Privacy Policy

Preamble

With the following data privacy statement, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes and to what extent. The data privacy statement applies to all processing of personal data carried out by us, both as part of the provision of our services and in particular on our websites, mobile, as well as within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).

The terms used are not gender-specific.

Stand: 27.01.2021

Overview of contents

Controller

defko sinter Kft
Köszegi ut 5 – 7, 9400 Sopron
Hungary

Persons authorised to represent the company::
E-mail address: info@defko.eu
Telephone: +36 99 321 098
Legal notice: https://defko.eu/en/legal-notice

Overview of processing

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

Types of data processed

  • Content data (e.g. entries on online forms).
  • Contact data (e.g. e-mail, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. visited websites, content interests, access times).
  • Location data (information about the geographical position of a device or person).

Categories of data subjects

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

Purposes of processing

  • Provision of our online offer and user friendliness.
  • Contact requests and communication.
  • Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures.
  • Provision of contractual services and customer service.
  • Managing and responding to requests.

Important legal bases

In the following, we share 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 provisions of the GDPR, the national data protection regulations in your or our country of residence and domicile may apply. Should more specific legal bases be relevant in individual cases, we will inform you of these in the data privacy statement.

  • Consent (Art. 6(1) p. 1 lit. a. GDPR) – The data subject has given his or her consent to the processing of personal data relating to him or her for a specific purpose or purposes.
  • Contract performance and precontractual enquiries (Art. 6(1) p. 1 lit. b. GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or for the performance of precontractual measures taken at the data subject’s request.
  • Legal obligation (Art. 6 (1) p. 1 lit. c. GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6(1) p. 1 lit. f. GDPR) – Processing is necessary for the purposes of the legitimate interests of the controller or 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.

Security measures

We take suitable technical and organisational measures to ensure appropriate risk protection levels, in accordance with the legal regulations and in consideration of the latest technology, implementation costs and the type, extent, circumstances and purposes of the processing, as well as the probability of occurrence and the extent of the threat to the rights and freedoms of natural persons.

The measures include, in particular, the securing of the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as its access, entry, transmission, securing of availability and separation. In addition, we have implemented procedures that ensure awareness of data subject rights, the erasure of date and responses to threats to the data. In addition, we consider the protection of personal data already during development and the choice of hardware, software and procedures, in line with the principle of data privacy, through the technology used and through settings that benefit data privacy.

SSL encryption (https): In order to protect your data transmitted via our online offer, we use SSL encryption. You can recognise such encrypted connections by the prefix https:// in the address bar of your browser.

Spam protection through CleanTalk: This site uses the CleanTalk plugin from CleanTalk Inc, 711 S Carson street, suite 4, Carson city, NV, 89701 USA to protect against Internet attacks. CleanTalk serves only as a malware scanner, anti-spam filter for IP networks, protection of contact and registration forms. Please note that your IP address will be sent to the cloud for verification. If you do not wish to do so, you will not be able to visit our online sites.

You can follow the link (https://cleantalk.org/help/cleantalk-gdrp-compliance) to see who and what data is stored and processed. Example: When you submit the contact form, this website will store your personal information such as your IP address, your email address, your personal message in the form of text and any other website form fields. For security reasons and to protect this website from spam, your data will be processed in the CleanTalk Cloud Service and stored in log files for 7 days. After the expiry of the aforementioned period, they will be completely deleted. CleanTalk may use information about IP / email address spam activity to provide appropriate anti-spam protection to all websites connected to its service. It is only the IP / email address that will be used for sending.

Transmission and disclosure of personal data

In the course of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organisational units or persons or that it is disclosed to them. 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 that serve to protect your data with the recipients of your data

Data processing in third 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, entities or companies, this will only be done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we only process or allow data to be processed in third countries with a recognised 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. The primary purpose of a cookie is to store information about a user during or after their visit within an online site. Stored information may include language settings on a website, login status, a shopping cart, or where a video was watched. 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 known as “user IDs”).

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their browser.
  • Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users used for reach measurement or marketing purposes may 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: On the one hand, cookies may be absolutely necessary for the operation of a website (e.g. to store logins or other user inputs or for security reasons).
  • Statistical, marketing and personalisation cookies: Furthermore, cookies are generally also used in the context of range measurement and when a user’s interests or behaviour (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that matches their potential interests. This process is also known as “tracking”, i.e. tracing the potential interests of users. . Insofar as we use cookies or “tracking” technologies, we will inform you separately in our data privacy statement or in the context of obtaining consent.

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

Retention period: If we do not provide you with explicit information on the storage period of permanent cookies (e.g. in the context of a so-called cookie opt-in), please assume that the retention period can be up to two years.

