Legal

Privacy Policy

Hoenle Medical GmbH · As of: 28 July 2020

Please note: This is a courtesy translation. Only the German version of this privacy policy is legally binding. In the event of any discrepancy, the German version prevails.

Introduction

With the following privacy policy we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that we process, for what purposes and to what extent. The 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, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer").

The terms used are not gender-specific.

As of: 28 July 2020

Table of contents

Controller

Hoenle Medical GmbH

Authorised representatives: Hoenle Medical GmbH

Email address: medizin@hoenlemedical.com

Legal notice: https://www.hoenlemedical.com/en/impressum

Contact of the Data Protection Officer

Mr Albin Gashi
datenschutz@drhoenle.de

Overview of processing

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

Types of data processed

  • Inventory data (e.g. names, addresses).
  • Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, CV, certificates, as well as further information about their person or qualification provided by applicants with regard to a specific position or voluntarily).
  • Content data (e.g. text entries, photographs, videos).
  • Contact data (e.g. email, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Location data (data indicating the location of an end user's terminal device).
  • Contract data (e.g. subject of contract, term, customer category).
  • Payment data (e.g. bank details, invoices, payment history).

Categories of data subjects

  • Employees (e.g. staff, applicants, former employees).
  • Applicants.
  • Business and contractual partners.
  • Interested parties.
  • Communication partners.
  • Customers.
  • Users (e.g. website visitors, users of online services).

Purposes of processing

  • Assessment of creditworthiness and credit standing.
  • Provision of our online offer and user-friendliness.
  • Visit action evaluation.
  • Application procedure (establishment and possible later execution as well as possible later termination of the employment relationship).
  • Office and organisational procedures.
  • Direct marketing (e.g. by email or post).
  • Interest-based and behaviour-based marketing.
  • Contact requests and communication.
  • Conversion measurement (measurement of the effectiveness of marketing measures).
  • Profiling (creation of user profiles).
  • Remarketing.
  • Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures.
  • Tracking (e.g. interest-/behaviour-based profiling, use of cookies).
  • Contractual services and service.
  • Administration and response to enquiries.

Automated decisions in individual cases

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

Relevant legal bases

In the following we inform you of the legal bases of the General Data Protection Regulation (GDPR) on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, the national data protection requirements in your or our country of residence and domicile may apply. Should more specific legal bases also be relevant in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6(1)(1)(a) GDPR) – The data subject has given their consent to the processing of their personal data for a specific purpose or several specific purposes.
  • Performance of a contract and pre-contractual enquiries (Art. 6(1)(1)(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)(1)(c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6(1)(1)(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 the protection of personal data.
  • Art. 9(1)(1)(b) GDPR (application procedure as a pre-contractual or contractual relationship) (Insofar as, within the scope of the application procedure, special categories of personal data within the meaning of Art. 9(1) GDPR (e.g. health data, such as severe-disability status or ethnic origin) are requested from applicants so that the controller or the data subject can exercise the rights and comply with the obligations arising from employment law and the law of social security and social protection, their processing is carried out pursuant to Art. 9(2)(b) GDPR; in the case of the protection of vital interests of applicants or other persons pursuant to Art. 9(2)(c) GDPR; or for the purposes of preventive healthcare or occupational medicine, for the assessment of the working capacity of the employee, for medical diagnosis, care or treatment in the health or social sector, or for the management of health or social care systems and services pursuant to Art. 9(2)(h) GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9(2)(a) GDPR.) – .

National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. This includes in particular the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains in particular special regulations on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as 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, execution or termination of employment relationships as well as the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

Security measures

We take appropriate technical and organisational 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 varying likelihood and severity of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, availability and separation concerning it. Furthermore, we have set up procedures that ensure the exercise of data-subject rights, the deletion of data and reactions to threats to the data. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design and by default.

Shortening of the IP address: Insofar as it is possible for us or storage of the IP address is not necessary, we shorten your IP address or have it shortened. In the case of shortening the IP address, also referred to as "IP masking", the last octet, i.e. the last two numbers of an IP address, is deleted (in this context, the IP address is an identifier individually assigned to an internet connection by the online access provider). The shortening of the IP address is intended to prevent or substantially impede the identification of a person on the basis of their IP address.

