Privacy policy

General

As operators of this and other websites, we take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

This privacy policy informs you about the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) on our website and the web pages, functions and content associated with it, as well as our other external online presence, such as our social media profiles, the other services we offer and the IT systems we use.

With regard to the terms used, such as “personal data” and “processing”, we refer to the definitions in Art. 4 of the EU General Data Protection Regulation (GDPR).

Security measures

We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk in accordance with Art. 32 GDPR, 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 risk to the rights and freedoms of natural persons.

Those measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling both physical access to it and regulating electronic access, data entry, disclosure, assurance of availability and separation of the data.

Furthermore, we have established procedures to ensure that data subjects can exercise their rights, that data is erased and that there is an appropriate response if the data is compromised. We also take account of protection of personal data during the development and selection of hardware, software and processes, in accordance with the principle of data protection through the design of technology and default settings that support data protection (Art. 25 GDPR).

The security measures include, in particular, encrypted transmission of data between your browser and our server.

SSL and TLS encryption

For security reasons and to protect the transmission of confidential content, such as orders or enquiries that you send to us as the site operator, this site uses the latest SSL or TLS encryption. You can recognise an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read in plain text by third parties.

Data security on the internet

We would like to point out that data transmission over the internet (e.g. communication by email) can involve security loopholes. Complete protection of data against access by third parties is not possible.

Data processing on this website

On the one hand, your data is collected by you providing it to us. This may, for example, take the form of data that you enter on a contact form.

Other data is collected automatically by IT systems when you visit the website. This is mainly technical data such as information about the internet browser, operating system or time of the page view. This data is collected automatically as soon as you access our website.

Some of the data is collected to ensure error-free provision of the website. Other data may be used to analyse your user behaviour.

You have the right to obtain information about the origin, recipient and purpose of your stored personal data at any time. You also have a right to request rectification, blocking or erasure of that data. You can contact us at any time at the address provided in the legal notice if you have any further questions about data protection. You also have the right to lodge a complaint with a competent supervisory authority.

Furthermore, you have the right to request the restriction of processing of your personal data in certain circumstances.

Details of your rights as a data subject can be found in the “General and mandatory information” section of this privacy policy.

Analytical tools and tools of third parties

When you visit our website, your usage behaviour can be evaluated statistically. This is achieved mainly with so-called analytical programs.

Detailed information about this can be found in the “Analytical tools and marketing” section of this privacy policy.

Payment transactions on this website

If, on conclusion of a contract involving costs, there is an obligation to provide us with your payment data (e.g. account number in the case of a direct debit authorisation), this data is required for the processing of payments.

Payment transactions using common means of payment (Visa/MasterCard, direct debit) are made exclusively via an encrypted SSL or TLS connection. You can recognise an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.

With encrypted communication, the payment data that you transmit to us cannot be read by third parties.

Cooperation with processors and third parties

If, in the course of our processing, we disclose data to other persons or companies (commissioned data processors or third parties), transmit it to them or otherwise grant them access to data, this happens only on the basis of legal permission (e.g. if transmission of the data to third parties, such as to payment service providers, is necessary for the performance of the contract pursuant to Art. 6(1) point (b) GDPR), if you have given your consent, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we commission third parties to process data on our behalf (commissioned data processing), this is done on the basis of an agreement pursuant to Art. 28(3) GDPR.

Information about data transfer to the USA and other third countries

If we process data in a third country (i.e. a country outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using third-party services or disclosing or transferring data to third parties, this happens only to fulfil our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permission, we only process or allow the processing of data in a third country if the special requirements of Art. 44 ff. GDPR are met. This means that the processing is carried out, for example, on the basis of special guarantees, such as officially recognised determination of a level of data protection corresponding to the EU or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).

Among other things, we use tools from companies based in the USA or other third countries that are not secure in terms of data protection law. When these tools are active, your personal data may be transferred to and processed in those third countries. Please note that a level of data protection comparable to that in the EU cannot be guaranteed in these countries. For example, US companies are obliged to hand over personal data to the security authorities without you as a data subject being able to take legal action to prevent this. It cannot therefore be ruled out that the US authorities (e.g. intelligence services) will process, evaluate and permanently store your data located on US servers for surveillance purposes. We have no control over these processing activities.

