Privacy Policy

Information about the processing of your data

In accordance with Art. 12 of the General Data Protection Regulation (hereinafter referred to as the GDPR), we are obliged to inform you about the processing of your data when you use our website. We take the protection of your personal data very seriously and this privacy policy informs you about the details of the processing of your data and about your legal rights in this regard.

We reserve the right to adapt the privacy policy with future effect, in particular in the event of further development of the website, the use of new technologies or changes to the legal bases or the corresponding case law.

We recommend that you read this privacy policy from time to time and take a printout or a copy for your documents.

Definitions

  • In the following, website means all of the controller’s pages at www.living-hotels.com;
  • personal data means any information relating to an identified or identifiable natural person. A person is identifiable if they can be identified, either directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier or to one or more special features that are an expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person. Personal data is therefore, for example, a person’s name, email address and telephone number, but may also include information about preferences, hobbies and memberships;
  • processing means operations or sets of operations carried out with or without the aid of automated procedures in connection with personal data, such as the collection, recording, organisation, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure or destruction;
  • pseudonymisation 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 organisational measures to ensure that the personal data cannot be attributed to an identified or identifiable natural person;
  • consent means any freely given, specific, informed and unambiguous indication of the data subject’s wishes in a particular case by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
  • Google means Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; reachable in the European Union at: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, fax: +353 (1) 436 1001.

Scope

This privacy policy applies to all pages of www.living-hotels.com. It does not cover any linked websites of other providers.

Responsible provider

The following party is responsible for the processing of personal data within the scope of this privacy policy:

Derag Living Hotels AG + Co. KG

Hotelzentrale

Frauenhoferstraße 2

80469 Munich

Email: info@deraghotels.de;

Telephone: +49 (0) 89 23701250

 

Questions about data protection

If you have any questions about data protection with regard to our company or our website, you can contact our data protection officer:

Spirit Legal LLP Rechtsanwälte

Attorney-at-law and data protection officer

Peter Hense

 

Postal address:

Data protection officer

c/o Derag Living Hotels AG + Co. KG

Frauenhoferstraße 2

80469 Munich

 

Contact via encrypted online form:

Contact data protection officer

Security

We have taken comprehensive technical and organisational precautions to protect your personal data from unauthorised access, abuse, loss and other external disruption. To this end, we regularly review our security measures and adapt them to current standards.

Your rights

You have the following rights with regard to the personal data concerning you that you can assert against us:

  • right of access (Art. 15 GDPR),
  • right to rectification (Art. 16 GDPR) or erasure (Art. 17 GDPR),
  • right to restriction of processing (Art. 18 GDPR),
  • right to object to processing (Art. 21 GDPR),
  • right to withdraw your consent (Art. 7(3) GDPR),
  • right to receive the data in a structured, commonly used, machine-readable format (“data portability”) and the right to transfer the data to another controller, if the prerequisites of Art. 20(1) (a), (b) GDPR are fulfilled (Art. 20 GDPR)

You can assert your rights by informing us using the contact details specified above under ‘Responsible provider’ or by contacting the data protection officer designated by us.

You also have the right to lodge a complaint with a data protection supervisory authority about our processing of your personal data (Art. 77 GDPR).

Use of the website, access data

In principle, you can use our website for purely informational purposes without disclosing your identity. When you access the individual pages of the website in this sense, this only results in access data being transferred to our web hosting service so that the website can be displayed to you. This is the following data:

  • browser type/browser version
  • operating system used
  • language and version of the browser software
  • hostname of the accessing device
  • IP address
  • website from which the request comes
  • content of the request (specific page)
  • date and time of the server request
  • access status/HTTP status code
  • referrer URL (website visited before)
  • volume of data transferred
  • time zone difference from Greenwich Mean Time (GMT)

Temporary processing of the IP address by the system is necessary to make it technically possible to deliver the website to your device. This requires processing of your IP address for the duration of the session. The legal basis of such processing is Art. 6(1) Sentence 1(f) GDPR.

The access data is not used to identify individual users and is not combined with other data sources. The access data is deleted when it is no longer required for achieving the purpose of its processing. In the case of recording the data to provide the website, this is the case when you end your visit to the website.

IP addresses are stored in log files to ensure the functionality of the website. In addition, the data serves us to optimise the website and to ensure the security of our information technology systems. No evaluation of the data for marketing purposes takes place in this context either. In principle, data is deleted after seven days at the latest; further processing is possible in individual cases. In this case, the IP address is deleted or so transformed that an assignment of the retrieving client is no longer possible.

The recording of data for the provision of the website and the processing of data in log files is an absolute necessity for the operation of the website. You may object to the processing. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). In the event that your objection is justified, we will examine the situation and either stop or adjust the data processing or point out to you the compelling legitimate reasons on the basis of which we will continue processing.

Cookies

In addition to the aforementioned access data, so-called cookies are stored in the internet browser of the device you use to access the website. These are small text files with a sequence of numbers that are stored locally in the cache of the browser used. Cookies do not become part of the device system and cannot execute programs. They serve to make our website user-friendly. The use of cookies may be technically necessary or may occur for other purposes (e.g. analysis/evaluation of website usage).

  1. a) Technically necessary cookies

Some elements of our website require that the retrieving browser can be identified even after a page change. This involves processing the following data in the cookies:

  • language settings
  • items in shopping basket
  • login information

The user data collected by technically necessary cookies is not processed to create user profiles. We also use session cookies, which store a session ID that can be used to assign various requests from your browser to the shared session. Session cookies are required for using the website. In particular, they enable us to recognise the device used when you return to the website. If you have an account with us, we use this cookie to recognise you on subsequent visits to the website; otherwise you would have to log in again each time you visited. The legal basis of this processing is Art. 6(1) Sentence 1(f) GDPR. We use session cookies to make using our website more attractive and effective. Session cookies are deleted as soon as you log out or close your browser.

Most browsers are preset to automatically accept cookies. You can object to the processing of your data by cookies. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). In the event that your objection is justified, we will examine the situation and either stop or adjust the data processing or point out to you the compelling legitimate reasons on the basis of which we will continue processing.

You can disable or restrict the transfer of cookies by changing the settings in your internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are disabled for our website, it may no longer be possible to use the full functionality of the website.

  1. b) Technically non-essential cookies

In addition, we also use cookies on the website which enable an analysis of users’ surfing behaviour. For example, this involves processing the following data in the cookies:

  • entered search terms
  • frequency of page views
  • use of website functions

These cookies are used to make using the website more efficient and attractive. The legal basis of this processing is Art. 6(1) Sentence 1(f) GDPR. The technically non-essential cookies are automatically deleted after a specified period, which may vary depending on the cookie.

You can object to the processing of your data by cookies. If you do not wish to use cookies, you have the option of changing your browser settings in order to generally or selectively block the placement of cookies or remove stored cookies. You can also have the corresponding information displayed before a cookie is placed. If you change the browser settings for the use of cookies or disable cookies, the functionality of this website may be restricted.

