Datenschutz Erklärung

Introduction

With the following data protection declaration we would like to inform you about the types of personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter also referred to collectively as "online offer").

The terms used are not gender-specific.

Stand: 26. Juli 2021

Table of contents



Responsible person

Sebastian Schmidt
Schwengebergstr. 1
34132 Kassel, DE

Authorized Representatives: Werner Schmidt Werner Schmidt

Mail address: schmidt.sebastian.89@web.de

Legal notice: https://two-rivers-privity.de/impressum



Overview of the processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.



Types of data processed

  • Event Data (Facebook) ("Event Data" is data that may be transmitted by us to Facebook, for example via Facebook pixels (via apps or otherwise), and that relates to individuals or their actions; the data includes, for example, information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc. Event data is processed for the purpose of targeting content and advertising information (custom audiences); event data does not include the actual content (such as comments posted), login information, and contact information (such as names, email addresses and phone numbers). Event data is deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account).
  • Stock data (e.g. names, addresses).
  • Content data (e.g. input into online forms).
  • Contact details (e.g. e-mail, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Location data (information on the geographical position of a device or person).
  • Contract data (e.g. object of contract, duration, customer category).
  • Payment data (e.g. bank details, invoices, payment history).


Categories of affected persons

  • Interested parties.
  • Communication partners.
  • Customers.
  • Users (e.g. website visitors, users of online services).


Purpose of processing

  • Affiliate tracking.
  • Provision of our online offer and user-friendliness.
  • Conversion measurement (measuring the effectiveness of marketing measures).
  • Cross-device tracking (cross-device processing of user data for marketing purposes).
  • Feedback (e.g. collecting feedback via online form).
  • Interest based and behavioral marketing.
  • Contact requests and communication.
  • Profiling (creation of user profiles).
  • Remarketing.
  • Range measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures.
  • Tracking (e.g. interest/behavioral profiling, use of cookies).
  • Provision of contractual services and customer service.
  • Management and response to inquiries.
  • Target group formation (determination of target groups relevant for marketing purposes or other output of content).


Applicable legal basis

In the following, we provide the legal basis of the General Data Protection Regulation (GDPR), on the basis of which we process personal data. Please note that in addition to the regulations of the GDPR, national data protection regulations may apply in your or our country of residence and domicile. Should more specific legal regulations apply in individual cases, we will inform you of these in the data protection declaration.

  • Consent (art. 6 par. 1 sentence 1 letter a. GDPR) - The data subject has given his/her consent to the processing of personal data concerning him/her for one or more specific purposes.
  • Fulfilment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to implement pre-contractual measures taken at the request of the data subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR) - The processing is necessary in order to protect the legitimate interests of the controller or of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the basic data protection regulation, national regulations on data protection apply in Germany. This includes in particular the law on protection against misuse of personal data in data processing (Bundesdatenschutzgesetz - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to deletion, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision making in individual cases including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (§ 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.



Security measures

We take appropriate technical and organizational measures in accordance with 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 probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

The measures include in particular the safeguarding of the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, disclosure, safeguarding of availability and separation of the data. Furthermore, we have established procedures to ensure that data subjects' rights are exercised, that data is deleted, and to respond to any threats to the data. 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, by designing technology and by using data protection-friendly default settings.

SSL-Encryption (https)To protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.



Transmission and disclosure of personal data

In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. The recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.



Data processing in third-party countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this is only done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we process or have the data processed only in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).



Use of cookies

Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user's computer. A cookie is primarily used to store information about a user during or after his visit within an online offer. The stored information can include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was viewed. The term "cookies" also includes other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also referred to as "user IDs")

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
  • Permanent Cookies: Permanent cookies remain stored even after closing the browser. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The interests of users used for reach measurement or marketing purposes can also be stored in such a cookie.
  • First-Party-Cookies: First-party cookies are set by ourselves.
  • Third-Party-Cookies: Third party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or absolutely necessary) cookies: Cookies may be absolutely necessary for the operation of a website (e.g. to store logins or other user entries or for security reasons).
  • Statistical, marketing and personalization cookiesFurthermore, cookies are generally used for range measurement and when the interests of a user or his behaviour (e.g. viewing certain contents, using functions etc.) are stored in a user profile on individual websites. Such profiles are used to show users e.g. content that corresponds to their potential interests. This process is also known as "tracking", i.e. following the potential interests of users. If we use cookies or "tracking" technologies, we will inform you separately in our privacy policy or when you give your consent.

Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in a business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfil our contractual obligations.