Storage period

Unless a more specific storage period is specified in this privacy policy, your personal data is kept by us until the purpose for processing the data no longer applies.

If you assert a legitimate request for erasure or revoke consent to data processing, your data will be erased unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, the data will be erased once those reasons no longer apply.

Explanation of terms

GDPR

EU General Data Protection Regulation (EU Regulation 2016/679)

Preeminent data protection law at European level with direct legal effect in all EU member states

BDSG

Federal Data Protection Act, the German data protection act.

TTDSG

Act on Data Protection and Privacy in Telecommunications and Telemedia (Telecommunications Telemedia Data Protection Act)

Adapts the previous data protection provisions on telemedia and telecommunications services to Regulation (EU) 2016/679 (General Data Protection Regulation) and transposes the regulations of Directive 2002/58/EC (ePrivacy Directive) into national law.

Personal data

Any information relating to an identified or identifiable natural person. (Art. 4(1) GDPR)

Controller

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. (Art. 4(7) GDPR)

Consent (of the data subject)

Any voluntary, specific, informed and unambiguous indication of the data subject’s wishes in the form of a statement or other unambiguous affirmative act by which they signify their agreement to processing of their personal data. (Art. 4(11) GDPR)

1 Controller

Controller

The controller for data processing within the meaning of data protection law on this website is

Werner & Mertz GmbH
Rheinallee 96
55120 Mainz, Germany

For contact details, see legal notice

If another operator of the website is named in the legal notice, that operator is also deemed to be the controller within the meaning of data protection law for processing operations on this website.

Data protection officer pursuant to Art. 37 – 39 GDPR

We have appointed a data protection officer:

Boris Koppenhöfer
c/o Koppenhöfer & Werner Beratungsgesellschaft mbH
Nikolausstraße 11
65343 Eltville am Rhein, Germany

Tel.: +49(6123)9213-61
Email: datenschutz@werner-mertz.com

2 General and mandatory information

Revocation of your consent to data processing

Many data processing operations are only possible with your explicit consent. You can revoke consent that you have given previously at any time. All you need to do is send us an informal message by email. The lawfulness of the data processing carried out up to the point of revocation remains unaffected by the revocation.

Right to object to data processing in specific cases and to direct marketing (Art. 21 GDPR)

IF THE DATA PROCESSING IS BASED ON ART. 6(1) POINT E OR F GDPR, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THOSE PROVISIONS. THE LEGAL BASIS ON WHICH PROCESSING IS CARRIED OUT CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING IS FOR THE PURPOSE OF ASSERTING, EXERCISING OR DEFENDING LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

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 DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS CONNECTED WITH SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to lodge a complaint with a supervisory authority

In the event of breaches of the GDPR or other provisions of data protection law, data subjects have the right to lodge a complaint with a supervisory authority for data protection, in particular in the Member State of their habitual residence, their place of work or the place of the alleged breach. The right to lodge a complaint is without prejudice to any other administrative or judicial remedy.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in performance of a contract handed over to you or to a third party in a common, machine-readable format. If you request direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.

Access, erasure and rectification

Within the framework of the applicable legal provisions, you have the right to access information about your stored personal data, its origin and recipients and the purpose of the data processing at any time and, if applicable, a right to rectification or erasure of that data. You can contact us at any time at the address given in the legal notice for this purpose and with any other questions about personal data.

Right to restrict processing

You have the right to request the restriction of processing of your personal data. You can contact us at any time at the address given in the legal notice for this purpose. The right to restrict processing exists in the following cases:

• If you dispute the accuracy of your personal data held by us, we will usually need time to verify this. For the duration of this verification procedure, you have the right to request restriction of the processing of your personal data.
• If processing of your personal data has happened / is happening unlawfully, you can request the restriction of data processing instead of erasure.
• If we no longer need your personal data, but you need it to exercise, defend or enforce legal claims, you have the right to request restriction of the processing of your personal data instead of erasure.
• If you have lodged an objection pursuant to Art. 21(1) GDPR, a balance must be struck between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to demand restriction of the processing of your personal data.

