This is our general Licensing agreement. By using our website and services you
automatically agree to the terms laid out in this agreement. They govern the rights and
limitations of the design licenses that you purchase via your subscription.
This data protection declaration explains to you the type, scope and purpose of the
processing of personal data (hereinafter referred to as “data”) within our online offer and
the associated websites, functions and contents as well as external online presences, e.g.
our social media profile (hereinafter jointly referred to as “online offer”). With regard to
the terms used, such as “processing” or “person responsible”, we refer to the definitions in
Art. 4 of the Basic Data Protection Ordinance (DSGVO).
Responsible Party
ThreadBasket GmbH
Knorrestr. 5
20099 Hamburg
GERMANY
E-Mail: [email protected]
Phone: +49 178 1427842
Represented by: Christian Heidorn
Legal Notice: https://www.threadbasket.com/legal/
Data Privacy Officer: [email protected]
Types of processed data:
- Inventory data (e.g., names, addresses).
- Contact details (e.g., e-mail, telephone numbers).
- Content data (e.g., text input, photographs, videos).
- Usage data (e.g., visited websites, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).
Categories of data subjects
Visitors and users of the online offer (hereinafter referred to as “users”).
Purpose of the data processing
- Provision of the online offer, its functions and contents.
- Answer contact requests and communicate with users.
- Security measures.
- Range measurement/marketing
Specific terms used
“Personal data” means any information relating to an identified or identifiable natural
person (hereinafter referred to as “data subject”); an identifiable natural person is one
who can be identified, directly or indirectly, in particular by assignment to an identifier
such as a name, an identification number, location data, an online identifier (e.g. cookie)
or to one or more special features that express the physical, physiological, genetic,
psychological, economic, cultural or social identity of that natural person.
“processing” means any operation or series of operations carried out with or without the aid
of automated procedures in connection with personal data. The term goes a long way and
covers practically every handling of data.
“pseudonymisation” means the processing of personal data in such a way that the personal data
can no longer be attributed to a specific data subject without the use of additional
information, provided that this additional information is kept separately and is subject to
technical and organisational measures to ensure that the personal data are not attributed to
an identified or identifiable natural person.
“Profiling” means any automated processing of personal data consisting in the use of such
personal data to evaluate certain personal aspects relating to a natural person, in
particular to analyse or predict aspects relating to the work performance, economic
situation, health, personal preferences, interests, reliability, behaviour, location or
relocation of that natural person.
Responsible” means the natural or legal person, authority, institution or other body that
alone or together with others decides on the purposes and means of processing personal
data.
“processor” means a natural or legal person, authority, institution or other body processing
personal data on behalf of the controller.
Applicable legal bases
In accordance with Art. 13 DSGVO, we inform you of the legal basis of our data processing. If
the legal basis is not mentioned in the data protection declaration, the following applies:
The legal basis for obtaining consents is Art. 6 para. 1 lit. a and Art. 7 DSGVO, the legal
basis for processing for the performance of our services and performance of contractual
measures as well as for answering inquiries is Art. 6 para. 1 lit. b DSGVO, the legal basis
for processing to fulfil our legal obligations is Art. 6 para. 1 lit. c DSGVO, and the legal
basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f DSGVO. In
the event that the vital interests of the data subject or another natural person require the
processing of personal data, Article 6(1)(d) DSGVO serves as the legal basis.
Safety precautions
We take appropriate technical and organisational measures to ensure a level of protection
appropriate to the risk, taking into account the state of the art, implementation costs and
the nature, scope, circumstances and purposes of processing as well as the different
probability of occurrence and severity of the risk to the rights and freedoms of natural
persons, in accordance with Art. 32 DSGVO.
Such measures shall in particular include ensuring the confidentiality, integrity and
availability of data by controlling physical access to the data, as well as the access,
input, transmission, security of availability and its separation. Furthermore, we have
established procedures to ensure the exercise of rights of data subjects, deletion of data
and reaction to endangerment of data. Furthermore, we already consider the protection of
personal data during the development or selection of hardware, software and procedures, in
accordance with the principle of data protection through technology design and data
protection-friendly presettings (Art. 25 DSGVO).
Cooperation with contract processors and third parties
If we disclose data to other persons and companies (contract processors or third parties)
within the scope of our processing, transmit it to them or otherwise grant them access to
the data, this shall only take place on the basis of a legal permission (e.g. if a
transmission of the data to third parties, such as payment service providers, in accordance
with Art. 6 Para. 1 lit. b DSGVO for contract fulfilment is necessary), if you have
consented, if a legal obligation provides for this or on the basis of our legitimate
interests (e.g. when using agents, web hosts, etc.).
If we commission third parties with the processing of data on the basis of a so-called “order
processing contract”, this is done on the basis of Art. 28 DSGVO.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European
Economic Area (EEA)) or if this occurs in the context of the use of third-party services or
disclosure or transfer of data to third parties, this only takes place if it occurs for the
fulfilment of our (pre)contractual obligations, on the basis of your consent, on the basis
of a legal obligation or on the basis of our legitimate interests. Subject to legal or
contractual permissions, we process or leave the data in a third country only if the special
requirements of Art. 44 ff. Process DSGVO. This means, for example, processing is carried
out on the basis of special guarantees, such as the officially recognised determination of a
data protection level corresponding to the EU (e.g. for the USA by the “Privacy Shield”) or
compliance with officially recognised special contractual obligations (so-called “standard
contractual clauses”).
Rights of data subjects
You have the right to request confirmation as to whether the data concerned are being
processed and to request information about these data as well as further information and a
copy of the data in accordance with Art. 15 DSGVO.
They have correspondingly. In accordance with Article 16 of the DSBER, you have the right to
request the completion of data concerning you or the correction of inaccurate data
concerning you.