Duration of storage: Unless we provide you with explicit information on the storage duration of permanent cookies (e.g. within the scope of a so-called cookie opt-in), please assume that the storage duration can be up to two years.

General information on revocation and opposition (opt-out): Depending on whether the processing is based on consent or legal permission, you may at any time revoke any consent you have given or object to the processing of your data by cookie technologies (collectively referred to as "opt-out"). You can initially declare your objection by means of the settings of your browser, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online service). An objection to the use of cookies for online marketing purposes can also be made by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ . In addition, you can receive further notices of objection in the context of the information on the service providers and cookies used.

Processing of cookie data based on consent: Before we process or have processed data in the context of the use of cookies, we ask the users for their consent, which can be revoked at any time. Before the consent has not been given, cookies are used if necessary, which are absolutely necessary for the operation of our online offer.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).


Use of online marketplaces for e-commerce

We offer our services on online platforms operated by other service providers. In this context, in addition to our privacy policy, the privacy policy of the respective platforms applies. This applies in particular with regard to the methods used on the platforms for measuring reach and for interest-based marketing.

  • Processed data types: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Customers.
  • Purposes of the processing: Provision of contractual services and customer service.
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Used services and service providers:

  • Amazon: Online marketplace for e-commerce; service provider: Amazon Europe Core S.à.r.l., Amazon EU S.à.r.l., Amazon Services Europe S.à.r.l. and Amazon Media EU S.à.r.l., all four located at 38, avenue John F. Kennedy, L-1855 Luxembourg, and Amazon Instant Video Germany GmbH, Domagkstr. 28, 80807 Munich, Germany (together "Amazon Europe"), parent company: Amazon.com, Inc. 2021 Seventh Ave, Seattle, Washington 98121, USA; Website: https://www.amazon.de/; Privacy policy: https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010.


Payment service provider

Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the persons concerned efficient and secure payment options and use other payment service providers in addition to banks and credit institutions (collectively "payment service providers").

The data processed by the payment service providers include 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 related data. These details are required to complete 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 payment service providers may transfer the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the general terms and conditions and the data protection information of the payment service providers.

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

  • Processed data types: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses)
  • Persons concerned: Customers, interested parties.
  • Purposes of the processing: Provision of contractual services and customer service.
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Used services and service providers:



Provision of the online offer and web hosting

In order to provide our online services securely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers managed by them) the online services can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security and technical maintenance services.

The data processed within the scope of providing the hosting offer may include all data concerning the users of our online offer, which are generated within the scope of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

Collection of access data and log filesWe ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, date and time of access, data volume transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the utilization of the servers and their stability.

  • Processed data types: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses)
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).


Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data are processed for the purposes of the publication medium only to the extent necessary for its presentation and for communication between authors and readers or for security reasons. In addition, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.

Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone leaves illegal content in comments and contributions (insults, prohibited political propaganda, etc.). In this case we can be prosecuted ourselves for the comment or contribution and are therefore interested in the identity of the author.

Furthermore, based on our legitimate interests, we reserve the right to process user data for the purpose of spam detection.

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

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

Akismet anti-spam check: We use the "Akismet" service based on our legitimate interests. With the help of Akismet, comments from real people are distinguished 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 is classified as spam, the data is stored beyond this time. This information includes the name entered, the e-mail address, the IP address, the comment content, the referrer, information on the browser used and the computer system and the time of entry.

Users are welcome to use pseudonyms or to refrain from entering their name or e-mail address. They can completely prevent the transmission of data by not using our comment system. That would be a pity, but unfortunately we do not see any alternatives that work as effectively.

  • Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses)
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Purposes of the processing: Provision of contractual services and customer service, feedback (e.g. collecting feedback via online form), security measures, administration and response to inquiries.
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Used services and service providers:



Contact

When contacting us (e.g. via contact form, e-mail, telephone or via social media), the data of the inquiring persons will be processed to the extent that this is necessary to answer the contact inquiries and any requested measures.

The answering of contact inquiries within the scope of contractual or pre-contractual relations is done in order to fulfill our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of our legitimate interest in answering the inquiries.

  • Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms).
  • Persons concerned: Communication partners.
  • Purposes of the processing: Contact requests and communication.
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).


Web analysis, monitoring and optimization

Web analysis (also known as "reach measurement") is used to evaluate the streams of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the range analysis we can, for example, identify at what time our online offer or its functions or contents are most frequently used or invite reuse. We can also understand which areas require optimization.