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

Transmission and disclosure 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 is disclosed to them. Recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases we observe the legal requirements and, in particular, conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.

Use of cookies

Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user's computer. A cookie primarily serves to store information about a user during or after their visit within an online offer. The stored information can include, for example, the language settings on a website, the login status, a shopping cart or the point at which a video was watched. The term cookies also includes other technologies that fulfil the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also referred to as "user IDs").

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their browser.
  • Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be stored or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users used for reach measurement or marketing purposes can be stored in such a cookie.
  • First-party cookies: First-party cookies are set by us ourselves.
  • Third-party cookies: Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or strictly required) cookies: Cookies can, on the one hand, be strictly necessary for the operation of a website (e.g. to store logins or other user entries or for reasons of security).
  • Statistics, marketing and personalisation cookies: Furthermore, cookies are usually also used in the context of reach measurement as well as when the interests of a user or their behaviour (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles serve to show users, for example, content that corresponds to their potential interests. This procedure is also referred to as "tracking", i.e. tracking the potential interests of users. Insofar as we use cookies or "tracking" technologies, we inform you separately in our privacy policy or in the context of obtaining consent.

Notes on legal bases: The legal basis on which we process your personal data with the help of cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for the processing of 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 commercial operation of our online offer and its improvement) or, if the use of cookies is necessary, in order to fulfil our contractual obligations.

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

General notes on withdrawal and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to withdraw a given consent or to object to the processing of your data by cookie technologies (collectively referred to as "opt-out"). You can initially declare your objection by means of the settings of your browser, e.g. by deactivating the use of cookies (whereby this may also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared by means of a large number of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can obtain further objection notes in the context of the information on the service providers and cookies used.

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

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

Commercial and business services

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

We process this data to fulfil our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with this information as well as the business organisation. We only pass on the data of the contractual partners within the framework of applicable law to third parties insofar as this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or with the consent of the data subjects (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisers, payment service providers or tax authorities). About further forms of processing, e.g. for marketing purposes, the contractual partners are informed within the framework of this privacy policy.

Which data is necessary for the aforementioned purposes, we inform the contractual partners before or in the context of the data collection, e.g. in online forms, by special marking (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. in principle after expiry of 4 years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal reasons of archiving (e.g. for tax purposes, as a rule 10 years). Data disclosed to us in the context of an order by the contractual partner we delete in accordance with the specifications of the order, in principle after the end of the order.

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

Economic analyses and market research: For business reasons and in order to be able to recognise 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). In doing so, we may, if available, take into account the profiles of registered users together with their information, e.g. on services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with aggregated, i.e. anonymised, values. Furthermore, we take the privacy of users into account and process the data for the analysis purposes as pseudonymously as possible and, where feasible, anonymously (e.g. as aggregated data).

Further information on commercial services: We process the data of our customers and clients (hereinafter uniformly referred to as "customers") in order to enable them to select, acquire or commission the chosen services or works as well as associated activities and their payment and delivery or execution or provision.

The required information is marked as such in the context of the order, purchase or comparable conclusion of contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations.

  • Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. email, telephone numbers), contract data (e.g. subject of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Interested parties, business and contractual partners, customers.
  • Purposes of processing: Contractual services and service, contact requests and communication, office and organisational procedures, administration and response to enquiries, visit action evaluation, interest-based and behaviour-based marketing, profiling (creation of user profiles).
  • Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(1)(b) GDPR), legal obligation (Art. 6(1)(1)(c) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).

Credit check

Insofar as we make advance payments or take on comparable economic risks (e.g. in the case of an order on account), we reserve the right, in order to safeguard our legitimate interests, to obtain an identity and credit report for the purpose of assessing the credit risk on the basis of mathematical-statistical procedures from service companies specialised in this (credit agencies).

We process the information received from the credit agencies about the statistical probability of a payment default in the context of an appropriate discretionary decision on the establishment, execution and termination of the contractual relationship. We reserve the right, in the event of a negative result of the credit check, to refuse payment on account or another advance payment.

The decision as to whether we make advance payments is made, in accordance with Art. 22 GDPR, solely on the basis of an automated decision in an individual case, which our software makes on the basis of the information from the credit agency.

Insofar as we obtain express consent from contractual partners, the legal basis for the credit report and the transmission of the customer's data to the credit agencies is consent. If no consent is obtained, the credit report is carried out on the basis of our legitimate interests in the reliability of our payment claims.

  • Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. email, telephone numbers), contract data (e.g. subject of contract, term, customer category).
  • Data subjects: Customers, interested parties.
  • Purposes of processing: Assessment of creditworthiness and credit standing.
  • Legal bases: Consent (Art. 6(1)(1)(a) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).
  • Automated decisions in individual cases: Credit information (decision based on a credit check).

Services and service providers used:

Provision of the online offer and web hosting

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

The data processed in the context of providing the hosting offer may include all the information relating to the users of our online offer that arises in the course of use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from 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 the recipients and senders as well as further information concerning the email dispatch (e.g. the providers involved) and the contents of the respective emails are processed. The aforementioned data may furthermore be processed for the purposes of detecting SPAM. We ask you to note that emails on the internet are generally not sent in encrypted form. As a rule, emails are indeed encrypted in transit, but (unless a so-called end-to-end encryption procedure is used) not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of the emails between the sender and 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). The server log files may include the address and name of the accessed websites and files, date and time of access, transmitted data volumes, notification of successful access, 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.

The server log files can be used, on the one hand, for security purposes, e.g. to avoid overloading the servers (in particular in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilisation of the servers and their stability.

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

Contact

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

The answering of contact enquiries in the context of contractual or pre-contractual relationships is carried out in order to fulfil our contractual obligations or to answer (pre-)contractual enquiries and otherwise on the basis of the legitimate interests in answering the enquiries.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. text entries, photographs, videos).
  • Data subjects: Communication partners.
  • Purposes of processing: Contact requests and communication.
  • Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(1)(b) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).

Application procedure

The application procedure requires applicants to provide us with the data necessary for their assessment and selection. Which information is required results from the job description or, in the case of online forms, from the information provided there.

In principle, the required information includes the information about the person, such as the name, the address, a contact option as well as the evidence of the qualifications necessary for a position. On request, we are also happy to inform you which information is required.

If made available, applicants can submit their applications to us by means of an online form. The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants can also submit their applications to us via email. Here, however, we ask you to note that emails on the internet are generally not sent in encrypted form. As a rule, emails are indeed encrypted in transit, but not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of the application between the sender and receipt on our server.

For the purposes of applicant search, submission of applications and selection of applicants, we may, in compliance with the legal requirements, use applicant management or recruitment software and platforms and services of third-party providers.

Applicants are welcome to contact us regarding the manner of submitting the application or to send us the application by post.

Processing of special categories of data: Insofar as, within the scope of the application procedure, special categories of personal data within the meaning of Art. 9(1) GDPR (e.g. health data, such as severe-disability status or ethnic origin) are requested from applicants so that the controller or the data subject can exercise the rights and comply with the obligations arising from employment law and the law of social security and social protection, their processing is carried out pursuant to Art. 9(2)(b) GDPR; in the case of the protection of vital interests of applicants or other persons pursuant to Art. 9(2)(c) GDPR; or for the purposes of preventive healthcare or occupational medicine, for the assessment of the working capacity of the employee, for medical diagnosis, for care or treatment in the health or social sector, or for the management of health or social care systems and services pursuant to Art. 9(2)(h) GDPR. In the case of a communication of the special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9(2)(a) GDPR.

Deletion of data: The data provided by the applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is not successful, the applicants' data is deleted. The applicants' data is also deleted if an application is withdrawn, which the applicants are entitled to do at any time. The deletion is carried out, subject to a justified withdrawal of the applicants, at the latest after the expiry of a period of six months, so that we can answer any follow-up questions about the application and comply with our obligations of proof under the provisions on equal treatment of applicants. Invoices for any travel expense reimbursement are archived in accordance with the tax law requirements.

Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, is carried out on the basis of consent. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the ongoing application procedure and that they can withdraw their consent at any time for the future.

  • Types of data processed: Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, CV, certificates, as well as further information about their person or qualification provided by applicants with regard to a specific position or voluntarily).
  • Data subjects: Applicants.
  • Purposes of processing: Application procedure (establishment and possible later execution as well as possible later termination of the employment relationship).
  • Legal bases: Art. 9(1)(1)(b) GDPR (application procedure as a pre-contractual or contractual relationship).

