Privacy policy
This privacy policy informs you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as "data") within the framework of the provision of our services as well as within our online offering and the associated websites, functions and content as well as external online presences, such as our social media profiles on Instagram or Facebook (hereinafter collectively referred to as "online offering"). With regard to the terms used, such as "processing" or "controller", we refer to the definitions in Art. 4 of theDatenschutzgrundverordnung (DSGVO).
Controller
Types of Data Processed
- Inventory data (e.g., personal master data, names or addresses).
- Contact data (e.g., email, telephone numbers).
- Content data (e.g., text entries, photographs, videos).
- Usage data (e.g., websites visited, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).
Categories of Data Subjects
Visitors and users of the online offering (hereinafter we collectively refer to the data subjects as "users").
Purpose of Processing
- Provision of the online offering, its functions and content.
- Responding to contact requests and communication with users.
- Security measures.
- Reach measurement/marketing
Terms Used
"Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
"Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data.
"Pseudonymization" means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
"Profiling" means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
"Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
"Processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Relevant Legal Bases
In accordance with Art. 13 DSGVO, we inform you of the legal basis of our data processing. For users from the scope of the General Data Protection Regulation (DSGVO), i.e. the EU and the EEA, the following applies unless the legal basis is not mentioned in the privacy policy:
The legal basis for obtaining consent is Art. 6 (1) lit. a and Art. 7 DSGVO;
The legal basis for processing to fulfill our services and carry out contractual measures as well as respond to inquiries is Art. 6 (1) lit. b DSGVO;
The legal basis for processing to fulfill our legal obligations is Art. 6 (1) lit. c DSGVO;
In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) lit. d DSGVO serves as the legal basis.
The legal basis for the necessary processing to perform a task carried out in the public interest or in the exercise of official authority vested in the controller is Art. 6 (1) lit. e DSGVO.
The legal basis for processing to protect our legitimate interests is Art. 6 (1) lit. f DSGVO.
The processing of data for purposes other than those for which they were collected is determined according to the provisions of Art. 6 (4) DSGVO.
The processing of special categories of data (according to Art. 9 (1) DSGVO) is determined according to the provisions of Art. 9 (2) DSGVO.
Security Measures
We take appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, input, disclosure, ensuring availability and segregation of data. Furthermore, we have established procedures that ensure the exercise of data subjects' rights, deletion of data and response to data threats. We also consider the protection of personal data already in the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design and by data protection-friendly default settings.
Cooperation with Processors, Joint Controllers and Third Parties
If, in the context of our processing, we disclose data to other persons and companies (processors, joint controllers or third parties), transfer it to them or otherwise grant them access to the data, this is done only on the basis of a legal permission (e.g. if a transfer of the data to third parties, such as payment service providers, is necessary for the performance of the contract), users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we disclose data to other companies in our group of companies, transfer it or otherwise grant them access, this is done in particular for administrative purposes as a legitimate interest and, beyond that, on a basis that complies with legal requirements.
Transfers to Third Countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this occurs in the context of the use of third party services or disclosure or transfer of data to other persons or companies, this only takes place if it is done to fulfill our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to express consent or contractually required transfer, we process or have the data processed only in third countries with a recognized level of data protection, which includes processors certified under the "Privacy Shield" or on the basis of special guarantees, such as contractual obligation through so-called standard data protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, EU Commission information page).
Rights of Data Subjects
You have the right to request confirmation as to whether data is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with legal requirements.
You have the right, in accordance with legal requirements, to request the completion of data concerning you or the correction of inaccurate data concerning you.
You have the right, in accordance with legal requirements, to request that relevant data be deleted immediately or, alternatively, to request a restriction on the processing of the data in accordance with legal requirements.
You have the right to request that the data concerning you that you have provided to us be received in accordance with legal requirements and to request its transmission to other controllers.
You also have the right, in accordance with legal requirements, to lodge a complaint with the competent supervisory authority.
Right to Withdraw Consent
You have the right to withdraw consent given with effect for the future.
Right to Object
You can object at any time to the future processing of data concerning you in accordance with legal requirements. The objection can be made in particular against processing for purposes of direct marketing.
Cookies and Right to Object to Direct Marketing
"Cookies" are small files that are stored on users' computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit to an online offering. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online offering and closes their browser. Such a cookie can store, for example, the contents of a shopping cart in an online shop or a login status. Cookies that remain stored even after the browser is closed are referred to as "permanent" or "persistent". For example, the login status can be stored if users visit it after several days. Likewise, the interests of users can be stored in such a cookie, which are used for range measurement or marketing purposes. "Third-party cookies" are cookies that are offered by providers other than the controller who operates the online offering (otherwise, if they are only their cookies, they are referred to as "first-party cookies").
We can use temporary and permanent cookies and provide information about this in our privacy policy.
