Privacy policy

Preamble

With the following data protection declaration, we would like to inform you about which types of your personal data (hereinafter also referred to as “data”) we process, for what purposes and to what extent. This data protection declaration applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offering”).

The terms used are not gender specific.

As of: August 5, 2024

Table of contents

  • Preamble
  • Responsible
  • Contact Data Protection Officer
  • Overview of processing
  • Relevant legal bases
  • Security measures
  • Transmission of personal data
  • Business Services
  • Provision of the online offer and web hosting
  • Use of cookies
  • Blogs and publication media
  • Contact and inquiry management
  • Web analysis, monitoring and optimization
  • Presences in social networks (social media)
  • Plug-ins and embedded functions and content
  • Management, organization and tools
  • Definitions

Responsible

DMK
Khatuna Totadze
Ilia Chavchavadze Str. 33
4600 Kutaisi
Georgia

Authorized representatives: Khatuna Totadze

Email address: khatuna.totadze@dmk.ge

Imprint: https://dmk.ge/imprint/?lang=en

Contact Data Protection Officer

admin@dmk.ge

Overview of processing

The following overview summarises the types of data processed and the purposes of their processing and refers to the persons concerned.

Types of data processed

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

Categories of data subjects

  • Service recipient and client.
  • Interested parties.
  • communication partner.
  • users.
  • Business and contractual partners.

Purposes of processing

  • Provision of contractual services and fulfilment of contractual obligations.
  • Communication.
  • Security measures.
  • Reach measurement.
  • Office and organizational procedures.
  • Organisational and administrative procedures.
  • Feedback.
  • Profiles with user-related information.
  • Provision of our online offering and user-friendliness.
  • Information technology infrastructure.
  • Public relations.
  • Business processes and business procedures.

Relevant legal bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of 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 domicile. If more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Article 6 (1) sentence 1 lit. a) GDPR) – The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
  • Contract performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR) – The processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.
  • Legal obligation (Article 6 (1) sentence 1 lit. c) GDPR) – The processing is necessary to fulfill a legal obligation to which the controller is subject.
  • Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR) – the processing is necessary to protect the legitimate interests of the controller or a third party, provided that the interests, fundamental rights and freedoms of the data subject which require the protection of personal data do not prevail.

Note on the validity of the GDPR and the Swiss DSG: This data protection notice serves to provide information in accordance with both the Swiss DSG and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that the terms of the GDPR are used due to the broader spatial application and comprehensibility. In particular, instead of the terms “processing” of “personal data”, “overriding interest” and “personal data requiring particular protection” used in the Swiss DSG, the terms “processing” of “personal data” as well as “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 according to the Swiss DSG within the scope of the validity of the Swiss DSG.

Third country (outside the EU and Switzerland): The data protection regulations in the country of residence of the controller apply in addition to or alongside the data protection regulations of the GDPR. These regulations may contain specific provisions that go beyond or deviate from the requirements of the GDPR. These include, among others, provisions to protect against misuse of personal data, regulations on rights of information and deletion, rights of objection, processing of special categories of personal data, processing for other purposes, transmission and automated decision-making including profiling.

Security measures

In accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

The measures include in particular ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to it, input, transfer, ensuring availability and separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to data threats. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect user data transmitted through our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), protecting the data from unauthorized access. TLS, as the advanced and more secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL. This serves as an indicator for users that their data is being transmitted securely and encrypted.

Transmission of personal data

As part of our processing of personal data, it may happen that these are transmitted to or disclosed to other bodies, companies, legally independent organizational 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 that serve to protect your data.

Business Services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”), within the framework of contractual and comparable legal relationships and associated measures and with regard to communication with the contractual partners (or pre-contractually), for example to answer inquiries.

We use this data to fulfill our contractual obligations. This includes in particular the obligations to provide the agreed services, any updating obligations and remedy in the event of warranty and other service disruptions. In addition, we use the data to protect our rights and for the purposes of the administrative tasks associated with these obligations and company organization. In addition, we process the data on the basis of our legitimate interests in both proper and economical business management and security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. 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 that this is necessary for the aforementioned purposes or to fulfill legal obligations. The contractual partners are informed about other forms of processing, such as for marketing purposes, in this data protection declaration.