Where we integrate cookies from third-party providers into our website, we point this out to you separately below.

  1. c) Cookie banner notice

When you visit the website, an information banner notifies you about the use of cookies for analysis purposes and refers you to this privacy policy. In this context, information is also provided about how the storage of cookies can be prevented by adjusting your browser settings.

Contacting our company

When contacting our company, e.g. by email, we will process the personal data provided by you so that we can respond to your enquiry.

In order for us to process enquiries submitted via the contact form on the website, it is essential that you provide a name or pseudonym and a valid email address. At the moment when you submit the message to us, the following data will also be processed:

  • IP address
  • date/time of registration

The legal basis of the processing is Art. 6(1) Sentence 1(f) GDPR and Art. 6(1) Sentence 1(b) GDPR, if the contact is made with the intention of concluding a contract.

Processing the personal data from the form allows us alone to process the contact you make with us. Where you contact us by email, this also constitutes the necessary legitimate interest in the processing of the data.

The data will not be transmitted to third parties in this context. The data is only processed in order to process the conversation. As soon as processing is no longer necessary, we delete the data generated in this context or, if statutory retention obligations apply, restrict processing of the data.

You have the possibility to object to the processing of your personal data for contact requests at any time. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). In particular, you have a right of objection if processing is not necessary to fulfil a contract with you, which is described by us in the previous description of the functions. In such a case, it may not be possible to continue processing the request. In the event that your objection is justified, we will examine the situation and either stop or adjust the data processing or point out to you the compelling legitimate reasons on the basis of which we will continue processing.

Processing and transmission of personal data for contractual purposes

We process your personal data if and to the extent necessary for the initiation, creation, execution and/or termination of a legal transaction with our company. The legal basis from this results from Art. 6(1) Sentence 1(b) GDPR.

Once the purpose has been achieved (e.g. contract processing), the personal data will be blocked for further processing or erased, unless we are entitled to retain the data for a longer period and process it as required in the respective context on the basis of a consent granted by you (e.g. consent to the processing of your email address for sending promotional emails), a contractual agreement, a statutory authorisation (e.g. authorisation to send direct advertising) or on the basis of justified interests (e.g. retention for asserting claims).

Your personal data will be passed on if

  • it is necessary for the creation, execution or termination of legal transactions with our company (e.g. when transmitting data to a payment service provider/a shipping company to process a contract with you) (Art. 6(1) Sentence 1(b) GDPR), or
  • a subcontractor or party we use to perform our obligations, which we use exclusively within the framework of providing the offers or services requested by you, needs this data (unless you are expressly informed otherwise, such auxiliary parties are only entitled to process the data insofar as this is necessary for the provision of the offer or service), or
  • there is an enforceable official order (Art. 6(1) Sentence 1(c) GDPR) or
  • there is an enforceable court order (Art. 6(1) Sentence 1(c) GDPR) or
  • we are legally obliged to do so (Art. 6(1) Sentence 1(c) GDPR) or
  • the processing is necessary in order to protect the vital interests of the data subject or another natural person (Art. 6(1) Sentence 1(d) GDPR) or
  • we are authorised or even obliged to pursue overriding legitimate interests (Art. 6(1) Sentence 1(f) GDPR).

Your personal data will not be transmitted to other persons, companies or bodies unless you have effectively consented to such transmission. The legal basis of the processing is then Art. 6(1) Sentence 1(a) GDPR.

Processing and transmission of personal data in the online ordering system

If you wish to submit an order or booking in our online shop, it is necessary for the initiation and conclusion of the contract that you provide personal data such as your name, your address and your email address. The mandatory data required for order and contract processing is marked as such; further information is provided voluntarily. We process your data for order processing; in particular, we will forward payment data to your chosen payment service provider or our main bank. When you make your booking or a booking request, the booking information is also transferred to external operators of internet booking engines (e.g. TourOnline AG, Borsigstraße 26, 73249, Wernau; “DIRS 21”) for purposes of contract performance or preparation. The legal basis for the processing is Art. 6(1) Sentence 1(b) GDPR. To prevent unauthorised third parties from accessing your personal data, the order process on the website is encrypted using SSL/TLS technology.

You can voluntarily create a customer account in which we store your data for future visits to the website. When you create a customer account, the data you enter is processed. Once you have successfully logged in, you are free to edit or delete all other data, including your customer account.

As soon as storage is no longer necessary, we delete the data generated in this context or, if statutory retention obligations apply, restrict processing of the data. Due to mandatory commercial and tax regulations, we are obliged to keep your address, payment and order data for a period of ten years. After two years after termination of the contract, we will restrict the processing and reduce the processing to compliance with our existing legal obligations.

Registration/password-protected area on the website

If you wish to use the password-protected area of our website, you must register by providing the following information:

  • email address
  • name
  • username
  • password chosen by you

You do not have to enter a real name and are free to use the website pseudonymously.

Furthermore, the following data is processed at the time of registration:

  • IP address
  • date/time of registration

The data will be deleted as soon as it is no longer required for achieving the purpose of its processing. This is the case for the data collected during the registration process if the registration on the website is cancelled or modified.

The following functions are available to you in the password-protected area:

  • Edit your profile data,
  • view past orders/bookings,
  • manage, change or cancel your newsletter subscription.

If you use the password-protected area of the website, e.g. to edit your profile data or to view orders and bookings made, we also process the data about your person required for the initiation or fulfilment of the contract, in particular address data and information about the payment method. The legal basis for the processing is Art. 6(1) Sentence 1(b) GDPR. The data will be deleted as soon as it is no longer required for achieving the purpose of its processing or as soon as there are no legitimate interests preventing its erasure. Due to mandatory commercial and tax regulations, we are obliged to keep your address, payment and order data for a period of ten years. After two years after termination of the contract, we will restrict the processing and reduce the processing to compliance with our existing legal obligations.

If you provided further data voluntarily (e.g. about interests, preferences, wish list), we process your data which is not necessary for the initiation or fulfilment of a contract, for as long as you use the password-protected area and if you do not delete it yourself beforehand. Our aim in this respect is to optimise the use of the website for you as a user. The legal basis for this is Art. 6(1) Sentence 1(f) GDPR.

You can object to the processing of the information provided by you voluntarily. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR).

You can manage, change or delete your voluntary information yourself at any time in the password-protected area. You are free to take measures in accordance with the ‘Your rights’ section, although if you do have any complaints we request that you first contact our company.

Processing of personal data under Section 30 of the Federal Act on Registration (BMG)

Under Section 30 of the German Federal Act on Registration (BMG), commercial accommodation, such as hotels in particular, are obliged to collect the following data from guests on the day of their arrival and to have the registration form signed by hand:

  • date of arrival and planned departure,
  • surname,
  • given names,
  • date of birth,
  • nationalities,
  • address,
  • number of persons travelling together and their nationalities, in the cases of Section 29(2), second and third sentences, and,
  • in the case of foreigners, serial number of the recognised and valid passport or passport substitute.
  • If applicable, further data for collecting tourist and resort taxes.

