GDPR

GDPR

Data Privacy

Preamble


With the following privacy policy, we would like to inform you about which types of your personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent in the context of the provision of our application.

The terms used are not gender-specific.

Last updated: March 14, 2023


Outline


Person in charge


ACC Flugsimulations GmbH
59581 Warstein

E-mail address:

mail@acc.world


Contact Data Protection Officer

mail@acc.world


Overview of processing operations

The following table summarises the types of data processed and the purposes for which they are processed, and refers to the data subjects.


Types of data processed


  • Inventory data.
  • Payment.
  • Standortdaten.
  • Contact details.
  • Inhaltsdaten.
  • Contract.
  • Usage.
  • Meta, communication and procedural data.
  • Event data (Facebook).


Categories of data subjects


  • Customers.
  • Interested parties.
  • Communication.
  • User.
  • Business and contractual partners.


Purposes of processing


  • Provision of contractual services and customer service.
  • Contact requests and communication.
  • Security Measures.
  • Direct marketing.
  • Reichweitenmessung.
  • Tracking.
  • Office and organizational procedures.
  • Konversionsmessung.
  • Manage and respond to requests.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offer and user-friendliness.
  • Information technology infrastructure.


Relevant legal bases


Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection requirements may apply in your or our country of residence or domicile. Furthermore, if more specific legal bases are relevant in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or for several specific purposes.
  • Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) - The processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures taken at the request of the data subject.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) - The processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) - The processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and the transmission and automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (§ 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. In addition, the data protection laws of the individual federal states may apply.


Security Measures


In accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

The measures shall 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, availability and segregation of data. In addition, we have put in place procedures to ensure the exercise of data subject rights, the deletion of data and reactions to the risk of data being compromised. Furthermore, we take the protection of personal data into account as early as the development and selection of hardware, software and processes in accordance with the principle of data protection, through technical design and through privacy-friendly default settings.

Shortening of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not necessary, the IP address will be shortened (also referred to as "IP masking"). In this case, the last two digits, or the last part of the IP address, are removed after a dot or replaced by placeholders. The abbreviation of the IP address is intended to prevent or make it much more difficult to identify a person by his or her IP address.


Transfer of personal data


In the course of our processing of personal data, it happens 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, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.


Deletion of data


The data processed by us will be deleted in accordance with the legal requirements as soon as their consents to processing are revoked or other permissions cease to apply (e.g. if the purpose of the processing of this data has ceased to exist or if it is not necessary for the purpose). Unless the data is erased because it is necessary for other purposes permitted by law, its processing will be limited to those purposes. This means that the data will be blocked and will not be processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or the storage of which is necessary for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.

Our privacy policy may also contain further information on the retention and deletion of data that takes precedence over the respective processing.


Use of cookies


Cookies are small text files or other storage notes that store information on end devices and read information from the end devices. For example, to store the login status in a user account, a shopping cart content in an e-shop, the accessed content or used functions of an online offer. Cookies can also be used for various purposes, e.g. for the purposes of the functionality, security and convenience of online offers as well as the creation of 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 required by law. In particular, consent is not required if the storage and reading of the information, including cookies, is absolutely necessary in order to provide the user with a telemedia service expressly requested by them (i.e. our online offer). The revocable consent is clearly communicated to the users and contains the information about the respective cookie usage.

Notes on data protection legal bases: The legal basis on which we process users' personal data with the help of cookies depends on whether we ask users for consent. If users give their consent, the legal basis for the processing of their data is their consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and improvement of its usability) or, if this is done in the context of the fulfilment of our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. We explain the purposes for which the cookies are processed by us in the course of this privacy policy or as part of our consent and processing processes.

Storage period: With regard to the storage period, a distinction is made between the following types of cookies:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his device (e.g. browser or mobile application).
  • Persistent cookies: Persistent cookies remain stored even after the device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. User data collected with the help of cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g. as part of obtaining consent), users should assume that cookies are permanent and can be stored for up to two years.

General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also object to the processing in accordance with the legal requirements in Art. 21 GDPR. Users can also object via their browser settings, e.g. by disabling the use of cookies (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.

Further information on processing processes, procedures and services:

  • Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the consent of users to the use of cookies, or the processing and providers mentioned in the context of the cookie consent management procedure, can be obtained, as well as managed and revoked by the users. In this case, the declaration of consent is stored in order not to have to repeat its request again and to be able to prove the consent in accordance with the legal obligation. The data can be stored on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. In this case, a pseudonymous user identifier is formed and stored with the time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and device used.