If you have restricted the processing of your personal data, apart from being stored such data may only be processed with your consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.

3 Hosting, service providers and content delivery networks (CDNs)

External hosting

Our websites are hosted by external service providers (hosts). The personal data collected on these websites is stored on the host’s servers. This may include, but is not limited to, IP addresses, contact requests, meta and communication data, contractual data, contact details, names, website access and other data generated via a website.

The host is used for the purpose of contract fulfilment vis-à-vis our potential and existing customers (Art. 6(1) point b GDPR) and in the interest of secure, fast and efficient provision of our website by a professional provider (Art. 6(1) point (f) GDPR). Insofar as corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1) point (a) GDPR and Section 25(1) TTDSG, provided that the consent includes the storage of cookies or access to information on the user’s end device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent may be revoked at any time.

Our host will only process your data to the extent necessary to fulfil its performance obligations and follow our instructions in relation to such data.

We use the following host(s):

Domainfactory GmbH
Neuturmstrasse 5
80331 Munich, Germany

Service providers / agencies

We use service providers for the development, administration and/or maintenance of our website.

Our service providers only process your data to the extent necessary to fulfil their tasks and follow our instructions in relation to such data.

We use the following service provider(s):

Knecht GmbH
Gaulsheimer Straße 16
55437 Ockenheim, Germany

Deep Media Technologies GmbH
Hohe Bleichen 8
20354 Hamburg
Germany

Vollbild Markus Schäfer & Mathias Sporn
Immelmannstraße 7A
55124 Mainz, Germany

4 Cookies, local storage

Cookies

Our internet pages use so-called “cookies”. Cookies are small text files, and they do not cause any damage to your end device. They are stored either temporarily for the duration of a session (session cookies) or permanently (permanent cookies) on your end device. Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your end device until you delete them yourself or until they are automatically deleted by your web browser.

In some cases, cookies from third-party companies may also be stored on your end device when you visit our site (third-party cookies). These enable us or you to use certain services of the third-party company (e.g. cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping basket function or the display of videos). Other cookies are used to evaluate user behaviour or display advertising.

Cookies that are necessary to carry out the electronic communication process, to provide certain functions that you have requested (e.g. for the shopping basket function) or to optimise the website (e.g. cookies to measure the web audience) (necessary cookies) are stored on the basis of Art. 6(1) point (f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for technically error-free and optimised provision of its services. If consent to the storage of cookies and similar recognition technologies has been requested, processing is carried out exclusively on the basis of that consent (Art. 6(1) point (a) GDPR and Section 25(1) TTDSG); consent may be revoked at any time.

You can set your browser so that you are informed when cookies are downloaded and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate automatic deletion of cookies when closing the browser. If cookies are disabled, the functionality of this website may be limited.

If cookies are used by third-party companies or for analytical purposes, we will inform you about this separately within the framework of this privacy policy and, if necessary, request your consent.

Local storage

In order for you to be able to adapt our web pages to your use, we use so-called local storage technology (also referred to as “local data” and “local storage”) in addition to cookies. In this process, data is stored locally in the cache of your browser and remains there even when you close the browser window or exit the program – unless you clear the cache.

Local storage allows your preferences when using our website to be stored on your computer and used by you. The data from the local storage is used, for example, to recognise you as a user of the website or to apply the settings you have put in place when you visit the website again.

Third parties cannot access the data stored in the local storage. It is not passed on to third parties and is not used for purposes other than those mentioned above.

Where the use of local storage technology is not absolutely necessary to enable the functionality of our website, we only use it with your consent, see Section 25 TTDSG, Art. 6(1) point (a) GDPR. You can revoke your consent at any time.

Consent tool

Our website uses consent technology to obtain your consent to the storage of certain cookies on your end device or the use of certain technologies and to document this in accordance with data protection law.