We are obliged to collect, process and pass on this data under the BMG, and the legal basis of this processing results from Art. 6(1) Sentence 1(c) GDPR.

We erase this data or restrict its processing as soon as this is permitted under the provisions of the BMG and if you have not given your consent (Art. 6(1) Sentence 1(a) GDPR) and there is no other legitimate interest on our part in continued processing.

Email marketing

Advertising to existing customers

We reserve the right to process the email address provided by you when booking in accordance with the statutory provisions in order to send you the following content by email whilst or after processing the contract, unless you have already objected to this processing of your email address:

  • other interesting offers from our portfolio,
  • information about company events,
  • technical information,
  • sending our catalogue,
  • questions about special requirements,
  • overview of possible leisure offers,
  • information on finding us by public transport.

The legal basis of the processing is Art. 6(1) Sentence 1(f) GDPR. We perform this processing for customer care and to enhance our services. We delete your data when you cancel your newsletter subscription, but no later than two years after termination of the contract.

We would like to point out that you can object to receiving direct advertising at any time without incurring any costs other than the transmission costs according to the basic rates. Here you have a general right of objection without giving reasons (Art. 21(2) GDPR). To do this, click on the unsubscribe link in the newsletter or send us your objection to the contact data provided under ‘Responsible provider’.

Newsletter

You have the possibility to subscribe on the website to our email newsletter or website push notifications, which we use to inform you regularly about the following content:

  • offers from our portfolio,
  • information about company events,
  • third-party offers (including events), provided you have consented to this,
  • new articles/collections,
  • special/time-limited offers.

In order to receive the newsletter, you need to give us the following personal data:

  • recipient (name or pseudonym)
  • valid email address

To subscribe to our email newsletter, please use the double opt-in process. Once you have entered the data marked as mandatory, we will send you an email to the email address you have provided, in which we ask you to expressly confirm your subscription to the newsletter (by clicking on a confirmation link). This is how we ensure that you really want to receive our email newsletter. If no confirmation takes place within 24 hours, we block the information transferred to us and delete it automatically after one month at the latest.

If you wish to register for website push notifications, you first need to agree to receive push notifications from the website in your web browser and confirm your registration.

Furthermore, the following data is processed at the time of subscription:

  • IP address,
  • date/time of registration for the newsletter,
  • time when you click on the confirmation link.

We process your IP address, the time of registration for the newsletter and for receiving website push notifications as well as the time of your confirmation in order to document your newsletter registration and to prevent abuse of your personal data. The legal basis of the processing is Art. 6(1) Sentence 1(f) GDPR. We process this data until two years after termination of the contract. If registration for the newsletter takes place and it is unrelated to the conclusion of a contract, we process this data until two years after termination of the usage. We delete this data when the newsletter subscription ends.

After your confirmation, we will process the email address and name/pseudonym of the recipient concerned for the purpose of sending our email newsletter and the website push notifications. The legal basis of the processing is Art. 6(1) Sentence 1(a) GDPR. We delete this data when you unsubscribe from the newsletter.

You can withdraw your consent to the processing of your email address for receiving the newsletter at any time, either by sending us a message (see the contact details under ‘Responsible provider’) or by clicking directly on the unsubscribe link in the newsletter. This does not affect the lawfulness of processing that has occurred based on the consent up until the point of your withdrawal (Art. 13(2)(c) GDPR).

We would like to point out that we analyse your user behaviour in relation to the sending of our newsletter. For this analysis, the emails sent out contain so-called web beacons or tracking pixels, which display single-pixel image files that are embedded in our website. For analysis purposes, we link the data mentioned under ‘Access data’ and the web beacons with your email address and an individual ID. Links received in the newsletter also contain this ID.

We use the data collected in this way to create a user profile in order to tailor the newsletter to your individual interests. Here we record when you read our newsletters, which links you click on in them and draw conclusions about your personal interests. We link this data to actions you perform on our website. The information is processed for as long as you have subscribed to the newsletter. Once you unsubscribe, we process the data for purely statistical purposes and anonymously.

Our intention here is to analyse the use of and to optimise the email advertising we send you. The legal basis of the processing is Art. 6(1) Sentence 1(f) GDPR.

You can object to this tracking at any time by clicking on the separate unsubscribe link provided in each newsletter or by informing us using the contact details provided under ‘Responsible provider’.

Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR).

You can also prevent tracking by disabling the display of images in your email client by default. This will mean that the newsletter will not be displayed completely and you may not be able to use all functions. If you choose to display the images manually, the above tracking will take place.

CleverReach email marketing service

We use CleverReach to send newsletters. It is provided by CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede. CleverReach is a service which allows the organisation and analysis of newsletter mailing. The data you enter to subscribe to the newsletter (e.g. email address) will be stored on CleverReach’s servers in Germany and/or Ireland.

The newsletters we send out with CleverReach enable us to analyse the behaviour of newsletter recipients. Among other things, it is possible to analyse how many recipients have opened the newsletter message and how often each link was clicked on in the newsletter. With the help of what’s known as conversion tracking, it can also be analysed whether a pre-defined action (e.g. purchase of a product on our website) took place after the newsletter link was clicked on. For more information about data analysis by CleverReach newsletters, please refer to: https://www.cleverreach.com/en/features/reporting-tracking/.

The analysis of the information mentioned serves to recognise the reading habits of the recipients so as to better adapt and distribute our newsletter content accordingly. The legal basis of the processing is Art. 6(1) Sentence 1(f) GDPR. We process this data until two years after termination of the contract. If registration for the newsletter takes place and it is unrelated to the conclusion of a contract, we process this data until two years after termination of the usage. We delete this data when the newsletter subscription ends. We have no knowledge of how long CleverReach stores data and have no way of influencing this. For more details, please refer to the CleverReach privacy policy at: https://www.cleverreach.com/en/privacy-policy/.

You can object to the processing in the future at any time by clicking on the unsubscribe link at the end of the newsletter. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR).

This will simultaneously end the processing of data for you being sent the newsletter and for statistical analysis. It is not possible to object to the distribution via CleverReach or the statistical evaluation separately.

Alternatively, you can object at http://www.aboutads.info/choices/ and http://www.youronlinechoices.com/ (for the European Union area).

Newsletter2go email marketing service

We use Newsletter2go to send newsletters. It is provided by Newsletter2go GmbH, Köpenicker Straße 126, 10179 Berlin. Newsletter2go is a service which allows the organisation and analysis of newsletter mailing. The data you enter to subscribe to the newsletter (e.g. email address) will be stored on Newsletter2go’s servers in Germany.

