Data protection
Introduction
With the following data protection declaration, 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. This data protection declaration applies to all processing of personal data carried out by us, both in the context of the provision of 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 offering").
As of April 26, 2024
table of contents
- Introduction
- responsible person
- Overview of processing
- Contact Data Protection Officer
- Relevant legal bases
- security measures
- transmission and disclosure of personal data
- data processing in third countries
- use of cookies
- Commercial and business services
- Use of online marketplaces for e-commerce
- payment service providers
- contact
- communication via messenger
- provision of the online offer and web hosting
- newsletter and broad communication
- online marketing
- Presences in social networks
- deletion of data
- Change and update of the privacy policy
- rights of the data subjects
- definitions of terms
responsible person
Rahel Morgen
Allschwilerstrasse 35
4055 Basel
Email: salut@ohyouprettythings.ch
Authorized representative : Rahel Morgen
Email address : salut@ohyouprettythings.ch
Contact Data Protection Officer
Overview of processing
The following overview summarises the types of data processed and the purposes of their processing and refers to the persons concerned.
types of data processed
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Inventory data (e.g. names, addresses).
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Content data (e.g. text entries, photographs, videos).
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Contact details (e.g. email, telephone numbers).
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Meta/communication data (e.g. device information, IP addresses).
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Usage data (e.g. websites visited, interest in content, access times).
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Contract data (e.g. subject matter of the contract, term, customer category).
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Payment data (e.g. bank details, invoices, payment history).
categories of data subjects
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business and contractual partners.
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interested parties.
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communication partner.
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Customers.
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Users (e.g. website visitors, users of online services).
purposes of processing
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Visit action evaluation.
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office and organizational procedures.
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Direct marketing (e.g. by email or post).
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Interest-based and behavioral marketing.
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contact requests and communication.
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Conversion measurement (measuring the effectiveness of marketing measures).
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Profiling (creation of user profiles).
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remarketing.
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Reach measurement (e.g. access statistics, recognition of returning visitors).
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security measures.
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Tracking (e.g. interest-/behavioral profiling, use of cookies).
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Contractual services and service.
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Managing and responding to inquiries.
Relevant legal bases
Below we share the legal basis of the General Data Protection Regulation (GDPR) on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, the national data protection regulations in your or our country of residence and domicile may apply.
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Consent (Article 6 (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 several specific purposes.
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Contract performance and pre-contractual inquiries (Article 6 (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 implementation of pre-contractual measures taken at the request of the data subject.
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Legal obligation (Article 6 (1) sentence 1 lit. c. GDPR) – The processing is necessary to fulfill a legal obligation to which the controller is subject.
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Legitimate interests (Article 6 (1) sentence 1 lit. f. GDPR) - Processing is necessary to safeguard the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject which require protection of personal data prevail.
National data protection regulations in Switzerland : In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Switzerland. This includes in particular the Federal Data Protection Act (DSG). The DSG applies in particular if no EU/EEC citizens are affected and, for example, only data from Swiss citizens is processed.
security measures
We take appropriate technical and organizational 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, to ensure a level of protection appropriate to the risk.
The measures include in particular ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, transfer, securing availability and separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to threats to data. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
SSL encryption (https) : We use SSL encryption to protect the data you transmit via our website. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.
transmission and disclosure of personal data
As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons or that it is disclosed to them. The recipients of this data may include, for example, payment institutions as part of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and in particular conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.
Data transfer within the organization : We may transfer personal data to other departments within our organization or grant them access to this data. If this transfer is for administrative purposes, the data is transferred based on our legitimate business and commercial interests or if it is necessary to fulfill our contractual obligations or if there is consent from the data subject or legal permission.
data processing in third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies, this will only be done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transmission, we only process or have the data processed in third countries with a recognized level of data protection, which include the US processors certified under the "Privacy Shield", or on the basis of special guarantees, such as contractual obligations through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).
use of cookies
Cookies are small files that are stored on users' devices. Cookies can be used to store various information. The information can include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was watched.
Cookies are also generally used when a user's interests or behavior (e.g. viewing certain content, using functions, etc.) are stored in a user profile on individual websites. Such profiles are used to show users content that corresponds to their potential interests, for example. This process is also known as "tracking," i.e. tracking the potential interests of users. The term cookies also includes other technologies that perform the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also known as "user IDs").
If we use cookies or tracking technologies, we will inform you separately in our privacy policy.