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

We delete the data after the expiry of statutory warranty and similar obligations, i.e. generally after four years, unless the data is stored in a customer account, e.g. as long as it must be kept for legal archiving reasons (e.g. for tax purposes, usually ten years). We delete data that was disclosed to us by the contractual partner as part of an order in accordance with the specifications and generally after the end of the order.

  • Types of data processed: Inventory data (e.g. full name, home address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers). Contract data (e.g. subject of the contract, term, customer category).
  • Affected persons: service recipients and clients; interested parties; business and contractual partners.
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; communication; office and organisational procedures; organisational and administrative procedures. Business processes and commercial procedures.
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR); Legal obligation (Art. 6 Para. 1 Clause 1 Letter c) GDPR). Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).

Further information on processing procedures, methods and services:

  • Agency services: We process our customers’ data as part of our contractual services, which may include, for example, conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consulting services and training services; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).

Provision of the online offer and web hosting

We process user data in order to be able 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. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, people involved); protocol data (e.g. log files relating to logins or the retrieval of data or access times). Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.). Security measures.
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. 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 from a corresponding server provider (also called “web host”) or obtain from other sources; legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 Letter 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”. The server log files can 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 avoid overloading the servers (particularly in the case of abusive attacks, so-called DDoS attacks), and to ensure the utilization of the servers and their stability; legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that needs to be retained for evidentiary purposes will not be deleted until the incident in question has been finally resolved.
  • E-mail sending and hosting: The web hosting services we use also include the sending, receiving and storing of e-mails. For these purposes, the addresses of the recipients and senders as well as other information regarding the e-mail sending (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data can also be processed for the purposes of detecting SPAM. Please note that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We cannot therefore accept any responsibility for the transmission path of the e-mails between the sender and the reception on our server; legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 Letter 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 Para. 1 Clause 1 lit. f) GDPR); Website: https://all-inkl.com/ ; Privacy Policy: https://all-inkl.com/datenschutzinformationen/ . Data processing agreement: Provided by the service provider.

Use of cookies

Cookies are small text files or other storage notes that store information on end devices and read it from them. For example, to store the log-in status in a user account, the contents of a shopping cart in an e-shop, the content accessed or the functions used in an online service. Cookies can also be used for various purposes, such as the functionality, security and convenience of online services and the creation of analyses of visitor flows.

Notes on consent: We use cookies in accordance with legal regulations. We therefore obtain prior consent from users, unless it is not required by law. Permission is not necessary in particular if the storage and reading of information, including cookies, is absolutely necessary in order to provide users with a telemedia service that they have expressly requested (i.e. our online offering). The revocable consent will be clearly communicated to them and will contain information on the respective cookie usage.

Notes on data protection legal bases: The data protection basis on which we process users’ personal data using cookies depends on whether we ask them for consent. If users accept, the legal basis for the use of their data is their declared consent. Otherwise, the data used using cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and the improvement of its usability) or, if this is done as part of the fulfillment of our contractual obligations, if the use of cookies is necessary to meet our contractual obligations. We will explain the purposes for which we use cookies in the course of this data protection declaration or as part of our consent and processing processes.

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

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed his or her device (e.g. browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, the log-in status can be saved and preferred content can be displayed directly when the user visits a website again. The user data collected using cookies can also be used to measure reach. If we do not provide users with explicit information about the type and storage period of cookies (e.g. when obtaining consent), they should assume that these are permanent and that the storage period can be up to two years.

General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also object to processing in accordance with the legal requirements, including by means of the privacy settings of their browser.

  • Types of data processed: Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR). Consent (Art. 6 Para. 1 Clause 1 Letter a) GDPR).

Further information on processing procedures, methods and services:

  • Processing of cookie data based on consent: We use a consent management solution that obtains users’ consent to the use of cookies or to the procedures and providers named in the consent management solution. This procedure is used to obtain, log, manage and revoke consent, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on users’ end devices. As part of this procedure, users’ consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers named in the consent management procedure. Users also have the option of managing and revoking their consent. The consent declarations are stored in order to avoid repeated queries and to be able to provide proof of consent in accordance with legal requirements. The data is stored on the server side and/or in a cookie (so-called opt-in cookie) or using comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information is available about the providers of consent management services, the following general information applies: The consent is stored for up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of the consent (e.g. relevant categories of cookies and/or service providers) and information about the browser, the system and the end device used; Legal basis: consent (Art. 6 Para. 1 Clause 1 lit. a) GDPR).

