other purpose, but will be deleted afterwards.

The use of Gravatar is based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f) GDPR, as we use Gravatar to offer post and comment authors the opportunity to personalize their posts with a profile picture.

By displaying the images, Gravatar learns the IP address of the user, as this is necessary for communication between a browser and an online service. Further information on the collection and use of data by Gravatar can be found in Automattic’s privacy policy: https://automattic.com/privacy/.

If users do not want a user picture linked to their e-mail address at Gravatar to appear in the comments, they should use an e-mail address that is not stored at Gravatar to comment. We would also like to point out that it is also possible to use an anonymous e-mail address or no e-mail address at all if users do not wish their own e-mail address to be sent to Gravatar. Users can completely prevent the transmission of data by not using our comment system.

Retrieval of emojis and smilies

Our WordPress blog uses graphic emojis (or smilies), i.e. small graphic files that express feelings, which are obtained from external servers. The providers of the servers collect the IP addresses of the users. This is necessary so that the emojie files can be transmitted to the user’s browser. The Emojie service is provided by Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA. Data protection information from Automattic: https://automattic.com/privacy/. The server domains used are s.w.org and twemoji.maxcdn.com, which, to our knowledge, are so-called content delivery networks, i.e. servers that are only used for the fast and secure transmission of files and the personal data of users is deleted after transmission.

The use of emojis is based on our legitimate interests, i.e. interest in an attractive design of our online offer in accordance with Art. 6 para. 1 lit. f. GDPR. GDPR.

Contact us

When contacting us (e.g. by contact form, e-mail, telephone or via social media), the user’s details will be used to process the contact request and its processing in accordance with Art. 6 para. 1 lit. b. (in the context of contractual/pre-contractual relationships), Art. 6 para. 1 lit. f. (other requests) GDPR. The user’s details may be stored in a customer relationship management system (“CRM system”) or comparable inquiry organization.

We delete the requests if they are no longer required. We review the necessity every two years; the statutory archiving obligations also apply.

With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.

Content of the newsletter: We only send newsletters, emails and other electronic notifications with advertising information (hereinafter “newsletter”) with the consent of the recipient or legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user’s consent. Otherwise, our newsletters contain information about our services and us.

Double opt-in and logging: Registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registering you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no-one can register with other people’s e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the mailing service provider are also logged.

Registration data: To register for the newsletter, it is sufficient to enter your e-mail address. Optionally, we ask you to enter a name so that we can address you personally in the newsletter.

The newsletter and the performance measurement associated with it are sent on the basis of the consent of the recipients in accordance with Art. 6 para. 1 lit. a, Art. 7 GDPR in conjunction with § 7 para. 2 no. 3 UWG or, if consent is not required, on the basis of our legitimate interests in direct marketing in accordance with Art. 6 para. 1 lt. f. GDPR in conjunction with. § 7 para. 3 UWG.

The registration process is logged on the basis of our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR. We are interested in using a user-friendly and secure newsletter system that serves both our business interests and the expectations of users and also allows us to provide proof 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 unsubscribe from 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 prove that consent was previously given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time.

The newsletter is sent using the mailing service provider “MailChimp”, a newsletter mailing 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 mailing 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 of compliance with the European level of data protection(https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active). The mailing service provider is used on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. GDPR and an order processing contract pursuant to Art. 28 para. 3 sentence 1 GDPR.

The mailing service provider may use the recipients’ data in pseudonymous form, i.e. without assigning it to a user, to optimize or improve its own services, e.g. to technically optimize the mailing and presentation of the newsletter or for statistical purposes. However, the mailing 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.

The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a mailing service provider, from their server. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, is initially collected.

This information is used 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 the 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 individual newsletter recipients. However, it is neither our intention nor, if used, that of the mailing service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

A separate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be canceled.

Hosting and e-mail delivery

The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services that we use for the purpose of operating this online offering.

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

Collection of access data and log files

We, or our hosting provider, collect data on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR. GDPR, we collect 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 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. to investigate misuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.

Google Analytics

On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use Google Analytics, a web analysis service provided by Google LLC (“Google”). GDPR) Google Analytics, a web analysis service of Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by the user is usually transmitted to a Google server in the USA and stored there.

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 offer by users, to compile reports on the activities within this online offer and to provide us with further services associated with the use of this online offer and the use of the Internet. Pseudonymous user profiles can be created from the processed data.