The newsletters we send out with Newsletter2go enable us to analyse the behaviour of newsletter recipients. Among other things, it is possible to analyse how many recipients have opened the newsletter message and how often each link was clicked on in the newsletter. With the help of what’s known as conversion tracking, it can also be analysed whether a pre-defined action (e.g. purchase of a product on our website) took place after the newsletter link was clicked on.

The analysis of the information mentioned serves to recognise the reading habits of the recipients so as to better adapt and distribute our newsletter content accordingly. The legal basis of the processing is Art. 6(1) Sentence 1(f) GDPR. We process this data until two years after termination of the contract. If registration for the newsletter takes place and it is unrelated to the conclusion of a contract, we process this data until two years after termination of the usage. We delete this data when the newsletter subscription ends. We have no knowledge of how long Newsletter2go stores data and have no way of influencing this. For more details, please refer to the Newsletter2go privacy policy at: https://www.newsletter2go.co.uk/data-protection/.

You can object to the processing in the future at any time by clicking on the unsubscribe link at the end of the newsletter. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). This will simultaneously end the processing of data for you being sent the newsletter and for statistical analysis. It is not possible to object to the distribution via Newsletter2go or the statistical evaluation separately.

Alternatively, you can object at http://www.aboutads.info/choices/ and http://www.youronlinechoices.com/ (for the European Union area).

OneSignal notification service

To send push notifications via your web browser, we use the marketing service OneSignal, provided by OneSignal, Inc., 2194 Esperanca Avenue, Santa Clara, CA 95054, web: https://onesignal.com, hereinafter referred to as “OneSignal”. OneSignal is a service which allows the organisation and analysis of push notifications. Your data will also be processed on OneSignal’s servers in India. We have concluded ‘standard contractual clauses’ with PushCrew in order to obligate OneSignal to maintain an appropriate level of data protection.

The newsletters we send with OneSignal allow us to analyse behaviour in the context of push notifications. For example, it is possible to analyse how many recipients have opened them and how often which link was clicked on in the newsletter. With the help of what’s known as conversion tracking, it can also be analysed whether a pre-defined action (e.g. purchase of a product on our website) took place after the newsletter link was clicked on.

The analysis of the information mentioned serves to recognise the reading habits of the recipients so as to better adapt and distribute our newsletter content accordingly. The legal basis of the processing is Art. 6(1) Sentence 1(f) GDPR. We process this data until two years after termination of the contract. If registration for the push notifications takes place and it is unrelated to the conclusion of a contract, we process this data until two years after termination of the usage. We delete this data when the newsletter subscription ends. We have no knowledge of how long OneSignal stores data and have no way of influencing this. For further information about the protection of your data and your privacy, please refer to https://onesignal.com/privacy_policy/.

You can object to the processing of data for OneSignal at any time by activating the unsubscribe link at the end of emails sent by OneSignal or by informing us using the contact details provided under ‘Responsible provider’. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). This will simultaneously end the processing of data for you being sent the newsletter and for statistical analysis. It is not possible to object to the distribution via OneSignal or the statistical evaluation separately.

Payment service providers (PSPs)

Transmission of personal data for credit card payments

In principle, your personal data is only passed on to the extent necessary for the execution of the contract. Specifically for payment processing, we transmit the payment data required for this to the bank commissioned with the payment or, if applicable, to the payment and invoicing service provider commissioned by us.

The processing is performed on the basis of Art. 6(1) Sentence 1(b) GDPR (processing for the performance of a contract). The data required for payment processing is transmitted securely using SSL encryption and processed exclusively for payment processing. As soon as storage is no longer necessary, we delete the data generated in this context or, if statutory retention obligations apply, restrict processing of the data.

Transmission of personal data for purposes of enforcing rights/ascertaining an address/debt collection

In the event of non-payment, we reserve the right to pass on the data provided at the time of booking to a lawyer and/or to external companies (e.g. Verband der Vereine Creditreform e.V., Hellersbergstraße 12, 41460 Neuss, Germany) if we have a legitimate interest pursuant to Art. 6(1) Sentence 1(f) GDPR in order to ascertain an address and/or enforce our rights.

In addition, we may pass on your information if this is necessary to protect our rights, as well as the rights of our affiliates, our cooperation partners, our employees and/or users of our website. Under no circumstances will we sell or rent your data to third parties. Such a transmission of your data would be based on Art. 6(1) Sentence 1(f) GDPR.

As soon as storage is no longer necessary, we delete the data generated in this context or, if statutory retention obligations apply, restrict processing of the data.

You have the possibility to object to the processing of your data at any time. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). In particular, you have a right of objection if processing is not necessary to fulfil a contract with you, which is described by us in the previous description of the functions. In the event that your objection is justified, we will examine the situation and either stop or adjust the data processing or point out to you the compelling legitimate reasons on the basis of which we will continue processing.

Hosting

We use external hosting services for the provision of the following services: infrastructure and platform services, computing capacity, storage resources and database services, security and technical maintenance services. This involves processing all data necessary for the operation and use of our website.

We use external hosting services to run this website. By using external hosting services, we aim to make the provision of our website efficient and secure. The legal basis of the processing is Art. 6(1) Sentence 1(f) GDPR.

The recording of data for the provision and use of the website and the processing of data using external web hosting services is an absolute necessity for the operation of the website. You may object to the processing. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). In the event that your objection is justified, we will examine the situation and either stop or adjust the data processing or point out to you the compelling legitimate reasons on the basis of which we will continue processing.

 

Integration of third-party content

The website integrates third-party content such as videos, maps, RSS feeds and graphics from other websites. This integration always requires that the providers of this content (“third-party providers”) perceive the IP addresses of users. This is because without the IP address they would not be able to send the content to the browser of the respective user. As such, the IP address is required to display this content.

We endeavour to only use content from third-party providers who process the IP address solely for delivering the content. We do however have no influence over whether the third-party providers process the IP addresses, e.g. for statistical purposes. If we are aware of such activity, we inform you of this in the following.

Some of the third parties may process data outside the European Union.

You can object by installing a JavaScript blocker such as the browser plug-in NoScript (www.noscript.net) or disabling JavaScript in your browser. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). This may however result in functional restrictions on the website.

Bookmarks

Bookmarks, e.g. to social networks such as Facebook.com, Twitter.com, Google+, allow you as a user of certain social networks to create links from our website on your social network profiles in order to bookmark them or share them with your social network contacts.

Bookmarks on our website can be recognised by the corresponding icons (e.g. “f”, “g+”) at the bottom of the page. When you open a page of our website, the bookmarks may place cookies on your device/in your browser, which are small text files with a sequence of numbers that make it possible to recognise the browser. If you are simultaneously logged in to one of the relevant social networks, this allows the operator of that social network to track which pages you visit, unless you have disabled the acceptance and storage of cookies in your browser settings. When you use bookmarks, information is sent to the respective social network.

We neither check nor can we be held responsible for comments or activities of persons who use bookmarks for this purpose. Persons who share our content via bookmarks are not entitled to speak for us and our website or to give such an impression vis-à-vis third parties.

