Privacy

Privacy Policy

Iintroduction

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

The terms used are not gender-specific.

Last Update:

Table of contents:

Responsible

Marcel Jonetzko, Lamorio UG (Limited liability)
Foockenstraße 52
65933, Frankfurt am Main
Germany

E-Mail-Adresse: Savrasociety@gmail.com

Overview of 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., entries in online forms).
  • Contact details (e.g. email, phone numbers).
  • Metadata/communication data (e.g., device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Location data (information about the geographic position of a device or person).
  • Contract data (e.g. subject matter of the contract, term, customer category).
  • Payment details (e.g. bank details, invoices, payment history).

Categories of data subjects

  • Business and contractual partners.
  • interested parties.
  • Communication partner.
  • Costumer.
  • Users (e.g., website visitors, users of online services).

Purposes of processing

  • Assessment of creditworthiness.
  • Provision of our online services and user-friendliness.
  • Evaluation of the visitor campaign.
  • Office and organizational procedures.
  • Cross-Device Tracking (geräteübergreifende Verarbeitung von Nutzerdaten für Marketingzwecke).
  • Direct marketing (e.g., via email or mail).
  • Interest-based and behavioral marketing.
  • Kontaktanfragen und Kommunikation.
  • Conversion tracking (measuring the effectiveness of marketing initiatives).
  • Profiling (creating user profiles).
  • Remarketing.
  • Direct marketing (e.g., via email or mail).
  • Safety measures.
  • Tracking (e.g., interest-based or behavioral profiling, use of cookies).
  • Provision of contractual services and customer service.
  • Managing and responding to inquiries.
  • Target audience identification (identifying target audiences relevant for marketing purposes or other content distribution).

Automated decisions in individual cases

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

Relevant legal bases

Below, we outline the legal bases under the General Data Protection Regulation (GDPR) on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations in your country of residence or our country of incorporation may apply. Furthermore, should more specific legal bases apply in individual cases, we will inform you of these in the Privacy Policy.

  • Consent (Art. 6(1)(a) of the GDPR) – The data subject has given consent to the processing of personal data concerning him or her for a specific purpose or for several specific purposes.
  • Contract Performance and Pre-Contractual Inquiries (Art. 6 Abs. 1 S. 1 lit. b. DSGVO) – The processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the data subject’s request.
  • Legal obligation (Art. 6 Abs. 1 S. 1 lit. c. DSGVO) – The processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f. DSGVO) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Security measures

We implement appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, the costs of implementation, and the nature, scope, context, and purposes of the processing, as well as the varying likelihood and severity of the risks to the rights and freedoms of natural persons, in order to ensure a level of security 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 to, input of, and disclosure of the data, ensuring its availability, and maintaining its separation. Furthermore, we have established procedures that ensure the exercise of data subjects’ rights, the erasure of data, and responses to data breaches. Furthermore, we take the protection of personal data into account from the very beginning of the development and selection of hardware, software, and procedures, in accordance with the principle of data protection by design and through privacy-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 entities, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, payment institutions in connection with payment transactions, service providers entrusted with IT tasks, or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, enter into appropriate contracts or agreements with the recipients of your data to ensure the protection of your data.

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 such processing occurs in connection with the use of third-party services or the disclosure or transfer of data to other individuals, entities, or companies, this is done solely in accordance with legal requirements.

Subject to express consent or where data transfer is required by contract or law, we process data or have it processed only in third countries with a recognized level of data protection, contractual obligations through the European Commission’s standard data protection clauses, where certifications are in place, or where binding internal data protection policies are in effect (Art. 44–49 GDPR, EU Commission information page: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

As part of the so-called “Data Privacy Framework” (DPF), the European Commission has also recognized the level of data protection provided by certain U.S. companies as adequate under the adequacy decision dated July 10, 2023. The list of certified companies, as well as further information on the DPF, can be found on the U.S. Department of Commerce website at https://www.dataprivacyframework.gov/ (in English). In our privacy policy, we inform you which of our service providers are certified under the Data Privacy Framework.

Use of cookies

Cookies are small text files or other storage mechanisms that store information on end devices and retrieve information from them. For example, to save the login status in a user account, the contents of a shopping cart in an online store, the content accessed, or the functions used on a website. Cookies can also be used for various purposes, such as ensuring the functionality, security, and convenience of websites, as well as for analyzing visitor traffic.

Information regarding consent: We use cookies in accordance with legal requirements. Therefore, we obtain prior consent from users unless such consent is not required by law. In particular, consent is not required if the storage and retrieval of information—including cookies—are strictly necessary to provide users with a telemedia service (i.e., our online offering) that they have expressly requested. The revocable consent is clearly communicated to users and includes information regarding the specific use of cookies.