In accordance with Art. 17 DSGVO, you have the right to demand that relevant data be deleted
immediately or, alternatively, to demand a restriction on the processing of the data in
accordance with Art. 18 DSGVO.
You have the right to request that the data concerning you that you have provided to us be
received in accordance with Art. 20 DSGVO and to request its transmission to other persons
responsible.
In accordance with Art. 77 DSGVO, they also have the right to file a complaint with the
competent supervisory authority.
Right of revocation
You have the right to revoke consents granted pursuant to Art. 7 para. 3 DSGVO with future
effect
Right of objection
You can object to the future processing of the data concerning you in accordance with Art. 21
DSGVO at any time. The objection may be lodged in particular against processing for direct
marketing purposes.
Cookies and right of objection in direct advertising
We use cookies to personalise content, ads and to analyse our traffic. We also share information about your use of our site with our advertising and analytics partners who may combine it with other information that you've provided to them or that they've collected from your use of their services.
Cookies” are small files that are stored on the user’s computer. Different data can be stored
within the cookies. A cookie is primarily used to store information about a user (or the
device on which the cookie is stored) during or after his or her visit to an online offer.
Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted
after a user leaves an online offer and closes his browser. In such a cookie, for example,
the content of a shopping basket in an online shop or a login status can be stored. Cookies
are referred to as “permanent” or “persistent” and remain stored even after the browser is
closed. For example, the login status can be saved when users visit it after several days.
Likewise, the interests of users used for range measurement or marketing purposes may be
stored in such a cookie. Third-party cookies” are cookies that are offered by providers
other than the person responsible for operating the online offer (otherwise, if they are
only its cookies, they are referred to as “first-party cookies”).
We may use temporary and permanent cookies and clarify this within the framework of our data
protection declaration.
If users do not want cookies to be stored on their computer, they are asked to deactivate the
corresponding option in the system settings of their browser. Stored cookies can be deleted
in the system settings of the browser. The exclusion of cookies can lead to functional
restrictions of this online offer.
A general objection to the use of cookies used for online marketing purposes can be declared
for many of the services, especially in the case of tracking, via the US site
http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/.
Furthermore, the storage of cookies can be achieved by deactivating them in the browser
settings. Please note that in this case not all functions of this online offer can be
used.
Deletion of data
The data processed by us will be deleted or their processing restricted in accordance with
Articles 17 and 18 DSGVO. Unless expressly stated in this data protection declaration, the
data stored by us will be deleted as soon as it is no longer required for its intended
purpose and the deletion does not conflict with any statutory storage obligations. If the
data are not deleted because they are necessary for other and legally permissible purposes,
their processing is restricted. 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 reasons.
According to legal requirements in Germany, the storage is carried out in particular for 10
years in accordance with §§ 147 para. 1 AO, 257 para. 1 no. 1 and 4, para. 4 HGB (books,
records, management reports, accounting documents, trading books, documents relevant for
taxation, etc.) and 6 years in accordance with § 257 para. 1 no. 2 and 3, para. 4 HGB
(commercial letters).
In accordance with legal requirements in Austria, storage is carried out in particular for 7
years in accordance with § 132 (1) BAO (accounting documents, receipts/invoices, accounts,
receipts, business papers, statement of income and expenses, etc.), for 22 years in
connection with real estate and for 10 years for documents in connection with electronically
provided services, telecommunications, radio and television services which are provided to
non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is
used.
Business processing
Additionally we process
- Contract data (for example, contract object, term, customer category).
- Payment data (e.g., bank details, payment history)
from our customers, prospects and business partners for the purpose of providing contractual
services, service and customer care, marketing, advertising and market research.
Order processing in the online shop and customer account
We process the data of our customers in the context of the order processes in our online shop
to enable them to select and order the selected products and services, as well as their
payment and delivery, or execution.
The processed data includes inventory data, communication data, contract data, payment data
and the persons affected by the processing include our customers, interested parties and
other business partners. The processing takes place for the purpose of providing contractual
services in the context of operating an online shop, billing, delivery and customer
services. We use session cookies for storing the contents of the shopping cart and permanent
cookies for storing the login status.
Processing is carried out on the basis of Art. 6 Para. 1 lit. b (execution of order
processes) and c (legally required archiving) DSGVO. The information marked as necessary is
required to establish and fulfil the contract. We disclose the data to third parties only
within the framework of delivery, payment or within the framework of legal permits and
obligations to legal advisors and authorities. The data will only be processed in third
countries if this is necessary for the fulfilment of the contract (e.g. at the customer’s
request upon delivery or payment).
Users can optionally create a user account, in particular by viewing their orders. During the
registration process, the required information will be communicated to the users. The user
accounts are not public and cannot be indexed by search engines. If users have terminated
their user account, their data will be deleted with regard to the user account, subject to
its storage is necessary for commercial or tax reasons according to Art. 6 Para. 1 lit. c
DSGVO. Data in the customer account remain up to its deletion with subsequent archiving in
the case of a legal obligation. It is up to the users to save their data before the end of
the contract if they have given notice of termination.
When registering, re-registering and using our online services, we store the IP address and
the time of the respective user action. The data is stored on the basis of our legitimate
interests as well as the user’s protection against misuse and other unauthorized use. A
passing on of this data to third parties does not take place in principle, unless it is
necessary for the pursuit of our claims or there is a legal obligation according to Art. 6
Abs. 1 lit. c DSGVO.
The deletion takes place after the expiry of statutory warranty and comparable obligations,
the necessity of data storage is reviewed every three years; in the case of statutory
archiving obligations, the deletion takes place after their expiry (end of commercial law (6
years) and tax law (10 years) storage obligation).
Agency services
As part of our contractual services, we process our customers’ data, which include conceptual
and strategic consulting, campaign planning, software and design development / consulting or
maintenance, implementation of campaigns and processes / handling, server administration,
data analysis / consulting services and training services.