When you visit our website, a connection is established to our servers in order to obtain your consent and other declarations regarding the use of cookies. We then save a cookie in your browser in order to be able to allocate the consent given – or its revocation – to you. The data collected in this way is stored until you request us to erase it, delete the cookie yourself or the purpose for storing the data no longer applies. Statutory retention obligations remain unaffected.

The purpose is to obtain the consent for the use of cookies required by law. The legal basis for this is Art. 6(1) point (c) GDPR.

CCM19

Our websites use CCM19 to obtain your consent to the storage of certain cookies on your end device or the use of certain technologies and to document this in accordance with data protection law. The provider of this technology is Papoo Software & Media GmbH, Auguststr. 4, 53229 Bonn, Germany (hereinafter “CCM19”).

When you visit our website, a connection is established to the servers of CCM19 in order to obtain your consent and other declarations regarding the use of cookies. CCM19 then saves a cookie in your browser in order to be able to allocate the consent given – or its revocation – to you. The data collected in this way is stored until you request us to erase it, delete the CCM19 cookie yourself or the purpose for storing the data no longer applies. Statutory retention obligations remain unaffected.

CCM19 is used in order to obtain the consent for the use of cookies required by law. The legal basis for this is Art. 6(1) point (c) GDPR.

Cookie settings

CCM19 options

Cookie/local storage information

Cookie informations

5 Data processing on the website

Server log files

The provider of the site automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. This information comprises:

• Browser type and version
• Operating system used
• Referrer URL
• Host name of the accessing computer
• Time of the server request
• IP address

This data is not merged with other data sources.

Collection of this data is based on Art. 6(1) point (f) GDPR. The website operator has a legitimate interest in technically error-free presentation and optimisation of its website – the server log files must be recorded for this purpose.

Contact form

If you send us enquiries via the contact form, the information you provide on the enquiry form, including the contact details you specify there, will be stored by us for the purpose of processing the enquiry and for any follow-up queries. We do not pass on this data without your consent.

This data is processed on the basis of Art. 6(1) point (b) GDPR if your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in effective handling of the enquiries addressed to us (Art. 6(1) point (f) GDPR) or on your consent (Art. 6(1) point (a) GDPR) if this has been requested.

The data you enter on the contact form is retained by us until you request us to erase it, revoke your consent to its storage or the purpose for storing the data no longer applies (e.g. when we have finished processing your enquiry). Statutory provisions – in particular retention periods – remain unaffected.

Blogger enquiry

If you send us an enquiry via a blogger enquiry form, the information you provide on the form, including the contact details you specify there, will be stored by us for the purpose of processing the blogger enquiry and for any follow-up queries. We do not pass on this data without your consent.

Processing of the data entered on the form is therefore always based on your consent (Art. 6(1) point (a) GDPR). You can revoke that consent at any time. All you need to do is send us an informal message by email. The lawfulness of the data processing operations carried out up to the point of revocation remains unaffected by the revocation.

This data is processed on the basis of Art. 6(1) point (b) GDPR if your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures.

The data you enter on the contact form is retained by us until you request us to erase it, revoke your consent to its storage or the purpose for storing the data no longer applies (e.g. when we have finished processing your enquiry). Statutory provisions – in particular retention periods – remain unaffected.

Registration on certain web pages

You may register on some of our web pages to use additional features on the page. We use the data entered in this connection only for the purpose of providing the respective offer or service for which you have registered. The mandatory information requested during registration must be provided in full. Otherwise registration will be refused.

For important changes, for example in the scope of the offer or in the case of technically necessary changes, we use the email address provided during registration to inform you.

The data entered during registration is processed, among other things, for the purpose of implementing the contractual relationship established by your registration and, if necessary, for initiating further contractual relationships (Art. 6(1) point (b) GDPR).

Processing of the data entered during registration is based, among other things, on your consent (Art. 6(1) point (a) GDPR). You can revoke any consent you have given at any time. All you need to do is send us an informal message by email. The lawfulness of the data processing already carried out remains unaffected by the revocation.

The data collected during registration is stored by us for as long as you are registered on our website and is then erased. Statutory retention periods remain unaffected.