Blogs and publication media

We use blogs or similar means of online communication and publication (hereinafter “publication medium”). Readers’ data is only processed for the purposes of the publication medium to the extent that it is necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium in the context of this data protection notice.

  • Types of data processed: Inventory data (e.g. full name, home address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as details of authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Feedback (e.g. collecting feedback via online form); provision of our online offer and user-friendliness; security measures. Organizational and administrative procedures.
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Comments and contributions: When users leave comments or other contributions, their IP addresses can be stored on the basis of our legitimate interests. This is done for our security in case someone leaves illegal content in comments and contributions (insults, prohibited political propaganda, etc.). In this case, we ourselves can be held liable for the comment or contribution and are therefore interested in the identity of the author. Furthermore, we reserve the right to process the user’s information for the purpose of spam detection on the basis of our legitimate interests. On the same legal basis, we reserve the right to store the IP addresses of users for the duration of surveys and to use cookies to avoid multiple voting. The personal information provided in the comments and contributions, any contact and website information as well as the content information will be stored by us permanently until the user objects; legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).
  • Profile pictures from Gravatar: Profile pictures – We use the Gravatar service within our online offering and in particular in the blog. Gravatar is a service where users can register and store profile pictures and their email addresses. If users leave posts or comments on other online presences (especially in blogs) with the respective email address, their profile pictures can be displayed next to the posts or comments. For this purpose, the email address provided by the user is transmitted to Gravatar in encrypted form to check whether a profile has been saved for it. This is the sole purpose of transmitting the email address. It is not used for any other purpose and is deleted afterwards. Gravatar is used on the basis of our legitimate interests, as with the help of Gravatar we offer the authors of posts and comments the opportunity to personalize their posts with a profile picture. By displaying the images, Gravatar finds out the IP address of the user, as this is necessary for communication between a browser and an online service. If users do not want a user image linked to their email address on Gravatar to appear in the comments, they should use an email address that is not stored on Gravatar to comment. We would also like to point out that it is also possible to use an anonymous email address or no email address at all if users do not want their own email address to be sent to Gravatar. Users can completely prevent the transmission of data by not using our comment system; Service provider: Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR); Website: https://automattic.com . Privacy Policy: https://automattic.com/privacy .
  • UpdraftPlus: backup software and backup storage; service provider: Simba Hosting Ltd., 11, Barringer Way, St. Neots, Cambs., PE19 1LW, GB; legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR); website: https://updraftplus.com/ . Privacy Policy: https://updraftplus.com/data-protection-and-privacy-centre/ .

Contact and inquiry management

When you contact us (e.g. by post, contact form, email, telephone or via social media) and within the framework of existing user and business relationships, the information provided by the person making the inquiry will be processed to the extent that this is necessary to answer the contact inquiries and any requested measures.

  • Types of data processed: Inventory data (e.g. full name, home address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as details of authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
  • Affected persons: communication partners.
  • Purposes of processing: communication; organizational and administrative procedures; feedback (e.g. collecting feedback via online form). Provision of our online offering and user-friendliness.
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR). Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).

Further information on processing procedures, methods and services:

  • Contact form: When you contact us via our contact form, by email or other means of communication, we process the personal data sent to us in order to answer and process the respective request. This usually includes details such as name, contact information and, if applicable, other information that is communicated to us and is necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR), legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).

Web analysis, monitoring and optimization

Web analysis (also known as “reach measurement”) is used to evaluate the flow of visitors to our online offering and can include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. Using reach analysis, we can, for example, identify at what time our online offering or its functions or content are used most frequently, or encourage reuse. It is also possible for us to understand which areas require optimization.

In addition to web analysis, we can also use testing procedures to test and optimize different versions of our online offering or its components.

Unless otherwise stated below, profiles, i.e. data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in a device and then read out. The information collected includes in particular websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to us or the providers of the services we use collecting their location data, the processing of location data is also possible.

In addition, the IP addresses of the users are stored. However, we use an IP masking process (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored as part of web analysis, A/B testing and optimization, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective processes.

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

  • Types of data processed: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online offer and user-friendliness.
  • Retention and deletion: Deletion as stated in the “General information on data retention and deletion” section. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 Para. 1 Clause 1 Letter a) GDPR). Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).