Information on the legal basis for data protection: The legal basis under data protection law on which we process users’ personal data using cookies depends on whether we ask users for their consent. If users consent, the legal basis for processing their data is their explicit consent. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g., in the business operation of our online offering and improving its usability) or, if this occurs within the scope of fulfilling our contractual obligations, when the use of cookies is necessary to fulfill our contractual obligations. We explain the purposes for which we process cookies in this Privacy Policy or as part of our consent and processing procedures.

Retention period: With regard to storage duration, the following types of cookies are distinguished:

  • Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user leaves a website and closes their device (e.g., browser or mobile app).
  • Persistent cookies Persistent cookies remain stored even after the device is shut down. This allows, for example, the login status to be saved or preferred content to be displayed immediately when the user visits a website again. Similarly, user data collected via cookies may be used for audience measurement. Unless we provide users with explicit information regarding the type and storage duration of cookies (e.g., when obtaining consent), users should assume that cookies are persistent and may be stored for up to two years.

General Information on Withdrawal and Opt-Out: Depending on whether the processing is based on consent or legal authorization, you have the option at any time to withdraw your consent or object to the processing of your data through cookie technologies (collectively referred to as “opt-out”). You can initially express your objection through your browser settings, e.g., by disabling the use of cookies (although this may also limit the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be made through a variety of services, particularly in the case of tracking, via the websites https://optout.aboutads.info und https://www.youronlinechoices.com/ explained. In addition, you can find further information on how to opt out in the details regarding the service providers and cookies used.

Processing of cookie data based on consent: We use a cookie consent management process through which users can grant, manage, and revoke their consent to the use of cookies, as well as to the processing activities and providers specified within the cookie consent management process. In this context, the declaration of consent is stored so that the request does not have to be repeated and so that consent can be demonstrated in accordance with legal obligations. Storage may occur on the server side and/or in a cookie (a so-called opt-in cookie, or using comparable technologies) in order to associate the consent with a user or their device. Subject to specific information provided by cookie management service providers, the following guidelines apply: The duration of consent storage can be up to two years. In this process, a pseudonymous user identifier is generated and stored along with the time of consent, details regarding the scope of consent (e.g., which categories of cookies and/or service providers), as well as the browser, system, and device used.

Cookie settings/opt-out option:

Commercial and business services

We process data from our contractual and business partners, such as customers and prospective customers (collectively referred to as “contractual partners”), in connection with contractual and similar legal relationships, as well as related activities and communications with contractual partners (or in the pre-contractual phase), for example, to respond to inquiries.

We process this data to fulfill our contractual obligations, to safeguard our rights, and for the purposes of administrative tasks associated with this information as well as for business organization. We disclose the data of our contractual partners to third parties within the framework of applicable law only to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations, or with the consent of the data subjects (e.g., to involved telecommunications, transportation, and other support services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Contractual partners are informed about other forms of processing, e.g., for marketing purposes, within the scope of this Privacy Policy.

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

We delete the data after the expiration of statutory warranty and similar 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 legal archiving purposes (e.g., for tax purposes, typically 10 years). If a period does not expressly begin on a specific date and lasts at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the period is the date on which the termination or other termination of the legal relationship takes effect. We delete data disclosed to us by the contractual partner in the context of an order in accordance with the terms of the order, generally upon completion of the order.

To the extent that 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 apply to the relationship between users and those providers.

Economic Analysis and Market Research: For business reasons and to identify market trends as well as the needs of our contractual partners and users, we analyze the data we have on business transactions, contracts, inquiries, etc., whereby the group of data subjects may include contractual partners, prospective customers, customers, visitors, and users of our online services.

The analyses are conducted for the purposes of business evaluations, marketing, and market research (e.g., to identify customer groups with different characteristics). In doing so, we may take into account the profiles of registered users, including their details—such as the services they have used—where available. The analyses are used solely by us and are not disclosed externally, unless they are anonymous analyses based on aggregated, i.e., anonymized, data. Furthermore, we respect users’ privacy and process the data for analytical purposes using pseudonyms whenever possible and, where feasible, anonymously (e.g., as aggregated data).