Business Services


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

We process this data in order to fulfil our contractual obligations. This includes, in particular, the obligations to provide the agreed services, any updating obligations and remedies in the event of warranty and other service failures. In addition, we process the data in order to safeguard our rights and for the purpose of the administrative tasks associated with these obligations, as well as the organization of the company. In addition, we process the data on the basis of our legitimate interests in proper and business management as well as in security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the scope of applicable law, we only pass on the data of contractual partners to third parties insofar as this is necessary for the aforementioned purposes or for the fulfilment of legal obligations. The contractual partners are informed about other forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.

We inform the contractual partners which data is required for the aforementioned purposes before or as part of the data collection, e.g. in online forms, by means of special markings (e.g. colours) or symbols (e.g. asterisks or similar), or in person.

We delete the data after expiry of statutory warranty and comparable obligations, i.e., generally after the expiry of 4 years, unless the data is stored in a customer account, e.g. as long as it must be stored for legal reasons of archiving. The statutory retention period is ten years for documents relevant to tax law as well as for trading books, inventories, opening balance sheets, annual financial statements, the work instructions and other organizational documents and accounting documents required to understand these documents, and six years for received commercial and business letters and reproductions of the sent commercial and business letters. The period shall commence at the end of the calendar year in which the last entry in the book was made, the inventory, the opening balance sheet, the annual financial statements or the management report were drawn up, the commercial or business letter was received or sent, or the accounting document was created, the record was made or the other documents were created.

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.

  • Types of data processed: inventory data (e.g. names, addresses); Payment data (e.g. bank details, invoices, payment history); contact details (e.g. e-mail, telephone numbers); Contract data (e.g. subject matter of the contract, duration, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status).
  • Data subjects: Customers; Interested parties; Business and contractual partners.
  • Purposes of processing: Provision of contractual services and customer service; security measures; contact requests and communication; Office and organizational procedures; managing and responding to requests; conversion measurement (measuring the effectiveness of marketing efforts); Profiles with user-related information (creating user profiles).
  • Legal basis: Performance of a contract and pre-contractual enquiries (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).

Further information on processing processes, procedures and services:

  • Customer account: Contractual partners can create an account within our online offer (e.g. customer or user account, or "customer account" for short). If the registration of a customer account is required, contractual partners 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. As part of the registration as well as subsequent logins and use of the customer account, we store the IP addresses of the customers along with the access times in order to be able to prove the 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 the retention of which is required by law. It is the customer's responsibility to back up their data in the event of termination of the customer account; Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
  • Economic analyses and market research: For business reasons and in order to be able to identify market trends, wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., whereby the group of data subjects may include contractual partners, interested parties, customers, visitors and users of our online offer. The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). If available, we may take into account the profiles of registered users and their information, e.g. on services used. The analyses are for our sole use and will not be disclosed externally, unless they are anonymous analyses with summarized, i.e. anonymized, values. Furthermore, we take into account the privacy of the users and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as aggregated data); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Shop and e-commerce: We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and related services, as well as to pay for them and deliver them or execute them. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution for our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such in the context of the order or comparable purchase process and includes the information required for delivery, provision and billing as well as contact information in order to be able to hold any consultation; Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR)


Vendors and Services Used in Business Operations


As part of our business activities, we use additional third-party services, platforms, interfaces or plug-ins (short "Services") in compliance with legal requirements. Their use is based on our interests in a proper, lawful and - This text area must be activated with a premium license. - Premiumtext Premiumtext Premiumtext Premiumtext Premiumtext Premiumtext Premiumtext Premiumtext Premiumtext Premiumtext Premiumtext

  • Types of data processed: inventory data (e.g. names, addresses); Payment data (e.g. bank details, invoices, payment history - This text area must be activated with a premium license. - Premiumtext Premiumtext ); contact details (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Contract data (e.g. subject matter of the contract, duration, customer category - This text area must be activated with a premium license. - Premiumtext Premiumtext ).
  • Data subjects: Customers; Interested parties; Users (e.g. website visitors, users of - This text area must be activated with a premium license. - PremiumText Premiumtext Premiumtext ); Business and contractual partners.
  • Purposes of processing: Provision of contractual services and customer service; Office and organizational procedures.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).