We process inventory data (e.g., customer master data, such as names or addresses), contact
data (e.g., e-mail, telephone numbers), content data (e.g., text entries, photographs,
videos), contract data (e.g., subject matter of the contract, term), payment data (e.g.,
bank details, payment history), usage and metadata (e.g. as part of the evaluation and
performance measurement of marketing measures). We do not process special categories of
personal data unless these are part of commissioned processing. This includes our customers,
prospects, their customers, users, website visitors or employees, as well as third parties.
The purpose of the processing is to provide contractual services, billing and our customer
service. The legal basis for processing results from Art. 6 para. 1 lit. b DSGVO
(contractual services), Art. 6 para. 1 lit. f DSGVO (analysis, statistics, optimisation,
safety measures). We process data which are necessary to justify and fulfil the contractual
services and point out the necessity of their disclosure. Disclosure to external parties
only takes place if it is necessary within the framework of an order. When processing the
data provided to us within the scope of an order, we act in accordance with the instructions
of the client and the legal requirements for order processing pursuant to Art. 28 DSGVO and
process the data for no other purposes than those stipulated in the order.
We delete the data after the expiry of statutory warranty and comparable obligations. The
necessity of storing the data is checked every three years; in the case of statutory
archiving obligations, the data is deleted after their expiry (6 years, in accordance with §
257 Paragraph 1 HGB, 10 years, in accordance with § 147 Paragraph 1 AO). In the case of data
disclosed to us within the scope of an order by the customer, we delete the data in
accordance with the specifications of the order, generally after the end of the order.
External payment services providers
We use external payment service providers through whose platforms users and we can make
payment transactions (e.g., each with a link to the data protection declaration, Paypal
(https://www.paypal.com/de/webapps/mpp/ua/privacy-full), Klarna
(https://www.klarna.com/de/datenschutz/), Skrill
(https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/), Giropay
(https://www.giropay.de/rechtliches/datenschutz-agb/), Visa
(https://www.visa.de/datenschutz), Mastercard
(https://www.mastercard.de/de-de/datenschutz.html), American Express
(https://www.americanexpress.com/de/content/privacy-policy-statement.html)
As part of the fulfilment of contracts, we suspend the payment service providers on the basis
of Art. 6 para. 1 lit. b. DSGVO. Furthermore, we employ external payment service providers
on the basis of our legitimate interests in accordance with Art. 6 para. 1 lit. b. DSGVO to
provide our users with effective and secure payment options.
The data processed by the payment service providers includes inventory data such as name and
address, bank data such as account numbers or credit card numbers, passwords, TANs and
checksums as well as contract, totals and recipient information. This information is
required to execute the transactions. However, the data entered will only be processed and
stored by the payment service providers. This means that we do not receive any account or
credit card related information, but only information with confirmation or negative
information about the payment. The data may be transferred by the payment service providers
to credit agencies. The purpose of this transmission is to verify identity and
creditworthiness. For this we refer to the terms and conditions and data protection
information of the payment service providers.
For payment transactions, the terms and conditions and the data protection information of the
respective payment service providers, which can be accessed within the respective websites
or transaction applications, apply. We refer to these also for the purpose of further
information and assertion of rights of revocation, information and other interested
parties.
Administration, financial accounting, office organization, contact management
We process data within the framework of administrative tasks as well as the organisation of
our company, financial accounting and compliance with legal obligations, e.g. archiving. We
process the same data that we process in the course of providing our contractual services.
The processing bases are Art. 6 para. 1 lit. c. DSGVO, Art. 6 para. 1 lit. f. DSGVO.
Customers, prospects, business partners and website visitors are affected by the processing.
The purpose and our interest in the processing lies in the administration, financial
accounting, office organization, archiving of data, thus tasks which serve the maintenance
of our business activities, perception of our tasks and provision of our services. The
deletion of the data with regard to contractual services and contractual communication
corresponds to the information provided in these processing activities.
We disclose or transmit data to the tax authorities, consultants, such as tax consultants or
auditors, as well as other fee offices and payment service providers.
Furthermore, we store information on suppliers, event organisers and other business partners
on the basis of our business interests, e.g. for the purpose of making contact at a later
date. We store this data, which is mainly company-related, permanently.
Business analyses and market research
In order to operate our business economically, to be able to recognize market tendencies,
wishes of the contracting parties and users, we analyze the data available to us to business
processes, contracts, inquiries, etc.. We process inventory data, communication data,
contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f.
DSGVO, whereby the persons concerned include contractual partners, interested parties,
customers, visitors and users of our online offer.
The analyses are carried out for the purpose of economic evaluations, marketing and market
research. We can take into account the profiles of registered users with information, e.g.
on the services they have used. The analyses serve us to increase the user-friendliness, the
optimization of our offer and the economic efficiency. The analyses serve us alone and are
not disclosed externally, unless they are anonymous analyses with aggregated values.
If these analyses or profiles are personal, they will be deleted or made anonymous upon
termination of the user, otherwise after two years from the conclusion of the contract. For
the rest, macroeconomic analyses and general trend determinations are prepared anonymously
wherever possible.
Participation in affiliate partner programs
Within our online offer, we use tracking measures customary in the industry on the basis of
our legitimate interests (i.e. interest in the analysis, optimisation and economic operation
of our online offer) in accordance with Art. 6 para. 1 letter f DSGVO, insofar as these are
necessary for the operation of the affiliate system. Below we explain the technical
background to the users.
The services offered by our contractual partners can also be advertised and linked on other
websites (so-called affiliate links or after-buy systems, if e.g. links or services of third
parties are offered after conclusion of a contract). The operators of the respective
websites receive a commission if users follow the affiliate links and then take advantage of
the offers.