Shop und E-Commerce: We process our customers’ data to enable them to select, purchase, or order the products, goods, and related services of their choice, as well as to facilitate payment and delivery or fulfillment. Where necessary for the fulfillment of an order, we engage service providers—in particular postal, freight, and shipping companies—to carry out delivery or fulfillment for our customers. We use the services of banks and payment service providers to process payment transactions. The required information is identified as such during the ordering or comparable purchase process and includes the details necessary for delivery, provision, and billing, as well as contact information to facilitate any necessary communication.

  • Types of data processed: Master data (e.g., names, addresses), payment data (e.g., bank details, invoices, payment history), contact data (e.g., email, phone numbers), contract data (e.g., subject matter of the contract, term, customer category), usage data (e.g., websites visited, interest in content, access times), Meta/communication data (e.g., device information, IP addresses).
  • Affected individuals: Prospective clients, business partners, and customers.
  • Purposes of processing Erbringung vertragliche Leistungen und Kundenservice, Kontaktanfragen und Kommunikation, Büro- und Organisationsverfahren, Verwaltung und Beantwortung von Anfragen, Sicherheitsmaßnahmen, Besuchsaktionsauswertung, Interessenbasiertes und verhaltensbezogenes Marketing, Profiling (Erstellen von Nutzerprofilen).
  • Relevant legal bases Contract performance and pre-contractual inquiries ((Art. 6 Abs. 1 S. 1 lit. c. DSGVO),, Legal obligation (Art. 6 Abs. 1 S. 1 lit. c. DSGVO), Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f. DSGVO).

Payment service provider

In the context of contractual and other legal relationships, in accordance with legal obligations, or otherwise based on our legitimate interests, we offer data subjects efficient and secure payment options and, for this purpose, engage not only banks and credit institutions but also other payment service providers (collectively, “payment service providers”).

The data processed by the payment service providers includes personal information, such as name and address; banking information, such as account numbers or credit card numbers; passwords, TANs, and verification codes; as well as details related to the contract, transaction amounts, and recipients. This information is required to process the transactions. However, the data entered is processed and stored solely by the payment service providers. This means that we do not receive any account or credit card-related information, but only information confirming or rejecting the payment. Under certain circumstances, the payment service providers may transmit the data to credit bureaus. The purpose of this transmission is to verify identity and creditworthiness. For more information, please refer to the Terms and Conditions and Privacy Policy of the payment service providers.

Payment transactions are subject to the terms and conditions and privacy policies of the respective payment service providers, which are available on their respective websites or within the transaction applications. We also refer you to these documents for further information and to exercise your rights of withdrawal, access, and other data subject rights.

  • Types of data processed: Master data (e.g., names, addresses), payment data (e.g., bank details, invoices, payment history), contact data (e.g., email, phone numbers), contract data (e.g., subject matter of the contract, term, customer category), usage data (e.g., websites visited, interest in content, access times), Meta/communication data (e.g., device information, IP addresses).
  • Affected individuals: Customers, prospective customers.
  • Purposes of processing Provision of contractual services and customer service.
  • Relevant legal bases Contract performance and pre-contractual inquiries ((Art. 6 Abs. 1 S. 1 lit. c. DSGVO),, Legal obligation (Art. 6 Abs. 1 S. 1 lit. c. DSGVO), Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f. DSGVO).

Services used and service providers:

Provision of the online service and web hosting

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

The data processed in connection with the provision of our hosting services may include any information relating to users of our online services that is generated during their use of and communication with the service. This typically includes the IP address, which is necessary to deliver the content of our online services to browsers, as well as any data entered within our online services or on websites.

Email Delivery and Hosting: The web hosting services we use also include the sending, receiving, and storage of emails. For these purposes, we process the addresses of the recipients and senders, as well as other information related to email transmission (e.g., the involved providers) and the content of the respective emails. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that emails are generally not sent in encrypted form over 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 assume any responsibility for the transmission of emails between the sender and their receipt on our server.

Collection of access data and log files: We (or our web hosting provider) collect data on every access to the server (so-called server log files). Server log files may include the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, a notification of successful access, browser type and version, the user’s operating system, the referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider.

Server log files can be used, on the one hand, for security purposes—for example, to prevent server overload (particularly in the case of malicious attacks, known as DDoS attacks)—and, on the other hand, to ensure server performance and stability.

  • Types of data processed: Content data (e.g., information entered in online forms), usage data (e.g., websites visited, content interests, access times), meta/communication data (e.g., device information, IP addresses).
  • Affected individuals: Users (e.g., website visitors, users of online services).
  • Relevant legal bases Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f. DSGVO)

Contact us

When you contact us (e.g., via the contact form, email, phone, or social media), we process the information provided by the person making the inquiry to the extent necessary to respond to the inquiry and take any requested actions.