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to withdraw any consent given or to 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 your browser settings, e.g. by deactivating the use of cookies (whereby this may also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared by means of a variety of services, especially in the case of tracking, through the websites https://optout.aboutads.info and https://www.youronlinechoices.com. In addition, you can receive further instructions on how to object in the context of the information on the service providers and cookies used.

Processing of cookie data on the basis of consent: Before we process data in the context of the use of cookies, or have it processed, we ask the users for consent that can be withdrawn at any time. Before the consent has been expressed, at most cookies are used which are absolutely necessary for the operation of our online offer.

Cookie settings/Objection option:

  • Types of data processed: Usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal bases: Consent (Art. 6(1) p. 1 lit. a. GDPR), Legitimate interests (Art. 6(1) p. 1 lit. f. GDPR).

Commercial and business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pr-contractual), e.g. to answer enquiries.

We process this data in order to fulfil our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with this information and for business organisation. Within the scope of the applicable law, we only disclose the data of the contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or with the consent of the persons concerned (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope of this data privacy statement.

We inform the contractual partners of the data required for the aforementioned purposes before or in the course of data collection, e.g. on online forms, by means of special marking (e.g. colours) or symbols (e.g. asterisks or similar), or in person.

We erase the data after expiry of the legal warranty and comparable obligations, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. as long as it must be kept for legal archiving reasons (e.g. for tax purposes generally 10 years). Data that is disclosed to us as part of an order by the contracting partner is erased according to the specifications of the order, as a rule upon its conclusion.

Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.

Provision of the online offer and web hosting

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

The data processed in the context of the provision of the hosting service may include all information relating to the users of our online service which is collected over the course 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.

Email sending and hosting: The web hosting services we use also include the sending, receiving and storing of e-mails. For these purposes, the addresses of the recipients and senders as well as further information concerning the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for SPAM detection purposes. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.

Collection of access data and logfiles: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server logfiles). The server logfiles can include the address and name of the accessed websites and files, date and time of access, transmitted data volumes, notification of successful visit, browser type and version, the operating system of the user, referrer URL (the site visited previously) and as a rule IP addresses and the enquiring 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 also to ensure the utilisation of the servers and their stability.

  • Types of data processed: 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).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f GDPR).

Contact us

When contacting us (e.g. via contact form, email, telephone or via social media), the information regarding the enquiring persons is processed insofar as this is necessary to answer the contact inquiries and any requested measures.

The answering of contact requests in the context of contractual or precontractual relations is carried out for the fulfilment of our contractual obligations or for the answering of (pre)contractual requests and, moreover, on the basis of the legitimate interests in answering the requests.

  • Types of data processed: Core 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).
  • Data subjects: Communication partners, interested parties.
  • Purposes of the processing: Contact requests and communication, managing and responding to requests.
  • Legal bases: Contract fulfilment and precontractual enquiries (Art. 6(1) p. 1 lit. b. GDPR), Legitimate interests (Art. 6(1) p. 1 lit. f. GDPR).

Presence on social networks (social media)

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

We would like to point out that data of the users can be processed outside the area of the European Union. This could create risks for users, for example by making it more difficult to enforce users’ rights.

Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created on the basis of usage behaviour and the resulting interests of the users. The usage profiles can in turn be used, for example, to display advertisements within 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 the interests of the users are stored. Furthermore, data may also be stored in the usage profiles irrespective of the devices used by the users (in particular if the users are members of the respective platforms and are logged in to them).

For a detailed description 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 point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data in each case and can take appropriate measures and provide information directly. If you still need help, then you can contact us.

  • Types of data processed: Core 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).
  • Data subjects: 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 bases: Legitimate interests (Art. 6(1) p. 1 lit. f GDPR).

Services used and service providers:

  • Instagram: Social network; service provider: Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy.
  • Facebook: Social network; service provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Opt-out: Advertising settings: https://www.facebook.com/settings?tab=ads; Additional privacy notices: Facebook page personal data sharing agreement: https://www.facebook.com/legal/terms/page_controller_addendum, Facebook Page Privacy Notice: https://www.facebook.com/legal/terms/information_about_page_insights_data.

Plugins and embedded functions as well as content

We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). This may include, for example, graphics, videos or social media buttons as well as posts (hereinafter uniformly referred to as “Content”).

The integration always presupposes that the third-party providers of this content process the IP addresses of the users, as they would not be able to send the content to their browser without the IP address. The IP address is therefore necessary for the presentation of this content or for these functions. We make every effort to use only such content whose provider only uses the IP address for supplying the content. Third-party providers can also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. Through the “pixel tags”, information such as visitor traffic on the pages of this website can be evaluated. The pseudonymised information can also be stored in cookies on the user’s device and contain e.g. technical information about the browser and the operating system, linked websites, duration and time of visit and other details about the use of our online offer, as well as be linked with such information from other sources.