If we ask users for consent to use cookies (e.g. in the context of cookie consent), the legal basis for this processing is Art. 6 (1) lit. a DSGVO. Otherwise, users' personal cookies are processed in accordance with the following explanations in this privacy policy on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 (1) lit. f DSGVO) or if the use of cookies is necessary to provide our contract-related services, pursuant to Art. 6 (1) lit. b DSGVO, or if the use of cookies is necessary for the performance of a task carried out in the public interest or in the exercise of official authority, pursuant to Art. 6 (1) lit. e DSGVO.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offering.
A general objection to the use of cookies used for online marketing purposes can be declared for many services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by disabling them in the browser settings. Please note that in this case not all functions of this online offering may be used.
Deletion of Data
The data processed by us will be deleted or restricted in its processing in accordance with legal requirements. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and there are no legal retention obligations preventing deletion.
If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
Changes and Updates to the Privacy Policy
We ask you to regularly inform yourself about the content of our privacy policy. We adapt the privacy policy as soon as the changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
Business-Related Processing
In addition, we process
- Contract data (e.g., contract subject matter, duration, customer category).
- Payment data (e.g., bank details, payment history)
from our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
Order Processing in Online Shop and Customer Account
We process the data of our customers within the framework of the ordering processes in our online shop to enable them to select and order the chosen products and services, as well as their payment and delivery or execution.
The processed data includes inventory data, communication data, contract data, payment data and the persons affected by the processing include our customers, prospects and other business partners. The processing is carried out for the purpose of providing contractual services in the context of operating an online shop, billing, delivery and customer service. For this purpose, we use session cookies for storing the shopping cart contents and permanent cookies for storing the login status.
The processing is carried out to fulfill our services and carry out contractual measures (e.g. execution of ordering processes) and to the extent that it is legally required (e.g., legally required archiving of business transactions for commercial and tax purposes). The information marked as required is necessary for establishing and fulfilling the contract. We only disclose the data to third parties within the framework of delivery, payment or within the framework of legal permissions and obligations, or if this is based on our legitimate interests, about which we inform you in this privacy policy (e.g., to legal and tax advisors, financial institutions, freight companies and authorities).
Users can optionally create a user account, in particular to view their orders. During registration, users are informed of the required mandatory information. User accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data with regard to the user account will be deleted, subject to their retention being necessary for commercial or tax law reasons. Information in the customer account remains until its deletion with subsequent archiving in the case of a legal obligation or our legitimate interests (e.g., in the case of legal disputes). It is the responsibility of users to save their data upon termination before the end of the contract.
Within the framework of registration and renewed logins as well as use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the users' interest in protection against misuse and other unauthorized use. As a rule, this data is not passed on to third parties, unless it is necessary to pursue our legal claims as a legitimate interest or there is a legal obligation to do so.
Deletion takes place after expiration of statutory warranty and other contractual rights or obligations (e.g., payment claims or performance obligations from contracts with customers), whereby the necessity of retaining the data is reviewed every three years; in the case of retention due to statutory archiving obligations, deletion takes place accordingly after their expiration.
External Payment Service Providers
We use external payment service providers, through whose platforms users and we can make payment transactions. These payment service providers may include, each with a link to the privacy policy: PayPal (https://www.paypal.com/de/webapps/mpp/ua/privacy-full), Klarna (https://www.klarna.com/de/datenschutz/), Skrill (https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/), Giropay (https://www.giropay.de/rechtliches/datenschutz-agb/), Visa (https://www.visa.de/datenschutz), Mastercard (https://www.mastercard.de/de-de/datenschutz.html), American Express (https://www.americanexpress.com/de/content/privacy-policy-statement.html), Stripe (https://stripe.com/de/privacy).
In the context of fulfilling contracts, we use payment service providers on the basis of Art. 6 (1) lit. b DSGVO. Otherwise, we use external payment service providers on the basis of our legitimate interests pursuant to Art. 6 (1) lit. f DSGVOin order to offer our users effective and secure payment options.
The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related information. The information is necessary to carry out the transactions. However, the data entered is only processed and stored by the payment service providers. This means we do not receive any account or credit card-related information, but only information confirming or rejecting the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to verify identity and creditworthiness. For this, we refer to the terms and conditions and privacy notices of the payment service providers.
For payment transactions, the terms and conditions and privacy notices of the respective payment service providers apply, which can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and assertion of withdrawal, information and other data subject rights.
Administration, Financial Accounting, Office Organization, Contact Management
We process data in the context of administrative tasks as well as organization of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the context of providing our contractual services. The processing bases are Art. 6 (1) lit. c DSGVO, Art. 6 (1) lit. f DSGVO. Customers, prospects, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in administration, financial accounting, office organization, archiving of data, i.e. tasks that serve to maintain our business activities, perform our tasks and provide our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information provided in these processing activities.
We disclose or transmit data to the tax authorities, advisors such as tax advisors or auditors, as well as other fee offices and payment service providers.
Furthermore, based on our business interests, we store information about suppliers, organizers and other business partners, e.g. for the purpose of later contact. We generally store this mostly company-related data permanently.