In addition to web analysis, we can also use test procedures, for example to test and optimize different versions of our online offer or its components.

For these purposes, so-called user profiles can be created and stored in a file (so-called "cookie") or similar procedures with the same purpose can be used. This information may include, for example, content viewed, web pages visited and elements used on those pages, and technical data such as the browser used, the computer system used, and information on usage times. If users have consented to the collection of their location data, this data may also be processed, depending on the provider.

The IP addresses of users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect the users. In general, in the context of web analysis, A/B testing and optimization, no clear user data (such as e-mail addresses or names) are stored, but pseudonyms. This means that we as well as the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

Notes on legal bases: If we ask the users for their consent to the use of the third party providers, the legal basis for the processing of data is the consent. Otherwise, the users' data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Purposes of the processing: Reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behavioral profiling, use of cookies), conversion measurement (measurement of the effectiveness of marketing measures), profiling (creation of user profiles).
  • Security measures: IP-Masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Used services and service providers:



Onlinemarketing

We process personal data for online marketing purposes, which may include in particular the marketing of advertising space or the display of advertising and other content (collectively referred to as "Content") based on the potential interests of users and the measurement of its effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar procedures are used to store user information relevant for the presentation of the aforementioned contents. This information may include, for example, the content viewed, web pages visited, online networks used, but also communication partners and technical details such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this data may also be processed.

The IP addresses of users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect the users. In general, no clear user data (such as e-mail addresses or names) are stored in the context of the online marketing process, but pseudonyms. This means that we as well as the providers of the online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in the cookies or by similar methods. These cookies can later be read out and analyzed for the purpose of presenting content on other websites that use the same online marketing process, and can also be supplemented with additional data and stored on the server of the online marketing process provider.

Exceptionally, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing methods we use and the network links the users' profiles with the aforementioned data. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.

As a matter of principle, we only have access to summarized information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyze the success of our marketing measures.

Unless otherwise stated, we ask you to assume that used cookies are stored for a period of two years.

Notes on legal bases: If we ask the users for their consent to the use of the third party providers, the legal basis for the processing of data is the consent. Otherwise, the users' data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

Facebook pixel and target group formation (custom audiences):

With the help of the Facebook pixel (or comparable functions, for the transmission of event data or contact information via interfaces in apps), 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 ensure that the Facebook Ads placed by us are only available to such users on Facebook and within the services of partners cooperating with Facebook (so-called "Audience Network") https://www.facebook.com/audiencenetwork/ that have also shown an interest in our online offering or that have certain characteristics (e.g. interest in certain topics or products that can be seen from the websites visited) that we transmit to Facebook (so-called "custom audiences"). With the help of the Facebook pixel, we also want to ensure that our Facebook Ads correspond to the potential interest of users and do not appear to be annoying. The Facebook pixel also enables us to track the effectiveness of Facebook ads for statistical and market research purposes.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographical position of a device or person), event data (Facebook) ("event data" is data that can be transferred from us to Facebook, e.g. via Facebook pixels (via apps or other means), and relates to persons or their actions; the data includes e.g., information about visits to websites, interactions with content, features, app installations, product purchases, etc.; the Event Data is processed for the purpose of creating target audiences for content and advertising information (Custom Audiences); Event Data does not include the actual content (such as written comments), login information, or contact information (such as names, email addresses, and phone numbers). Event data is deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account).
  • Persons concerned: Users (e.g. website visitors, users of online services), interested persons.
  • Purposes of the processing: Tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, conversion measurement (measurement of the effectiveness of marketing measures), interest-based and behavioural marketing, profiling (creation of user profiles), reach measurement (e.g. access statistics, recognition of returning visitors), target group formation (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes)
  • Security measures: IP-Masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
  • Possibility of objection (Opt-Out): We refer to the data protection notices of the respective providers and to the possibilities of objection (so-called "opt-out") indicated for the providers. If no explicit opt-out has been specified, it is possible to deactivate cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary form for the respective areas:
    a) Europe: https://www.youronlinechoices.eu.
    b) Canada: https://www.youradchoices.ca/choices.
    c) USA: https://www.aboutads.info/choices.
    d) Cross-territorial: https://optout.aboutads.info.

Used services and service providers:



Affiliate-Programs and Affiliate-Links

We include so-called affiliate links or other references (which may include search masks, widgets or discount codes) to the offers and services of third parties in our online offer (collectively referred to as "affiliate links"). If users follow the affiliate links or subsequently take advantage of the offers, we may receive commission or other benefits from these third parties (collectively, "commission").

