Privacy policy

Introduction

With the following data protection declaration we would like to inform you about the types of personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter also referred to collectively as "online offer").
The terms used are not gender-specific.

Controller

Lukas Franczyk
Berger Straße 381
60385 Frankfurt am Main
Germany
E-mail address: mail@approvedrichclub.com
Legal notice: https://proverich.com/imprint

Overview of the processing

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

Types of data processed
  • Inventory data (e.g. names, addresses)
  • Content data (e.g. text entries, photographs, videos)
  • 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)
  • Location data (data indicating the location of an end user's terminal device)
  • Contract data (e.g. subject of contract, duration, customer category)
  • Payment data (e.g. bank details, invoices, payment history)
Categories of data subjects
  • Business and contractual partners
  • interested parties
  • communication partners
  • customers
  • Users (e.g. website visitors, users of online services)
Categories of data subjects
  • Business and contractual partners
  • interested parties
  • communication partners
  • customers
  • Users (e.g. website visitors, users of online services)
Purposes of processing
  • Affiliate tracking
  • Visitor activity evaluation
  • Office and organizational procedures
  • Cross-device tracking (cross-device processing of user data for marketing purposes)
  • Direct marketing (e.g. by e-mail or postal mail)
  • Interest based and behavioral marketing
  • Contact requests and communication
  • Profiling (creation of user profiles)
  • remarketing
  • Reach measurement (e.g. access statistics, recognition of returning visitors)
  • Security measures
  • Tracking (e.g. interest/behavioral profiling, use of cookies)
  • Contractual performance and service
  • Management and response to inquiries
  • Target group formation (determination of target groups relevant for marketing purposes or other output of content)
Applicable legal basis

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

  • Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO) - The data subject has given his or her consent to the processing of personal data relating to him or her for one or more specific purposes.
  • Fulfilment of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the request of the data subject.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c GDPR) - The processing is necessary for the performance of a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR) - The processing is necessary to safeguard the legitimate interests of the controller or of a third party, unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data outweigh these.
National data protection regulations in Germany

In addition to the data protection regulations of the EU General Data Protection Regulation, national regulations on data protection apply in Germany. These include in particular the law on protection against misuse of personal data in data processing (Bundesdatenschutzgesetz - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to deletion, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision making in individual cases including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (§ 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Furthermore, federal state data protection laws of the individual federal states may apply.

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, in order to ensure a level of protection appropriate to the risk.

Such measures shall include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, security of availability and separation of data relating to them. Furthermore, we have established procedures to ensure that data subjects' rights are exercised, data is deleted, and responses are made to any threats to the data. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes in accordance with the principle of data protection, by designing technology and by using data protection-friendly default settings.

Transmission and disclosure of personal data

In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. The recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

Use of cookies

Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user's computer. A cookie is primarily used to store information about a user during or after his visit within an online offer. The stored information can include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was viewed. 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 referred to as "user IDs").

The following cookie types and functions are distinguished:
  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
  • Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The interests of users used for reach measurement or marketing purposes can also be stored in such a cookie.
  • First-party cookies: First-party cookies are set by us.
  • Third party cookies (also: third party cookies): Third party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or absolutely necessary) cookies: Cookies may be absolutely necessary for the operation of a website (e.g. to store logins or other user input or for security reasons).
  • Statistical, marketing and personalization cookies: Furthermore, cookies are usually also used in the context of range measurement and when the interests of a user or his or her behavior (e.g. viewing certain content, using functions, etc.) on individual web pages are stored in a user profile. Such profiles are used to show users e.g. content that corresponds to their potential interests. This procedure is also known as "tracking", i.e. following the potential interests of users. If we use cookies or "tracking" technologies, we will inform you separately in our privacy policy or when you give your consent.
Information on legal bases:
Information on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in a business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfil our contractual obligations.
Duration of storage: Unless we provide you with explicit information on the duration of storage of permanent cookies (e.g. within the framework of a so-called cookie opt-in), please assume that the storage period can be up to two years.
General notes on revocation and objection (opt-out): Depending on whether processing is based on consent or legal permission, you have the option at any time to revoke any consent given or to object to the processing of your data by cookie technologies (collectively referred to as "opt-out"). You can initially declare your objection by means of the settings of your browser, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online service). An objection to the use of cookies for online marketing purposes can also be declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further notices of objection in the context of the information on the service providers and cookies used.
Processing of cookie data based on consent: Before we process or have processed data in the context of the use of cookies, we ask users for their consent, which can be revoked at any time. Before consent has not been given, we will only use cookies that are absolutely necessary for the operation of our online service.
  • Processed types of data: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), legitimate interests (Art. 6 para. 1 sentence 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 scope of contractual and comparable legal relationships and associated measures and within the scope of communication with the contractual partners (or pre-contractual), e.g. to answer inquiries.