The legal basis for the use of the bookmarks is Art. 6(1) Sentence 1(f) GDPR. We have no knowledge of how the operators of social networks further process data or how long they store it, and nor do we have any way of influencing this.

You have the right to object to the creation of these user profiles, although you must contact the respective plug-in provider to exercise this right. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR).

There are also various ways in which you can prevent the creation of user profiles and thus make use of your right to object:

  • by setting your browser software accordingly; in particular, disabling third-party cookies means that you will not receive any ads from third-party providers;
  • by disabling interest-based ads from providers who are part of the “About Ads” self-regulation initiative via the link http://www.aboutads.info/choices; please note that this setting will be erased if you erase your cookies.

Google Fonts

We use web fonts provided by Google for the uniform display of fonts. When you retrieve a page, your browser loads the required web fonts into your browser cache in order to display texts and fonts correctly.

For this purpose, the browser you are using must connect to Google’s servers. By doing so, Google becomes aware that our website has been accessed via your IP address. Our use of Google Fonts is in the interest of a uniform and visually appealing presentation of our online offers. This constitutes a legitimate interest within the meaning of Art. 6(1) Sentence 1(f) GDPR. We have no knowledge of how long Google stores data and have no way of influencing this.

You can object to the processing by changing your browser settings in such a way that the browser does not support web fonts – although then your device will use a default font. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR).

For more information about Google Fonts, please refer to https://developers.google.com/fonts/faq and Google’s privacy policy: https://www.google.com/policies/privacy/.

Google Tag Manager

We use Google Tag Manager on our website. Google Tag Manager is a solution that allows marketers to manage website tags through a single interface. The Tag Manager tool itself (which implements the tags) is a cookieless domain and does not record any personal data. The tool triggers other tags, which in turn may record data. Google Tag Manager does not access this data. If deactivation has occurred at the domain or cookie level, it will remain effective for all tracking tags implemented with Google Tag Manager.

YouTube videos

Our website uses plug-ins from the video platform YouTube.de/YouTube.com, a service whose provider – represented by Google – is YouTube LLC (headquartered at 901 Cherry Avenue, San Bruno, CA 94066, USA; “YouTube”). The plug-ins allow us to embed visual content (“videos”) on this website that we have published on Youtube.de/Youtube.com.

The videos are all embedded in ‘extended privacy mode’, which means that no data about you as a user will be transferred to YouTube if you do not play the videos. Only when you play the videos is the following data transferred. We have no influence on this data transfer.

By visiting the website, YouTube receives the information that you have retrieved the corresponding subpage of our website. In addition, the data mentioned under ‘Access data’ is submitted. This occurs regardless of whether YouTube provides a user account that you are logged in with or whether no user account exists. If you are logged in to Google, your data will be directly associated with your account. If you do not wish for this data to be associated with your YouTube profile, you must log out before activating the button.

YouTube stores your data as usage profiles and processes it for purposes of advertising, market research and/or the demand-oriented design of its website. Such analysis takes place in particular (even for users who are not logged in) to provide demand-oriented advertising and to inform other users of the social network about your activities on our website.

The legal basis of the processing is Art. 6(1) Sentence 1(f) GDPR. The processing serves to make our website more attractive and to offer you additional services. We have no knowledge of how long YouTube stores data and have no way of influencing this.

You have the right to object to the processing, although you must contact YouTube to exercise this right. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). You can disable or restrict the transfer of cookies by changing the settings in your internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are disabled for our website, it may no longer be possible to use the full functionality of the website.

For more information about the purpose and scope of processing by YouTube, please refer to its privacy policy at https://www.google.de/intl/en/policies/privacy.

Integration of Vimeo

We use plug-ins from Vimeo to integrate videos on our website. Vimeo is operated by Vimeo LLC, 555 West 18th Street, New York, New York 10011, USA. The plug-ins allow us to embed visual content (“videos”) on this website which we have published on www.vimeo.com.

If you visit one of our web pages with the Vimeo plug-in, this establishes a connection to the Vimeo servers. In this way, the Vimeo server is notified of which web page you have visited. If you are simultaneously logged in as a member of Vimeo, Vimeo will associate this information with your personal user account. When using the plug-in, e.g. playing a video by pressing the play button, this information is also assigned to your user account. Vimeo stores your data as usage profiles and processes it for purposes of advertising, market research and/or the demand-oriented design of its website. Such analysis takes place in particular (even for users who are not logged in) to provide demand-oriented advertising and to inform other users of the social network about your activities on our website.

The legal basis of the processing is Art. 6(1) Sentence 1(f) GDPR. The processing serves to make our website more attractive and to offer you additional services. We have no knowledge of how long Vimeo stores data and have no way of influencing this. We have concluded ‘standard contractual clauses’ with Vimeo in order to obligate Vimeo to maintain an appropriate level of data protection.

You have the right to object to the processing, although you must contact Vimeo to exercise this right. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). You can disable or restrict the transfer of cookies by changing the settings in your internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are disabled for our website, it may no longer be possible to use the full functionality of the website.

For further details about this data processing and information about data protection at Vimeo, please refer to: https://vimeo.com/privacy.

Integration of Google Maps

Google Maps

This website also uses the Google Maps service from Google to display maps or sections of maps, thus enabling you to conveniently use the map function on the website.

By visiting the website, Google receives the information that you have retrieved the corresponding subpage of our website. In addition, the data mentioned under ‘Access data’ is transferred to Google. This occurs regardless of whether Google provides a user account that you are logged in with or whether no user account exists. If you are logged in to Google, your data will be directly associated with your account. If you do not wish for this data to be associated with your Google profile, you must log out before activating the button.

Google stores your data as usage profiles and processes it for purposes of advertising, market research and/or the demand-oriented design of its website. Such analysis takes place in particular (even for users who are not logged in) to provide demand-oriented advertising and to inform other users of the social network about your activities on our website.

The legal basis of the processing is Art. 6(1) Sentence 1(f) GDPR. The processing serves to make our website more attractive and to offer you additional services. We have no knowledge of how long Google stores data and have no way of influencing this.

For more information about the purpose and scope of processing by the plug-in provider, please refer to the provider’s privacy policy. There you will also find further information about your rights in this regard and settings options to protect your privacy: http://www.google.de/intl/en/policies/privacy. Google also processes your personal data in the USA and has subjected itself to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. For more information about the Google Maps terms of use, please refer tohttps://www.google.com/intl/de_de/help/terms_maps.html.

You have the right to object to the processing, although you must contact Google to exercise this right. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). You can disable or restrict the transfer of cookies by changing the settings in your internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are disabled for our website, it may no longer be possible to use the full functionality of the website.

Services for statistical, analysis and marketing purposes

We use services from third parties for statistical, analysis and marketing purposes. This enables us to offer you a user-friendly, optimised experience when visiting the website. The third-party providers use cookies to control their services (see ‘Cookies’ above). Unless otherwise explained below, this does not involve the processing of personal data.