In order to be able to track whether users have taken advantage of the offers of an affiliate link used by us, it is necessary that the respective third party providers learn that users have followed an affiliate link used within our online offer. The assignment of the affiliate links to the respective business transactions or other actions (e.g. purchases) serves the sole purpose of the commission settlement and is cancelled as soon as it is no longer necessary for the purpose.

For the purposes of the aforementioned affiliate link assignment, the affiliate links may be supplemented with certain values that are part of the link or may be stored elsewhere, e.g. in a cookie. These values may include in particular the initial website (referrer), the time, an online identification of the operator of the website on which the affiliate link was located, an online identification of the respective offer, the type of link used, the type of offer and an online identification of the user.

Notes on legal bases: If we ask the users for their consent to the use of the third party providers, the legal basis for the processing of data is the consent. Furthermore, their use can be a component of our (pre-)contractual services, provided that the use of the third party providers has been agreed in this context. Otherwise, the users' data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Processed data types: Contract data (e.g. subject matter of contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses)
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Purposes of the processing: Affiliate tracking.
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Fulfilment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR)

Used services and service providers:

  • Amazon Partner Program: Amazon - Partner Program - Amazon and the Amazon logo are trademarks of Amazon.com, Inc. or one of its affiliates. service provider: Amazon Europe Core S.à.r.l., Amazon EU S.à.r.l., Amazon Services Europe S.à.r.l. and Amazon Media EU S.à.r.l., all four located at 38, avenue John F. Kennedy, L-1855 Luxembourg, and Amazon Instant Video Germany GmbH, Domagkstr. 28, 80807 Munich, Germany (together "Amazon Europe"), parent company: Amazon.com, Inc., 2021 Seventh Ave, Seattle, Washington 98121, USA; Website: https://www.amazon.de; Privacy policy: https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010.


Presence in social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.

We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.

Furthermore, user data within social networks is usually processed for market research and advertising purposes. Thus, for example, user profiles can be created based on user 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 networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behaviour and interests of the users are stored. Furthermore, data may 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).

For a detailed presentation of the respective forms of processing and the possibilities of objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.

Also in the case of requests for information and the assertion of data subject rights, we would like to point out that these can be most effectively asserted with the providers. Only the providers have access to the data of the users in each case and can directly take appropriate measures and provide information. Should you nevertheless require assistance, you can contact us.

Facebook: We are jointly responsible with Facebook Ireland Ltd. for the collection (but not the further processing) of data of visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content that users view or interact with, or the actions they take (see "Things you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see "Device Information" in the Facebook Data Policy Statement: https://www.facebook.com/policy). As explained in the Facebook Data Policy under "How we use this information," Facebook also collects and uses information to provide analytics services, called "page insights," to site operators to help them understand how people interact with their sites and with content associated with them. We have a special agreement with Facebook ("Page Insights Information, https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of the persons concerned (i.e. users can, for example, send information or requests for deletion directly to Facebook). The rights of users (in particular to information, deletion, objection and complaints to the competent supervisory authority) are not limited by the agreements with Facebook. Further information can be found in the "Information on Page-Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data).

  • Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses)
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Purposes of the processing: Contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Used services and service providers:



Plugins, embedded functions and content

We include in our online offer functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as "third party providers"). These can be, for example, graphics, videos or social media buttons and contributions (hereinafter referred to uniformly as "content").

The integration always requires that the third party providers of this content process the IP address of the users, as without the IP address they would not be able to send the content to their browsers. The IP address is therefore required to display these contents or functions. We make every effort to use only such content whose respective providers use the IP address only 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. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain technical information about the browser and operating system, the websites to be linked, the time of visit and other details about the use of our online offer as well as being linked to such information from other sources.

Notes on legal bases: If we ask the users for their consent to the use of the third party providers, the legal basis for the processing of data is the consent. Otherwise, the users' data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographical position of a device or person), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Purposes of the processing: Provision of our online services and user-friendliness, provision of contractual services and customer service, security measures, administration and response to inquiries.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR), consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR).

Used services and service providers:



Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their permission to process them is revoked or other permissions cease to apply (e.g. if the purpose for which they were processed ceases to apply or if they are not necessary for the purpose).

Unless the data are deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or that must be stored for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.

Further information on the deletion of personal data can also be found in the individual data protection notes of this privacy policy.



Amendment and update of the privacy policy

We kindly ask you to inform yourself regularly about the content of our privacy policy. We will adapt the data protection declaration as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes make it necessary for you to take action to cooperate (e.g. to give your consent) or to receive other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.