Payment


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

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, sum and recipient-related information. The details are required to carry out the transactions. However, the data entered will only be processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transfer is to verify identity and creditworthiness. For this purpose, we refer to the terms and conditions and the data protection notices of the payment service providers.

The terms and conditions and data protection notices of the respective payment service providers, which can be accessed within the respective websites or transaction applications, apply to payment transactions. We also refer to them for further information and to assert rights of revocation, information and other rights of data subject.

  • 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 the contract, duration, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status).
  • Data subjects: Customers; Interested parties.
  • Purposes of processing: Provision of contractual services and customer service.
  • Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further information on processing processes, procedures and services:

  • Giropay: payment services (technical integration of online payment methods); Service provider: giropay GmbH, An der Welle 4, 60322 Frankfurt, Germany; Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.giropay.de; Privacy Policy: https://www.giropay.de/rechtliches/datenschutzerklaerung/.
  • Klarna / Sofortüberweisung: Payment services (technical connection of online payment methods); Service provider: Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden; Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.klarna.com/de; Privacy Policy: https://www.klarna.com/de/datenschutz.
  • PayPal: payment services (technical connection of online payment methods) (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; Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.paypal.com/de; Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
  • Stripe: payment services (technical integration of online payment methods); Service Provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://stripe.com; Privacy Policy: https://stripe.com/de/privacy.


Provision of the online offer and web hosting


We process users' data in order to be able to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or device.

  • Types of data processed: usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status); Content data (e.g. entries in online forms).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.); security measures; Provision of contractual services and customer service.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

  • Provision of our online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also known as a "web host"); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Collection of access data and log files: Access to our online services is logged in the form of so-called "server log files". The server log files may include the address and name of the websites and files accessed, date and time of access, data volumes transferred, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. On the one hand, 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, on the other hand, to ensure the utilization of the servers and their stability; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is necessary for evidentiary purposes are excluded from deletion until the respective incident has been finally clarified.
  • 1&1 IONOS: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.ionos.de; Privacy Policy: https://www.ionos.de/terms-gtc/terms-privacy; Data processing agreement: https://www.ionos.de/hilfe/datenschutz/allgemeine-informationen-zur-datenschutz-grundverordnung-dsgvo/auftragsverarbeitung/.
  • Instart: Content-Delivery-Network (CDN) - service with the help of which content of an online offering, in particular large media files, such as graphics or program scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet; Service Provider: Instart Logic, Inc., 450 Lambert Avenue, Palo Alto, CA 94306, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instart.com; Privacy Policy: https://www.instart.com/company/legal/privacy-policy.


Contact & Enquiry Management


When contacting us (e.g. by post, contact form, e-mail, telephone or social media) as well as in the context of existing user and business relationships, the information of the enquiring persons will be processed insofar as this is necessary to answer the contact requests and any requested measures.

  • Types of data processed: contact details (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 and procedural data (e.g. IP addresses, times, identification numbers, consent status).
  • Data subjects: Communication partners.
  • Purposes of processing: contact requests and communication; managing and responding to requests; feedback (e.g. collecting feedback via online form); Provision of our online offer and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).


Communication via messenger


We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, encryption, the use of the metadata of the communication and your options for objecting.

You can also contact us in alternative ways, e.g. by phone or e-mail. Please use the contact options provided to you or the contact options provided within our online offer.

In the case of end-to-end encryption of content (i.e., the content of your message and attachments), please note that the content of the communication (i.e., the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use an up-to-date version of Messenger with encryption enabled to ensure that message content is encrypted.

However, we would also like to point out to our communication partners that although the providers of the messengers do not view the content, they can find out that and when communication partners communicate with us, as well as technical information about the device used by the communication partners and, depending on the settings of their device, location information (so-called metadata) is processed.

Notes on legal bases: If we ask communication partners for permission before communicating with them via messenger, the legal basis for our processing of their data is their consent. In addition, if we do not ask for your consent and you contact us, for example, on your own initiative, we use Messenger in relation to our contractual partners as well as in the context of the initiation of the contract as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and in meeting the needs of our communication partners in communication via Messenger. Furthermore, we would like to point out that we will not transmit the contact details provided to us to the messengers for the first time without your consent.