In summary, it is necessary for our online offer that we can track whether users who are
interested in affiliate links and/or the offers available from us subsequently perceive the
offers at the request of the affiliate links or our online platform. For this purpose, the
affiliate links and our offers are supplemented by certain values that can be set as part of
the link or otherwise, e.g. in a cookie. The values include in particular the initial
website (referrer), time, an online identification of the operator of the website on which
the affiliate link was located, an online identification of the respective offer, an online
identification of the user, as well as tracking specific values such as advertising media
ID, partner ID and categorisations.
The online identifiers used by us are pseudonymous values. This means that the online
identifiers themselves do not contain any personal data such as names or e-mail addresses.
You only help us to determine whether the same user who clicked on an affiliate link or was
interested in an offer via our online offer has accepted the offer, i.e. has concluded a
contract with the provider, for example. However, the online identification is personal
insofar as the partner company and also we, the online identification together with other
user data are available. Only in this way can the partner company inform us whether the user
has accepted the offer and we can, for example, pay out the bonus.
Registration function
Users can create a user account. Within the scope of registration, the required mandatory
data are communicated to the users and processed on the basis of Art. 6 para. 1 letter b
DSGVO for the purpose of providing the user account. The processed data includes in
particular the login information (name, password and an e-mail address). The data entered
during registration will be used for the purpose of using the user account and its
purpose.
Users may be notified by e-mail of information relevant to their user account, such as
technical changes. If users have cancelled their user account, their data will be deleted
with regard to the user account, subject to a statutory retention obligation. It is up to
the users to save their data before the end of the contract if they have given notice of
termination. We are entitled to irretrievably delete all user data stored during the term of
the contract.
As part of the use of our registration and login functions as well as the use of the user
account, we store the IP address and the time of the respective user action. The data is
stored on the basis of our legitimate interests as well as the user’s protection against
misuse and other unauthorized use. A passing on of this data to third parties does not take
place in principle, unless it is necessary to pursue our claims or there is a legal
obligation in accordance with Art. 6 para. 1 lit. c DSGVO. The IP addresses are anonymized
or deleted after 7 days at the latest.
DISQUS comment function
On the basis of our legitimate interests in an efficient, secure and user-friendly comment
management pursuant to Art. 6 para. 1 letter f. DSGVO has launched the commentary service
DISQUS, offered by DISQUS, Inc. 301 Howard St, Floor 3 San Francisco, California- 94105,
USA. DISQUS is certified under the Privacy Shield Agreement and thus offers a guarantee to
comply with European data protection law:
https://www.privacyshield.gov/participant?id=a2zt0000000TRkEAAW&status=Active.
To use the DISQUS comment function, users can log in via their own DISQUS user account or an
existing social media account (e.g. OpenID, Facebook, Twitter or Google). DISQS obtains the
user’s login data from the platforms. It is also possible to use the DISQUS comment function
as a guest, without creating or using user accounts at DISQUS or one of the specified social
media providers.
We only embed DISQUS with its functions into our website, whereby we can influence the
comments of the users. However, the users enter into a direct contractual relationship with
DISQUS, in the context of which DISQS processes the comments of the users and is a contact
for any deletion of the user’s data. We refer to DISQUS’s data protection declaration:
https://help.disqus.com/terms-and-policies/disqus-privacy-policy and also point out to users
that they can assume that DISQUS stores not only the comment content but also its IP address
and the time of the comment, and can store cookies on users’ computers and use them to
display advertising. Users may, however, object to the processing of their data for the
purpose of displaying advertisements: https://disqus.com/data-sharing-settings.
Akismet Anti-Spam Check
Our online offer uses the service “Akismet” offered by Automattic Inc, 60 29th Street #343,
San Francisco, CA 94110, USA. The use is based on our legitimate interests within the
meaning of Art. 6 para. 1 lit. f) DSGVO. With the help of this service, comments of real
people are distinguished from spam comments. All comment information is sent to a server in
the USA, where it is analyzed and stored for four days for comparison purposes. If a comment
has been classified as spam, the data will be stored after this time. This information
includes the name entered, the e-mail address, the IP address, the comment content, the
referrer, information on the browser used, the computer system and the time of entry.
Further information on Akismet’s collection and use of the data can be found in Automattic’s
privacy policy: https://automattic.com/privacy/.
Users are welcome to use pseudonyms or refrain from entering their name or email address. You
can completely prevent the transfer of data by not using our comment system. That would be a
pity, but unfortunately we see no other alternatives that work just as effectively.
Retrieval of profile pictures from Gravatar
We use the service Gravatar of Automattic Inc. 60 29th Street #343, San Francisco, CA 94110,
USA, within our online offer and especially in our blog.
Gravatar is a service where users can log in and store profile pictures and their e-mail
addresses. If users leave contributions or comments with the respective e-mail address on
other online presences (above all in blogs), their profile pictures can be displayed next to
the contributions or comments. For this purpose, the e-mail address provided by the users is
transmitted to Gravatar in encrypted form for the purpose of checking whether a profile has
been saved for it. This is the sole purpose of the transmission of the e-mail address and it
will not be used for other purposes, but will be deleted thereafter.
The use of Gravatar is based on our legitimate interests within the meaning of Art. 6 Para. 1
letter f) DSGVO, as we offer the possibility of personalising their contributions with a
profile picture with the help of Gravatar.
By displaying the images, Gravatar obtains the IP address of the users, as this is necessary
for communication between a browser and an online service. For more information on
Gravatar’s collection and use of the data, please refer to Automattic’s privacy policy:
https://automattic.com/privacy/.
If users do not want an image associated with their email address to appear in Gravatar’s
comments, you should use a non-Gravatar email address for commenting. We would also like to
point out that it is also possible to use an anonymous or no e-mail address if users do not
wish their own e-mail address to be sent to Gravatar. Users can completely prevent the
transfer of data by not using our comment system.
