Privacy Policy

The Shape-Line Group GmbH

Introduction

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

As of: 31.07.2023

• Introduction
• Controller
• Overview of Processing Activities
• Contact Data Protection Officer
• Relevant Legal Bases
• Security Measures
• Transfer and Disclosure of Personal Data
• Data Processing in Third Countries
• Use of Cookies
• Commercial and Business Services
• Payment Service Providers
• Credit Check
• Provision of the Online Offering and Web Hosting
• Contacting Us
• Newsletter and Electronic Notifications
• Web Analytics, Monitoring, and Optimization
• Online Marketing
• Presences on Social Networks (Social Media)
• Plugins and Embedded Functions and Content
• Deletion of Data
• Changes and Updates to the Privacy Policy
• Rights of Data Subjects
• Definitions

Controller

The Shape-Line Group GmbH
Brausewettergasse 8
A-1220 Wien

T: +43 2236 251 91-0
M: office@shapeline.at

Overview of Processing Activities

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

Types of Data Processed

• Inventory data (e.g., names, addresses).
• Content data (e.g., entries in online forms).
• Contact data (e.g., email, telephone numbers).
• Meta/communication data (e.g., device information, IP addresses).
• Usage data (e.g., visited websites, interest in content, access times).
• Location data (information on the geographical position of a device or a person).
• Contract data (e.g., subject matter of the contract, term, customer category).
• Payment data (e.g., bank details, invoices, payment history).

Categories of Data Subjects

• Business and contractual partners.
• Prospective customers
• Communication partners
• Customers
• Users (e.g., website visitors, users of online services).

Purposes of Processing

• Assessment of creditworthiness and solvency.
• Provision of our online offering and user-friendliness.
• Visit action evaluation
• Office and organizational procedures.
• Cross-device tracking (cross-device processing of user data for marketing purposes).
• Direct marketing (e.g., via email or postal mail).
• Interest-based and behavioral marketing.
• Contact inquiries and communication.
• Conversion measurement (measuring the effectiveness of marketing measures).
• Profiling (creation of user profiles).
• Remarketing
• Reach measurement (e.g., access statistics, recognition of recurring visitors).
• Security measures.
• Tracking (e.g., interest/behavior-based profiling, use of cookies).
• Provision of contractual services and customer service.
• Management and response to inquiries.
• Target group formation (determining target groups relevant for marketing purposes or other output of content).

Automated Individual Decision-Making

• Credit report (decision based on a credit check).

Relevant Legal Bases

Below, we inform you about the legal bases of the General Data Protection Regulation (GDPR) on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations in your or our country of residence and establishment may apply. Furthermore, if more specific legal bases are relevant in individual cases, we will inform you about them in the privacy policy.

• Consent (Art. 6 (1) sentence 1 lit. a GDPR) – The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
• Performance of contract and pre-contractual inquiries (Art. 6 (1) sentence 1 lit. b GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
• Legal obligation (Art. 6 (1) sentence 1 lit. c GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
• Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Security Measures

In accordance with statutory requirements and taking into account the state of the art, implementation costs, and the nature, scope, context, and purposes of processing as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, ensuring availability, and their separation. Furthermore, we have established procedures that ensure the exercise of data subjects' rights, the deletion of data, and responses to data breaches. We also consider the protection of personal data during the development or selection of hardware, software, and procedures in accordance with the principle of data protection by design and by default.

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

Transfer and Disclosure of Personal Data

In the course of our processing of personal data, it may happen that data is transferred to or disclosed to other entities, companies, legally independent organizational units, or persons. 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 comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

Data Processing in Third Countries

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

Subject to express consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications, or binding internal data protection regulations (Arts. 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).

Within the framework of the "Trans-Atlantic Data Privacy Framework" (TADPF), the EU Commission has also recognized the data protection level for certain companies from the USA. The list of certified companies and further information on the TADPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). Information in German and other languages can be found on the EU Commission website: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/eu-us-data-transfers_de We will also inform you about the companies we use that are certified under the Trans-Atlantic Data Privacy Framework.