We process this data for the purpose of fulfilling our contractual obligations, securing our rights and for the purposes of the administrative tasks associated with this data as well as for business organization. Within the framework of the applicable law, we will only pass on the data of the contractual partners to third parties to the extent that is necessary for the aforementioned purposes or to fulfil legal obligations or with the consent of the persons concerned (e.g. to involved telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.

We will inform the contractual partners which data is required for the above-mentioned purposes before or within the scope of data collection, e.g. in online forms, by special marking (e.g. colors) or symbols (e.g. asterisks or similar), or personally.

We delete the data after expiration of legal warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g., as long as it must be kept for legal archiving reasons (e.g., for tax purposes usually 10 years). We will delete data that has been disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, generally after the end of the order.

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

Customer account: Contractual partners can create an account within our online offer (e.g. customer or user account, in short "customer account"). If the registration of a customer account is required, contractual partners are informed of this as well as of the information required for registration. The customer accounts are not public and cannot be indexed by search engines. Within the scope of registration and subsequent logins and use of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove the registration and prevent possible misuse of the customer account.

If customers have cancelled their customer account, the data concerning the customer account will be deleted, subject to the retention of such data being required by law. It is the responsibility of customers to secure their data when they cancel their customer account.

Store and e-commerce: We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and related services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, in order to carry out the delivery or execution of the order for our customers. For the processing of payment transactions we use the services of banks and payment service providers. The required information is marked as such within the scope of the order or comparable acquisition process and includes the information required for delivery, or provision and invoicing, as well as contact information in order to be able to make any necessary arrangements.

  • Processed data types: 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, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Interested parties, business and contractual partners, customers.
  • Purposes of processing: contractual services and performance, contact requests and communication, office and organizational procedures, administration and answering of requests, security measures.
  • Legal basis: Fulfilment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
Payment service provider
Within the scope of contractual and other legal relationships, due to legal obligations or otherwise based on our legitimate interests, we offer the persons concerned efficient and secure payment options and use other payment service providers in addition to banks and credit institutions (collectively "payment service providers"). The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient related data. These details are required to complete the transactions. However, the data entered is only processed by the payment service providers and stored by them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the payment service providers may transfer the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the general terms and conditions and the data protection information of the payment service providers. For payment transactions, the terms and conditions and the data protection notices of the respective payment service providers apply, which can be accessed within the respective websites or transaction applications. We also refer to these for further information and the assertion of rights of revocation, disclosure and other rights of affected persons.
  • Processed data types: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Customers, interested parties.
  • Purposes of processing: Contractual performance and service, contact requests and communication, affiliate tracking.
  • Legal basis: Fulfilment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
Services used and service providers:
  • Stripe: payment services; service providers: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Website: https://stripe.com/de; Privacy Policy: https://stripe.com/de/privacy.
Registration, login and user account

Users can create a user account. Within the scope of registration, users are provided with the required mandatory data which is processed for the purpose of providing the user account on the basis of contractual obligation fulfilment. The processed data includes in particular the login information (name, password and an e-mail address). The data entered during registration is used for the purposes of using the user account and its purpose. Users can be informed by e-mail about processes relevant to their user account, such as technical changes. If users have cancelled their user account, their data with regard to the user account will be deleted, subject to a legal obligation to retain data. It is the responsibility of users to back up their data before the end of the contract if they have terminated it. We are entitled to irretrievably delete all of the user's data stored during the contract period. Within the scope 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 storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorized use. As a matter of principle, this data is not passed on to third parties, unless it is necessary to pursue our claims or there is a legal obligation to do so.