Some of the third-party providers offer users the option of directly objecting to the use of the respective feature, e.g. by placing an opt-out cookie.

If you activate such an opt-out cookie, the third-party provider will no longer process data about your usage behaviour in the future. It is also possible to merely object individually to a partial selection of external services. If you change the browser or device used or delete all cookies, you will be required to set the opt-out cookie again.

Furthermore, you can also object directly to the use of cookies via the opt-out platform of the organisation Bundesverband Digitale Wirtschaft e.V. (BVDW) at http://www.meine-cookies.org/cookies_verwalten/praeferenzmanager.html or via the deactivation page of the Network Advertising Initiative at http://www.networkadvertising.org/choices/. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). As regards objecting to data processing for direct marketing purposes, you have a general right of objection without giving reasons (Art. 21(2) GDPR). More information about usage-based advertising and opt-out options can also be viewed via the following link: http://www.youronlinechoices.com/de/.

In the following, we inform you about the services from external providers currently in use on our website, about the purpose and scope of the respective processing in each case, and about how you can object.

Google Analytics

In order to tailor our website perfectly to your interests, we use Google Analytics, a web analytics service from Google. Google Analytics uses ‘cookies’ (see ‘Cookies’ above), which are stored on your device to enable the analysis of how you use the website. The information generated in this way about your use of this website is transferred to and stored by Google on a server in the USA.

However, if IP anonymisation is activated on this website, then within European Union Member States or in other member states of the European Economic Area Google will shorten your IP address before transferring it. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. On our behalf, Google will use this information for the purpose of evaluating your use of this website, compiling reports for us on website activity, and providing us with other services relating to website usage and internet usage.

Google will not associate your browser’s IP address transmitted for Google Analytics purposes with any other data held by Google.

This website uses Google Analytics with the “_anonymizeIp()” extension. As a result, IP addresses are further processed in abbreviated form, meaning that any association with individual persons can be ruled out. As far as the data collected about you relates to you personally, that relation is therefore excluded immediately and the personal data thus erased without delay.

We use Google Analytics to analyse and regularly improve the use of our website. The statistics help us to improve our website and make it more interesting for you as a user. For the exceptional cases in which personal data is transferred to the USA, Google has subjected itself to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The legal basis of the processing by Google Analytics is Art. 6(1) Sentence 1(f) GDPR. The Analytics cookies are deleted after 14 months at the latest.

You have the right to object. You can prevent the storage of cookies using the corresponding settings in your browser software; however, we would like to point out that if you do this you may not be able to use the full functionality of this website. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). As regards objecting to data processing for direct marketing purposes, you have a general right of objection without giving reasons (Art. 21(2) GDPR). Furthermore, you can prevent the recording of data generated by the cookie about your use of the website (including your IP address) and its processing by Google by downloading and installing the browser plug-in available via the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

For more information about the third-party provider Google, please refer to:

http://www.google.com/analytics/terms/de.html, http://www.google.com/intl/de/analytics/learn/privacy.html, http://www.google.de/intl/en/policies/privacy.

 

Mouseflow

This website uses Mouseflow, a web analytics tool provided by Mouseflow ApS (Flaesketorvet 68, 1711 Copenhagen V, Denmark; email: hallo@mouseflow.com, data protection information at: https://mouseflow.com/privacy/, hereinafter referred to as “Mouseflow”).

This tool records movements on the websites monitored in so-called heatmaps. All data is collected without us being able to assign it to specific users. All we can see is how a user’s mouse moves, where the user clicked and how far the user scrolled. This allows us to make our website better and more customer-friendly. The tool also records the screen size of the device, the device type, information about the browser, the country from which the site was accessed and the preferred language. If personal data is displayed on a website, it is automatically hidden by Mouseflow. We therefore have no access to such personal data.

Mouseflow uses ‘cookies’ (see ‘Cookies’ above) to analyse usage behaviour; these are stored on your device to enable the analysis of how you use the website. The information generated by the tracking code and cookie about your visit to our website is transmitted to the Mouseflow servers and stored there. The tracking code collects information about your device, such as your IP address, device type and browser information, geographical location (country only), and your preferred language for the display of our website, pages visited, and the date and time when the website was visited. Mouseflow shortens your IP address before it is processed further. As far as the data collected about you relates to you personally, that relation is therefore excluded immediately and the personal data thus erased without delay.

This makes it possible to record selected individual visits. This results in a log of mouse movements, mouse clicks and keyboard interactions, with the intention of randomly mapping individual visits to this website as so-called session replays and evaluating them in the form of what Mouseflow calls heatmaps. By conducting these evaluations, we pursue our interest in improving the website and making it more attractive for our customers. The legal basis of the processing of your data is Art. 6(1) Sentence 1(f) GDPR. In this case, we do not store any personal data and do not pass it on to third parties. We have no knowledge of how long Mouseflow stores data and have no way of influencing this.

You have the right to object to the processing. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). As regards objecting to data processing for direct marketing purposes, you have a general right of objection without giving reasons (Art. 21(2) GDPR). If you do not want your data to be processed by Mouseflow, you can object here: https://mouseflow.com/opt-out/. Alternatively, you can adjust your browser software accordingly; in particular, disabling third-party cookies means that you will not receive any ads from third-party providers.

Usage-based online advertising

Facebook Custom Audiences

The website also uses the Website Custom Audiences function by means of the so-called Facebook Pixel, provided by Facebook, Inc. (the provider is Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland, email: impressum-support@support.facebook.com, data protection information at: https://www.facebook.com/privacy/explanation; hereinafter referred to as: “Facebook”).

This allows users of the website to see interest-based advertisements (“Facebook Ads”) when visiting the social network Facebook or other websites that also use the process. Here we are pursuing the interest of showing you ads that are of interest to you in order to make our website more interesting for you.

Due to the marketing tools used, your browser automatically establishes a direct connection to the Facebook server. We have no influence on the extent and further processing of the data collected by Facebook through the use of this tool and therefore inform you according to what we know: By integrating Facebook Custom Audiences, Facebook receives the information that you have retrieved the corresponding page on our website, or that you have clicked on one of our ads. If you are registered with a Facebook service, Facebook can associate the visit with your account. Even if you are not registered with Facebook or have not logged in, it is possible that the provider will obtain and store your IP address and other identifying information.

The legal basis of the processing of your data is Art. 6(1) Sentence 1(f) GDPR. In this case, we do not store any personal data about you. We have no knowledge of how long Facebook stores data and have no way of influencing this.

Logged-in users can disable the Facebook Custom Audiences function at https://www.facebook.com/settings/?tab=ads# in order to exercise their right to object. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). As regards objecting to data processing for direct marketing purposes, you have a general right of objection without giving reasons (Art. 21(2) GDPR).

