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Privacy statement

Preamble

With the following privacy policy, 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 privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as ‘online offering’).

The terms used are not gender-specific.

As of 31 December 2023

Table of contents

Person in charge

DI Christoph Galik e.U.
Rosenberguertel 21, 8010 Graz
Austria

Email address: office@mysong.christophgalik.com mobile: +43 664 3238161 Legal notice: https://mysong.christophgalik.com/impressum

Overview of processing operations

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

Types of data processed

  • Inventory data
  • Payment details.
  • Contact details.
  • Content data.
  • Contract details.
  • Usage data.
  • Meta, communication and procedural data.

Categories of data subjects

  • Customers.
  • Interested parties.
  • Communication partner.
  • Users.
  • Business and contractual partners.
  • Participants.

Purpose of processing

  • Provision of contractual services and fulfilment of contractual obligations.
  • Contact requests and communication.
  • Safety measures
  • Direct marketing.
  • Reach measurement.
  • Tracking.
  • Office and organisational procedures.
  • Conversion measurement.
  • Managing and responding to enquiries.
  • Feedback.
  • Marketing.
  • Profiles containing user-related information.
  • Provision of our online services and user-friendliness.
  • Information technology infrastructure.

Relevant legal bases

Relevant legal basis under the GDPR: Below you will find an overview of the legal basis of the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or registered office. If more specific legal bases are applicable in individual cases, we will inform you of this in the privacy policy.

  • Consent (Art. 6(1)(a) GDPR) - The data subject has given consent to the processing of their personal data for one or more specific purposes.
  • Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6(1)(c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6(1)(f) GDPR) - Processing is necessary to safeguard the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject requiring the protection of personal data prevail.

National data protection regulations in Austria: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Austria. These include, in particular, the Federal Act on the Protection of Individuals with regard to the Processing of Personal Data (Data Protection Act – DSG). The Data Protection Act contains, in particular, special regulations on the right to information, the right to rectification or erasure, the processing of special categories of personal data, processing for other purposes and transfer, and automated decision-making in individual cases.

Reference to the applicability of the GDPR and Swiss DSG: This privacy policy serves to provide information in accordance with both the Swiss Federal Act on Data Protection (Swiss DSG) and the General Data Protection Regulation (GDPR). For this reason, please note that the terms used in the GDPR are used for the sake of broader geographical application and comprehensibility. In particular, instead of the terms ‘processing’ of ‘personal data’, ‘overriding interest’ and ‘sensitive personal data’ used in the Swiss FADP, the terms “processing” of ‘personal data’, ‘legitimate interest’ and ‘special categories of data’ used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DSG within the scope of the Swiss DSG.

safety measures

We take appropriate technical and organisational measures in accordance with legal requirements, taking into account the state of the art, implementation costs, the nature, scope, circumstances and purposes of processing, as well as the varying likelihood and severity of threats to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

These measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, transfer, availability and separation relating to it. Furthermore, we have established procedures to ensure that data subjects' rights are exercised, data is deleted and responses are made to data breaches. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and data protection-friendly default settings.

TLS/SSL encryption (https): We use TLS/SSL encryption to protect user data transmitted via our online services. Secure Sockets Layer (SSL) is the standard technology for securing internet connections by encrypting the data transmitted between a website or app and a browser (or between two servers). Transport Layer Security (TLS) is an updated and more secure version of SSL. Hyper Text Transfer Protocol Secure (HTTPS) is displayed in the URL when a website is secured by an SSL/TLS certificate.

Transfer of personal data

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

Data transfer within the organisation: We may transfer personal data to other departments within our organisation or grant them access to this data. If this transfer is for administrative purposes, the transfer of data is based on our legitimate business and economic interests or is necessary to fulfil our contractual obligations or if the consent of the data subjects or legal permission has been obtained.

International data transfers

Data processing in 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 processing takes place in connection with the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this will only be done in accordance with the legal requirements. If the level of data protection in the third country has been recognised by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers will only take place if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46(2)(c) GDPR), express consent or in the case of contractual or legally required transfers (Art. 49(1) GDPR). In addition, we will inform you of the basis for third-country transfers for the individual providers from the third country, whereby adequacy decisions take precedence as the basis. Information on third-country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de.

EU-US Trans-Atlantic Data Privacy Framework: Within the framework of the so-called ‘Data Privacy Framework’ (DPF), the EU Commission has also recognised the level of data protection for certain US companies as secure within the framework of the adequacy decision of 10 July 2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). We will inform you in our privacy policy which service providers we use are certified under the Data Privacy Framework.