Online Forum:

Participation in the forum requires registration, in which, subject to other details in the registration form, you must provide a name or your name, a password and the e-mail address to which the access data will be sent. For security reasons, the password should be state-of-the-art, i.e. complicated (users will be advised of this during registration if necessary) and not used elsewhere. Posts in the forum are not visible to the public but only to members of the forum; sometimes, their visibility is limited to certain members or groups of members. The contributions of the authors are stored with their names, if registered or indicated, the time and the content of the entry. When registering and writing entries, the IP addresses of the users are also stored, in case the entries contain illegal content and the IP addresses could be used for legal prosecution. The controller reserves the right to delete the registrations and entries on the basis of an appropriate consideration.

  • Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Contractual services and performance, security measures, administration and answering of inquiries.
  • Legal basis:rt. 6 para. 1 sentence 1 lit. a GDPR), Fulfilment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
Contact

When contacting us (e.g. via contact form, e-mail, telephone or social media), the data of the inquiring persons will be processed to the extent necessary to answer the contact inquiries and any requested measures. The answering of contact inquiries within the scope of contractual or pre-contractual relations is carried out in order to fulfill our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of the legitimate interest in answering the inquiries.

  • Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos).
  • Persons concerned:rtner.
  • Purposes of processing: contact requests and communication.
  • Legal basis: Fulfilment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
Newsletter and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter referred to as "newsletters") only with the consent of the recipients or a legal permission. If, in the course of registering for the newsletter, its contents are specifically described, they are decisive for the consent of the users. Furthermore, our newsletters contain information about our services and us. To subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name for the purpose of personal contact in the newsletter, or other information if this is necessary for the purposes of the newsletter.

Double opt-in procedure:The registration for our newsletter is always carried out 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 register with someone else’s e-mail addresses. The newsletter registrations are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored by the mailing service provider are also logged.

Deletion and restriction of processing: We may store the deleted e-mail addresses 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 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 former existence of a consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list for this purpose alone (so-called "block list"). The logging of the registration procedure is based on our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Information on legal bases: The dispatch of newsletters is based on the consent of the recipients or, if consent is not required, on 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 e-mails, this is done on the basis of our legitimate interests. The registration process will be 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, actions and offers.

Analysis and success measurement: The newsletters contain a so-called "web-beacon", i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened, or, if we use a mailing service provider, from their server. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and the time of retrieval, is initially collected. This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined by means of 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 intention nor, if used, that of the mailing service provider to observe individual users. Rather, the evaluations serve to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The evaluation of the newsletter and the measurement of success rates are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves 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 objected to.

- Processed data types: 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). - Affected persons: Communication partners. - Purposes of processing: direct marketing (e.g. by e-mail or by post). - Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR). - Opt-out: You can cancel the receipt of 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 e-mail.
Web analysis, monitoring and optimization

Web analysis (also known as "reach measurement") is used to evaluate the streams of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the range analysis we can, for example, identify at what time our online offer or its functions or contents are most frequently used or invite reuse. We can also understand which areas require optimization. In addition to web analysis, we can also use test procedures, e.g. to test and optimize different versions of our online offer or its components. For these purposes, so-called user profiles can be created and stored in a file (so-called "cookie") or similar procedures with the same purpose can be used. This information may include, for example, content viewed, web pages visited and elements used there, and technical details 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 data may also be processed, depending on the provider. The IP addresses of users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect the users. In general, in the context of web analysis, A/B testing and optimization, no clear user data (such as e-mail addresses or names) are stored, but pseudonyms. This means that we as well as the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures. We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

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

  • Processed types of data: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behaviour-related profiling, use of cookies), visitor action evaluation, profiling (creation of user profiles).
  • Security measures: IP-Masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
  • Used services and service providers:
  • Google Analytics: coverage measurement and web analysis; service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com/intl/de/about/analytics/; privacy policy: https://policies.google.com/privacy.
Online marketing

We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the display of advertising and other content (collectively referred to as "Content") based on the potential interests of users and the measurement of its effectiveness. For these purposes, so-called user profiles are created and stored in a file (a so-called "cookie") or similar procedures are used, by means of which user data relevant to the presentation of the aforementioned content is stored. This information may include, for example, the content viewed, web pages visited, online networks used, but also communication partners and technical details 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 data may also be processed. The IP addresses of users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect the users. In general, no clear user data (such as e-mail addresses or names) are stored in the context of the online marketing process, but pseudonyms. This means that we as well as the providers of the online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles. As a rule, the information in the profiles is stored in the cookies or by means of similar procedures. These cookies can later be read out and analyzed for the purpose of presenting content on other websites that use the same online marketing procedure, and can also be supplemented with additional data and stored on the server of the online marketing procedure provider. As an exception, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing procedure we use and the network links the user profiles with the aforementioned data. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration. As a matter of principle, we only receive access to summarized information about the success of our advertisements. However, we can check in the context of so-called conversion measurements which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyze the success of our marketing measures. Unless otherwise stated, we ask you to assume that used cookies are stored for a period of two years.