We only use Google Analytics 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 will the full IP address be transmitted to a Google server in the USA and truncated there.

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; users can also prevent Google from collecting the data generated by the cookie and relating to their use of the online offer and from processing this data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

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

Users’ personal data is deleted or anonymized after 14 months.

Google Universal Analytics

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

Google AdWords and conversion measurement

On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA (“Google”). 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 online marketing process Google “AdWords” to place ads in the Google advertising network (e.g. in search results, in videos, on websites, etc.) so that they are displayed to users who are likely to be interested in the ads. This allows us to display ads for and within our online offering 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 that they have shown an interest in on 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 accessed, a code from Google is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as “web beacons”) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). This file records which websites the user has visited, which content they are interested in and which offers the user has clicked on, as well as technical information about the browser and operating system, referring websites, time of visit and other information about the use of the online offer.

We also receive an individual “conversion cookie”. The information obtained with the help of the cookie is used by Google to create conversion statistics for us. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page with a conversion tracking tag. However, we do not receive any information with which users can be personally identified.

User data is processed pseudonymously within the Google advertising network. This means that Google does not store and process the user’s name or email address, for example, but processes the relevant data in relation to cookies within pseudonymous user profiles. This means that, from Google’s perspective, 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 about the user is transmitted to Google and stored on Google’s servers in the USA.

Jetpack (WordPress Stats)

On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use the Jetpack plugin (here sub-function “Wordpress Stats”). GDPR) the Jetpack plugin (here the sub-function “Wordpress Stats”), which integrates a tool for the statistical evaluation of visitor access and is provided by Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA. Jetpack uses so-called “cookies”, text files that are stored on your computer and enable your use of the website to be analyzed.

The information generated by the cookie about your use of this online offer is stored on a server in the USA. The processed data can be used to create user profiles, whereby these are only used for analysis and not for advertising purposes. Further information can be found in Automattic’s privacy policy: https://automattic.com/privacy/ and information on Jetpack cookies: https://jetpack.com/support/cookies/.

Facebook pixel, custom audiences and Facebook conversion

Within our online offer, 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 due to our legitimate interests in the analysis, optimization and economic operation of our online offer and for these purposes.

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, it is possible for Facebook to determine the visitors of our online offer as a target group for the display of ads (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Facebook (so-called “custom audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of users and are not annoying. With the help of the Facebook pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion”).

The processing of data by Facebook takes place within the framework of Facebook’s data usage policy. Accordingly, general information on the display of Facebook ads can be found in Facebook’s data usage policy: https://www.facebook.com/policy. Specific information and details about the Facebook pixel and how it works can be found in Facebook’s help section: https://www.facebook.com/business/help/651294705016616.

You can object to the collection by the Facebook pixel and use of your data to display Facebook ads. To set which types of ads are displayed to you within Facebook, you can go to the page set up by Facebook and follow the instructions on the settings for usage-based advertising: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.

You can also object to the use of cookies for reach measurement and advertising purposes via the deactivation page of the network advertising initiative(http://optout.networkadvertising.org/) and additionally the US website(http://www.aboutads.info/choices) or the European website(http://www.youronlinechoices.com/uk/your-ad-choices/).

Visual Website Optimizer

Within our online offer, on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR. GDPR), the Visual Website Optimizer service (an offer from Wingify Software Private Limited, 404, Gopal Heights, Netaji Subhash Place, Pitam Pura, Delhi 110034, India) is used.

Visual Website Optimizer uses A/B testing, click tracking and heat maps to track the effects of various changes to a website (e.g. changes to input fields, design, etc.). A/B tests are used to improve the user-friendliness and performance of online offers. For example, users are shown different versions of a website or its elements, such as input forms, on which the placement of the content or labels of the navigation elements can differ. Based on the user’s behavior, e.g. longer time spent on the website or more frequent interaction with the elements, it can then be determined which of these websites or elements are more likely to meet the user’s needs. “Click tracking” makes it possible to monitor the movements of users within an entire online offering. As the results of these tests are more accurate if the user’s interaction can be tracked over a certain period of time (e.g. to see whether a user likes to return), cookies are usually stored on the user’s computer for these test purposes. “Heatmaps” are mouse movements of users that are summarized into an overall picture, which can be used, for example, to recognize which website elements are preferred and which website elements users prefer less.

Cookies are only stored on users’ devices for these test purposes. Only pseudonymous user data is processed. For more information, please refer to the Visual Website Optimizer privacy policy: https://vwo.com/privacy-policy/.