Business Analysis and Market Research
In order to operate our business economically, to recognize market trends, wishes of contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc. We process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 (1) lit. f DSGVO, whereby the affected persons include contractual partners, prospects, customers, visitors and users of our online offering.
The analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we can consider the profiles of registered users with information, e.g. on the services they have used. The analyses serve us to increase user-friendliness, optimize our offering and business efficiency. The analyses serve only us and are not disclosed externally, unless they are anonymous analyses with aggregated values.
If these analyses or profiles are personal, they will be deleted or anonymized upon termination by the users, otherwise after two years from the conclusion of the contract. Otherwise, the overall business analyses and general trend determinations are created anonymously whenever possible.
Participation in Affiliate Partner Programs
Within our online offering, we use industry-standard tracking measures based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering) pursuant to Art. 6 (1) lit. f DSGVO, insofar as these are necessary for the operation of the affiliate system. In the following, we inform users about the technical background.
The services offered by our contractual partners can also be advertised and linked on other websites (so-called affiliate links or after-buy systems, if e.g. links or services of third parties are offered after a contract conclusion). The operators of the respective websites receive a commission if users follow the affiliate links and subsequently accept the offers.
In summary, it is necessary for our online offering that we can track whether users who are interested in affiliate links and/or the offers available from us subsequently accept the offers at the instigation of the affiliate links or our online platform. For this purpose, the affiliate links and our offers are supplemented by certain values that can be a component of the link or otherwise, e.g. set in a cookie. The values include in particular the source website (referrer), time, an online identifier of the operators of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as tracking-specific values such as advertising material ID, partner ID and categorizations.
The online identifiers of users that we use are pseudonymous values. This means the online identifiers themselves do not contain any personal data such as names or email addresses. They only help us determine whether the same user who clicked on an affiliate link or was interested in an offer through our online offering has accepted the offer, i.e. e.g. concluded a contract with the provider. However, the online identifier is personal insofar as the partner company and also we have the online identifier together with other user data. Only in this way can the partner company inform us whether that user has accepted the offer and we can e.g. pay out the bonus.
Contact
When contacting us (e.g. via contact form, email, telephone or via social media), the user's information is processed for handling the contact request and its processing pursuant to Art. 6 (1) lit. b (within the framework of contractual/pre-contractual relationships), Art. 6 (1) lit. f (other inquiries) DSGVO. Users' information can be stored in a Customer Relationship Management System ("CRM System") or comparable request organization.
We delete requests if they are no longer required. We review the necessity every two years; furthermore, the statutory archiving obligations apply.
Newsletter
With the following information, we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your right to object. By subscribing to our newsletter, you agree to receive it and to the procedures described.
Content of the newsletter: We send newsletters, emails and other electronic notifications with promotional information (hereinafter "newsletter") only with the consent of the recipients or legal permission. If the contents of the newsletter are specifically described during registration, they are decisive for the users' consent. Otherwise, our newsletters contain information about our services and us.
Double opt-in and logging: Registration for our newsletter is carried out in a so-called double opt-in procedure. This means you will receive an email after registration asking you to confirm your registration. This confirmation is necessary so that no one can register with foreign email addresses. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the registration and confirmation time, as well as the IP address. Changes to your data stored with the dispatch service provider are also logged.
Registration data: To register for the newsletter, it is sufficient if you provide your email address. Optionally, we ask you to provide a name for personal address in the newsletter.
The dispatch of the newsletter and the success measurement associated with it are based on the consent of the recipients pursuant to Art. 6 (1) lit. a, Art. 7 DSGVOin conjunction with Section 7 (2) No. 3 UWG or, if consent is not required, on the basis of our legitimate interests in direct marketing pursuant to Art. 6 (1) lit. f DSGVO in conjunction with Section 7 (3) UWG.
The logging of the registration procedure is based on our legitimate interests pursuant to Art. 6 (1) lit. f DSGVO. Our interest is directed at using a user-friendly and secure newsletter system that serves both our business interests and the expectations of users and also allows us to prove consent.
Cancellation/revocation - You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. A link to cancel the newsletter can be found at the end of each newsletter. We can store the unsubscribed email addresses for up to three years based on our legitimate interests before we delete them in order to be able to prove previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.
Hosting and Email Dispatch
The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, email dispatch, security services and technical maintenance services that we use for the purpose of operating this online offering.
In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, prospects and visitors to this online offering on the basis of our legitimate interests in an efficient and secure provision of this online offering pursuant to Art. 6 (1) lit. f DSGVO in conjunction with Art. 28 DSGVO (conclusion of data processing agreement).
Collection of Access Data and Log Files
We or our hosting provider collects data on every access to the server on which this service is located (so-called server log files) on the basis of our legitimate interests within the meaning of Art. 6 (1) lit. f DSGVO. Access data includes the name of the accessed website, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Log file information is stored for security reasons (e.g. to investigate abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is required for evidence purposes is excluded from deletion until the final clarification of the respective incident.