Use of Cookies

Cookies are small text files, or other storage notes, that store information on end devices and read information from end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the accessed content, or used functions of an online offering. Cookies can also be used for different purposes, e.g., for the functionality, security, and convenience of online offerings, as well as for creating analyses of visitor flows.

Notes on consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, unless this is not legally required. Consent is particularly not necessary if the storage and reading of information, including cookies, are absolutely necessary to provide users with a telemedia service (i.e., our online offering) explicitly requested by them. The revocable consent is clearly communicated to users and contains information about the respective cookie usage.

Notes on data protection legal bases: The data protection legal basis on which we process users' personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing your data is the declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g., in the economic operation of our online offering and improving its usability) or, if this occurs within the framework of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We will explain the purposes for which we process cookies in the course of this privacy policy or in the context of our consent and processing procedures.

Storage duration: With regard to the storage duration, the following types of cookies are distinguished:

• Temporary cookies (also: session cookies):Temporary cookies are deleted at the latest after a user has left an online offering and closed their end device (e.g., browser or mobile application).
• Permanent cookies:Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user revisits a website. Likewise, the data collected from users with the help of cookies can be used for reach measurement. Unless we provide users with explicit information on the type and storage duration of cookies (e.g., in the context of obtaining consent), users should assume that cookies are permanent and the storage duration 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 always have the option to revoke given consent or to object to the processing of your data by cookie technologies (collectively referred to as "opt-out"). You can declare your objection initially through your browser settings, e.g., by deactivating the use of cookies (although this may also restrict the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared via a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can find further objection information in the details regarding the service providers and cookies used.

Processing of cookie data based on consent: We use a cookie consent management procedure, within which user consent to the use of cookies, or the processing and providers mentioned within the cookie consent management procedure, can be obtained, managed, and revoked by users. The consent declaration is stored to avoid having to repeat the query and to be able to demonstrate consent in accordance with legal obligations. Storage can take place server-side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies) to be able to assign the consent to a user or their device. Subject to individual details about the providers of cookie management services, the following notes apply: The duration of consent storage can be up to two years. A pseudonymized user identifier is created and stored with the time of consent, information on the scope of consent (e.g., which categories of cookies and/or service providers) as well as the browser, system, and end device used.

Cookie settings/objection options:

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 and related measures, and in the context of communication with contractual partners (or pre-contractually), e.g., to answer inquiries.

We process this data for the fulfillment of our contractual obligations, to secure our rights, and for the purposes of the administrative tasks associated with this information and the organizational structure of the company. We only pass on the data of contractual partners to third parties within the framework of applicable law, if this is necessary for the aforementioned purposes or to fulfill legal obligations, or if the affected persons have given their consent (e.g., to involved telecommunication, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Contractual partners will be informed about further forms of processing, e.g., for marketing purposes, within the framework of this privacy policy.

We inform contractual partners about which data is required for the aforementioned purposes before or during data collection, e.g., in online forms, by special marking (e.g., colors) or symbols (e.g., asterisks or similar), or personally.

We delete the data after the expiry of 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 retained for legal archiving reasons (e.g., for tax purposes, usually 10 years). Data disclosed to us by the contractual partner in the context of an order will be deleted in accordance with the terms of the order, generally after the end of the order.

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 users and providers.

Customer Account: Contracting parties can create an account within our online offering (e.g., customer or user account, or "customer account" for short). If the registration of a customer account is required, contracting parties will be informed of this, as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. During registration, subsequent logins, and use of the customer account, we store customers' IP addresses along with access times to prove registration and prevent any misuse of the customer account.

If customers have terminated their customer account, the data relating to the customer account will be deleted, subject to legal retention requirements. It is the customers' responsibility to secure their data upon termination of the customer account.

Economic Analysis and Market Research: For business reasons and to identify market trends, wishes of contracting parties and users, we analyze the data available to us regarding business transactions, contracts, inquiries, etc., whereby the group of affected persons may include contracting parties, interested parties, customers, visitors, and users of our online offering.

The analyses are carried out for the purpose of business evaluations, marketing, and market research (e.g., to determine customer groups with different characteristics). In doing so, we may, if available, take into account the profiles of registered users including their details, e.g., on services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarized, i.e., anonymized values. Furthermore, we respect the privacy of users and process data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g., as aggregated data).