Deletion of data

The data we process will be deleted in accordance with legal requirements as soon as the consents permitting its processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data no longer applies or it is not necessary for the purpose). If the data is not deleted because it is required for other, legally permissible purposes, its processing will be restricted to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person. Our data protection information may also contain further details on the storage and deletion of data that take precedence for the respective processing operations.

Rights of data subjects

Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

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

Business services

We process data from 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 contractual partners (or pre-contractually), e.g. to respond to enquiries.

We process this data in order to fulfil our contractual obligations. These include, in particular, obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. In addition, we process the data to protect our rights and for the purposes of administrative tasks associated with these obligations and company organisation. Furthermore, we process the data on the basis of our legitimate interests in proper and economical business management and in security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent necessary for the aforementioned purposes or to fulfil legal obligations. Contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.

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

We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. as long as it must be retained for archiving purposes for legal reasons. The statutory retention period is ten years for tax-relevant documents, commercial books, inventories, opening balance sheets, annual financial statements, work instructions and other organisational documents and accounting documents necessary for understanding these documents, and six years for commercial and business letters received and copies of commercial and business letters sent. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, opening balance sheet, annual financial statements or management report was prepared, the commercial or business letter was received or sent, or the accounting document was created, or the record was made or the other documents were created.

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

  • Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); Contact data (e.g. email, telephone numbers); Contract data (e.g. subject matter of the contract, term, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
  • Persons affected: Customers; prospective customers. Business and contractual partners.
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; security measures; contact requests and communication; office and organisational procedures; administration and response to enquiries; conversion measurement (measurement of the effectiveness of marketing measures). Profiles with user-related information (creation of user profiles).
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR); legal obligation (Art. 6(1)(c) GDPR); legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing procedures, methods and services:

  • Economic analyses and market research: For business reasons and in order to identify market trends and the wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., whereby the group of data subjects may include contractual partners, interested parties, customers, visitors and users of our online offering. The analyses are carried out for the purposes of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we may take into account the profiles of registered users, including their details, e.g. on services used, if available. The analyses are for our own use only and are not disclosed externally, unless they are anonymous analyses with summarised, i.e. anonymised, values. Furthermore, we respect the privacy of users and process the data for analysis purposes pseudonymously and, where feasible, anonymously (e.g. as summarised data). Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
  • Shop and e-commerce: We process our customers' data to enable them to select, purchase or order the selected products, goods and related services, as well as to pay for and deliver or execute them. If necessary for the execution of an order, we use service providers, in particular postal, freight forwarding and shipping companies, to carry out the delivery or execution for our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such during the ordering or comparable purchase process and includes the information required for delivery, provision and billing, as well as contact information for any necessary consultation. Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR).
  • Artistic and literary achievements: We process our clients' data to enable them to select, purchase or commission the chosen services or works and related activities, as well as to enable payment and delivery or execution or provision thereof.

    The required information is marked as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for delivery and billing as well as contact information for any necessary consultations. Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR).

Use of online platforms for offering and sales purposes

We offer our services on online platforms operated by other service providers. In this context, the privacy policies of the respective platforms apply in addition to our privacy policy. This applies in particular with regard to the execution of the payment process and the procedures used on the platforms for reach measurement and interest-based marketing.

  • Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); Contact data (e.g. email, telephone numbers); Contract data (e.g. subject matter of the contract, term, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
  • Persons affected: Customers.
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations. Marketing.
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR).

Providers and services used in the course of business activities

Within the scope of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers (hereinafter referred to as ‘services’) in compliance with legal requirements.

  • Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history) ); contact details (e.g. email, telephone numbers); content data (e.g. entries in online forms); contract data (e.g. subject matter of the contract, term, customer category).
  • Persons affected: Customers; prospective customers; users (e.g. website visitors) - ). Geschäfts- und Vertragspartner.
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations. Office and organisational procedures.
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Provision of online services and web hosting

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

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status); content data (e.g. entries in online forms).
  • Persons affected: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online services and user-friendliness; IT infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)). Security measures.
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing procedures, methods and services:

  • Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from an appropriate server provider (also known as a ‘web host’). Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
  • Collection of access data and log files: Access to our online offering is logged in the form of so-called ‘server log files’. Server log files may include the address and name of the websites and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to prevent server overload (especially in the case of malicious attacks, known as DDoS attacks) and to ensure server utilisation and stability. Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data that must be retained for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
  • Email delivery and hosting: The web hosting services we use also include the sending, receiving and storage of emails. For these purposes, the addresses of the recipients and senders, as well as other information relating to the sending of emails (e.g. the providers involved) and the content of the respective emails, are processed. The aforementioned data may also be processed for the purpose of detecting spam. Please note that emails are generally not sent in encrypted form on the internet. As a rule, emails are encrypted during transmission, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We therefore cannot accept any responsibility for the transmission of emails between the sender and the recipient on our server. Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
  • ALL-INKL: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: ALL-INKL.COM - Neue Medien Münnich, Owner: René Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://all-inkl.com/; Privacy policy: https://all-inkl.com/datenschutzinformationen/. Order processing agreement: Provided by the service provider.

Registration, login and user account

Users can create a user account. During registration, users are informed of the required mandatory information, which is processed for the purpose of providing the user account on the basis of contractual obligation fulfilment. The data processed includes, in particular, login information (username, password and email address).

When you use our registration and login functions and your user account, we store your IP address and the time of the respective user action. This data is stored on the basis of our legitimate interests and those of our users in protecting against misuse and other unauthorised use. 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.

Users may be informed by email about processes relevant to their user account, such as technical changes.

  • Types of data processed: Inventory data (e.g. names, addresses); contact details (e.g. email, telephone numbers); content data (e.g. entries in online forms); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
  • Persons affected: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; security measures; administration and response to enquiries. Provision of our online offering and user-friendliness.
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing procedures, methods and services:

  • Registration with real name: Due to the nature of our community, we ask users to only use our services under their real names. This means that the use of pseudonyms is not permitted. Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR).
  • User profiles are not public: User profiles are not publicly visible or accessible.
  • Deletion of data after termination: When users have terminated their user accounts, their data relating to the user account will be deleted, subject to legal permission, obligation or consent of the users. Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR).

Blogs and publication media

We use blogs or similar means of online communication and publication (hereinafter referred to as ‘publication medium’). Reader data is only processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. For further information, please refer to the information on the processing of visitors to our publication medium in this privacy policy.

  • Types of data processed: Master data (e.g. names, addresses); Contact data (e.g. email, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
  • Persons affected: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; feedback (e.g. collection of feedback via online form); provision of our online offering and user-friendliness. Security measures.
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing procedures, methods and services:

Contact and enquiry management

When contacting us (e.g. by post, contact form, email, telephone or social media) and within the framework of existing user and business relationships, the information provided by the enquiring persons will be processed to the extent necessary to respond to contact enquiries and any requested measures.

  • Types of data processed: Contact details (e.g. email address, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
  • Persons affected: Communication partner.
  • Purposes of processing: Contact requests and communication; managing and responding to enquiries; feedback (e.g. collecting feedback via online forms). Provision of our online services and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). Contract performance and pre-contractual enquiries (Art. 6(1)(b) GDPR).

Further information on processing procedures, methods and services:

  • Kontaktformular: Wenn Nutzer über unser Kontaktformular, E-Mail oder andere Kommunikationswege mit uns in Kontakt treten, verarbeiten wir die uns in diesem Zusammenhang mitgeteilten Daten zur Bearbeitung des mitgeteilten Anliegens; Legal basis: Vertragserfüllung und vorvertragliche Anfragen (Art. 6 Abs. 1 S. 1 lit. b) DSGVO), Berechtigte Interessen (Art. 6 Abs. 1 S. 1 lit. f) DSGVO).

Communication via messenger

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

You can also contact us by other means, e.g. by telephone or email. Please use the contact details provided to you or those specified within our online offering.

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

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

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

Revocation, objection and deletion: You may revoke your consent at any time.