Notes on legal bases: The legal basis on which we process your personal data using 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 processing your data is your declared consent. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and its improvement) or if the use of cookies is necessary to fulfill our contractual obligations.
Revocation and objection (opt-out): Regardless of whether the processing is based on consent or legal permission, you have the option at any time to revoke your consent or to object to the processing of your data using cookie technologies (collectively referred to as "opt-out").
You can initially declare your objection by means of the settings in your browser, e.g. by deactivating the use of cookies (although this may also limit the functionality of our online offer).
An objection to the use of cookies for online marketing purposes can be declared using a variety of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/ or generally at http://optout.aboutads.info .
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Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
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Data subjects: Users (e.g. website visitors, users of online services).
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Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a GDPR), Legitimate Interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Commercial and business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners") within the framework of contractual and comparable legal relationships as well as related measures and within the framework of communication with the contractual partners (or pre-contractually), e.g. to answer inquiries.
We process this data to fulfill our contractual obligations, to protect our rights and for the purposes of the administrative tasks associated with this information and for business organization. Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations or with the consent of the contractual partners (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners are informed about other forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.
We inform our contractual partners which data is required for the aforementioned purposes before or during 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 the expiry of statutory warranty and similar obligations, i.e., generally after 4 years, unless the data is stored in a customer account, e.g., for as long as it must be kept for legal archiving reasons (e.g., for tax purposes, usually 10 years). We delete data that was disclosed to us by the contractual partner as part of an order in accordance with the specifications of the order, generally after the end of the order.
To the extent that 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 to the relationship between the users and the providers.
Customer account : Contractual partners can create an account within our online offering (e.g. customer or user account, "customer account" for short). If the registration of a customer account is required, contractual partners will be informed of this and of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. As part of the registration process and subsequent logins and use of the customer account, we save the customers' IP addresses along with the access times in order to be able to prove registration and prevent any misuse of the customer account.
If customers have terminated their customer account, the data relating to the customer account will be deleted, unless their retention is required for legal reasons. It is the customer's responsibility to back up their data when the customer account is terminated.
Online shop and e-commerce : We process our customers' data to enable them to select, purchase or order the selected products, goods and related services, as well as to pay for and deliver or execute them.
The required information is marked as such in the ordering or comparable purchasing 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.
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Types of data processed: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
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Affected persons: interested parties, business and contractual partners, customers.
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Purposes of processing: Contractual services and service, contact requests and communication, office and organizational procedures, administration and response to requests, security measures.
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Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legal obligation (Art. 6 Para. 1 S. 1 lit. c. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Use of online marketplaces for e-commerce
We offer our services on online platforms operated by other service providers. In this context, the data protection notices of the respective platforms apply in addition to our data protection notices. This applies in particular with regard to the methods used on the platforms for range measurement and interest-based marketing.
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Types of data processed: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
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Data subjects: Customers.
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Purposes of processing: Contractual services and service.
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Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Services and service providers used:
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shopify: e-commerce platform and cloud services; service provider: Shopify International Limited, Victoria Buildings, 2nd floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland; website: https://www.shopify.de ; privacy policy: https://www.shopify.de/legal/datenschutz .
payment service providers
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, in addition to banks and credit institutions, use other payment service providers (collectively "payment service providers").
The data processed by the payment service providers includes inventory data such as name and address, bank details such as account numbers or credit card numbers, passwords, TANs and checksums as well as contract, sum and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, only information confirming or rejecting the payment. The payment service providers may transmit the data to credit agencies. This transmission is for the purpose of checking identity and creditworthiness. For this purpose, we refer to the terms and conditions and the data protection information of the payment service providers.
The terms and conditions and data protection notices of the respective payment service providers apply to payment transactions and can be accessed on the respective websites or transaction applications. We also refer to these for further information and to assert revocation, information and other rights of those affected.
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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, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
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Affected persons: customers, interested parties.
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Purposes of processing: Contractual services and service.
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Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Services and service providers used:
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American Express: payment services; service provider: American Express Europe SA, Theodor-Heuss-Allee 112, 60486 Frankfurt am Main, Germany; website: https://www.americanexpress.com/de ; privacy policy:https://www.americanexpress.com/de/legal/online-datenschutzerklarung.html .
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Mastercard: payment services; service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; website: https://www.mastercard.de/de-de.html ; privacy policy: https://www.mastercard.de/de-de/datenschutz.html .