Comment function

For comment functions on our website, in addition to your comment, details of when the comment was created, your email address and, unless you post anonymously, the user name you have chosen will be stored.

Storage of IP addresses

Our comment function may store the IP addresses of users who post comments. Since we do not check comments on our site before they are activated, we need this data in order to be able to take action against the author in the event of breaches of the law such as posting of offensive comments or propaganda.

Subscription to comments

As a user of the site, you may be able to subscribe to comments after registering. You will usually receive a confirmation email to check that you are the owner of the email address provided. You can unsubscribe from this function at any time via a link in the notification emails. The data entered in the context of subscribing to comments is erased in this case; however, if you have transmitted this data to us for other purposes and at another point (e.g. to subscribe to the newsletter), it will be retained by us.

Storage period for comments

The comments and the associated data (e.g. IP address) are stored and remain on our website until the commented content has been completely erased or the comments have to be erased for legal reasons (e.g. offensive comments).

Legal basis

Storage of the comments is based on your consent (Art. 6(1) point (a) GDPR). You can revoke any consent you have given at any time. All you need to do is send us an informal message by email. The lawfulness of the data processing operations already carried out remains unaffected by the revocation.

6 eCommerce

Processing data (customer and contract data)

We process personal data only insofar as is necessary for the establishment, content or amendment of the legal relationship (master data). This is done on the basis of Art. 6(1) point (b) GDPR, which permits the processing of data for the fulfilment of a contract or pre-contractual measures. We only process personal data about the use of our website (usage data) insofar as this is necessary to enable the user to use the service or to bill the user.

The customer data collected is erased on completion of the order or termination of the business relationship. Statutory retention periods remain unaffected.

Data transmission on conclusion of a contract for our online shops

We only transmit personal data to third parties if this is necessary within the framework of contract processing, for example to the companies used for delivery of the goods or to the financial institution commissioned with payment processing. Further transmission of the data does not take place or does so only if you have expressly consented to such transmission. Your data is not passed on to third parties – for marketing purposes, for example – without your express consent.

The basis for data processing is Art. 6(1) point (b) GDPR, which permits the processing of data for the fulfilment of a contract or pre-contractual measures.

Data transmission on conclusion of a contract for services and digital content

We only transmit personal data to third parties if this is necessary to process the contract, for example to the financial institution commissioned with processing the payments.

Further transmission of the data does not take place or does so only if you have expressly consented to such transmission. Your data is not passed on to third parties – for marketing purposes, for example – without your express consent.

The basis for data processing is Art. 6(1) point (b) GDPR, which permits the processing of data for the fulfilment of a contract or pre-contractual measures.

Credit checks

If we offer purchase on account or another method of payment for which we make advance payments, we may carry out a credit check (scoring). For this purpose, we transmit the data you have entered (e.g. name, address, age and bank details) to a credit agency. The probability of default is determined on the basis of this data. In the event of a high risk of default, we may refuse the payment method in question.

The credit assessment is carried out to perform the contract (Art. 6(1) point (b) GDPR) and to avoid payment defaults (legitimate interest according to Art. 6(1) point (f) GDPR). If consent has been obtained, the credit check is carried out on the basis of that consent (Art. 6 para. 1 lit. GDPR); consent may be revoked at any time.

7 Analytical tools and marketing

Google Analytics

Our website may use functions of the web analysis service Google Analytics. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyse the behaviour of website visitors. In doing so, the website operator receives a variety of usage data, such as page views, duration of visit, operating systems used and the origin of the user. This data is assigned to the user’s end device. There is no assignment to a user ID.

Google Analytics also allows us to record your mouse and scroll movements and clicks. Furthermore, Google Analytics uses various modelling approaches to augment the data sets collected and employs machine learning technologies in data analysis.

Google Analytics applies technologies that enable recognition of the user for the purpose of analysing user behaviour (e.g. cookies or device fingerprinting). The information collected by Google about the use of this website is usually transferred to a Google server in the USA and stored there.

The use of this service is based on your consent according to Art. 6(1) point (a) GDPR and Section 25(1) TTDSG. Consent may be revoked at any time.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/.