  • Types of data processed: Contact details (e.g. email address, telephone numbers); usage data (e.g. websites visited, interest in content) ); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers) ).
  • Persons affected: Communication partner.
  • Purposes of processing: Contact requests and communication; direct marketing (e.g. by email or post).
  • Legal basis: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Use of cookies

We use the consent tool ‘Real Cookie Banner’ to manage the cookies and similar technologies (tracking pixels, web beacons, etc.) we use and the related consents. Details on how ‘Real Cookie Banner’ works can be found at https://devowl.io/de/rcb/datenverarbeitung/. The legal basis for the processing of personal data in this context is Art. 6 (1) (c) GDPR and Art. 6 (1) (f) GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents. The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide personal data. If you do not provide personal data, we cannot manage your consents.

audio content

We use hosting and analysis services provided by service providers to offer our audio content for listening or downloading and to obtain statistical information about the retrieval of audio content.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
  • Persons affected: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); conversion measurement (measurement of the effectiveness of marketing measures); profiles with user-related information (creation of user profiles). Provision of our online offering and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing procedures, methods and services:

Newsletters and electronic notifications

We send newsletters, emails and other electronic notifications (hereinafter referred to as ‘newsletters’) only with the consent of the recipients or with legal permission. If the content of the newsletter is specifically described during the registration process, this description is decisive for the consent of the users. Otherwise, our newsletters contain information about our services and about us.

To subscribe to our newsletters, all you need to do is provide your email address. However, we may ask you to provide a name so that we can address you personally in the newsletter, or other information if this is necessary for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter is always carried out using a double opt-in procedure. This means that after registering, you will receive an email asking you to confirm your registration. This confirmation is necessary to prevent anyone from registering with someone else's email address. Newsletter registrations are logged in order to be able to verify the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the mailing service provider are also logged.

Deletion and restriction of processing: We may store the email addresses provided for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address in a block list for this purpose alone.

The registration process is logged on the basis of our legitimate interests for the purpose of verifying that it has been carried out correctly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure mailing system.

Contents:

Information about us, our services, promotions and offers.

  • Types of data processed: Inventory data (e.g. names, addresses); contact details (e.g. email, telephone numbers); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status); usage data (e.g. websites visited, interest in content, access times).
  • Persons affected: Communication partner.
  • Purposes of processing: Direct marketing (e.g. via e-mail or post).
  • Legal basis: Consent (Art. 6(1)(a) GDPR).
  • Right to object (opt-out): You can unsubscribe from our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to unsubscribe from the newsletter at the end of each newsletter, or you can use one of the contact options listed above, preferably email.

Further information on processing procedures, methods and services:

  • Measurement of open and click rates: The newsletters contain a so-called ‘web beacon’, i.e. a pixel-sized file that is retrieved from our server or, if we use a mailing service provider, from their server when the newsletter is opened. As part of this retrieval, technical information such as information about your browser and your system, as well as your IP address and the time of retrieval, is collected first.

    This information is used to technically improve our newsletter based on technical data or target groups and their reading behaviour based on their location (which can be determined using their IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. The evaluations help us to recognise 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 measurement of open rates and click rates as well as the storage of these measurement results in the users’ profiles; Legal basis: Consent (Art. 6(1)(a) GDPR).

Advertising communication via email, post, fax or telephone

We process personal data for the purposes of marketing communication, which may be carried out through various channels, such as e-mail, telephone, postal mail or fax, in accordance with the applicable legal provisions.

Recipients shall have the right to withdraw consent at any time or to object to marketing communications at any time.

Following a withdrawal of consent or an objection, we shall retain the data necessary to demonstrate the validity of the prior authorization for contact or transmission for a period of up to three years after the end of the year in which the withdrawal or objection occurred, on the basis of our legitimate interests. The processing of such data shall be limited to the purpose of a possible defense against claims. Furthermore, on the basis of our legitimate interest in permanently respecting the withdrawal or objection of users, we shall retain the data necessary to prevent renewed contact (e.g., depending on the communication channel, the e-mail address, telephone number, or name).

  • Types of data processed: Inventory data (e.g., names, addresses); contact data (e.g., e-mail addresses, telephone numbers).
  • Persons affected: Communication partner.
  • Purposes of processing: Direct marketing (e.g. via e-mail or post).
  • Legal basis: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Surveys and questionnaires

We conduct surveys and questionnaires in order to collect information for the purpose communicated in each case. The surveys and questionnaires conducted by us (hereinafter referred to as ‘Surveys’) shall be evaluated on an anonymous basis. The processing of personal data shall only take place to the extent necessary for the provision and technical implementation of the Surveys (e.g., processing of the IP address in order to display the Survey in the user’s browser, or the use of a cookie to enable the resumption of the Survey).