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TWINT: payment services; service provider: TWINT AG
Stauffacherstrasse 41, CH-8004 Zurich; Switzerland; Website: https://www.twint.ch ; Privacy Policy: https://www.twint.ch/datenschutz-app/ -
Stripe: payment services; service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; website: https://stripe.com/de ; privacy policy: https://stripe.com/de/privacy .
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Visa: payment services; service provider: Visa Europe Services Inc., London branch, 1 Sheldon Square, London W2 6TT, GB; website: https://www.visa.de ; privacy policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html .
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Apple Pay: payment services; service provider: Hollyhill Ln, Hollyhill Industrial Estate, Cork, T23 YK84, Ireland Website: www.apple.com/apple-pay/ ; privacy policy: https://support.apple.com/de-ch/101554#:~:text=Apple%20stores%20data%20that%20can%20be%20connected%20with%20Apple.
contact
When you contact us (e.g. via contact form, e-mail, telephone or via social media), the information provided by the person making the inquiry will be processed to the extent necessary to answer the contact enquiries and any requested measures.
Contact requests within the framework of contractual or pre-contractual relationships are answered to fulfill our contractual obligations or to answer (pre)contractual requests and otherwise on the basis of legitimate interests in answering the requests.
Chat function : For the purposes of communication and answering inquiries, we offer a chat function within our online offering. Users' input within the chat is processed for the purpose of answering their inquiries.
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Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, 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).
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Affected persons: communication partners, interested parties.
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Purposes of processing: contact requests and communication, administration and response to requests.
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Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
communication via messenger
We use messenger services for communication purposes and therefore ask you to note the following information on the functionality of the messengers, encryption, the use of communication metadata and your options for objection.
You can also contact us in alternative ways, e.g. by telephone or email. Please use the contact options provided to you or the contact options provided within our online offering.
In the case of end-to-end encryption of content (ie, the content of your message and attachments), we would like to point out that the communication content (ie, 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 a current version of the messenger with encryption activated to ensure that the message content is encrypted.
However, we would also like to point out to our communication partners that although the providers of the messengers cannot see 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) are also 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. Otherwise, if we do not ask for consent and they contact us on their own initiative, for example, we use messengers in relation to our contractual partners and in the context of contract initiation 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 meeting the needs of our communication partners in communicating via messengers. We would also 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 object to communication with us via messenger at any time. In the case of communication via messenger, we delete the messages in accordance with our general deletion guidelines (ie, for example, as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information from the communication partners, if no reference to a previous conversation is to be expected and there are no statutory retention periods that prevent deletion.
Reservation of reference to other communication channels: Finally, we would like to point out that for reasons of your security, we reserve the right not to answer inquiries via messenger. This is the case, for example, if internal contractual details require special confidentiality or if a response via messenger does not meet the formal requirements. In such cases, we will refer you to more appropriate communication channels.
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Types of data processed: contact data (e.g. e-mail, telephone numbers), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
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Data subjects: communication partners.
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Purposes of processing: contact requests and communication, direct marketing (e.g. by e-mail or post).
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Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a GDPR), Legitimate Interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Services and service providers used:
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Facebook Messenger: Facebook Messenger with end-to-end encryption (the end-to-end encryption of Facebook Messenger requires activation if it is not activated by default); service provider: https://www.facebook.com , Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; website: https://www.facebook.com ; data protection declaration: https://www.facebook.com/about/privacy ; Privacy Shield (guaranteeing data protection level when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active ; option to object (opt-out): https://www.facebook.com/settings?tab=ads .
provision of the online offer and web hosting
In order to provide our online offering securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offering can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.
The data processed in the context of providing the hosting service may include all information concerning the users of our online service that arises in the context of use and communication. This usually includes the IP address, which is necessary in order to be able to deliver the content of online services to browsers, and all entries made within our online service or on websites.
E-mail sending and hosting : The web hosting services we use also include the sending, receiving and storing of e-mails. For these purposes, the addresses of the recipients and senders as well as other information regarding the e-mail sending (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purposes of detecting SPAM. Please note that e-mails are generally not sent encrypted on the Internet. E-mails are usually encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We cannot therefore accept any responsibility for the transmission path of the e-mails between the sender and the recipient 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 can include the address and name of the web pages and files accessed, the date and time of access, the amount of data transferred, 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 for security purposes, e.g. to avoid overloading the servers (particularly in the case of abusive attacks, so-called DDoS attacks) and to ensure the utilization of the servers and their stability.