If you do not want the Visual Website Optimizer to record your usage behavior, you can object to data collection using this link: https://[BITTE-IHREDOMAIN-EINSETZEN]/ ?vwo_opt_out=1.

Online presence in social media

We maintain online presences within social networks and platforms in order to communicate with the 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 may result in risks for users because, for example, it could make it more difficult to enforce users’ rights. With regard to US providers that are certified under the Privacy Shield, we would like to point out that they thereby undertake to comply with the data protection standards of the EU.

Furthermore, user data is generally processed for market research and advertising purposes. For example, usage profiles can be created from the usage behavior and the resulting interests of the 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 behavior and interests are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).

The processing of users’ personal data is based on our legitimate interests in effective user information and communication with users in accordance with Art. 6 para. 1 lit. f. GDPR. GDPR. If users are asked by the respective providers to consent to data processing (i.e. to give 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 and the opt-out options, we refer to the following linked information from the providers.

In the case of requests for information and the assertion of user rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still 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=ads and http://www.youronlinechoices.com, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.

– Google/YouTube (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – Privacy Policy: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.

– Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – Privacy Policy/ Opt-Out: http://instagram.com/about/legal/privacy/.

– Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) – Privacy Policy: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.

– Pinterest (Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA) – Privacy Policy/ Opt-Out: https://about.pinterest.com/de/privacy-policy.

– LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland) – Privacy Policy https://www.linkedin.com/legal/privacy-policy, Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active.

– Xing (XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany) – Privacy Policy/ Opt-Out: https://privacy.xing.com/de/datenschutzerklaerung.

– Wakalet (Wakelet Limited, 76 Quay Street, Manchester, M3 4PR, United Kingdom) – Privacy Policy/ Opt-Out: https://wakelet.com/privacy.html.

– Soundcloud (SoundCloud Limited, Rheinsberger Str. 76/77, 10115 Berlin, Germany) – Privacy Policy/ Opt-Out: https://soundcloud.com/pages/privacy.

Integration of third-party services and content

On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use content or service offers from third-party providers within our online offer. GDPR), we use content or service offers from third-party providers 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 are aware of the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags can be used to analyze 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 contain, among other things, technical information about the browser and operating system, referring websites, visiting time and other information about the use of our online offer, as well as being linked to such information from other sources.

Vimeo

We can integrate the videos of the platform “Vimeo” of the provider Vimeo Inc, Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA. Privacy policy: https://vimeo.com/privacy. We would like to point out that Vimeo may use Google Analytics and refer to the privacy policy(https://policies.google.com/privacy) and opt-out options for Google Analytics(http://tools.google.com/dlpage/gaoptout?hl=de) or Google’s settings for the use of data for marketing purposes(https://adssettings.google.com/).

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 Fonts

We integrate the fonts (“Google Fonts”) 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 ReCaptcha

We integrate the function for recognizing bots, e.g. for entries in online forms (“ReCaptcha”) 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.

Use of Facebook social plugins

On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use social plugins (“plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd. GDPR) social plugins (“plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”).
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 Facebook. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.

When a user accesses a function of this online offering that contains such a plugin, their 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 offering. User profiles can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects with the help of this plugin and therefore inform users according to our level of knowledge.

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 their Facebook account. If users interact with the plugins, for example by clicking the Like button or posting a comment, the corresponding information is transmitted directly from your device to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to find out their IP address and store it. According to Facebook, only an anonymized IP address is stored in Germany.

The purpose and scope of the data collection and the further processing and use of the data by Facebook as well as the related rights and setting options to protect the privacy of users can be found in Facebook’s data protection information: https://www.facebook.com/about/privacy/.

If a user is a Facebook member and does not want Facebook to collect data about them via this online service and link it to their membership data stored on Facebook, they must log out of Facebook and delete their cookies before using our online service. Further settings and objections to 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 site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are adopted for all devices, such as desktop computers or mobile devices.

Twitter

Functions and content of the Twitter service, offered by Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, may be integrated into our online offering. This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online offering within Twitter.
If the users are members of the Twitter platform, Twitter can assign the access to the above-mentioned content and functions to the users’ profiles 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

Functions and content of the Instagram service, offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA, may be integrated into our online offering. This may include, for example, content such as images, videos or texts 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 access to the above-mentioned content and functions to the users’ profiles there. Instagram’s privacy policy: http://instagram.com/about/legal/privacy/.