  • Types of data processed: Contact details (e.g. email address, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
  • Persons affected: Communication partners; participants.
  • Purposes of processing: Feedback (e.g., collection of feedback via online form).
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Web analytics, monitoring and optimisation

Web analytics (also referred to as ‘audience measurement’) serve to evaluate the visitor traffic to our online offering and may include pseudonymous values relating to the behavior, interests, or demographic information of visitors, such as age or gender. By means of audience measurement, we are able to determine, for example, at what times our online offering, its functions, or its content are most frequently used or encourage repeated use. We are likewise able to identify which areas require optimization.

In addition to web analytics, we may also employ testing procedures in order to test and optimize different versions of our online offering or its components.

“Unless otherwise specified below, profiles may be created for these purposes, i.e., data aggregated to a usage process, and information may be stored in a browser or on an end device and retrieved therefrom. The data collected shall in particular include the websites visited and the elements used therein, as well as technical information such as the browser used, the computer system employed, and information regarding usage times. Where users have consented to the collection of their location data, either to us or to the providers of the services we employ, location data may also be processed.

Users’ IP addresses shall also be stored. However, we employ an IP masking procedure (i.e., pseudonymization by truncation of the IP address) in order to protect users. As a general rule, no clear data of users (such as e-mail addresses or names) shall be stored in the context of web analytics, A/B testing, and optimization, but rather pseudonyms. This means that neither we nor the providers of the software employed shall know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
  • Persons affected: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Audience measurement (e.g., access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).

online marketing

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

For these purposes, so-called user profiles shall be created and stored in a file (a so-called ‘cookie’), or similar methods shall be employed by which information relevant to the display of the aforementioned content is stored with respect to the user. Such information may include, for example, content viewed, websites visited, online networks used, as well as communication partners and technical information such as the browser used, the computer system employed, and details regarding usage times and functions utilized. Where users have consented to the collection of their location data, such data may also be processed.

Users’ IP addresses shall also be stored. However, in order to protect users, we employ available IP masking procedures (i.e., pseudonymization by truncation of the IP address). As a general rule, no clear data of users (such as e-mail addresses or names) shall be stored within the framework of online marketing procedures, but rather pseudonyms. This means that neither we nor the providers of the online marketing procedures shall know the actual identity of the users, but only the information stored in their profiles.

The information contained in the profiles shall as a rule be stored in cookies or by means of similar methods. Such cookies may subsequently be read on other websites that employ the same online marketing procedure and may be analyzed for the purposes of displaying content, supplemented with additional data, and stored on the server of the provider of the online marketing procedure.”

“By way of exception, clear data may be assigned to the profiles. This may occur, for example, where users are members of a social network whose online marketing procedure we employ and the network links the users’ profiles with the aforementioned information. Users are advised that they may enter into additional agreements with the providers, for example by granting consent in the course of registration.

As a rule, we shall only have access to aggregated information regarding the success of our advertisements. However, within the framework of so-called conversion measurements, we may ascertain which of our online marketing procedures have led to a so-called conversion, i.e., for example, the conclusion of a contract with us. Conversion measurement shall be used solely for the purpose of analyzing the success of our marketing activities.

Unless otherwise specified, please assume that the cookies used shall be stored for a period of two years.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
  • Persons affected: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Audience measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest- / behavior-based profiling, use of cookies); marketing; profiles with user-related information (creation of user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Right to object (opt-out): “We refer to the data protection notices of the respective providers and to the opt-out options provided by such providers (so-called ‘opt-out’). Where no explicit opt-out option is indicated, you may, on the one hand, disable cookies in your browser settings. However, this may result in restrictions to the functionality of our online offering. We therefore additionally recommend the following opt-out options, which are provided collectively 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) Cross-regional: https://optout.aboutads.info.

Presence on social networks (social media)

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

We hereby point out that users’ data may be processed outside the territory of the European Union. This may give rise to risks for users, for example, by making it more difficult to enforce users’ rights.

Furthermore, users’ data shall as a rule be processed within social networks for the purposes of market research and advertising. For example, user profiles may be created on the basis of users’ behavior and resulting interests. Such user profiles may in turn be used, for example, to display advertisements within and outside the networks that are presumed to correspond to the users’ interests. For these purposes, cookies are generally stored on users’ devices, in which the users’ usage behavior and interests are recorded. In addition, data may also be stored in the user profiles irrespective of the devices used by the users (in particular where 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 opt-out options, we refer to the privacy policies and statements of the operators of the respective networks.