Notes on legal bases: Where we ask users to consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data is 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 refer you to the information on the use of cookies in this data privacy statement.

  • Types of data processed: 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 a person), content data (e.g. entries in online forms), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
  • Data subjects: Users (e.g. website visitors, users of online services), communication partners.
  • Purposes of the processing: Provision of our online offer and user experience, provision of contractual services and customer service, contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), interest-based and behavioural marketing, profiling (creation of user profiles), security measures, administration and response to requests.
  • Legal bases: Legitimate interests (Art. 6()1 p. 1 lit. f. GDPR), consent (Art. 6()1 p. 1 lit. a. GDPR), contract performance and precontractual requests (Art. 6 par. 1 p. 1 lit. b. GDPR).

Services used and service providers:

  • Google Fonts: We integrate the fonts (“Google Fonts”) of the provider Google, whereby the user’s data is used solely for the purpose of displaying the fonts in the user’s browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform presentation and taking into account possible licensing restrictions for their integration. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://fonts.google.com/; Datenschutzerklärung: https://policies.google.com/privacy.
  • Google Maps: We integrate the maps of the service “Google Maps” of the provider Google. The processed data can include in particular IP addresses and location data of the users, but which is not collected without their consent (as a rule as part of the settings of their mobile devices); service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://cloud.google.com/maps-platform; Privacy policy: https://policies.google.com/privacy; Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, ad display settings: https://adssettings.google.com/authenticated.
  • YouTube videos: Video content; service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, ad display settings: https://adssettings.google.com/authenticated.
  • Borlabs cookie: This website uses a Borlabs cookie, which sets a technically necessary cookie (Borlabs) to store your cookie consents. The Borlabs cookie does not process any personal data. The Borlabs cookie stores the consent you have given when accessing the website. If you wish to withdraw this consent, simply delete the cookie in your browser. When you re-enter/reload the website, you will be asked again for your cookie consent.
  • WPML: The use of WPML serves to be able to represent our web page multilingually. We use WPML provided by OnTheGoSystems Limited, 22/F 3 Lockhart Road, Wanchai, Hong Kong (hereinafter: referred to as WPML). When you visit our website, WPML stores a cookie on your device to remember your language preference. Personal data can be stored and evaluated, especially the activity of the user (in particular which pages have been visited and on which elements have been clicked) as well as device and browser information (in particular the IP address and the operating system). Further information on the collection and storage of data by WPML can be found here: https://wpml.org/documentation/privacy-policy-and-gdpr-compliance

Web analysis, monitoring and optimisation

We process personal data for online marketing purposes, including but not limited to displaying promotional and other content (collectively “Content”) based on users’ potential interests and measuring its effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which the user data relevant for the presentation of the aforementioned contents is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information 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 may also be processed.

The IP addresses of the users are also stored. However, we use IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear data of the users (such as e-mail addresses or names) is stored in the online marketing process, but instead pseudonyms. This means that we, as well as the providers of the online marketing methods, 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 cookies or by means of similar procedures. These cookies can later generally be read on other websites that use the same online marketing method and analysed for the purpose of displaying content as well as supplemented with additional data and stored on the server of the online marketing method provider.

Exceptionally, clear data can be assigned to 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 profiles of the users in the aforementioned information. We ask you to note that users can make additional agreements with the providers, e.g. by giving their consent as part of the registration process.

We generally only receive access to aggregate information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing methods have led to a so-called conversion, i.e. for example, to a contract being concluded with us. Conversion measurement is used solely to analyse the success of our marketing efforts.

Notes on legal bases: Where we ask users to consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data is 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 refer you to the information on the use of cookies in this data privacy statement.

  • Types of data processed: Usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services), interested parties.
  • Purposes of the processing: Tracking (e.g. interest/behaviour-based profiling, use of cookies), remarketing, conversion evaluation, interest-based and behaviour-based marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures: IP masking (pseudonymisation of the IP address).
  • Legal bases: Consent (Art. 6()1 p. 1 lit. a GDPR), Legitimate Interests (Art. 6()1 p. 1 lit. f GDPR).
  • Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the objection options given by the providers (so-called \”opt-out\”). If no explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. However, this may limit the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary form for the respective territories: a) Europe: https://www.youronlinechoices.eu.
    b) Canada: https://www.youradchoices.ca/choices.
    c) USA: https://www.aboutads.info/choices.
    d) Inter-territorial: http://optout.aboutads.info.

Services used and service providers:

  • Google Analytics: Online marketing and web analytics; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; Opt-out: Opt-out plugin: http://tools.google.com/dlpage/gaoptout?hl=de, ad display settings: https://adssettings.google.com/authenticated.

Erasure of data

The data processed by us will be deleted in accordance with the legal requirements as soon as the consents permitted for processing are withdrawn or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose).