Rights of the data subjects

As a data subject, you are entitled to various rights under the GDPR, which result in particular from Art. 15 to 21 GDPR:

  • Right of objection: You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you that is carried out pursuant to art. 6, paragraph 1, letter e or f of the GDPR; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing, including profiling, insofar as it is linked to such direct marketing.
  • Right of revocation for consents: You have the right to revoke given consents at any time.
  • Right of access to information: You have the right to request confirmation as to whether or not data in question is being processed and to receive information about this data and other information and a copy of the data in accordance with legal requirements.
  • Right of rectification: In accordance with the law, you have the right to request the completion of the data concerning you or the correction of incorrect data concerning you.
  • Right to cancellation and limitation of processing: In accordance with the statutory provisions, you have the right to demand that data concerning you be deleted immediately, or alternatively, in accordance with the statutory provisions, to demand that the processing of the data be restricted.
  • Right to data transferability: You have the right, in accordance with legal requirements, to receive data concerning you that you have provided to us in a structured, common and machine-readable format or to request that it be transferred to another person responsible.
  • Complaint to the supervisory authority: You also have the right, in accordance with the statutory provisions, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the suspected infringement, if you believe that the processing of personal data concerning you is in breach of the GDPR.


Definitions of terms

This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined above all in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.

  • Affiliate tracking: As part of the affiliate tracking, links are logged with the help of which the linking websites refer users to websites with product or other offers. The operators of the respective linking websites can receive a commission if users follow these so-called affiliate links and then take advantage of the offers (e.g. buy goods or services). To this end, it is necessary for the providers to be able to track whether users who are interested in certain offers subsequently take notice of them at the instigation of the affiliate links. Therefore, for affiliate links to work, it is necessary for them to be supplemented with certain values that become part of the link or are stored elsewhere, e.g. in a cookie. These values include in particular the initial website (referrer), the time, an online identification of the operator of the website on which the affiliate link was located, an online identification of the respective offer, an online identification of the user as well as tracking specific values, such as advertising material ID, partner ID and categorizations
  • Cross-Device Tracking: Cross-device tracking is a form of tracking in which the behavioral and interest information of users is recorded across devices in so-called profiles by assigning users an online ID. This allows the user information to be analyzed for marketing purposes, regardless of the browser or device used (e.g., cell phone or desktop computer). With most providers, the online ID is not linked to clear data, such as names, postal or e-mail addresses.
  • IP-Masking: IP masking" is a method of deleting the last octet, i.e. the last two numbers of an IP address, so that the IP address can no longer be used to uniquely identify a person. IP-Masking is therefore a means of pseudonymizing processing methods, especially in online marketing
  • Interest based and behavioral marketing: One speaks of interest-based and/or behavioral marketing when the potential interests of users in advertisements and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behavior (e.g. visiting and staying on certain websites, buying behavior or interaction with other users), which is stored in a so-called profile. As a rule, cookies are used for these purposes.
  • Conversion measurement: Conversion measurement (also known as "visitor action evaluation") is a method to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user's devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, this enables us to track whether the ads we have placed on other websites have been successful.
  • Personal data: "Personal data" shall mean any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); an identifiable 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. a cookie) or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiling: Profiling" is any automated processing of personal data that consists of using such personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information on age, gender, location and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Range measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behaviour or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, identify at what time visitors visit their website and what content they are interested in. This enables them to better adapt the contents of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis purposes in order to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
  • Remarketing: One speaks of "remarketing" or "retargeting", for example, when it is noted for advertising purposes which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • location data: Location data is created when a mobile device (or another device with the technical requirements for a location determination) connects to a radio cell, a WLAN or similar technical means and functions of location determination. Location data serve to indicate the geographically determinable position of the earth at which the respective device is located. Location data can be used, for example, to display map functions or other information dependent on a location.
  • Tracking: One speaks of "tracking" when the behavior of users can be traced across several online offerings. As a rule, behavioral and interest information regarding the online offerings used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
  • Responsible person Controller" shall mean 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.
  • Processing: "Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually all handling of data, be it collection, analysis, storage, transmission or deletion.
  • Target group formation: One speaks of target group formation (or "custom audiences") when target groups are determined for advertising purposes, e.g. the insertion of advertisements. For example, based on a user's interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online store where he/she viewed the products. In turn, one speaks of "Lookalike Audiences" (or similar target groups) if the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used to create custom audiences and lookalike audiences.

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