We respond to contact inquiries made in the context of contractual or pre-contractual relationships to fulfill our contractual obligations or to respond to (pre-)contractual inquiries, and otherwise based on our legitimate interest in responding to such inquiries.

  • Types of data processed: Master data (e.g., names, addresses), contact data (e.g., email addresses, phone numbers), content data (e.g., entries in online forms), usage data (e.g., websites visited, content interests, access times), meta/communication data (e.g., device information, IP addresses).
  • Affected individuals: Communication partners, prospective clients.
  • Purposes of processing Contact requests and communication; managing and responding to inquiries.
  • Relevant legal bases Contract performance and pre-contractual inquiries ((Art. 6 Abs. 1 S. 1 lit. c. DSGVO),, Legal obligation (Art. 6 Abs. 1 S. 1 lit. c. DSGVO), Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f. DSGVO).

Services used and service providers:

  • Contact form: When users contact us via our contact form, email, or other communication channels, we process the data provided to us in this context to address the matter raised. For this purpose, we process personal data within the scope of pre-contractual and contractual business relationships to the extent necessary for their fulfillment, and otherwise based on our legitimate interests, the interests of our communication partners in having their inquiries addressed, and our legal retention obligations.

Newsletters and electronic notifications

We send newsletters, emails, and other electronic notifications (hereinafter “newsletters”) only with the recipients’ consent or when permitted by law. If the content of a newsletter is specifically described during the sign-up process, that description is decisive for the user’s consent. In addition, our newsletters contain information about our services and our company.

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 we can address you personally in the newsletter, or additional information if it is necessary for the purposes of the newsletter.

Double opt-in process: Subscription to our newsletter is always handled via a double opt-in process. This means that after you subscribe, you will receive an email asking you to confirm your subscription. This confirmation is necessary to ensure that no one can subscribe using someone else’s email address. Newsletter subscriptions are logged to provide proof of 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 with the mailing service provider are also logged.

Erasure and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them, in order to be able to demonstrate that consent was previously given. The processing of this data is limited to the purpose of potentially defending against claims. An individual request for deletion is possible at any time, provided that the prior existence of consent is confirmed at the same time. In the event of obligations to permanently honor objections, we reserve the right to store the email address solely for this purpose in a block list (so-called “blacklist”).

We log the registration process based on our legitimate interests for the purpose of verifying that it was carried out properly. If we engage a service provider to send emails, we do so based on our legitimate interests in maintaining an efficient and secure email delivery system.

Notes on the legal basis: Newsletters are sent based on the recipients’ consent or, if consent is not required, based on our legitimate interests in direct marketing, provided that such marketing is permitted by law, e.g., in the case of marketing to existing customers. If we engage a service provider to send emails, this is done based on our legitimate interests. The registration process is recorded based on our legitimate interests to demonstrate that it was carried out in accordance with the law.

contents: Information about us, our services, promotions, and special offers.

  • Types of data processed: Master data (e.g., names, addresses), payment data (e.g., bank details, invoices, payment history), contact data (e.g., email, phone numbers), contract data (e.g., subject matter of the contract, term, customer category), usage data (e.g., websites visited, interest in content, access times), Meta/communication data (e.g., device information, IP addresses).
  • Affected individuals: Communication partner.
  • Purposes of processing Direct marketing (e.g., via email or mail).
  • Relevant legal bases Contract performance and pre-contractual inquiries ((Art. 6 Abs. 1 S. 1 lit. c. DSGVO),, Legal obligation (Art. 6 Abs. 1 S. 1 lit. c. DSGVO), Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f. DSGVO).
  • Right to opt out: You can unsubscribe from our newsletter at any time, i.e., withdraw your consent or opt out of receiving future issues. You will find a link to unsubscribe at the bottom of each newsletter, or you can use any of the contact options listed above—preferably email—to do so.

Services used and service providers:

  • Measuring open and click-through rates: The newsletters contain a so-called "web beacon," i.e., a pixel-sized file that is retrieved from our server, or its server if we use a mailing service provider, when the newsletter is opened. During this retrieval, technical information, such as details about your browser and operating system, as well as your IP address and the time of retrieval, are collected. This information is used to technically improve our newsletter based on the technical data or to analyze target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked. The information is assigned to individual newsletter recipients and stored in their profiles until they are deleted. The evaluations serve to understand the reading habits of our users and to adapt our content to them or to send different content according to their interests. The measurement of open and click rates, as well as the storage of the measurement results in user profiles and their further processing, are based on the users' consent. Unfortunately, it is not possible to separately revoke consent for performance tracking; in this case, the entire newsletter subscription must be cancelled or objected to. In that case, the stored profile information will be deleted. Relevant legal bases Consent
  • CleverReach: Email marketing platform; Service provider: CleverReach GmbH & Co. KG, //CRASH Building, Schafjückenweg 2, 26180 Rastede, Deutschland; Website: https://www.cleverreach.com/dePrivacy Policy https://www.cleverreach.com/de/datenschutz/; Auftragsverarbeitungsvertrag: Mit Anbieter abgeschlossen.
  • Mailchimp: E-Mail-Versand- und E-Mail-Marketing-Plattform; Dienstanbieter: Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Website: https://mailchimp.comPrivacy Policy https://mailchimp.com/legal/; Data Processing Agreement https://mailchimp.com/legal/; Basis for transfers to third countries: Data Privacy Framework, Standard Contractual Clauses (included in the Data Processing Agreement); Further information: Special security measures: https://mailchimp.com/help/Mailchimp-european-data-transfers/.

Onlinemarketing

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 users’ potential interests, as well as the measurement of their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (known as a “cookie”) or similar methods are used to store user information relevant to the display of the aforementioned content. This information may include, for example, content viewed, websites visited, online networks used, as well as communication partners and technical details such as the browser used, the computer system used, and information regarding usage times. If users have consented to the collection of their location data, this data may also be processed.

We also collect users’ IP addresses. However, we use available IP masking methods (i.e., pseudonymization by truncating the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored as part of online marketing procedures; instead, pseudonyms are used. This means that neither we nor the providers of online marketing services know the actual identity of users, but only the information stored in their profiles.

The information in the profiles is typically stored in cookies or using similar methods. These cookies can generally be read later on other websites that use the same online marketing method, analyzed for the purpose of displaying content, supplemented with additional data, and stored on the server of the online marketing provider.

The information in the profiles is typically stored in cookies or using similar methods. These cookies can generally be read later on other websites that use the same online marketing method, analyzed for the purpose of displaying content, supplemented with additional data, and stored on the server of the online marketing provider.

We generally only have access to aggregated data regarding the performance of our advertisements. However, through conversion tracking, we can determine which of our online marketing activities have led to a conversion—that is, for example, to the conclusion of a contract with us. Conversion tracking is used solely to analyze the effectiveness of our marketing efforts.

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

Notes on the legal basis: If we ask users for their consent to the use of third-party providers, the legal basis for processing their data is consent. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e., our interest in providing efficient, cost-effective, and user-friendly services). In this context, we would also like to draw your attention to the information regarding the use of cookies in this Privacy Policy.

  • Types of data processed: Usage data (e.g., websites visited, content interests, access times), meta/communication data (e.g., device information, IP addresses), location data (information regarding the geographic location of a device or a person).
  • Affected individuals: Users (e.g., website visitors, users of online services), prospective customers.
  • Purposes of processing Tracking (z.B. interessens-/verhaltensbezogenes Profiling, Nutzung von Cookies), Remarketing, Besuchsaktionsauswertung, Interessenbasiertes und verhaltensbezogenes Marketing, Profiling (Erstellen von Nutzerprofilen), Konversionsmessung (Messung der Effektivität von Marketingmaßnahmen), Reichweitenmessung (z.B. Zugriffsstatistiken, Erkennung wiederkehrender Besucher), Zielgruppenbildung (Bestimmung von für Marketingzwecke relevanten Zielgruppen oder sonstige Ausgabe von Inhalten), Cross-Device Tracking (geräteübergreifende Verarbeitung von Nutzerdaten für Marketingzwecke).
  • Security measures IP-Masking (Pseudonymisierung der IP-Adresse).
  • Relevant legal bases Contract performance and pre-contractual inquiries ((Art. 6 Abs. 1 S. 1 lit. c. DSGVO),, Legal obligation (Art. 6 Abs. 1 S. 1 lit. c. DSGVO), Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f. DSGVO).
  • Right to opt out: Please refer to the privacy policies of the respective providers and the opt-out options provided by them. If no explicit opt-out option is provided, you can disable cookies in your browser settings. However, this may limit certain features of our website. We therefore also recommend the following opt-out options, which are summarized and offered for specific regions: a) Europe: https://www.youronlinechoices.eu.
    b) Kanada: https://www.youradchoices.ca/choices.
    c) USA: https://www.aboutads.info/choices.
    d) Cross-regional: https://optout.aboutads.info.