Even in the case of requests for information or the exercise of data subject rights, we point out that these are most effectively asserted with the providers. Only the providers have access to the users’ data in each case and can directly take the appropriate measures and provide information. Should you nevertheless require assistance, you may contact us.

  • Types of data processed: Contact details (e.g. email address, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
  • Persons affected: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Contact requests and communication; feedback (e.g., collection of feedback via online form); marketing.
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing procedures, methods and services:

  • Instagram: Social network; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.instagram.com. Privacy policy: https://instagram.com/about/legal/privacy.
  • Facebook Pages: Profiles within the social network Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Basis for third-country transfers: EU-US Data Privacy Framework (DPF), Standardvertragsklauseln (https://www.facebook.com/legal/EU_data_transfer_addendum); Further information: Together with Meta Platforms Ireland Limited, we are jointly responsible for the collection (but not the further processing) of data of visitors to our Facebook page (so-called ‘Fanpage’). Such data include information regarding the types of content that users view or interact with, or actions taken by them (see ‘Things you and others do and provide’ in the Facebook Data Policy): https://www.facebook.com/policy), as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see ‘Device information’ in the Facebook Data Policy): https://www.facebook.com/policy). As explained in the Facebook Data Policy under ‘How do we use this information?’, Facebook also collects and uses information in order to provide analytics services, so-called ‘Page Insights’, to page operators, enabling them to gain insights into how people interact with their pages and with the content associated with them. We have entered into a specific agreement with Facebook (‘Page Insights Information’, https://www.facebook.com/legal/terms/page_controller_addendum), which, in particular, governs the security measures that Facebook is required to observe and under which Facebook has undertaken to fulfill data subject rights (i.e., users may, for example, direct requests for information or deletion directly to Facebook). The rights of users (in particular the rights of access, deletion, objection, and complaint to the competent supervisory authority) shall not be restricted by the agreements with Facebook. Further information can be found in the ‘Page Insights Information’ (https://www.facebook.com/legal/terms/information_about_page_insights_data), The joint controllership is limited to the collection of data by and transmission of data to Meta Platforms Ireland Limited, a company established in the EU. Any further processing of the data falls under the sole responsibility of Meta Platforms Ireland Limited, which in particular includes the transfer of the data to its parent company, Meta Platforms, Inc., in the United States.
  • YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Privacy policy: https://business.safety.google/privacy/; Basis for third-country transfers: EU-US Data Privacy Framework (DPF). Right to object (opt-out): https://myadcenter.google.com/personalizationoff.

Plugins, embedded functions and content

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

The integration always requires that the third-party providers of such Content process the users’ IP address, since they would not be able to transmit the Content to the users’ browser without the IP address. The IP address is therefore necessary for the display of such Content or functions. We endeavor to use only Content whose respective providers use the IP address solely for the delivery of the Content. Third-party providers may furthermore employ so-called pixel tags (invisible graphics, also referred to as ‘web beacons’) for statistical or marketing purposes. By means of pixel tags, information such as visitor traffic on the pages of this website may be evaluated. Pseudonymous information may furthermore be stored in cookies on the users’ devices and may include, among other things, technical information regarding the browser and operating system, referring websites, the time of visit, as well as additional details concerning the use of our online offering, and may also be combined with such information from other sources.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
  • Persons affected: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online services and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing procedures, methods and services:

  • Integration of third-party software, scripts, or frameworks (e.g., jQuery): We integrate software into our online offering that we retrieve from the servers of other providers (e.g., function libraries that we use for the display or user-friendliness of our online offering). In this context, the respective providers collect the users’ IP address and may process it for the purpose of transmitting the software to the users’ browser, as well as for security purposes and for the evaluation and optimization of their offering. Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
  • Google Fonts (Bezug vom Google Server): The retrieval of fonts (and symbols) serves the purpose of ensuring a technically secure, maintenance-free, and efficient use of fonts and symbols with regard to up-to-dateness and loading times, their uniform display, and the consideration of possible licensing restrictions. The provider of the fonts is informed of the user’s IP address so that the fonts can be made available in the user’s browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) are transmitted, which are necessary for the provision of the fonts depending on the devices used and the technical environment. Such data may be processed on a server of the font provider in the United States. When visiting our online offering, users’ browsers send their browser HTTP requests to the Google Fonts Web API (i.e., a software interface for retrieving the fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) of Google Fonts and subsequently the fonts specified in the CSS. These HTTP requests include (1) the IP address used by the respective user to access the Internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user agent, which describes the browser and operating system versions of the website visitors, as well as the referring URL (i.e., the web page on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers, nor are they analyzed. The Google Fonts Web API logs details of the HTTP requests (requested URL, user agent, and referring URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families that the user wishes to load. These data are logged so that Google can determine how often a particular font family is requested. In the case of the Google Fonts Web API, the user agent must adjust the font generated for the respective browser type. The user agent is logged primarily for debugging purposes and is used to generate aggregated usage statistics measuring the popularity of font families. These aggregated usage statistics are published on the ‘Analytics’ page of Google Fonts. Finally, the referring URL is logged so that the data can be used for maintaining production and for generating an aggregated report on the top integrations based on the number of font requests. According to Google’s own statements, none of the information collected by Google Fonts is used to create profiles of end users or for targeted advertising. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://fonts.google.com/; Privacy policy: https://business.safety.google/privacy/; Basis for third-country transfers: EU-US Data Privacy Framework (DPF). Further information: https://developers.google.com/fonts/faq/privacy?hl=de.