Shop and E-Commerce: We process the data of our customers to enable them to select, acquire, or order the chosen products, goods, and associated services, as well as their payment and delivery, or execution. If required for the execution of an order, we use service providers, in particular postal, forwarding, and shipping companies, to carry out the delivery or execution to our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is marked as such within the order or comparable purchase process and includes the details required for delivery, provision, and billing, as well as contact information to enable any necessary consultation.

• Types of data processed: Inventory data (e.g., names, addresses), payment data (e.g., bank details, invoices, payment history), contact data (e.g., email, phone numbers), contract data (e.g., subject matter of contract, term, customer category), usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
• Affected persons: Interested parties, business and contractual partners, customers.
• Purposes of processing: Provision of contractual services and customer service, contact inquiries and communication, office and organizational procedures, management and answering of inquiries, security measures, visit action evaluation, interest-based and behavioral marketing, profiling (creation of user profiles).
• Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Payment Service Providers

In the context of contractual and other legal relationships, due to legal obligations, or otherwise on the basis of our legitimate interests, we offer efficient and secure payment options to the data subjects and use other payment service providers in addition to banks and credit institutions (collectively "Payment Service Providers").

The data processed by the payment service providers includes inventory data, such as name and address, bank details, such as account numbers or credit card numbers, passwords, TANs, and checksums, as well as contract, sum, and recipient-related information. This information is required to carry out the transactions. However, the entered data is only processed by the payment service providers and stored by them. This means that we do not receive any account or credit card-related information, but only information confirming or rejecting the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. This transmission is for the purpose of identity and creditworthiness checks. For this, we refer to the terms and conditions and privacy notices of the payment service providers.

The terms and conditions and privacy notices of the respective payment service providers, which are available on the respective websites or transaction applications, apply to payment transactions. We also refer to these for further information and for asserting rights of withdrawal, information, and other data subject rights.

• Types of data processed: Inventory data (e.g., names, addresses), payment data (e.g., bank details, invoices, payment history), contract data (e.g., subject matter of contract, term, customer category), usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
• Affected persons: Customers, interested parties.
• Purposes of processing: Provision of contractual services and customer service.
• Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services used and service providers:

• PayPal: Payment services and solutions (e.g., PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Website: https://www.paypal.com/de; Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

Provision of the online offering and web hosting

To provide our online offering securely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers managed by them) the online offering 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 providing the hosting offering may include all information relating to the users of our online offering that arises during use and communication. This regularly includes the IP address, which is necessary to deliver the content of online offerings to browsers, and all entries made within our online offering or on websites.

Email dispatch and hosting: The web hosting services we use also include the dispatch, receipt, and storage of emails. For these purposes, the addresses of recipients and senders, as well as other information concerning the email dispatch (e.g., the participating providers) and the content of the respective emails, are processed. The aforementioned data may also be processed for spam detection purposes. We kindly ask you to note that emails are generally not sent encrypted on the internet. As a rule, emails are encrypted during transport, 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 responsibility for the transmission path of emails between the sender and the receipt on our server.

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

The server log files can be used for security purposes, e.g., to prevent server overload (especially in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure server utilization and stability.

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

Contacting Us

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

The answering of contact inquiries within the framework of contractual or pre-contractual relationships takes place for the fulfillment of our contractual obligations or for the answering of (pre-)contractual inquiries and otherwise on the basis of legitimate interests in answering the inquiries.

• Types of data processed: Inventory data (e.g., names, addresses), contact data (e.g., email, telephone numbers), content data (e.g., entries in online forms), usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
• Affected persons: Communication partners, interested parties.
• Purposes of processing: Contact inquiries and communication, management and answering of inquiries.
• Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Newsletters and electronic notifications

We send newsletters, emails and other electronic notifications (hereinafter "newsletters") only with the consent of the recipients or a legal permission. If the content of the newsletter is specifically described during registration, it is decisive for the user's consent. Otherwise, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to provide your email address. However, we may ask you to provide a name, for personalized addressing in the newsletter, or other information, if this is necessary for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter generally takes place in a so-called double opt-in procedure. This means that after registration, you will receive an email 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 time of registration and confirmation as well as the IP address. Changes to your data stored with the mailing service provider are also logged.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them, in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of a consent is also confirmed. In the case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a blacklist.