There are various ways in which you can block the Facebook Custom Audiences function and thus make use of your right to object:

  • by setting your browser software accordingly; in particular, disabling third-party cookies means that you will not receive any ads from third-party providers;
  • by disabling interest-based ads from providers who are part of the “About Ads” self-regulation initiative via the link http://www.aboutads.info/choices; please note that this setting will be erased if you erase your cookies.

For more information about processing by Facebook, please refer to: https://www.facebook.com/about/privacy.

Facebook Analytics

To use Facebook Analytics we also use the so-called tracking pixel, provided by Facebook, Inc. (the provider is Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland, email: impressum-support@support.facebook.com, data protection information at: https://www.facebook.com/privacy/explanation; hereinafter referred to as: “Facebook”) to track your user behaviour. The information obtained by the tracking pixel cookie serves us solely for statistical purposes, is transmitted to us anonymously by Facebook and does not provide any information about the person of the user. Facebook will, however, connect the information to your Facebook account, store and use it for its own promotional purposes in accordance with Facebook’s Privacy Policy, and may also transfer your data to Facebook’s partners. Even if you are not registered with Facebook or have not logged in, it is possible that the provider will obtain and store your IP address and other identifying information.

The processing of your data in this regard is in accordance with Art. 6(1)(f) GDPR. By using Facebook Analytics, we are pursuing the interest of being able to better evaluate our website and improve our range of services. In this case, we do not store any personal data about you. We have no knowledge of how long Facebook stores data and have no way of influencing this.

Logged-in users can disable the Facebook Analytics function at https://www.facebook.com/settings/?tab=ads# in order to exercise their right to object. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). As regards objecting to data processing for direct marketing purposes, you have a general right of objection without giving reasons (Art. 21(2) GDPR).

There are various ways in which you can block the Facebook Analytics function and thus make use of your right to object:

  • by setting your browser software accordingly; in particular, disabling third-party cookies means that you will not receive any ads from third-party providers;
  • by disabling interest-based ads from providers who are part of the “About Ads” self-regulation initiative via the link http://www.aboutads.info/choices; please note that this setting will be erased if you erase your cookies.

For further information about Facebook’s data protection provisions, please refer to the relevant privacy policy at https://de-de.facebook.com/about/privacy/.

Google AdWords Conversion

We use the services of Google AdWords from Google to draw attention to our attractive offers with the help of advertising media (so-called Google AdWords) on external websites. In relation to the data of the advertising campaigns, we can determine how successful the individual advertising measures are. Here we are pursuing the interest of showing you ads that are of interest to you in order to make our website more interesting for you and to achieve a fair calculation of advertising costs.

These advertising media are delivered by Google via so-called ad servers. For this purpose, we use ad server cookies, which can be used to measure certain parameters for measuring success, such as the display of ads or clicks by users. If you reach our website via a Google ad, Google AdWords stores a cookie on your device. These cookies usually expire after 30 days and are not intended to identify you personally. Analysis values usually stored for this cookie are the unique cookie ID, the number of ad impressions per placement (frequency), the last impression (relevant for post-view conversions) and opt-out information (marker showing that the user no longer wishes to be targeted).

These cookies allow Google to recognise your internet browser. If a user visits certain pages of an AdWords customer’s website and the cookie stored on their device has not yet expired, Google and the customer can recognise that the user has clicked on the ad and has been redirected to this site. Each AdWords customer is assigned a different cookie. Cookies cannot therefore be tracked via the websites of AdWords customers. We do not process any personal data ourselves in the aforementioned advertising measures. We only receive statistical analyses from Google. On the basis of these analyses, we can recognise which of the advertising measures used are particularly effective. We do not receive any further data from the use of advertising media; in particular, we cannot identify users on the basis of this information.

Due to the marketing tools used, your browser automatically establishes a direct connection to the Google server. We have no influence on the extent and further processing of the data collected by Google through the use of this tool and therefore inform you according to what we know: By integrating AdWords Conversion, Google receives the information that you have retrieved the corresponding part of our website, or that you have clicked on one of our ads. If you are registered with a Google service, Google can associate the visit with your account. Even if you are not registered with Google or have not logged in, it is possible that the provider will obtain and store your IP address. Google processes the data in the USA and has subjected itself to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

The legal basis of the processing of your data is Art. 6(1) Sentence 1(f) GDPR. We have no knowledge of how long Google stores data and have no way of influencing this.

You have the right to object to the processing of your data. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). As regards objecting to data processing for direct marketing purposes, you have a general right of objection without giving reasons (Art. 21(2) GDPR).

There are various ways in which you can prevent your participation in this tracking procedure:

  • by setting your browser software accordingly; in particular, disabling third-party cookies means that you will not receive any ads from third-party providers;
  • by disabling cookies for conversion tracking, by setting your browser in such a way that it blocks cookies from the domain www.googleadservices.com, https://www.google.de/settings/ads; please note that this setting will be erased if you erase your cookies;
  • by disabling interest-based ads from providers who are part of the “About Ads” self-regulation initiative via the link http://www.aboutads.info/choices; please note that this setting will be erased if you erase your cookies;
  • by permanent deactivation in your browser Firefox, Internet Explorer or Google Chrome via the link http://www.google.com/settings/ads/plugin. We would like to point out that if you do so you may not be able to use the full functionality of this service.

For further information about privacy at Google, please refer to: http://www.google.com/intl/en/policies/privacy and https://services.google.com/sitestats/de.html. Alternatively, you can visit the website of the Network Advertising Initiative (NAI) at http://www.networkadvertising.org.

Google DoubleClick

Furthermore, our website uses Google’s online marketing tool DoubleClick. DoubleClick uses cookies to display relevant ads to users, improve campaign performance reports, and to prevent a user from seeing the same ads more than once. Google uses a cookie ID – a pseudonymous identification number assigned to your browser – to track which ads are displayed in which browser and can thus prevent them from being displayed more than once. This pseudonym is assigned information about user activities on the website. This allows Google and its partner sites to display ads based on previous visits to websites. In addition, DoubleClick can use the cookie ID to record conversions related to ad requests. This happens for example when a user sees a DoubleClick ad and later visits the advertiser’s website with the same browser and buys something there.

The information generated by DoubleClick cookies is transferred to and stored by Google on servers in the USA. Google complies with the data protection provisions of the EU-US Privacy Shield agreement and is certified for the Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The data will only be transferred to third parties within the scope of legal regulations or order processing. According to Google, DoubleClick cookies do not contain any personal information.

Due to the marketing tools used, your browser automatically establishes a direct connection to the Google server. We have no influence on the extent and further processing of the data collected by Google through the use of this tool and therefore inform you according to what we know: By integrating DoubleClick, Google receives the information that you have retrieved the corresponding part of our website, or that you have clicked on one of our ads. If you are registered with a Google service, Google can associate the visit with your account. Even if you are not registered with Google or have not logged in, it is possible that the provider will obtain and store your IP address.