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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).
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Data subjects: Users (e.g. website visitors, users of online services).
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Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
newsletter and broad communication
We only send newsletters, emails and other electronic notifications (hereinafter "newsletters") with the consent of the recipient or with legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user's consent. In addition, our newsletters contain information about our services and us.
To subscribe to our newsletter, it is generally sufficient to provide your email 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 always carried out using a so-called double opt-in procedure. This means that after registration you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register using someone else's email address. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider are also logged.
Deletion and restriction of processing: We can store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address in a blocking list (so-called "blacklist") for this purpose alone.
The registration process is logged on the basis of our legitimate interests for the purpose of proving that it was carried out correctly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure shipping system.
Notes on legal bases: The newsletter is sent based on the consent of the recipient or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of advertising to existing customers. If we commission a service provider to send emails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests in order to prove that it was carried out in accordance with the law.
Contents : Information about us, our services, promotions and offers.
Measuring success : The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from its server. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, are initially collected.
This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their access locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our aim nor that of the shipping service provider, if used, to observe individual users. Rather, the evaluations help us to recognize the reading habits of our users and adapt our content to them or to send different content according to the interests of our users.
The evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the user, on the basis of our legitimate interests for the purposes of using a user-friendly and secure newsletter system that serves both our business interests and meets the expectations of the users.
Unfortunately, a separate revocation of the performance measurement is not possible; in this case, the entire newsletter subscription must be cancelled or revoked.
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Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
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Data subjects: communication partners.
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Purposes of processing: direct marketing (e.g. by e-mail or post).
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Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a GDPR), Legitimate Interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
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Opt-out option: You can cancel your subscription to our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email.
Services and service providers used:
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Mailchimp: email marketing platform; service provider: \"Mailchimp\" - Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; website: https://mailchimp.com ; privacy policy: https://mailchimp.com/legal/privacy/ ; Privacy Shield (guaranteeing data protection level when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active .
online marketing
We process personal data for the purposes of online marketing, which includes in particular 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 procedures are used by means of which the information about the user relevant for 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 and information on usage times. If users have consented to the collection of their location data, this can also be processed.
The IP addresses of the users are also stored. However, we use IP masking procedures (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored as part of the online marketing process, but rather pseudonyms. This means that neither we nor the providers of the online marketing process know the actual identity of the users, only the information stored in their profiles.
The information in the profiles is usually stored in cookies or using similar processes. These cookies can generally also be read later on other websites that use the same online marketing process and analyzed for the purposes of displaying content, as well as supplemented with further data and stored on the server of the online marketing process provider.
In exceptional cases, clear data can be assigned to profiles. This is the case if, for example, the users are members of a social network whose online marketing processes we use and the network links the users' profiles in the aforementioned information. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.
In principle, we only receive access to summarized information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, ie, for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyze the success of our marketing measures.
Notes on legal bases: If we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
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Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
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Affected persons: users (e.g. website visitors, users of online services), interested parties.
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Purposes of processing: Tracking (e.g. interest/behavior-related profiling, use of cookies), remarketing, visit action evaluation, interest-based and behavior-related 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).
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Security measures: IP masking (pseudonymization of the IP address).
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Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a GDPR), Legitimate Interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
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Opt-out option: Please refer to the privacy policy of the respective provider and the opt-out options provided by the provider (so-called “opt-out”). If no explicit opt-out option has been provided, you have the option of deactivating 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 summarized for each region: a) Europe: https://www.youronlinechoices.eu . b) Canada: https://www.youradchoices.ca/choices . c) USA: https://www.aboutads.info/choices . d) Cross-regional: http://optout.aboutads.info .
Services and service providers used:
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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/ ; data protection declaration: https://policies.google.com/privacy ; Privacy Shield (guaranteeing data protection level when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active ; possibility of objection (opt-out): opt-out plug-in: http://tools.google.com/dlpage/gaoptout?hl=de , settings for the display of advertisements: https://adssettings.google.com/authenticated .
Presences in social networks
We maintain online presences within social networks in order to communicate with the users active there or to offer information about us there.
We would like to point out that user data may be processed outside the European Union. This may result in risks for users, as it may make it more difficult to enforce user rights. With regard to US providers who are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we would like to point out that they are thereby committed to complying with EU data protection standards.