The logging of the registration process is based on our legitimate interests for the purpose of proving its proper course. Insofar as we commission a service provider with the sending of emails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Notes on legal bases: Newsletters are sent based on the recipients' consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, provided and insofar as this is legally permitted, e.g., in the case of existing customer advertising. Insofar as we commission a service provider with the sending of emails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to prove that it was carried out in accordance with the law.

Content: Information about us, our services, promotions, and offers.

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

This information is used for the technical improvement of our newsletter based on technical data or target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened, and which links are clicked. Although this information can technically be assigned to individual newsletter recipients, it is neither our intention nor, if used, that of the dispatch service provider, to observe individual users. Rather, the evaluations serve us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The evaluation of the newsletter and the success measurement are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves both our business interests and the expectations of the users.

A separate revocation of the success measurement is unfortunately not possible; in this case, the entire newsletter subscription must be cancelled or objected to.

• Types of data processed: Inventory data (e.g., names, addresses), contact data (e.g., email, phone numbers), meta/communication data (e.g., device information, IP addresses), usage data (e.g., visited websites, interest in content, access times).
• Affected persons: Communication partners
  
• Purposes of processing: Direct marketing (e.g., by email or post).
• Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
• Right to object (Opt-Out): You can unsubscribe from our newsletter at any time, i.e., revoke your consent or object to further receipt. A link to unsubscribe from the newsletter can be found either at the end of each newsletter or you can use one of the contact options provided above, preferably email, for this purpose.

Services used and service providers:

• CleverReach: Email marketing platform; Service provider: CleverReach GmbH & Co. KG, //CRASH Building, Schafjückenweg 2, 26180 Rastede, Germany; Website: https://www.cleverreach.com/de; Privacy Policy: https://www.cleverreach.com/de/datenschutz/; Data Processing Agreement: Concluded with provider.
• Security measures: https://mailchimp.com/help/Mailchimp-european-data-transfers/.

Web Analysis, Monitoring and Optimization

Web analysis (also known as "reach measurement") serves to evaluate the visitor flows to our online offering and can include behavioral, interest-related or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, determine at what times our online offering or its functions or content are used most frequently or are inviting for reuse. We can also identify areas that require optimization.

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

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

User IP addresses are also collected. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored within the framework of web analysis, A/B testing and optimization, but rather pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

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

• Types of data processed: Usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
• Affected persons: Users (e.g., website visitors, users of online services).
• Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors), tracking (e.g., interest-/behavior-based profiling, use of cookies), evaluation of visit actions, profiling (creation of user profiles).
• Security measures: IP masking (pseudonymization of the IP address).
• Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services used and service providers:

• Google Analytics: We use Google Analytics to measure and analyze the use of our online offering based on a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It serves to assign analytical information to an end device in order to identify which content users have accessed within one or various usage processes, which search terms they have used, re-accessed, or interacted with our online offering. The time and duration of use are also stored, as are the sources of users who refer to our online offering and technical aspects of their end devices and browsers. Pseudonymous user profiles are created with information from the use of various devices, whereby cookies may be used. In Analytics, higher-level geographic location data is provided by collecting the following metadata via IP lookup: "City" (and the derived city latitude and longitude), "Continent", "Country", "Region", "Subcontinent" (and the ID-based equivalents). To ensure the protection of user data in the EU, Google receives and processes all user data via domains and servers within the EU. User IP addresses are not logged and are truncated by the last two digits by default. IP address truncation takes place on EU servers for EU users. Furthermore, all sensitive data collected from users in the EU is deleted before it is collected via EU domains and servers; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Standard Contractual Clauses (ensuring data protection level when processing in third countries): https://business.safety.google/adsprocessorterms; Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for advertising display: https://adssettings.google.com/authenticated; Further information: https://privacy.google.com/businesses/adsservices (types of processing and data processed).
• Google Tag Manager: Google Tag Manager is a solution that allows us to manage so-called website tags via an interface and thus integrate other services into our online offering (for more information, please refer to other information in this privacy policy). The Tag Manager itself (which implements the tags) does not create user profiles or store cookies, for example. Google only learns the user's IP address, which is necessary to run the Google Tag Manager; 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; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement:
  https://business.safety.google/adsprocessorterms; Standard Contractual Clauses (ensuring data protection level when processing in third countries): https://business.safety.google/adsprocessorterms; Further information: https://privacy.google.com/businesses/adsservices (types of processing and data processed).