Services used and service providers:

  • Meta-pixels and audience targeting (Custom Audiences): With the help of the Meta Pixel (or comparable functions for transmitting event data or contact information via interfaces within apps), Meta is able to identify visitors to our website as a target audience for the display of ads (so-called “Meta Ads”). Accordingly, we use the Meta Pixel to ensure that the Meta Ads we place are shown only to such users on Meta platforms and within the services of partners cooperating with Meta (the so-called “Audience Network”) https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offerings or who exhibit certain characteristics (e.g., interest in specific topics or products, as indicated by the websites they have visited), which we transmit to Meta (so-called “Custom Audiences”). We also use the Meta pixel to ensure that our Meta ads align with users’ potential interests and do not come across as intrusive. With the help of the Meta pixel, we can also track the effectiveness of Meta ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Meta ad (so-called “conversion tracking”); Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent Website: https://www.facebook.comPrivacy Policy https://www.facebook.com/privacy/policy/; Data Processing Agreement https://www.facebook.com/legal/terms/dataprocessing; Basis for transfers to third countries: Data Privacy Framework (DPF); Additional information: User event data, i.e., behavioral and interest-based information, is used for the purposes of targeted advertising and audience targeting based on the joint controller agreement (“Controller Addendum,” https://www.facebook.com/legal/controller_addendum) is processed. Joint responsibility is limited to the collection and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, particularly with regard to the transfer of data to the parent company Meta Platforms, Inc. in the United States (based on the Standard Contractual Clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
  • Google Ad Manager: We use the “Google Ad Manager” service to place ads on the Google Display Network (e.g., in search results, in videos, on websites, etc.). Google Ad Manager is characterized by the fact that ads are displayed in real time based on users’ presumed interests. This allows us to show ads for our online offering to users who may have a potential interest in our offering or who have previously shown interest in it, as well as to measure the success of the ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f) DSGVO); Website: https://marketingplatform.google.comPrivacy Policy https://policies.google.com/privacy; Basis for transfers to third countries: Data Privacy Framework (DPF); Further information: Types of processing and the data processed: https://business.safety.google/adsservices/; Data Processing Terms for Google Advertising Products: Information about the services, Data Processing Terms between data controllers, and Standard Contractual Clauses for data transfers to third countries: https://business.safety.google/adscontrollerterms; Data Processing Terms for Google Advertising Products: Information about the services, Data Processing Terms between data controllers, and Standard Contractual Clauses for data transfers to third countries: https://business.safety.google/adsprocessorterms.
  • Google Ads and Conversion Tracking: Online marketing methods used to place content and ads within the service provider’s advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who are likely to be interested in the ads. In addition, we measure the conversion of the ads, i.e., whether users have taken the opportunity to interact with the ads and use the advertised offers (so-called conversions). However, we only receive anonymous information and no personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Contract performance and pre-contractual inquiries ((Art. 6 Abs. 1 S. 1 lit. c. DSGVO),, Legal obligation (Art. 6 Abs. 1 S. 1 lit. c. DSGVO), Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f. DSGVO). Website: https://marketingplatform.google.comPrivacy Policy https://policies.google.com/privacy; Basis for transfers to third countries: Data Privacy Framework (DPF); Further information: Types of processing and the data processed: https://business.safety.google/adsservices/; Data processing agreements between data controllers and standard contractual clauses for data transfers to third countries: https://business.safety.google/adscontrollerterms.

Presences in social networks (social media)

We maintain online presences on social media platforms and, in this context, process user data in order to communicate with users active on those platforms or to provide information about us.

Please note that this may involve the processing of user data outside the European Union. This may pose risks to users, as it could, for example, make it more difficult to enforce their rights.

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created based on users’ behavior and the resulting interests. These usage profiles can in turn be used, for example, to display advertisements within and outside the networks that are presumed to correspond to users’ interests. For these purposes, cookies are typically stored on users’ computers, in which users’ usage behavior and interests are recorded. Furthermore, data may also be stored in the usage profiles regardless of the devices used by the users (particularly if the users are members of the respective platforms and are logged in to them).

For a detailed description of the specific processing methods and opt-out options, please refer to the privacy policies and information provided by the operators of the respective networks.

We would also like to point out that requests for information and the exercise of data subject rights are most effectively handled directly with the service providers. Only the service providers have access to users’ data and can take appropriate action and provide information directly. If you still need assistance, please feel free to contact us.