Retrieval of emojis and smilies
Within our WordPress blog, graphical emojis (or smilies), i.e. small graphical files that
express feelings, are used that are obtained from external servers. The providers of the
servers collect the IP addresses of the users. This is necessary so that the emojie files
can be transmitted to the users’ browsers. The Emojie service is offered by Automattic Inc,
60 29th Street #343, San Francisco, CA 94110, USA. Automattic’s privacy policy:
https://automattic.com/privacy/. The server domains used are s.w.org and twemoji.maxcdn.com,
whereby to our knowledge these are so-called content-delivery networks, i.e. servers which
serve only a fast and secure transmission of the files and the personal data of the users
are deleted after the transmission.
Emojis is used on the basis of our legitimate interests, i.e. interest in an attractive
design of our online offer in accordance with Art. 6 para. 1 lit. f. DSGVO.
Contact
When contacting us (e.g. via contact form, e-mail, telephone or social media), the user’s
details are processed for processing the contact enquiry and its processing in accordance
with Art. 6 para. 1 lit. b) DSGVO. User information can be stored in a customer relationship
management system (“CRM system”) or comparable request organization.
We delete the requests if they are no longer necessary. We review this requirement every two
years; the statutory archiving obligations also apply.
CRM system Zendesk
We use the CRM system “Zendesk” of the provider Zendesk, Inc. 989 Market Street #300, San
Francisco, CA 94102, USA, in order to process user inquiries faster and more efficiently
(legitimate interest according to art. 6 par. 1 lit. f. DSGVO).
Zendesk is certified under the Privacy Shield Agreement and thus offers an additional
guarantee to comply with European data protection law
(https://www.privacyshield.gov/participant?id=a2zt0000000TOjeAAG&status=Active).
Zendesk uses the user data only for technical processing of the enquiries and does not pass
them on to third parties. To use Zendesk, you must provide at least a correct email address.
Pseudonymous use is possible. During the processing of service requests, it may be necessary
to collect further data (name, address). The use of Zendesk is optional and serves to
improve and accelerate our customer and user service.
If users do not agree to the collection and storage of data in Zendesk’s external system, we
offer them alternative contact options for submitting service requests by e-mail, telephone,
fax or post.
For further information, please refer to Zendesk’s privacy policy:
https://www.zendesk.de/company/customers-partners/privacy-policy/.
Newsletter
With the following information we inform you about the contents of our newsletter as well as
the registration, dispatch and statistical evaluation procedure and your rights of
objection. By subscribing to our newsletter you agree to the receipt and the described
procedures.
Content of the newsletter: We send newsletters, e-mails and other electronic notifications
containing advertising information (hereinafter “newsletters”) only with the consent of the
recipients or a legal permission. If the contents of a newsletter are specifically described
within the scope of a registration, they are decisive for the consent of the users. In
addition, our newsletters contain information about our services and us.
Double opt-in and logging: Subscription to our newsletter takes place in a so-called double
opt-in procedure. This means that after registration you will receive an e-mail asking you
to confirm your registration. This confirmation is necessary so that no one can log in with
other e-mail addresses. Subscriptions to the newsletter are logged in order to be able to
prove the registration process in accordance with legal requirements. This includes the
storage of the login and confirmation time, as well as the IP address. The changes to your
data stored with the shipping service provider are also logged.
Credentials: To subscribe to the newsletter, simply enter your e-mail address. Optionally, we
ask you to enter a name in the newsletter in order to address us personally.
The dispatch of the newsletter and the performance measurement associated with it are based
on the recipient’s consent pursuant to Art. 6 para. 1 lit. a, Art. 7 DSGVO in conjunction
with § 7 para. 2 no. 3 UWG or, if consent is not required, on the basis of our legitimate
interests in direct marketing pursuant to Art. 6 para. 1 lt. f. DSGVO in conjunction with
Section 7 para. 3 UWG.
The registration procedure is recorded on the basis of our legitimate interests pursuant to
Art. 6 para. 1 lit. f DSGVO. We are interested in the use of a user-friendly and secure
newsletter system that serves both our business interests and the expectations of users and
also allows us to provide proof of consent.
Cancellation/Revocation – You can cancel the receipt of our newsletter at any time, i.e.
revoke your consent. You will find a link to cancel the newsletter at the end of each
newsletter. We may store the e-mail addresses we have unsubscribed for up to three years on
the basis of our legitimate interests before we delete them in order to be able to prove a
previously given consent. The processing of these data is limited to the purpose of a
possible defence against claims. An individual application for cancellation is possible at
any time, provided that at the same time the former existence of a consent is confirmed.
Newsletter – Mailchimp
The newsletter is sent by the mail service provider “MailChimp”, a newsletter delivery
platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000,
Atlanta, GA 30308, USA. The data protection regulations of the shipping service provider can
be viewed here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC d/b/a
MailChimp is certified under the Privacy Shield Agreement and thus offers a guarantee to
comply with the European data protection level
(https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active). The
dispatch service provider is used on the basis of our legitimate interests according to Art.
6 Para. 1 letter f DSGVO and an order processing contract according to Art. 28 Para. 3 S. 1
DSGVO.
The shipping service provider can use the recipient’s data in pseudonymous form, i.e. without
assignment to a user, to optimize or improve its own services, e.g. to technically optimize
the dispatch and presentation of the newsletter or for statistical purposes. However, the
shipping service does not use the data of our newsletter recipients to write them down
itself or to pass the data on to third parties.
Newsletter – Performance Measurement
The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file which is downloaded
from our server when the newsletter is opened or, if we use a shipping service provider,
from whose server. Within the scope of this retrieval, technical information, such as
information about the browser and your system, as well as your IP address and time of
retrieval are initially collected.