Cloud services

We use software services accessible via the internet and executed on the servers of their providers (so-called "cloud services", also referred to as "software as a service") for the following purposes: document storage and management, calendar management, email dispatch, spreadsheets and presentations, exchange of documents, content and information with specific recipients or publication of websites, forms or other content and information as well as chats and participation in audio and video conferences.

In this context, personal data may be processed and stored on the servers of the providers, insofar as it is part of communication processes with us or is otherwise processed by us, as set out in this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their content. The providers of the cloud services also process usage data and metadata, which they use for security purposes and service optimisation.

Insofar as we use the cloud services to provide forms or other documents and content for other users or publicly accessible websites, the providers may store cookies on the users' devices for the purposes of web analysis or to remember the users' settings (e.g. in the case of media control).

Notes on legal bases: Insofar as we ask for consent to the use of the cloud services, the legal basis of the processing is consent. Furthermore, their use may be part of our (pre-)contractual services, insofar as the use of the cloud services was agreed in this context. Otherwise, the data of the users is processed on the basis of our legitimate interests (i.e. interest in efficient and secure administrative and collaboration processes).

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Customers, employees (e.g. staff, applicants, former employees), interested parties, communication partners.
  • Purposes of processing: Office and organisational procedures.
  • Legal bases: Consent (Art. 6(1)(1)(a) GDPR), performance of a contract and pre-contractual enquiries (Art. 6(1)(1)(b) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).

Promotional communication via email, post, fax or telephone

We process personal data for the purposes of promotional communication, which can be carried out via various channels, such as email, telephone, post or fax, in accordance with the legal requirements.

The recipients have the right to withdraw given consents at any time or to object to the promotional communication at any time.

After withdrawal or objection, we may store the data required to prove the consent for up to three years on the basis of our legitimate interests before we delete it. 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 a consent is confirmed at the same time.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g. by email or post).
  • Legal bases: Consent (Art. 6(1)(1)(a) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).

Online marketing

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

The IP addresses of the users are also stored. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear data of the users (such as email addresses or names) is stored in the context of the online marketing procedure, 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 the cookies or by means of similar procedures. These cookies can later, generally also on other websites that use the same online marketing procedure, be read out and analysed for the purposes of displaying content, as well as supplemented with further data and stored on the server of the online marketing procedure 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 procedure we use and the network links the users' profiles with the aforementioned information. We ask you to note that users can make additional arrangements with the providers, e.g. by consent in the context of registration.

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

Unless otherwise stated, we ask you to assume that cookies used are stored for a period of two years.

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

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services), interested parties.
  • Purposes of processing: Tracking (e.g. interest-/behaviour-based profiling, use of cookies), remarketing, visit action evaluation, interest-based and behaviour-based marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures: IP masking (pseudonymisation of the IP address).
  • Legal bases: Consent (Art. 6(1)(1)(a) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).
  • Objection option (opt-out): We refer to the privacy notices of the respective providers and the objection options (so-called "opt-out") specified for the providers. Insofar as no explicit opt-out option has been specified, you have the option, on the one hand, of switching off cookies in the settings of your browser. However, this may restrict functions of our online offer. We therefore additionally recommend the following opt-out options, which are offered in summary directed at 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 and service providers used:

  • Google Analytics: Online marketing and web analysis; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com/intl/de/about/analytics/; privacy policy: https://policies.google.com/privacy; objection option (opt-out): opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertising: https://adssettings.google.com/authenticated.
  • Google Ads and conversion measurement: We use the online marketing procedure "Google Ads" to place advertisements in the Google advertising network (e.g. in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the advertisements. Furthermore, we measure the conversion of the advertisements. However, we only learn the anonymous total number of users who clicked on our advertisement and were forwarded to a page provided with a so-called "conversion tracking tag". We ourselves, however, receive no information with which users can be identified. 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.

Plugins and embedded functions and content

We integrate into our online offer functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may be, for example, graphics, videos or social media buttons as well as 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 without the IP address they could not send the content to their browser. The IP address is thus necessary for the display of this content or functions. We endeavour to use only such content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to as "web beacons") for statistical or marketing purposes. By means of the "pixel tags", information such as the visitor traffic on the pages of this website can be evaluated. The pseudonymous information may furthermore be stored in cookies on the user's device and, among other things, contain technical information about the browser and the operating system, referring websites, the time of visit as well as further information on the use of our online offer, as well as be linked with such information from other sources.