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

Facebook pixel: With the help of the Facebook pixel, Facebook is on the one hand 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 in order to display the Facebook ads placed by us only to those users on Facebook and within the services of partners cooperating with Facebook (so-called "Audience Network" https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offering or who exhibit certain characteristics (e.g. interest in certain topics or products that can be seen from the websites visited) that we transmit to Facebook (so-called "Custom Audiences"). With the help of the Facebook pixel, we also want to ensure that our Facebook Ads correspond to the potential interest of users and do not appear to be annoying. The Facebook pixel also enables us to track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook ad (so-called "conversion measurement").

  • Types of data processed: Usage data (e.g., web pages visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses), location data (data indicating the location of an end user's end device).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, visitor action analysis, interest-based and behavioural marketing, profiling (creation of user profiles), reach measurement (e.g. access statistics, recognition of returning visitors), target group formation (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (processing of user data across devices for marketing purposes).
  • Security measures: IP-Masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
  • Possibility of objection (Opt-Out): We refer to the data protection information of the respective providers and the possibilities of objection (so-called "Opt-Out") indicated for the providers. If no explicit opt-out option has been specified, it is possible to deactivate cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary form for the respective areas: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Transnational: https://optout.aboutads.info.
  • Used services and service providers:
  • Google Ads and conversion measurement: We use the online marketing process "Google Ads" to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads. We also measure the conversion of the ads. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page with a so-called "conversion tracking tag". However, we do not receive any information that can identify users. Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy.
  • Google Ad Manager: We use the "Google Marketing Platform" (and services such as "Google Ad Manager") to place ads on the Google advertising network (e.g., in search results, in videos, on web pages, etc.). The Google Marketing Platform is characterized by the fact that ads are displayed in real time based on the presumed interests of users. This allows us to display ads for and within our online offering in a more targeted manner, so that we can show users only ads that potentially match their interests. For example, if a user is shown ads for products that he or she has been interested in on other websites, this is called "remarketing". Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy.
  • Facebook Pixels: 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; Privacy Policy: https://www.facebook.com/about/privacy; Opt-Out: https://www.facebook.com/settings?tab=ads; Additional Privacy Notice: Agreement on Joint Processing of Personal Information with the Facebook Pixel (and other Facebook business tools): https://www.facebook.com/legal/controller_addendum.
Presence in social networks (social media)

We maintain online presences within social networks and in this context we process user data in order to communicate with the users active there or to offer information about us. Please note that user data may be processed outside the European Union. This can result in risks for the users, because the enforcement of the users' rights could be made more difficult. Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, user profiles can be created on the basis of user behavior and the resulting interests of the users. The user profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behaviour and interests of the users are stored. Furthermore, data may also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them). For a detailed description of the respective forms of processing and the possibilities of objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks. Also in the case of requests for information and the assertion of data subject rights, we would like to point out that these can most effectively be asserted with the providers. Only the providers have access to the data of the users in each case and can directly take appropriate measures and provide information. Should you nevertheless require assistance, you can contact us.

  • Processed data types: 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).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
  • Legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
  • Used services and service providers:
  • Instagram: Social network; Service provider: Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy.
  • 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; Privacy Policy: https://www.facebook.com/about/privacy; Opt-Out: Advertising Settings: https://www.facebook.com/settings?tab=ads; Additional Privacy Notice: Agreement on Joint Processing of Personal Information on Facebook Pages: https://www.facebook.com/legal/terms/page_controller_addendum, Privacy Notice for Facebook Pages: https://www.facebook.com/legal/terms/information_about_page_insights_data; Agreement on Joint Processing of Personal Information with Facebook Business Tools: https://www.facebook.com/legal/controller_addendum.
Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consent permitted for processing is revoked or other permissions cease to apply (e.g. if the purpose for which the data were processed ceases to apply or if they are not necessary for the purpose). Unless the data are deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or that must be stored for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person. Further information on the deletion of personal data may also be provided in the individual data protection notes of this privacy policy.