If the data is not erased because it is required for other and legally permissible purposes, its processing is restricted 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 stored for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.

Further information on the erasure of personal data can also be found in the individual data protection notices of this data protection declaration.

Modification and updating of the privacy policy

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

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

Rights of data subjects

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

  • Right to object: You have the right, on grounds emerging from your particular situation, to object at any time to the processing of your personal data on the basis of Art. 6(1) lit. e or GDPR; this also applies to profiling based on one of these provisions. If your personal data is processed to carry out direct advertising, you have the right to object at any time against the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is linked to such direct advertising.
  • Right to withdraw consent: You have the right to withdraw any granted consents at any time.
  • Right to information: You have the right to request a confirmation of whether relevant data is being processed and to information about this data, as well as further information and a copy of the data, in accordance with legal regulations.
  • Right to rectification: According to legal regulations, you have the right to request the supplementation of your data or the rectification of incorrect data affecting you.
  • Right to erasure and restriction of processing: According to legal regulations, you have the right to request that your data is erased without delay, or alternatively in accordance with the law to request a restriction of the processing of the data.
  • Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements, or to demand that it be transferred to another responsible party.
  • Complaint to supervisory authority: Furthermore, you have the right according to legal regulations to raise a complaint to a supervisory authority, in particular in the member state of your place of habitual residence, your workplace or the location of the purported contravention, if you are of the opinion that the processing of your personal data infringes the GDPR.

Definition of terms

This section provides an overview of the terms used in this privacy statement. Many of the terms are taken from the law and defined in particular in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended primarily to aid understanding. The terms are sorted alphabetically.

  • Conversion tracking: “Conversion tracking” refers to a process by which the effectiveness of marketing measures can be determined. This is usually done by storing a cookie on the users’ devices within the websites where the marketing takes place and then retrieving it again on the target website. For example, we can see if the ads we have placed on other websites have been successful.
  • Cross-device tracking: Cross-device tracking is a form of tracking in which users’ behavioural and interest information is recorded across devices in so-called profiles by assigning users an online identifier. This allows user information to be analysed for marketing purposes, irrespective of the browsers or devices used (e.g. mobile phones or desktop computers). For most providers, the online identifier is not linked to clear data such as names, postal addresses or e-mail addresses.
  • IP masking: “IP masking” is a method by which the last octet, i.e. the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymising processing operations, especially in online marketing
  • Interest-based and behavioural marketing: Interest-based and/or behaviour-based marketing is when potential user interests in advertisements and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behaviour (e.g. visiting certain websites and staying on them, buying behaviour or interaction with other users), which is stored in a so-called profile. Cookies are generally used for these purposes.
  • Conversion measurement: Conversion measurement is a method used to determine the effectiveness of marketing efforts. This is usually done by storing a cookie on the users’ devices within the websites where the marketing takes place and then retrieving it again on the target website. For example, we can see whether the ads we have placed on other websites have been successful.
  • Personal data: “Personal data” is all information referring to an identified or identifiable natural person (hereinafter “data subject”); a natural person is considered identifiable who can be identified directly or indirectly, especially through attribution of a name, reference number, location data, online indicator (e.g. cookie) or of one or more special characteristics, which are the expression of the physical, physiological genetic, mental, economic, cultural or social identity of this natural person.
  • Profiling: “Profiling” is any form of automated processing of personal data which consists of using that 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 relating to age, gender, location data 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-through behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online site and may include visitors’ behaviour or interests in certain information, such as web page content. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This allows them, for example, to better adapt the content of the website to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Remarketing: One speaks of “remarketing” or “retargeting” when, for example, for advertising purposes, it is noted 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 generated when a mobile device (or any other device with the technical requirements of location determination) connects to a radio cell, a WLAN or similar technical means and functions of location determination. Location data is used to indicate the geographically determinable position in the world 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: “Tracking” is when the behaviour of users can be traced across multiple online offers. As a rule, with regard to the online offers used, behavioural and interest information 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.
  • Controller: The “controller” refers to a natural or legal person, authority, establishment or other department which alone or together with others decides on the purposes and means of processing personal data.
  • Processing: “Processing” is any process or series of processes carried out with personal data with or without the help of automated procedures. The term is wide-ranging and encompasses practically every handling of data, be it collection, evaluation, storage, transmission or erasure.
  • Custom audiences: Targeting (or “custom audiences”) is when target groups are determined for advertising purposes, e.g. display of advertisements. For example, based on a user’s interest in certain products or topics on the Internet, it can be inferred that this user is interested in advertisements for similar products or the online shop where the user viewed the products. “Lookalike audiences” (or similar target groups) are when 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 for the purpose of creating Custom Audiences and Lookalike Audiences.