Revocation, objection and deletion: You can revoke your consent at any time and -


  • Types of data processed: contact details (e.g. e-mail, telephone numbers); Usage data (e.g. websites visited, interest in content, - This text area must be activated with a premium license. - Premiumtext Premiumtext Premiumtext ); Meta, communication and procedural data (e.g. IP addresses, time details, identification numbers, - This text area must be activated with a premium license. - Premiumtext Premiumtext Premiumtext ).
  • Data subjects: Communication partners.
  • Purposes of processing: contact requests and communication; Direct marketing (e.g. by e-mail or post).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).


Newsletters and electronic notifications


We only send newsletters, e-mails and other electronic notifications (hereinafter referred to as "newsletters") with the consent of the recipients or a legal permission. Insofar as the contents of the newsletter are specifically described in the context of a subscription, they are decisive for the consent of the user. In addition, our newsletters contain information about our services and us.

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

Double opt-in procedure: Registration for our newsletter is generally carried out in a so-called double opt-in procedure. This means that you will receive an e-mail after registration in which you will be asked to confirm your registration. This confirmation is necessary so that no one can log in with someone else's email addresses. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider will also be logged.

Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years on the basis of 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 a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe contradictions, we reserve the right to store the e-mail address in a blacklist (so-called "blocklist") solely for this purpose.

The registration process is logged on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system.

Contents:

Information about us, our services, promotions and offers.

  • Types of data processed: inventory data (e.g. names, addresses); contact details (e.g. e-mail, telephone numbers); Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g. by e-mail or post).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
  • Possibility of objection (opt-out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent, or .dem object to further receipt. You will either find a link to unsubscribe from the newsletter at the end of each newsletter or you can use one of the contact options listed above, preferably e-mail.


Promotional communication via e-mail, post, fax or telephone


We process personal data for the purpose of advertising communication, which can be carried out via various channels, such as e-mail, telephone, post or fax, in accordance with the legal requirements.

Recipients have the right to revoke their consent at any time or to object to promotional communication at any time.

After revocation or objection, we store the data required to prove the previous authorization for contacting or sending you for up to three years after the end of the year of the revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defence against claims. On the basis of the legitimate interest in permanently observing the revocation or objection of the users, we also store the data necessary to avoid re-contacting them (e.g. e-mail address, telephone number, name, depending on the communication channel).

  • Types of data processed: inventory data (e.g. names, addresses); Contact details (e.g. e-mail, telephone numbers).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g. by e-mail or post).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).


Web Analysis, Monitoring and Optimization


Web analysis (also referred to as "reach measurement") is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the reach analysis, we can, for example, identify at what time our online offer or its functions or content are most frequently used or invite them to reuse. We can also understand which areas need to be optimized.

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

Unless otherwise stated below, profiles, i.e. data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in a device and read from it. The information collected includes, in particular, websites visited and elements used there, as well as 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 vis-à-vis us or the providers of the services we use, location data may also be processed.

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

  • Types of data processed: usage data (e.g. websites visited, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creating user profiles); Tracking (e.g. interest/behavioural profiling, use of cookies); Provision of our online offer and user-friendliness.
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing processes, procedures and services:


Online Marketing


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

For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar processes are used, by means of which the information about the user relevant to the presentation of the aforementioned content 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, as well as information on usage times and functions used. If users have consented to the collection of their location data, this data can also be processed.

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

The information in the profiles is usually stored in cookies or by means of similar processes. 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 further data and stored on the server of the online marketing process provider.

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

As a matter of principle, we only have access to aggregated information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e. e.g. to the conclusion of a contract with us. Conversion measurement is used solely to analyze the success of our marketing efforts.

Unless otherwise specified, we ask you to assume that cookies used will be stored for a period of two years.

  • Types of data processed: usage data (e.g. websites visited, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status).
  • Data subjects: 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/behavioural profiling, use of cookies); Marketing; profiles with user-related information (creating user profiles); Conversion measurement (measuring the effectiveness of marketing efforts).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the objection options specified for the providers (so-called "opt-out"). If no explicit opt-out option has been specified, you have the option of disabling cookies in your browser settings. However, this may restrict the functions of our online offering. We therefore also recommend the following opt-out options, which are offered in summary 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) Cross-territorial: https://optout.aboutads.info.

Further information on processing processes, procedures and services:


Presence in social networks (social media)


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

We would like to point out that user data may be processed outside the area of the European Union. This may result in risks for users, e.g. because it could make it more difficult to enforce users' rights.

Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, user profiles can be created on the basis of user behavior and the resulting interests of the users. In turn, the user profiles can be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on users' computers, in which the user's usage behaviour and interests are stored. Furthermore, data may also be stored in the usage profiles, regardless 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 options for objection (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the user's data and can directly take appropriate measures and provide information. If you still need help, you can contact us.

  • Types of data processed: contact details (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 and procedural data (e.g. IP addresses, times, identification numbers, consent status).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: contact requests and communication; feedback (e.g. collecting feedback via online form); Marketing.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

  • Instagram: Social network; Service Provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy.
  • Facebook pages: Profiles within the social network Facebook - Together with Meta Platforms Ireland Limited, we are responsible for the collection (but not the further processing) of data of visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content that users view or interact with, or the actions they take (see "Things you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices users use (e.g., IP addresses, operating system, browser type, language preferences, cookie data; see "Device Information" in the Facebook Data Policy: https://www.facebook.com/policy). As explained in Facebook's Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services called "Page Insights" to Page Operators to help them understand how people interact with their Pages and with the content associated with them. We have entered into a special agreement with Facebook ("Page Insights Information", https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). 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. Further information can be found in the "About Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data); Service Provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Standard contractual clauses (ensuring the level of data protection for processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; For more information, please see: Joint Responsibility Agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data. Joint responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular with regard to the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the Standard Contractual Clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
  • YouTube: social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Privacy Policy: https://policies.google.com/privacy; Possibility of objection (opt-out): https://adssettings.google.com/authenticated.


Plugins and embedded functions as well as content


We integrate functional and content elements into our online offering, which are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). This may include, for example, graphics, videos or city maps (hereinafter referred to collectively as "Content").

The integration always presupposes that the third-party providers of this content process the IP address of the users, as without the IP address they would not be able to send the content to their browser. The IP address is therefore required for the display of this content or functions. We make every effort to only use content whose respective providers only use the IP address to deliver the content. Third parties may also use pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information on the browser and operating system, referring websites, time of visit and other information on the use of our online offering, as well as be combined with such information from other sources.

  • Types of data processed: usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status); Inventory data (e.g. names, addresses); contact details (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Location data (information about the geographic location of a device or person); Event data (Facebook) ("Event data" is data that can be transmitted by us to Facebook, e.g. via Facebook pixel (via apps or other means) and relates to individuals or their actions; The data includes, for example, information about visits to websites, interactions with content, features, installations of apps, purchases of products, etc.; the event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); Event data does not include the actual content (such as written comments), login information, and contact information (i.e., names, email addresses, and phone numbers). Event data will be deleted by Facebook after a maximum of two years, the target groups formed from it will be deleted with the deletion of our Facebook account).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness; Provision of contractual services and customer service.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing processes, procedures and services:

  • 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 offer within Facebook. The list and appearance of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/ - We are jointly with Meta Platforms Ireland Limited responsible for the collection or receipt in the context of a transfer (but not further processing) of "Event Data" that Facebook collects or collects in the context of the Facebook social plugins (and embed functions for content) that are carried out on our online offering. in the context of a transfer for the following purposes: a) display of content and advertising information that correspond to the presumed interests of the users; b) delivery of commercial and transactional messages (e.g. targeting users via Facebook Messenger); c) Improve ad delivery and personalize features and content (e.g., improve identification of what content or advertising information is likely to be in line with users' interests). We have concluded a special agreement with Facebook ("Addendum for Controllers", https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with metrics, analyses and reports (which are aggregated, i.e. do not receive any information about individual users and are anonymous to us), then this processing is not carried out within the framework 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 Conditions' (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; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy.
  • Google Fonts (sourced from Google Server): Procurement of fonts (and symbols) for the purpose of a technically secure, maintenance-free and efficient use of fonts and symbols with regard to topicality and loading times, their uniform presentation and consideration of possible licensing restrictions. The user's IP address is provided to the provider of the fonts so that the fonts can be made available in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) necessary for the provision of the fonts depending on the devices used and the technical environment are transmitted. This data may be processed on a server of the provider of the fonts in the USA - When visiting our website, the user's browser sends its browser HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving the fonts). The Google Fonts Web API provides users with Google Fonts' Cascading Style Sheets (CSS) and then the fonts specified in the CCS. These HTTP requests include (1) the IP address used by each user to access the Internet, (2) the requested URL on Google's server, and (3) the HTTP headers, including the user agent that describes the browser and operating system versions of the website visitors, and the referring URL (i.e., the web page on which the Google font is to be displayed). IP addresses are not logged or stored on Google servers and are not analyzed. The Google Fonts Web API logs details of the HTTP requests (requested URL, user agent, and referral URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent has to customize the font that is generated for the respective browser type. The user-agent is primarily logged for debugging and is used to generate aggregate usage statistics that are used to measure the popularity of font families. These aggregated usage statistics are published on the Google Fonts Analytics page. Finally, the referral URL is logged so that the data can be used for production maintenance and an aggregated report on the top integrations based on the number of font requests can be generated. According to Google, it does not use any of the information collected by Google Fonts to create profiles of end users or to serve targeted ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy; Further information: https://developers.google.com/fonts/faq/privacy?hl=de.
  • Google Maps: We integrate the maps of the "Google Maps" service of the provider Google. The data processed may include, in particular, IP addresses and location data of users; Service Provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://mapsplatform.google.com/; Privacy Policy: https://policies.google.com/privacy.
  • OpenStreetMap: We integrate the maps of the service "OpenStreetMap", which are offered on the basis of the Open Data Commons Open Database License (ODbL) by the OpenStreetMap Foundation (OSMF). The data of the users is used by OpenStreetMap exclusively for the purpose of displaying the map functions and for the intermediate storage of the selected settings. This data may include, in particular, IP addresses and location data of users, which, however, are not collected without their consent (usually carried out as part of the settings of their mobile devices); Service provider: OpenStreetMap Foundation (OSMF); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.openstreetmap.de; Privacy Policy: https://wiki.osmfoundation.org/wiki/Privacy_Policy.
  • YouTube videos: video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Possibility of objection (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • YouTube videos: video content; YouTube videos are integrated via a special domain (recognizable by the component "youtube-nocookie") in the so-called "extended data protection mode", which means that no cookies are collected on user activities in order to personalize the video playback. Nevertheless, information about the user's interaction with the video (e.g. remembering the last playback point) may be stored; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy.


Changes and updates to the Privacy Policy


We ask you to regularly inform yourself about the content of our privacy policy. We will amend the Privacy Policy as soon as the changes to the data processing we carry out make it necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or another 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 us.


Rights of data subjects


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

  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data which is carried out on the basis of Art. 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions. If your personal data is processed for the purpose of direct marketing, you have the right to object at any time to the processing of your personal data for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw your consent at any time.
  • Right of access: You have the right to request confirmation as to whether the data in question is being processed and to request access to this data, as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the law, you have the right to request the completion of the data concerning you or the correction of the inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be erased without undue delay or, alternatively, to demand that the processing of the data be restricted in accordance with the legal requirements.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with the legal requirements, or to request that it be transmitted to another controller.
  • Lodge a complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you believe that the processing of your personal data infringes the requirements of the GDPR.


Definitions


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

  • Conversion measurement: Conversion measurement (also known as "visit action evaluation") is a method used to determine the effectiveness of marketing efforts. For this purpose, a cookie is usually stored on the user's devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, it allows us to understand whether the ads we serve on other websites have been successful.
  • Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter referred to as "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. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any type of automated processing of personal data consisting in the use of such personal data to identify certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information relating to demographics, behaviour and interests, such as interacting with websites and their content, etc.) analyze, evaluate, or predict them (e.g., interest in certain content or products, click behavior on a website, or location). Cookies and web beacons are often used for profiling purposes.
  • Reach measurement: Reach measurement (also referred to as web analytics) is used to evaluate the flow of visitors to an online offer and can include the behavior or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, see at what time visitors visit their website and what content they are interested in. This allows them to better adapt the content of the website to the needs of their visitors, for example. For the purpose of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
  • 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 Wi-Fi network or similar technical means and functions of location determination. Location data is used to indicate the geographically determinable position on earth at which the respective device is located. Location data can be used, for example, to display map functions or other location-related information.
  • Tracking: "Tracking" is when the behavior of users can be tracked across several online offers. As a rule, behavioural and interest information is stored in cookies or on servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can then be used, for example, to show users advertisements that are likely to match their interests.
  • Controller: "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.
  • Processing: "Processing" means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and encompasses practically any handling of data, be it collection, evaluation, storage, transmission or deletion.


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