Amendment and update of the data protection declaration

We kindly ask you to inform yourself regularly about the content of our privacy policy. We will adapt the data protection declaration as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes make it necessary for you to take action to cooperate (e.g. to give your consent) or to receive other individual notification. If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.

Rights of the data subjects

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

  • Right of objection: You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data relating to you which is carried out pursuant to Art. 6, paragraph 1, letter e or f of the GDPR; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing, including profiling, insofar as it is linked to such direct marketing.
  • Right to withdraw consent: You have the right to revoke consents at any time.
  • Right to information: You have the right to request confirmation as to whether or not data in question is being processed and to receive information about this data and further information and a copy of the data in accordance with the legal requirements.
  • Right of rectification: You have the right to request the completion of the data concerning you or the rectification of incorrect data concerning you, in accordance with the law.
  • Right to erasure and limitation of processing: You have the right to request, in accordance with the law, the immediate erasure of data concerning you or, alternatively, in accordance with the law, the limitation of processing of the data.
  • Right to data transferability:You have the right, in accordance with the legal requirements, to receive data concerning you that you have provided to us in a structured, common and machine-readable format or to demand that it be transferred to another controller.
  • Complaints to supervisory authorities: 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 in which you are normally resident, your place of work or the place where the alleged infringement is committed, if you believe that the processing of personal data relating to you is in breach of the GDPR.
Supervisory authority responsible for us:

The Hessian Commissioner for Data Protection and Freedom of Information Gustav-Stresemann-Ring 1 65189 Wiesbaden Germany

Definitions of terms

This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined above all in Art. 4 DSGVO. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.

  • Affiliate tracking: As part of affiliate tracking, links are logged with which the linking websites refer users to websites with product or other offers. The operators of the respective linking websites can receive a commission if users follow these so-called affiliate links and then take advantage of the offers (e.g. buy goods or services). To this end, it is necessary for the providers to be able to track whether users who are interested in certain offers subsequently take notice of them at the instigation of the affiliate links. Therefore, for affiliate links to work, it is necessary for them to be supplemented with certain values that become part of the link or are stored elsewhere, e.g. in a cookie. These values include in particular the initial website (referrer), the 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 material ID, partner ID and categorizations.
  • Conversion tracking: Conversion tracking is a method of determining the effectiveness of marketing activities. For this purpose, a cookie is usually stored on the user's device within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, we can use this to track whether the ads we have placed on other websites have been successful).
  • Cross-device tracking: Cross-device tracking is a form of tracking in which behavioral and interest information of users is recorded across devices in so-called profiles by assigning users an online ID. This allows the user information to be analyzed for marketing purposes, regardless of the browser or device used (e.g., cell phone or desktop computer). With most providers, the online ID is not linked to clear data, such as names, postal or e-mail addresses.
  • IP-Masking: IP-Masking is a method in which the last octet, i.e. the last two numbers of an IP address, are 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 methods, especially in online marketing
  • Interest-based and behavioral marketing: We speak of interest-based and/or behavioral marketing when the potential interests of users in ads and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behavior (e.g., visiting and spending time on certain websites, purchasing behavior or interaction with other users), which is stored in a so-called profile. As a rule, cookies are used for these purposes.
  • Personal data: "Personal data" shall mean any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiling: "Profiling" is any automated processing of personal data that consists of using personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information on age, gender, location 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, identify at what time visitors visit their website and what content they are interested in. This enables them to better adapt the contents of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis purposes in order to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
  • Remarketing: One speaks of "remarketing" or "retargeting", for example, when it is noted for advertising purposes in which products a user has been interested on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Tracking: One speaks of "tracking" when the behavior of users can be traced across several online offers. As a rule, behavioral and interest information regarding the online offers 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 display advertisements to users that are likely to match their interests.
  • Controller: The term "controller" refers to the natural or legal person, authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data.
  • Processing: "Processing" shall mean any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers practically all handling of data, whether it be collection, analysis, storage, transmission or deletion.
  • Target group formation: One speaks of target group formation (or "custom audiences") when target groups are determined for advertising purposes, e.g. the insertion of advertisements. For example, based on a user's interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online store where he/she viewed the products. In turn, one speaks of "Lookalike Audiences" (or similar target groups) if the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used to create custom audiences and lookalike audiences.