  • Types of data processed: Master data (e.g., names, addresses), contact data (e.g., email addresses, phone numbers), content data (e.g., entries in online forms), usage data (e.g., websites visited, content interests, access times), meta/communication data (e.g., device information, IP addresses).
  • Affected individuals: Users (e.g., website visitors, users of online services).
  • Purposes of processing Contact requests and communication, tracking (e.g., interest-based or behavioral profiling, use of cookies), remarketing, audience measurement (e.g., traffic statistics, identification of returning visitors).
  • Relevant legal bases Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f. DSGVO)

Services used and service providers:

  • Instagram: A social network that allows users to share photos and videos, comment on and like posts, send messages, and follow profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland; Relevant legal bases Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f) DSGVO); Website: https://www.instagram.com; Privacy Policy https://privacycenter.instagram.com/policy/; Basis for transfers to third countries: Data Privacy Framework (DPF).
  • Facebook-Seiten: Profiles on the Facebook social network – We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (known as a “fan page”). This data includes information about the types of content users view or interact with, or the actions they take (see “Things you and others do and provide” in the Facebook Data Policy: https://www.facebook.com/privacy/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/privacy/policy/). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services—known as “Page Insights”—to page administrators, so they can gain insights into how people interact with their pages and the content associated with them. We have entered into a special agreement with Facebook (“Information on Page Insights,” https://www.facebook.com/legal/terms/page_controller_addendum), which specifically outlines the security measures Facebook must adhere to and in which Facebook has agreed to uphold data subjects’ rights (i.e., users can, for example, submit requests for information or deletion directly to Facebook). Users’ rights (in particular the rights to access, erasure, objection, and complaint to the competent supervisory authority) are not 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) is processed. Joint responsibility is limited to the collection and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, particularly with regard to the transfer of data to the parent company Meta Platforms, Inc. in the United States (based on the Standard Contractual Clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.). Legal basis: Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f) DSGVO); Website: https://www.facebook.comPrivacy Policy https://www.facebook.com/privacy/policy/; Basis for transfers to third countries: Data Privacy Framework (DPF).
  • Pinterest: Social network; Service provider: Pinterest Inc., 635 High Street, Palo Alto, CA 94301, USA; Website: https://www.pinterest.comPrivacy Policy https://about.pinterest.com/de/privacy-policy; For more information: Pinterest Data Exchange Appendix (APPENDIX A): https://business.pinterest.com/de/pinterest-advertising-services-agreement/.
  • TikTok: Social network / video platform; Service provider: musical.ly Inc., 10351 Santa Monica Blvd #310, Los Angeles, CA 90025, USA; Website: https://www.tiktok.comPrivacy Policy https://www.tiktok.com/de/privacy-policy.
  • X: Social network; Service provider: X Internet Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland; Privacy Policy: https://x.com/de/privacy, (Settings: https://x.com/settings/account/personalization).

Deletion of data

The data we process will be deleted in accordance with legal requirements as soon as the consent authorizing its processing is revoked or other legal grounds for processing no longer apply (e.g., if the purpose for which the data was processed no longer exists or if the data is no longer necessary for that purpose).

Unless the data is not deleted because it is required for other legally permissible purposes, its processing is limited to those purposes. This means that the data is blocked and not processed for any other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons, or whose storage is necessary to assert, exercise, or defend legal claims, or to protect the rights of another natural or legal person.

Further information regarding the deletion of personal data may also be provided in the individual privacy notices included in this Privacy Policy.

Changes and updates to the privacy policy

We ask that you review the content of our Privacy Policy on a regular basis. We will update the Privacy Policy as soon as changes to our data processing practices make it necessary to do so. We will notify you as soon as the changes require action on your part (e.g., consent) or any other individual notification.

Please note that any addresses and contact information for companies and organizations provided in this Privacy Policy may change over time; we ask that you verify this information before contacting them.

Rights of data subjects

As data subjects, you have various rights under the DSGVO, which arise in particular from Articles 15 through 21 of the DSGVO:

  • Right to object You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data carried out pursuant to Article 6(1)(e) or (f) of the DSGVO; this also applies to profiling based on these provisions. If your personal data is processed for the purpose of direct marketing, you have the right to object at any time to the processing of your personal data for such marketing purposes; this also applies to profiling to the extent that it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw your consent at any time.
  • Right to access information: You have the right to request confirmation as to whether your personal data is being processed, as well as access to that data, additional information, and a copy of the data in accordance with legal requirements.
  • Right to rectification: In accordance with legal requirements, you have the right to request that the data concerning you be completed or that any inaccurate data concerning you be corrected.
  • 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 a restriction on the processing of such data in accordance with legal requirements.
  • Right to data portability: You have the right to receive the personal data 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 regulatory authority: You also have the right, in accordance with legal requirements, to lodge a complaint with a supervisory authority—in particular in the Member State of your habitual residence, your place of work, or the place where the alleged infringement occurred—if you believe that the processing of your personal data violates the GDPR.