This information is used to technically improve the services based on the technical data or
the target groups and their reading behaviour based on their retrieval locations (which can
be determined using the IP address) or access times. The statistical surveys also include
determining whether the newsletters are opened, when they are opened and which links are
clicked. For technical reasons, this information can be assigned to the individual
newsletter recipients. However, it is neither our endeavour, nor, if used, that of the
shipping service provider, to observe individual users. The evaluations serve us much more
to recognize the reading habits of our users and to adapt our contents to them or to send
different contents according to the interests of our users.
Hosting and e-mail dispatch
The hosting services we use serve to provide the following services: Infrastructure and
platform services, computing capacity, storage space and database services, e-mail delivery,
security services and technical maintenance services that we use for the purpose of
operating this online offer.
We or our hosting provider process inventory data, contact data, content data, contract data,
usage data, meta- and communication data of customers, interested parties and visitors of
this online offer on the basis of our legitimate interests in an efficient and secure
provision of this online offer according to Art. 6 Para. 1 lit. f DSGVO in conjunction with.
Art. 28 DSGVO (conclusion of order processing contract).
Collection of access data and log files
We, or our hosting provider, collect the following data on the basis of our legitimate
interests within the meaning of Art. 6 para. 1 lit. f. DSGVO data on each access to the
server on which this service is located (so-called server log files). Access data includes
the name of the accessed website, file, date and time of access, transferred data volume,
notification of successful access, browser type and version, the user’s operating system,
referrer URL (the previously visited page), IP address and the requesting provider.
Log file information is stored for a maximum of 7 days for security reasons (e.g. to
investigate misuse or fraud) and then deleted. Data whose further storage is required for
evidentiary purposes are excluded from deletion until the respective incident has been
finally clarified.
Google Analytics
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and
economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO)
Google Analytics, a web analysis service of Google LLC (“Google”). Google uses cookies. The
information generated by the cookie about the use of the online offer by users is generally
transferred to a Google server in the USA and stored there.
Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply
with European data protection law
(https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online offer by
users, to compile reports on the activities within this online offer and to provide us with
further services associated with the use of this online offer and the use of the Internet.
Pseudonymous user profiles can be created from the processed data.
We use Google Analytics only with IP anonymization enabled. This means that Google will
reduce the IP address of users within Member States of the European Union or in other states
party to the Agreement on the European Economic Area. Only in exceptional cases will the
full IP address be transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user’s browser is not merged with other Google data. Users
can prevent the storage of cookies by setting their browser software accordingly; users can
also prevent Google from collecting the data generated by the cookie and relating to their
use of the online offer and the processing of this data by Google by downloading and
installing the browser plug-in available under the following link:
http://tools.google.com/dlpage/gaoptout?hl=en.
Further information on data use by Google, possible settings and objections can be found in
Google’s data protection declaration (https://policies.google.com/technologies/ads) and in
the settings for the display of advertisements by Google
(https://adssettings.google.com/authenticated).
Users’ personal data will be deleted or made anonymous after 14 months.
Google Universal Analytics
We use Google Analytics in its design as “Universal Analytics”. “Universal Analytics” refers
to a process by Google Analytics in which the user analysis is based on a pseudonymous user
ID and a pseudonymous profile of the user with information from the use of various devices
is created (so-called “cross-device tracking”).
Target group formation with Google Analytics
We use Google Analytics to display the ads placed by Google and its partners within
advertising services only to users who have also shown an interest in our online offer or
who have certain characteristics (e.g. interests in certain topics or products that are
determined by the web pages visited) that we transmit to Google (so-called “remarketing” or
“Google Analytics Audiences”). With the help of remarketing audiences we would also like to
ensure that our ads correspond to the potential interest of the users.
Google AdWords and Conversion Measurement
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and
economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO)
the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA,
(“Google”).
Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply
with European data protection law
(https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
We use the online marketing process Google “AdWords” to place ads 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 ads. This allows us to display ads for and
within our online offer more specifically in order to present users only ads that
potentially correspond to their interests. For example, if a user is shown ads for products
in which he is interested in other online offers, this is referred to as “remarketing”. For
these purposes, when our and other websites on which the Google Advertising Network is
active are accessed, Google directly executes a code from Google and (re)marketing tags
(invisible graphics or code, also known as “web beacons”) are integrated into the website.
With their help, an individual cookie, i.e. a small file, is stored on the user’s device
(comparable technologies can also be used instead of cookies). In this file it is noted
which websites the user visits, which contents he is interested in and which offers the user
has clicked on, technical information on the browser and operating system, referring
websites, visiting time and further information on the use of the online offer.
We also receive an individual “conversion cookie”. The information collected with the help of
cookies is used by Google to generate conversion statistics for us. However, we only see the
total number of anonymous users who clicked on our ad and were redirected to a page with a
conversion tracking tag. However, we do not receive any information that personally
identifies users.
User data is processed pseudonymously within the Google advertising network. This means that
Google does not store and process, for example, the names or e-mail addresses of users, but
processes the relevant data cookie-related within pseudonymous user profiles. This means
from Google’s point of view, the ads are not managed and displayed for a specifically
identified person, but for the cookie holder, regardless of who this cookie holder is. This
does not apply if a user has expressly permitted Google to process the data without this
pseudonymisation. The information collected about the users is transmitted to Google and
stored on Google’s servers in the USA.
Further information on data use by Google, possible settings and objections can be found in
Google’s data protection declaration (https://policies.google.com/technologies/ads) and in
the settings for the display of advertisements by Google
(https://adssettings.google.com/authenticated).
Facebook Pixel, Custom Audiences and Facebook Conversion
Due to our legitimate interests in the analysis, optimisation and economic operation of our
online offer and for these purposes the so-called “Facebook pixel” of the social network
Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or,
if you are based in the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour,
Dublin 2, Ireland (“Facebook”), is used within our online offer.
Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee to
comply with European data protection law
(https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
With the help of the Facebook pixel, Facebook is able to determine the visitors of our online
offer as a target group for the presentation of ads (so-called “Facebook ads”). Accordingly,
we use the Facebook pixel to display the Facebook ads we post only to Facebook users who
have also shown an interest in our online offering or who have certain features (e.g.
interests in certain topics or products that are determined by the websites visited) that we
transmit to Facebook (so-called “custom audiences”). We also want to use the Facebook pixel
to ensure that our Facebook ads meet the potential interest of users and are not a nuisance.
The Facebook pixel also helps us understand the effectiveness of Facebook ads for
statistical and market research purposes by showing whether users have been redirected to
our website after clicking on a Facebook ad (so-called “conversion”).
Facebook processes the data in accordance with Facebook’s Data Usage Policy. Accordingly,
general information on the display of Facebook ads can be found in the Facebook Data Usage
Policy: https://www.facebook.com/policy.php. For specific information and details about the
Facebook pixel and how it works, please visit the Facebook Help section:
https://www.facebook.com/business/help/651294705016616.
You can object to the collection by the Facebook pixel and use of your data to display
Facebook ads. To set what types of ads you see within Facebook, you can visit the page set
up by Facebook and follow the instructions on usage-based advertising settings:
https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e. they
are applied to all devices, such as desktop computers or mobile devices.
You may also object to the use of cookies for range measurement and advertising purposes via
the deactivation page of the network advertising initiative
(http://optout.networkadvertising.org/) and additionally the US website
(http://www.aboutads.info/choices) or the European website
(http://www.youronlinechoices.com/uk/your-ad-choices/).
Bing Ads
Within our online offer, we make no representations or warranties of any kind based on our
legitimate interests (i.e. interest in the analysis, optimisation and economic operation of
our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO), the conversion and
tracking tool “Bing Ads” of Microsoft Corporation, One Microsoft Way, Redmond, WA
98052-6399, USA. Microsoft stores cookies on the user’s devices in order to enable an
analysis of the use of our online offer by the user if users have accessed our online offer
via a Microsoft Bing display (so-called “conversion measurement”). Microsoft and we can
recognize in this way that someone has clicked on an ad, has been redirected to our online
offer and has reached a previously defined target page (so-called “conversion page”). We
only see the total number of users who clicked on a Bing ad and were then redirected to the
conversion page. No IP addresses are stored. No personal information about the identity of
the users is communicated.
Microsoft is certified under the Privacy Shield Agreement and thus offers a guarantee to
comply with European data protection law
(https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active).
If users do not wish to participate in the Bing Ads tracking process, you can also deactivate
the necessary setting of a cookie via browser settings or use Microsoft’s opt-out page:
http://choice.microsoft.com/de-DE/opt-out.
Users can find further information on data protection and the cookies used at Microsoft Bing
Ads in Microsoft’s data protection declaration:
https://privacy.microsoft.com/de-de/privacystatement.
Visual Website Optimizer
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and
economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO)
the service Visual Website Optimizer (an offer of Wingify Software Private Limited, 404,
Gopal Heights, Netaji Subhash Place, Pitam Pura, Delhi 110034, India).
Visual Website Optimizer allows in the context of so-called “A/B-Testings”, “Clicktracking”
and “Heatmaps” to understand how different changes of a website affect (e.g. changes of the
input fields, the design, etc.). A/B tests serve to improve the user-friendliness and
performance of online offers. For example, users are shown different versions of a website
or its elements, such as input forms, on which the placement of the content or labels of the
navigation elements can differ. Subsequently, it is possible to determine which of these
websites or elements are more suited to the needs of the users on the basis of the users’
behaviour, e.g. longer stays on the website or more frequent interaction with the elements.
“Clicktracking” allows users to keep track of their movements within an entire online
offering. Since the results of these tests are more accurate if the user interaction can be
monitored over a certain period of time (e.g. if a user likes to return), cookies are
usually stored on the user’s computers for these test purposes. “Heatmaps” are mouse
movements of the users, which are combined to an overall picture, with the help of which
e.g. it is possible to recognize which website elements are preferred and which website
elements users prefer less.
Cookies are only stored on the user’s devices for these test purposes. Only pseudonymous user
data is processed. For further information, please refer to the Visual Website Optimizer
Privacy Policy: https://vwo.com/privacy-policy/.
If you do not want the Visual Website Optimizer to record your usage behavior, you can use
this link to object to data collection: https://[PLEASE INSERT YOUR
DOMAIN]/?vwo_opt_out=1.
Online presence in social media
We maintain online presences within social networks and platforms in order to communicate
with active customers, interested parties and users and to inform them about our services.
When accessing the respective networks and platforms, the terms and conditions and the data
processing guidelines of their respective operators apply.
Unless otherwise stated in our privacy policy, we process the data of users who communicate
with us within social networks and platforms, e.g. write articles on our websites or send us
messages.
Integration of third-party services and content
Within our online offer, we make no representations or warranties of any kind based on our
legitimate interests (i.e. interest in the analysis, optimisation and economic operation of
our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) content or service
offerings of third parties to incorporate their content and services, such as videos or
fonts (hereinafter uniformly referred to as “content”).
This always presupposes that the third party providers of this content perceive the IP
address of the users, since without the IP address they could not send the content to their
browser. The IP address is therefore required for the display of this content. We make every
effort to use only those contents whose respective providers use the IP address only for the
delivery of the contents. Third-party providers may also use so-called pixel tags (invisible
graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags”
can be used to evaluate information such as visitor traffic on the pages of this website.
The pseudonymous information may also be stored in cookies on the user’s device and may
include technical information about the browser and operating system, referring websites,
visiting time and other information about the use of our online offer, as well as be linked
to such information from other sources.