Management, organisation and support tools

We use services, platforms, and software of other providers (hereinafter referred to as ‘third-party providers’) for the purposes of organization, administration, planning, and the provision of our services. In selecting such third-party providers and their services, we observe the legal requirements.

In this context, personal data may be processed and stored on the servers of the third-party providers. This may concern various categories of data that we process in accordance with this Privacy Policy. Such data may in particular include users’ master data and contact data, data relating to transactions, contracts, other processes, and their content.

Where users are referred to third-party providers or to their software or platforms in the course of communication, business, or other relationships with us, the third-party providers may process usage data and metadata for security purposes, for service optimization, or for marketing purposes. We therefore ask that you consult the privacy policies of the respective third-party providers.

  • Types of data processed: Content data (e.g., entries in online forms); usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
  • Persons affected: Communication partners; users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations. Office and organisational procedures.

Amendments and updates to the Privacy Policy

We kindly ask you to inform yourself regularly about the content of our Privacy Policy. We shall amend the Privacy Policy whenever changes in our data processing activities make this necessary. We shall inform you whenever such changes require an action on your part (e.g., consent) or any other form of individual notification.

Where we provide addresses and contact information of companies and organizations in this Privacy Policy, please note that such addresses may change over time, and we kindly ask you to verify the information before establishing contact.

definition of terms

This section provides an overview of the terminology used in this Privacy Policy. Where terms are legally defined, their statutory definitions shall apply. The following explanations are primarily intended to facilitate understanding.

  • Conversion measurement: Conversion measurement (also referred to as ‘visit action evaluation’) is a method by which the effectiveness of marketing activities can be determined. For this purpose, a cookie is generally stored on users’ devices within the websites on which the marketing activities take place and is subsequently retrieved on the target website. In this way, for example, we can ascertain whether the advertisements placed by us on other websites have been successful.
  • Personal data: ‘Personal data’ means any information relating to an identified or identifiable natural person (hereinafter referred to as ‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
  • Profiles with user-related information: The processing of ‘profiles with user-related information’ (hereinafter referred to as ‘profiles’) shall include any type of automated processing of personal data that consists of using such personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person. Depending on the type of profiling, this may include various information regarding demographics, behavior, and interests, such as interaction with websites and their content. For example, it may serve to predict interests in particular content or products, click behavior on a website, or location. For the purposes of profiling, cookies and web beacons are frequently employed.
  • Audience measurement: Audience measurement (also referred to as web analytics) serves to evaluate the visitor flows of an online offering and may include the behavior or interests of visitors with respect to certain information, such as the content of websites. By means of audience measurement, operators of online offerings can, for example, determine at what times users visit their websites and which content they are interested in. This enables them, for example, to better adapt the content of the websites to the needs of their visitors. For the purposes of audience measurement, pseudonymous cookies and web beacons are frequently employed in order to recognize returning visitors and thereby obtain more precise analyses of the use of an online offering.
  • Tracking: Tracking’ refers to the ability to trace users’ behavior across multiple online offerings. As a rule, behavioral and interest-related information regarding the online offerings used is stored in cookies or on the servers of the providers of tracking technologies (so-called profiling). Such information may subsequently be used, for example, to display advertisements to users that are presumed to correspond to their interests.
  • Controller: ‘Controller’ means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: Processing’ means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers virtually any handling of data, such as collection, evaluation, storage, transmission, or erasure.

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