Online Marketing

We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the display of promotional and other content (collectively referred to as "content") based on users' potential interests, as well as measuring their 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 information relevant for the display of the aforementioned content is stored about the user. This information may include, for example, viewed content, visited websites, online networks used, but also communication partners and technical information, such as the browser used, the computer system used, and information about usage times. If users have consented to the collection of their location data, this data may also be processed.

User IP addresses are also collected. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored within the framework of online marketing procedures, but rather pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is generally stored in cookies or by means of similar procedures. These cookies can later generally also be read out on other websites that use the same online marketing procedure and analyzed for the purpose of displaying content, as well as supplemented with further data and stored on the server of the online marketing procedure provider.

In exceptional cases, clear data can be assigned to the profiles. This is the case, for example, if users are members of a social network whose online marketing procedure we use and the network links the user profiles with the aforementioned information. We ask you to note that users can make additional agreements with the providers, e.g., by consenting during registration.

We generally only gain access to aggregated information about the success of our advertisements. However, within the framework of so-called conversion measurement, we can check which of our online marketing procedures have led to a so-called conversion, i.e., e.g., to a contract conclusion with us. Conversion measurement is used solely to analyze the success of our marketing measures.

Unless otherwise stated, please assume that used cookies are stored for a period of two years.

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

• Types of data processed: Usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses), location data (information about the geographical position of a device or a person).
• Affected persons: Users (e.g., website visitors, users of online services), interested parties.
• Purposes of processing: Tracking (e.g., interest-/behavior-based profiling, use of cookies), remarketing, evaluation of visit actions, interest-based and behavior-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), target group formation (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes).
• Security measures: IP masking (pseudonymization of the IP address).
• Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
• Right to object (Opt-Out): We refer to the data protection notices of the respective providers and the opt-out options (so-called "opt-out") specified for the providers. If no explicit opt-out option has been specified, there is the possibility that you can disable cookies in your browser settings. However, this may restrict the functionality of our online offering. We therefore also recommend the following opt-out options, which are offered in summary for the respective areas:a) Europe: https://www.youronlinechoices.eu.
  b) Canada: https://www.youradchoices.ca/choices.
  c) USA: https://www.aboutads.info/choices.
  d) Cross-regional: https://optout.aboutads.info.

Services used and service providers:

• Facebook Pixel and Custom Audiences: With the help of the Facebook Pixel (or comparable functions for transmitting event data or contact information via interfaces in apps), Facebook is able to determine visitors to our online offering as a target group for the display of advertisements (so-called "Facebook Ads"). Accordingly, we use the Facebook Pixel to show Facebook Ads placed by us only to users on Facebook and within the services of partners cooperating with Facebook (so-called "Audience Network" https://www.facebook.com/audiencenetwork/) who have shown an interest in our online offering or who have certain characteristics (e.g., interest in certain topics or products, which become apparent from the visited websites) that we transmit to Facebook (so-called "Custom Audiences"). With the help of the Facebook Pixel, we also want to ensure that our Facebook Ads correspond to the potential interests of users and do not appear annoying. With the help of the Facebook Pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called "conversion measurement"); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Standard contractual clauses (guaranteeing data protection level when processed in third countries): The "Facebook EU Data Transfer Addendum" (https://www.facebook.com/legal/EU_data_transfer_addendum) applies in the case of commissioned processing by Facebook as the basis for processing event data of EU citizens in the USA and the inclusion in Facebook's "Platform Terms" (https://developers.facebook.com/terms) with regard to Facebook's independent processing of event data for advertising purposes; Further information: The "Data Processing Terms" (https://www.facebook.com/legal/terms/dataprocessing/update) apply with regard to event data that Facebook processes on behalf of companies to provide reports and analyses; Furthermore, the "Controller Addendum" applies as an agreement on joint controllership (Art. 26 para. 1 sentence 3 GDPR), which is relevant in the case of Facebook's independent processing of event data for targeting purposes as well as the improvement and security of Facebook products.
• Google Ad Manager: We use the "Google Marketing Platform" (and services such as "Google Ad Manager") to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.). The Google Marketing Platform is characterized by the fact that ads are displayed in real time based on the presumed interests of users. This allows us to display ads for and within our online offering more targeted, to present users only with ads that potentially correspond to their interests. If, for example, a user is shown ads for products in which they have shown interest on other online offerings, this is referred to as "remarketing"; 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; Privacy Policy: https://policies.google.com/privacy; Further information: Types of processing and processed data: https://privacy.google.com/businesses/adsservices; Data processing terms for Google advertising products: Information on the services data processing terms between controllers and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms; if Google acts as a processor, data processing terms for Google advertising products and standard contractual clauses for third-country data transfers: https://business.safety.google/adsprocessorterms.
• Google Ads and Conversion Measurement: We use the online marketing process "Google Ads" to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.), so that they are shown to users who have a presumed interest in the ads (so-called "conversion"). We also measure the conversion of the ads. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page equipped with a so-called "conversion tracking tag". We ourselves do not receive any information that could identify users; 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; Privacy Policy: https://policies.google.com/privacy; Further information: Types of processing and processed data: https://privacy.google.com/businesses/adsservices; Data processing terms for Google advertising products: Information on the services data processing terms between controllers and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.

Presences in Social Networks (Social Media)

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

We point out that user data may be processed outside the European Union. This may result in risks for users, for example, because the enforcement of user rights could be made more difficult.

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created based on user behavior and resulting interests. These usage profiles, in turn, can be used to display advertisements within and outside the networks that presumably correspond to the users' interests. For these purposes, cookies are generally stored on the users' computers, in which user behavior and interests are stored. Furthermore, data can also be stored in the usage profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in there).

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

Even 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 user data and can directly take appropriate measures and provide information. Should you still need help, you can contact us.

• Types of data processed: Master data (e.g., names, addresses), contact data (e.g., email, phone numbers), content data (e.g., entries in online forms), usage data (e.g., visited websites, 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 processing: Contact inquiries and communication, tracking (e.g., interest-based/behavioral profiling, use of cookies), remarketing, reach measurement (e.g., access statistics, recognition of recurring visitors).
• Legal basis: Legitimate interests (Art. 6 para. 1 lit. f GDPR).

Services used and service providers:

• Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy.

Plugins and embedded features and content

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

The integration always requires that the third-party providers of this content process the IP address 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 required for the display of this content or functions. We endeavor to only use content whose respective providers only use the IP address for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. "Pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the users' device and may include technical information about the browser and operating system, referring websites, visit time, and other information about the use of our online offering, and can also be linked to such information from other sources.

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

• Types of data processed: Usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses), location data (information about the geographical position of a device or person), content data (e.g., entries in online forms), inventory data (e.g., names, addresses), contact data (e.g., email, phone numbers).
• Affected persons: Users (e.g., website visitors, users of online services), communication partners.
• Purposes of processing: Provision of our online offering and user-friendliness, provision of contractual services and customer service, contact inquiries and communication, tracking (e.g., interest/behavioral profiling, use of cookies), interest-based and behavioral marketing, profiling (creation of user profiles), security measures, administration and response to inquiries.
• Legal bases: Legitimate interests (Art. 6 para. 1 lit. f GDPR), consent (Art. 6 para. 1 lit. a GDPR), fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 lit. b GDPR).