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

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (data indicating the location of an end user's terminal device), inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. text entries, photographs, videos).
  • Data subjects: Users (e.g. website visitors, users of online services), communication partners.
  • Purposes of processing: Provision of our online offer and user-friendliness, contractual services and service, security measures, administration and response to enquiries, contact requests and communication, direct marketing (e.g. by email or post), tracking (e.g. interest-/behaviour-based profiling, use of cookies), interest-based and behaviour-based marketing, profiling (creation of user profiles).
  • Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR), consent (Art. 6(1)(1)(a) GDPR), performance of a contract and pre-contractual enquiries (Art. 6(1)(1)(b) GDPR).

Services and service providers used:

Deletion of data

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

Insofar as the data is not deleted because it is required for other and legally permissible purposes, its processing is limited to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.

Further notes on the deletion of personal data may also be provided in the context of the individual data protection notices of this privacy policy.

Amendment and update of the privacy policy

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

Insofar as we provide addresses and contact information of companies and organisations in this privacy policy, we ask you to 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 are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

  • Right to object: You have the right, on grounds relating to your particular situation, to object at any time to the processing of the personal data concerning you which is based on Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for 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 given consents at any time.
  • Right of access: You have the right to request confirmation as to whether data in question is being processed and to obtain access to this data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: You have the right, in accordance with the legal requirements, to request the completion of the data concerning you or the rectification of the incorrect data concerning you.
  • Right to erasure and restriction of processing: You have the right, in accordance with the legal requirements, to request that data concerning you be deleted without delay, or alternatively, in accordance with the legal requirements, to request a restriction of the processing of the data.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us, in accordance with the legal requirements, in a structured, commonly used and machine-readable format, or to request its transmission to another controller.
  • Complaint to a supervisory authority: You also have the right, in accordance with the legal requirements, 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 consider that the processing of the personal data concerning you infringes the GDPR.

Definitions of terms

In this section you receive an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined above all in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended above all to aid understanding. The terms are sorted alphabetically.

  • Visit action evaluation: "Visit action evaluation" (English "conversion tracking") refers to a procedure by which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users' devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, we can thus track whether the advertisements placed by us on other websites were successful.
  • Credit information: 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 credit application or an online application procedure without any human intervention). Such automated decisions are, pursuant to Art. 22 GDPR, only permissible if the data subjects consent, if they are necessary for the performance of a contract or if national laws permit these decisions.
  • IP masking: "IP masking" is a method by which the last octet, i.e. the last two numbers of an IP address, is deleted so that the IP address can no longer serve for the unambiguous identification of a person. Therefore, IP masking is a means of pseudonymising processing procedures, in particular in online marketing.
  • Interest-based and behaviour-based marketing: Interest-based and/or behaviour-based marketing is when potential interests of users in advertisements and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behaviour (e.g. visiting certain websites and dwelling on them, purchasing behaviour or interaction with other users), which is stored in a so-called profile. For these purposes, cookies are usually used.
  • Conversion measurement: Conversion measurement is a procedure by which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users' devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, we can thus track whether the advertisements placed by us on other websites were successful.
  • Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiling: "Profiling" means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person (depending on the type of profiling, this includes information concerning age, gender, location data and movement data, interaction with websites and their content, purchasing behaviour, social interactions with other people), to analyse or evaluate them or to predict them (e.g. the interests in certain content or products, click behaviour on a website or the whereabouts). Cookies and web beacons are frequently used for the purposes of profiling.
  • Reach measurement: Reach measurement (also referred to as web analytics) serves to evaluate the visitor flows of an online offer and can include the behaviour or interests of visitors in certain information, such as content of websites. With the help of reach analysis, website owners can, for example, recognise at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are frequently used to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Remarketing: "Remarketing" or "retargeting" is when, for example for advertising purposes, it is noted which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Tracking: "Tracking" is when the behaviour of users can be traced across several online offers. As a rule, behavioural and interest information is stored with regard to the online offers used in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can subsequently be used, for example, to show users advertisements that presumably correspond to 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" is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically any handling of data, be it collection, evaluation, storage, transmission or deletion.