Definitions of terms

This section provides an overview of the terms used in this Privacy Policy. Many of these terms are derived from the law and are defined primarily in Article 4 of the GDPR. The legal definitions are binding. The explanations below, however, are intended primarily to aid understanding. The terms are listed in alphabetical order.

  • Visit Campaign Evaluation: “Conversion tracking” refers to a method used to measure the effectiveness of marketing campaigns. To do this, a cookie is typically stored on users’ devices while they are on the websites where the marketing campaigns are running, and then retrieved again on the destination website. For example, this allows us to determine whether the ads we placed on other websites were successful.
  • Credit report: Automated decisions are based on automatic data processing without human intervention (e.g., in the case of an automatic rejection of a purchase on account, an online loan application, or an online job application process without any human involvement). Such automated decisions are permissible under Article 22 of the dsgvo only if data subjects consent, if they are necessary for the performance of a contract, or if national laws permit such decisions.
  • Cross-Device Tracking: Cross-device tracking is a form of tracking in which users’ behavioral and interest data is collected across devices in so-called profiles by assigning users an online identifier. This typically allows user data to be analyzed for marketing purposes regardless of the browsers or devices used (e.g., mobile phones or desktop computers). For most providers, the online identifier is not linked to personally identifiable information, such as names, postal addresses, or email addresses.
  • IP-Masking: “IP masking” refers to a method in which the last octet—that is, the last two digits of an IP address—is removed so that the IP address can no longer be used to uniquely identify an individual. As such, IP masking is a means of pseudonymizing data processing procedures, particularly in online marketing.
  • Interest-based and behavioral marketing. Interest-based and/or behavioral marketing refers to the practice of predicting users’ potential interests in ads and other content as accurately as possible. This is done by analyzing data on their past behavior (e.g., visiting and spending time on specific websites, purchasing behavior, or interactions with other users), which is stored in a so-called profile. Cookies are typically used for these purposes.
  • Conversion tracking: Conversion tracking is a method used to determine the effectiveness of marketing campaigns. Typically, a cookie is stored on users' devices within the websites where the marketing campaigns take place and then retrieved again on the target website. For example, this allows us to track whether the ads we placed on other websites were successful.
  • Personal data: ‘Personal data’ means any information relating to an identified or identifiable natural person (hereinafter the ‘data subject’); a natural person is considered to be identifiable, directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special features that express the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
  • Profiling: Profiling refers to any type of automated processing of personal data that involves using this personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information concerning age, gender, location and movement data, interaction with websites and their content, purchasing behavior, and social interactions with other people). For example, an individual's interests in specific content or products, their click behavior on a website, or their location are frequently used for profiling purposes. Cookies and web beacons are commonly used for this purpose.
  • range measurement: Web analytics (also known as audience measurement) is used to analyze visitor traffic to an online service and can include visitor behavior or interest in specific information, such as website content. With the help of audience analysis, website owners can, for example, determine when visitors access their website and which content they are interested in. This allows them to better tailor the website content to their visitors' needs. Pseudonymous cookies and web beacons are frequently used for audience analysis to recognize returning visitors and thus obtain more accurate analyses of online service usage.
  • Remarketing: “Remarketing” or “retargeting” refers to the practice of recording, for advertising purposes, which products a user has shown interest in on a website, in order to remind the user of these products on other websites, e.g., in advertisements.
  • location data: Location data is generated when a mobile device (or any other device with the technical capabilities for location tracking) connects to a cell tower, Wi-Fi network, or similar location-determining technology. Location data indicates the geographically identifiable position of the device on Earth. It can be used, for example, to display maps or other location-dependent information.
  • Tracking: "Tracking" refers to the process of observing user behavior across multiple online services. Typically, behavioral and interest information related to the online services used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
  • Responsible: The term “controller” refers to 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 or on sets of personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, be it collection, analysis, storage, transmission, or erasure.
  • Target group formation: Target group creation (or "custom audiences") refers to the process of defining target groups for advertising purposes, such as displaying advertisements. For example, based on a user's interest in certain products or topics online, it can be inferred that this user will be interested in advertisements for similar products or the online shop where they viewed those products. "Lookalike audiences" (or similar target groups) are created when content deemed suitable is displayed to users whose profiles or interests are likely to match those of the users for whom the profiles were created. Cookies and web beacons are typically used to create custom and lookalike audiences.
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