Further information on processing procedures, methods and services:

  • Google Analytics: We use Google Analytics to measure and analyze the use of our online offering based on a pseudonymous user identification number. This identification number does not contain any unique data such as names or email addresses. It is used to assign analysis information to a device in order to recognize which content users have accessed within one or more usage processes, which search terms they have used, accessed them again or interacted with our online offering. The time of use and its duration are also stored, as well as the sources of users who refer to our online offering and technical aspects of their devices and browsers. Pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based counterparts). For EU traffic, the IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. It is not logged, is not accessible and is not used for any other purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 Para. 1 Clause 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/ ; Security measures: IP masking (pseudonymization of the IP address); Privacy policy: https://policies.google.com/privacy ; Data processing agreement: https://business.safety.google/adsprocessorterms/ ; Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de , Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff . Further information: https://business.safety.google/adsservices/ (types of processing and data processed).

Presences in social networks (social media)

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

We would like to point out that user data may be processed outside the European Union. This may result in risks for users because it could, for example, make it more difficult to enforce user rights.

Furthermore, the data of users within social networks is usually processed for market research and advertising purposes. For example, user profiles can be created based on the user’s usage behavior and the resulting interests. The latter can then be used to place advertisements within and outside the networks that presumably correspond to the user’s interests. Cookies are therefore usually stored on users’ computers in which the user’s usage behavior and interests are stored. In addition, data can also be stored in the user profiles regardless of the devices used by the users (especially if they are members of the respective platforms and are logged in there).

For a detailed description of the respective processing methods and the options for objection (opt-out), please refer to the data protection declarations and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we would like to point out that these can be asserted most effectively with the providers. Only the latter have access to the user data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

  • Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as details of authorship or time of creation). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Purposes of processing: communication; feedback (e.g. collecting feedback via online form). Public relations.
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Facebook pages: Profiles within the social network Facebook – We are jointly responsible with Meta Platforms Ireland Limited for collecting (but not further processing) data from visitors to our Facebook page (so-called “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, so-called “Page Insights”, to page operators so that they can gain insights into how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook (“Information about Page Insights”, https://www.facebook.com/legal/terms/page_controller_addendum ), which in particular regulates which security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of those affected (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the responsible supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information about Page Insights” ( https://www.facebook.com/legal/terms/information_about_page_insights_data ). The joint controllership is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular the transmission of the data to the parent company Meta Platforms, Inc. in the USA; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR); Website: https://www.facebook.com . Privacy Policy: https://www.facebook.com/privacy/policy/ .

Plug-ins and 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”). These may include, for example, graphics, videos or city maps (hereinafter referred to uniformly as “content”).

The integration always requires that the third-party providers of this content process the IP address of the users, since without an IP address they would not be able to send the content to their browser. The IP address is therefore required to display this content or functions. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers can also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user’s device and contain, among other things, technical information about the browser and operating system, referring websites, the time of visit and other information about the use of our online offering, but can also be linked to such information from other sources.

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

  • Types of data processed: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, people involved); inventory data (e.g. full name, home address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or visual messages and contributions as well as information relating to them, such as information on authorship or time of creation). Location data (information on the geographical position of a device or person).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Purpose of processing: Provision of our online offer and user-friendliness.
  • Retention and deletion: Deletion as stated in the “General information on data retention and deletion” section. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
  • Legal basis: Consent (Art. 6 Para. 1 Clause 1 Letter a) GDPR). Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).

Further information on processing procedures, methods and services:

  • Google Fonts (obtained from Google server): Obtaining fonts (and symbols) for the purpose of technically secure, maintenance-free and efficient use of fonts and symbols with regard to timeliness and loading times, their uniform presentation and 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) is transmitted that is necessary for the provision of the fonts depending on the devices used and the technical environment. This data can be processed on a server of the provider of the fonts in the USA – When visiting our online offer, the user’s browser sends 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) from Google Fonts and then the fonts specified in the CCS. These HTTP requests include (1) the IP address used by the user to access the Internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user agent describing the browser and operating system versions of website visitors, and the referring URL (i.e., the web page where the Google font should be displayed). IP addresses are neither logged nor stored on Google servers, and they are not analyzed. The Google Fonts Web API logs details of 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 for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. The Google Fonts Web API requires the user agent to customize the font that is generated for the respective browser type. The user agent is logged primarily for debugging purposes and is used to generate aggregated usage statistics that measure the popularity of font families. These aggregated usage statistics are published on the Google Fonts Analytics page. Finally, the referring URL is logged so that the data can be used for production maintenance and to generate an aggregated report on the top integrations based on the number of font requests. According to Google, it does not use any of the information collected by Google Fonts to create profiles of end users or to display targeted ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR); Website: https://fonts.google.com/ ; Privacy Policy: https://policies.google.com/privacy . Further information: https://developers.google.com/fonts/faq/privacy?hl=de .
  • Google Maps: We integrate the maps of the “Google Maps” service provided by Google. The data processed may include, in particular, IP addresses and location data of users; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Consent (Art. 6 Para. 1 Clause 1 lit. a) GDPR); Website: https://mapsplatform.google.com/ . Privacy Policy: https://policies.google.com/privacy .
  • YouTube videos: video content; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: consent (Art. 6 Para. 1 Clause 1 lit. a) GDPR); website: https://www.youtube.com ; Privacy Policy: https://policies.google.com/privacy . Possibility of objection (opt-out): Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de , Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff .

Management, organization and tools

We use services, platforms and software from other providers (hereinafter referred to as “third-party providers”) for the purposes of organizing, managing, planning and providing our services. When selecting 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 third-party providers. This may affect various data that we process in accordance with this data protection declaration. This data may include, in particular, master data and contact details of users, data on transactions, contracts, other processes and their contents.

If users are referred to third-party providers or their software or platforms as part of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, to optimize the service or for marketing purposes. We therefore ask that you observe the data protection notices of the respective third-party providers.

  • Types of data processed: Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as details of authorship or time of creation); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
  • Affected persons: communication partners. Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Office and organizational procedures.
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Definitions

This section provides you with an overview of the terms used in this privacy policy. To the extent that the terms are defined by law, their legal definitions apply. The following explanations, however, are primarily intended to aid understanding.

  • Inventory data: Inventory data includes essential information that is necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data can include, among other things, personal and demographic information such as names, contact information (addresses, telephone numbers, email addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between people and services, institutions or systems by enabling clear assignment and communication.
  • Content data: Content data includes information generated during the creation, editing and publishing of all types of content. This category of data can include text, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not only limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication dates
  • Contact details: Contact details are essential information that enables communication with people or organizations. They include, among others, telephone numbers, postal addresses and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.
  • Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about the way data is processed, transmitted and managed. Metadata, also known as data about data, includes information that describes the context, origin and structure of other data. It can include information about file size, creation date, author of a document and change histories. Communication data records the exchange of information between users across different channels, such as email traffic, call logs, social media messages and chat histories, including the people involved, timestamps and transmission paths. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review events.
  • Usage data: Usage data refers to information that records how users interact with digital products, services or platforms. This data includes a wide range of information that shows how users use applications, which features they prefer, how long they spend on certain pages and which paths they take through an application. Usage data can also include frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences and potential problem areas within digital offerings
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a 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”, or “profiles” for short, includes any type of automated processing of personal data consisting in the use of 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 different information relating to demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Log Data: Log data is information about events or activities logged on a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages, and other details about the usage or operation of a system. Log data is often used to analyze system problems, monitor security, or create performance reports.
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, operators of online offerings can, for example, recognize at what time users visit their websites and what 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 reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
  • Location data: Location data is created when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, a WLAN or similar technical means and functions for location determination. Location data is used to indicate the geographically definable position on earth in which the respective device is located. Location data can be used, for example, to display map functions or other location-dependent information.
  • Controller: The “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of processing personal data.
  • Processing: “Processing” is any operation or set of operations which is carried out with or without the aid of automated procedures in connection with personal data. The term is broad and covers practically every handling of data, be it the collection, evaluation, storage, transmission or deletion.
  • Contract data: Contract data is specific information related to the formalization of an agreement between two or more parties. It documents the terms under which services or products are provided, exchanged or sold. This category of data is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data can include start and end dates of the contract, the type of services or products agreed upon, pricing agreements, payment terms, termination rights, renewal options and special conditions or clauses. It serves as the legal basis for the relationship between the parties and is crucial for clarifying rights and obligations, enforcing claims and resolving disputes.
  • Payment data: Payment data includes all information needed to process payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction data, verification numbers and billing information. Payment data can also include information about payment status, chargebacks, authorizations and fees.

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