Furthermore, the data of users within social networks is usually processed for market research and advertising purposes. For example, user profiles can be created based on the user's usage behavior and the resulting interests. The user profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the user's interests. For these purposes, cookies are usually stored on the user's computers in which the user's usage behavior and interests are stored. Furthermore, data can also be stored in the user profiles regardless of the devices used by the user (especially if the users are members of the respective platforms and are logged in to them).
For a detailed description of the respective processing methods and the options for objection (opt-out), please refer to the data protection declarations 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 data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
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Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, 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).
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Data subjects: Users (e.g. website visitors, users of online services).
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Purposes of processing: contact requests and communication, tracking (e.g. interest-/behavior-related profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
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Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
Services and service providers used:
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Instagram: social network; service provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; website: https://www.instagram.com ; privacy policy: http://instagram.com/about/legal/privacy .
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Facebook: social network; service provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; website: https://www.facebook.com ; data protection declaration: https://www.facebook.com/about/privacy ; Privacy Shield (guaranteeing data protection level when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active ; possibility of objection (opt-out): settings for advertisements: https://www.facebook.com/settings?tab=ads ; Additional information on data protection: Agreement on joint processing of personal data on Facebook pages: https://www.facebook.com/legal/terms/page_controller_addendum , Data protection information for Facebook pages:https://www.facebook.com/legal/terms/information_about_page_insights_data .
deletion of data
The data we process will be deleted in accordance with legal requirements as soon as the consents permitted for processing are revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or it is no longer required for the purpose).
If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.
Further information on the deletion of personal data can also be found in the individual data protection notices of this data protection declaration.
Change and update of the privacy policy
We ask you to regularly inform yourself about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
rights of the data subjects
As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 18 and 21 of the GDPR:
- Right to object: You have the right to object at any time to the processing of personal data concerning you which is carried out on the basis of Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you are processed in order to conduct direct advertising, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct advertising.
- Right to withdraw consent: You have the right to withdraw consent at any time.
- Right to information: You have the right to request confirmation as to whether data concerning you is being processed and to request information about this data as well as further information and a copy of the data in accordance with legal requirements.
- Right to rectification: You have the right, in accordance with the statutory provisions, to request that the data concerning you be completed or that inaccurate data concerning you be rectified.
- Right to erasure and restriction of processing: You have the right, in accordance with the statutory provisions, to request that data concerning you be erased immediately or, alternatively, to request that the processing of the data be restricted in accordance with the statutory provisions.
- Right to data portability: You have the right to receive the data concerning you that you have made available to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transmitted to another controller.
- Complaint to the supervisory authority: You also have the right, in accordance with the statutory provisions, 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 personal data concerning you infringes the GDPR.
definitions of terms
This section provides you with 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, however, are primarily intended to help you understand. The terms are sorted alphabetically.
- Conversion tracking: "Conversion tracking" is a process that can be used to determine the effectiveness of marketing measures. This usually involves storing a cookie on the user's device on the website where the marketing measures are carried out and then retrieving it on the target website. For example, this allows us to see whether the ads we have placed on other websites were successful.
- IP masking: “IP masking” is a method in which the last octet, i.e. the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymizing processing procedures, especially in online marketing.
- Interest-based and behavioral marketing: Interest-based and/or behavioral marketing is when users' potential interests in advertisements and other content are predetermined as precisely as possible. This is done using information about their previous behavior (e.g. visiting certain websites and staying on them, purchasing behavior or interaction with other users), which is stored in a so-called profile. Cookies are usually used for these purposes.
- Conversion measurement: Conversion measurement is a method that can be used to determine the effectiveness of marketing measures. To do this, a cookie is usually stored on the user's device within the websites on which the marketing measures take place and then retrieved again on the target website. For example, we can use this to see whether the ads we have placed 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 special characteristics that express the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Profiling: “Profiling” refers to any form of automated processing of personal data consisting of the use of personal data to analyse, evaluate or predict 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, shopping behaviour, social interactions with other people) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
- Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering 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, recognize 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 often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
- 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 behavior of users can be tracked across multiple online offerings. As a rule, behavior and interest information with regard to the online offerings used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to show users advertisements that are likely to correspond to their interests.
- Controller: The “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of processing 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 every handling of data, be it collection, evaluation, storage, transmission or deletion.