The legal basis of the processing is Art. 6(1) Sentence 1(f) GDPR. The DoubleClick cookies are deleted after six months at the latest. By using DoubleClick, we are pursuing the interest of showing you ads that may be of interest to you in order to make our website more interesting for you.

You have the right to object. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). As regards objecting to data processing for direct marketing purposes, you have a general right of objection without giving reasons (Art. 21(2) GDPR). There are various ways in which you can prevent your participation in this tracking procedure:

  • by setting your browser software accordingly; in particular, disabling third-party cookies means that you will not receive any ads from third-party providers;
  • by disabling cookies for conversion tracking, by setting your browser in such a way that it blocks cookies from the domain www.googleadservices.com, https://www.google.de/settings/ads; please note that this setting will be erased if you erase your cookies;
  • by disabling interest-based ads from providers who are part of the “About Ads” self-regulation initiative via the link http://www.aboutads.info/choices; please note that this setting will be erased if you erase your cookies;
  • by permanent deactivation in your browser Firefox, Internet Explorer or Google Chrome via the link http://www.google.com/settings/ads/plugin.

For more information about DoubleClick, please refer to: https://www.google.de/doubleclick, http://support.google.com, https://policies.google.com/privacy?hl=de (about privacy at Google in general).

Google Remarketing

Besides AdWords Conversion, we also use Google’s remarketing feature. This is a process we use in an attempt to contact you again. After visiting our website, this feature allows you to be shown our ads when you continue to use the internet. This is done by means of cookies stored in your browser, which Google uses to record and evaluate your usage behaviour when visiting various websites. This is how Google can determine that you have previously visited our website. According to its own information, Google does not combine the data collected in the context of remarketing with any of your personal data which may be processed by Google. Specifically, according to Google, pseudonymisation is used during remarketing.

The legal basis of the processing is Art. 6(1) Sentence 1(f) GDPR. We have no knowledge of how long Google stores data and have no way of influencing this.

You have the right to object to the processing of your data. There are various ways in which you can prevent your participation in this tracking procedure:

  • by setting your browser software accordingly; in particular, disabling third-party cookies means that you will not receive any ads from third-party providers;
  • by disabling cookies for conversion tracking, by setting your browser in such a way that it blocks cookies from the domain www.googleadservices.com, https://www.google.de/settings/ads; please note that this setting will be erased if you erase your cookies;
  • by disabling interest-based ads from providers who are part of the “About Ads” self-regulation initiative via the link http://www.aboutads.info/choices; please note that this setting will be erased if you erase your cookies;
  • by permanent deactivation in your browser Firefox, Internet Explorer or Google Chrome via the link http://www.google.com/settings/ads/plugin.

Bing Ads

Our website uses the conversion and tracking tool Bing Ads, which is provided by Microsoft Corporation (One Microsoft Way, Redmond, WA 98052-6399, “Microsoft”).

This involves Microsoft storing a cookie on users’ devices to enable an analysis of how our website is used. The prerequisite for this is that the user has reached our website via an ad from Bing Ads. In this way, both we and Microsoft can see that someone has clicked on an ad, has been redirected to our website and has reached a predetermined target page. We only see the total number of users who have clicked on a Bing ad and were then forwarded to the target page (conversions). No IP addresses are stored.

Due to the marketing tools used, your browser automatically establishes a direct connection to the Microsoft server. We have no way of influencing the scope or the further processing of the data caused by the use of Bing Ads. Microsoft has subjected itself to the EU-US Privacy Shield (https://www.privacyshield.gov/EU-US-Framework), thus offering a guarantee that it complies with European data protection law.

The legal basis of the processing of your data is Art. 6(1) Sentence 1(f) GDPR. We have no knowledge of how long Microsoft stores data and have no way of influencing this. For further information about privacy at Microsoft, please refer to: https://privacy.microsoft.com/en-gb/privacystatement.

 

You have the right to object to the processing of your data. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). As regards objecting to data processing for direct marketing purposes, you have a general right of objection without giving reasons (Art. 21(2) GDPR). There are various ways in which you can object to the processing:

  • by setting your browser software accordingly; in particular, disabling third-party cookies means that you will not receive any ads from third-party providers; or
  • by disabling interest-based ads from providers who are part of the “About Ads” self-regulation initiative via the link http://www.aboutads.info/choices; please note that this setting will be erased if you erase your cookies.

Social network plug-ins

Social network plug-ins are integrated into our website. These are provided by the following providers:

The plug-ins can be recognised on our website by the aforementioned lettering or, in some cases, by small stylised symbols.

We offer you the possibility to communicate directly with the provider of the plug-in via the button. Only if you click on the marked field and thereby activate it does the plug-in provider receive the information that you have accessed the corresponding page of our website. In addition, the data mentioned under ‘Access data’ is transmitted.

In the case of Facebook and XING, according to the respective providers’ own information, IP addresses in Germany are anonymised immediately after their collection. By activating the plug-in, personal data about you is therefore transferred to the respective plug-in provider and processed there (in the USA in the case of US providers). Since the plug-in provider collects data via cookies in particular, we recommend that before clicking on the greyed-out box you delete all cookies using your browser’s security settings.

We have no influence on the data collected and processing procedures, and nor are we aware of the full scope of data processing, the purposes of processing, or the storage periods. We also have no information about the erasure of the data collected by the plug-in provider.

The plug-in provider stores the data collected about you as usage profiles and processes this for purposes of advertising, market research and/or the demand-oriented design of its website. Such analysis takes place in particular (including for users who are not logged in) to display demand-oriented advertising and to inform other users of the social network about your activities on our website.

The legal basis of the use of the plug-ins is Art. 6(1) Sentence 1(f) GDPR. Through the plug-ins we offer you the possibility to interact with social networks and other users, so that we can improve our website and make it more interesting for you as a user.

You have the right to object to the creation of these user profiles, although you must contact the respective plug-in provider to exercise this right. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). As regards objecting to data processing for direct marketing purposes, you have a general right of objection without giving reasons (Art. 21(2) GDPR). There are also various ways in which you can prevent the creation of user profiles and thus make use of your right to object:

  • by setting your browser software accordingly; in particular, disabling third-party cookies means that you will not receive any ads from third-party providers;
  • by disabling interest-based ads from providers who are part of the “About Ads” self-regulation initiative via the link http://www.aboutads.info/choices; please note that this setting will be erased if you erase your cookies.

The data is transferred regardless of whether you have an account with the plug-in provider and are logged in there. If you are logged in with the plug-in provider, the data about you collected by us will be directly assigned to your existing account with that plug-in provider. If you click or tap on the activated button and, for example, share a link to the page, the plug-in provider will also store this information in your user account and share it publicly with your contacts.

After using a social network, we recommend that you log out regularly, especially however before activating the button, as in this way you can avoid being assigned to your profile with the respective plug-in provider.

Copyright Ó by Spirit Legal LLP

 

 

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