Services and service providers used:

• Facebook Plugins and Content: Facebook Social Plugins and Content – This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online offering within Facebook. The list and appearance of Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/– Together with Meta Platforms Ireland Limited, we are jointly responsible for the collection or receipt as part of a transmission (but not the further processing) of "event data" that Facebook collects via Facebook social plugins (and content embedding functions) executed on our online offering or receives as part of a transmission for the following purposes: a) displaying content and advertising information that corresponds to the alleged interests of users; b) delivering commercial and transactional messages (e.g., addressing users via Facebook Messenger); c) improving ad delivery and personalizing functions and content (e.g., improving the detection of what content or advertising information allegedly corresponds to the interests of users). We have concluded a special agreement with Facebook ("Controller Addendum", https://www.facebook.com/legal/controller_addendum), which specifies, in particular, what security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the rights of data subjects (i.e., users can, for example, direct requests for information or deletion directly to Facebook). Note: If Facebook provides us with metrics, analyses, and reports (which are aggregated, i.e., contain no information about individual users and are anonymous to us), this processing does not take place within the scope of joint responsibility, but on the basis of a data processing agreement ("Data Processing Terms", https://www.facebook.com/legal/terms/dataprocessing), the "Data Security Terms" (https://www.facebook.com/legal/terms/data_security_terms) as well as, with regard to processing in the USA, on the basis of standard contractual clauses ("Facebook EU Data Transfer Addendum", https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy.
• Google Fonts: We integrate the fonts ("Google Fonts") of the provider Google, whereby the user 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 display, and considering 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/; Privacy Policy: https://policies.google.com/privacy.
• Google Maps: We integrate the maps from the "Google Maps" service provided by Google. The processed data may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually obtained through 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 option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for displaying advertisements: https://adssettings.google.com/authenticated.
• Twitter Plugins and Content: Twitter Plugins and Buttons – This may include, for example, content such as images, videos or texts and buttons that allow users to share content from this online offering within Twitter; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, Parent company: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Website:https://twitter.com/de; Privacy Policy:https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
• YouTube Videos: Video content; 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://www.youtube.com; Privacy Policy:https://policies.google.com/privacy; Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for displaying advertisements: https://adssettings.google.com/authenticated.

Deletion of Data

The data processed by us will be deleted in accordance with legal requirements as soon as the consents permitted for their processing are revoked or other permissions cease to apply (e.g., if the purpose of processing this data has lapsed or they are no longer necessary for the purpose).

If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted to these purposes. This means that 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 reasons or whose storage is necessary for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person.

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

Amendment and Update of the Privacy Policy

We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as changes require your cooperation (e.g., consent) or other individual notification.

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

Rights of Data Subjects

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

• Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, you shall have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
• Right to withdraw consent: You have the right to withdraw given consents at any time.
• Right of access: You have the right to request confirmation as to whether data concerning you is being processed and for information about this data as well as for further information and a copy of the data in accordance with legal requirements.
• Right to rectification: In accordance with legal requirements, you have the right to demand the completion of data concerning you or the rectification of inaccurate data concerning you.
• Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to demand that data concerning you be erased without undue delay, or alternatively, in accordance with legal requirements, to demand 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, commonly used and machine-readable format in accordance with legal requirements, or to demand its transmission to another controller.
• Right to lodge a complaint with a supervisory authority: You also have the right, in accordance with legal requirements, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Definitions

In this section, you will find an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined primarily in Article 4 of the GDPR. The legal definitions are binding. The following explanations are primarily intended to aid understanding. The terms are sorted alphabetically.

• Visit action evaluation: "Visit action evaluation" (English "Conversion Tracking") refers to a method with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users' devices within the websites where the marketing measures take place and then retrieved again on the target website. For example, we can thus track whether the ads we placed on other websites were successful.
• Credit assessment: Automated decisions are based on automatic data processing without human intervention (e.g., in the case of an automatic rejection of a purchase on account, an online loan application, or an online application process without any human intervention). Such automated decisions are only permissible under Article 22 GDPR if data subjects consent, if they are necessary for the fulfillment of a contract, or if national laws permit these decisions.
• Cross-Device Tracking: Cross-device tracking is a form of tracking in which behavioral and interest information of users is recorded across devices in so-called profiles by assigning an online identifier to the users. This allows user information to be analyzed, typically for marketing purposes, regardless of the browsers or devices used (e.g., mobile phones or desktop computers). The online identifier is not linked to clear data, such as names, postal addresses, or email addresses, for most providers.