Vimeo
We can integrate the videos of the platform “Vimeo” of the provider Vimeo Inc, Attention:
Legal Department, 555 West 18th Street New York, New York 10011, USA. Privacy policy:
https://vimeo.com/privacy. We point out that Vimeo may use Google Analytics and refer to the
privacy policy (https://www.google.com/policies/privacy) and opt-out options for Google
Analytics (http://tools.google.com/dlpage/gaoptout?hl=en) or Google’s settings for data use
for marketing purposes (https://adssettings.google.com/.).
Youtube
We integrate the videos of the platform “YouTube” of the provider Google LLC, 1600
Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy:
https://www.google.com/policies/privacy/, Opt-Out:
https://adssettings.google.com/authenticated.
Google Fonts
We integrate the fonts (“Google Fonts”) of the provider Google LLC, 1600 Amphitheatre
Parkway, Mountain View, CA 94043, USA. Privacy Policy:
https://www.google.com/policies/privacy/, Opt-Out:
https://adssettings.google.com/authenticated.
Google ReCaptcha
We integrate the function for the recognition of bots, e.g. for entries in online forms
(“ReCaptcha”) of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA
94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out:
https://adssettings.google.com/authenticated.
Google Maps
We integrate the maps of the service “Google Maps” of the provider Google LLC, 1600
Amphitheatre Parkway, Mountain View, CA 94043, USA. The processed data may include in
particular IP addresses and location data of the users, which, however, are not collected
without their consent (as a rule within the framework of the settings of their mobile
devices). The data can be processed in the USA. Privacy Policy:
https://www.google.com/policies/privacy/, Opt-Out:
https://adssettings.google.com/authenticated.
Using Facebook Social Plugins
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and
economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO)
Social Plugins (“Plugins”) of the social network facebook.com, which is operated by Facebook
Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The
plugins can display interaction elements or content (e.g. videos, graphics or text
contributions) and are identified by one of the Facebook logos (white “f” on blue tile, the
terms “like”, “like” or a “thumbs up” sign) or are marked with the addition “Facebook Social
Plugin”. The list and appearance of Facebook Social Plugins can be viewed here:
https://developers.facebook.com/docs/plugins/.
Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee to
comply with European data protection law
(https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
When a user calls up a function of this online offer that contains such a plugin, his device
establishes a direct connection to the Facebook servers. The content of the plugin is
transmitted by Facebook directly to the user’s device and integrated into the online offer.
The processed data can be used to create user profiles. We therefore have no influence on
the amount of data Facebook collects with the help of this plugin and therefore inform users
according to our level of knowledge.
By integrating the plugins, Facebook receives information that a user has called up the
corresponding page of the online offer. If the user is logged in to Facebook, Facebook can
assign the visit to his Facebook account. When users interact with the plugins, such as
pressing the Like button or posting a comment, the information is sent directly from your
device to Facebook and stored there. If a user is not a member of Facebook, it is still
possible for Facebook to obtain and store their IP address. According to Facebook, only an
anonymized IP address is stored in Germany.
The purpose and scope of the data collection and the further processing and use of the data
by Facebook, as well as the relevant rights and setting options for the protection of users’
privacy, can be found in Facebook’s data protection information:
https://www.facebook.com/about/privacy/.
If a user is a Facebook member and does not want Facebook to collect data about him via this
online offer and link it to his membership data stored on Facebook, he must log out of
Facebook before using our online offer and delete his cookies. Further settings and
objections to the use of data for advertising purposes are possible within the Facebook
profile settings: https://www.facebook.com/settings?tab=ads or via the US page
http://www.aboutads.info/choices/ or the EU page http://www.youronlinechoices.com/. The
settings are platform-independent, i.e. they are applied to all devices, such as desktop
computers or mobile devices.
Twitter
Functions and contents of the Twitter service, offered by Twitter Inc, 1355 Market Street,
Suite 900, San Francisco, CA 94103, USA, can be integrated into our online offering. This
may include, for example, content such as images, videos or texts and buttons with which
users can express their appreciation of the content, subscribe to the authors of the content
or our contributions. If the users are members of the Twitter platform, Twitter can assign
calling up the above content and functions to the users’ profiles there. Twitter is
certified under the Privacy Shield Agreement and thus offers a guarantee to comply with
European data protection law
(https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active). Privacy
Policy: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization.
Instagram
Within our online offer, functions and contents of the Instagram service, offered by
Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA, can be integrated. This may
include, for example, content such as images, videos or texts and buttons with which users
can express their appreciation of the content, subscribe to the authors of the content or
our contributions. If the users are members of the Instagram platform, Instagram can assign
the call of the above contents and functions to the profiles of the users there. Instagram
Privacy Policy: http://instagram.com/about/legal/privacy/.
Pinterest
Within our online offer, functions and contents of the Pinterest service, offered by
Pinterest Inc. 635 High Street, Palo Alto, CA, 94301, USA, can be integrated. This may
include, for example, content such as images, videos or texts and buttons with which users
can express their appreciation of the content, subscribe to the authors of the content or
our contributions. If the users are members of the Pinterest platform, Pinterest can assign
the call of the above contents and functions to the profiles of the users there. Pinterest’s
privacy policy: https://about.pinterest.com/de/privacy-policy.
Sharing functions of AddThis
The “AddThis” service (1595 Spring Hill Rd Suite 300 Vienna, VA 22182, USA) is used within
our online offer to share the contents of this online offer within social networks
(so-called sharing).
The use is based on our legitimate interests, i.e. interest in a distribution of our online
offer according to Art. 6 para. 1 lit. f. DSGVO.
AddThis uses the personal information of users for the provision and execution of the sharing
functions. In addition, AddThis may use pseudonymous information of users for marketing
purposes. This data is stored on the user’s computer using so-called “cookie” text files.
Privacy Policy: http://www.addthis.com/privacy, Opt-Out:
http://www.addthis.com/privacy/opt-out.