Browser plugin

You can prevent the collection and processing of your data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

You can find more information about how Google Analytics handles user data in Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=en.

Google Signals

We use Google Signals on certain pages. When you visit our website, Google Analytics collects, among other things, your location, search history, YouTube history and demographic data (visitor data). This data can be used for personalised advertising with the help of Google Signals. If you have a Google account, visitor data from Google Signals is linked to your Google account and used for personalised advertising. The data is also used to compile anonymised statistics about the behaviour of our users.

Google Tag Manager

We use Google Tag Manager on certain web pages. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Tag Manager is a tool that allows us to integrate tracking and statistical tools and other technologies into our website. Google Tag Manager itself does not create user profiles, does not store cookies and does not perform any independent analyses. It is only used to manage and deliver the tools integrated through it. However, Google Tag Manager collects your IP address, which may also be transferred to Google’s parent company in the United States.

The use of Google Tag Manager is based on Art. 6(1) point (f) GDPR. The website operator has a legitimate interest in fast, straightforward integration and administration of various tools on the website. Insofar as corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1) point (a) GDPR and Section 25(1) TTDSG, provided that the consent includes the storage of cookies or access to information on the user’s end device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent may be revoked at any time.

Matomo

Our website uses the open source web analytics service Matomo.

With the help of Matomo, we are able to collect and analyse data about the use of our website by website visitors. This enables us to find out, among other things, which pages are accessed, when they are accessed and which region the access comes from. We also collect various log files (e.g. IP address, referrer, browsers and operating systems used) and can measure whether our website visitors carry out certain actions (e.g. clicks, purchases, etc.).

The use of this analytical tool is based on Art. 6(1) point (f) GDPR. The website operator has a legitimate interest in analysing user behaviour in order to optimise both the website and its advertising. Insofar as corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1) point (a) GDPR and Section 25(1) TTDSG, provided that the consent includes the storage of cookies or access to information on the user’s end device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent may be revoked at any time.

IP anonymisation

We use IP anonymisation for analysis with Matomo. Your IP address is truncated before analysis so that it can no longer be clearly assigned to you.

Hosting

We host Matomo exclusively on our own servers so that all analytical data remains with us and is not passed on.

Meta Pixel (formerly Facebook Pixel)

Our website uses the visitor action pixel from Facebook/Meta for conversion measurement. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. However, according to Facebook, the data collected is also transferred to the USA and other third countries.

The behaviour of page visitors can be tracked in this way after they have been redirected to the provider’s website by clicking on a Facebook ad. This allows the effectiveness of Facebook ads to be evaluated for statistical and market research purposes and optimisation of future advertising campaigns.

The data collected is anonymous for us as the operator of this website, and we cannot draw any conclusions about the identity of users. However, the data is stored and processed by Facebook so that a connection to the respective user profile is possible and Facebook can use the data for its own marketing purposes, in accordance with the Facebook privacy policy (https://en-gb.facebook.com/about/privacy/). This allows Facebook to place advertising both on Facebook pages and outside of Facebook. As the site operator, we have no control over this use of data.

The use of this service is based on your consent according to Art. 6(1) point (a) GDPR and Section 25(1) TTDSG. Consent may be revoked at any time.

Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are joint controllers for this data processing (Art. 26 GDPR). Our responsibility as joint controller is limited exclusively to collection of the data and its transfer to Facebook. Processing of the data by Facebook that takes place after the data has been forwarded is not part of our joint responsibility. The obligations incumbent on us jointly were set out in a joint processing agreement. The text of the agreement can be found at: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Facebook tool and for implementing the tool on our website in a manner that complies with data protection legislation. Facebook is responsible for the data security of Facebook products. You can exercise your rights as a data subject (e.g. requests for information) in relation to the data processed by Facebook directly with Facebook. If you exercise your rights as a data subject with us, we are obliged to forward the matter to Facebook.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum and https://en-gb.facebook.com/help/566994660333381.

You can find further information about protecting your privacy in Facebook’s privacy policy: https://en-gb.facebook.com/about/privacy/.

You can also disable the “Custom Audience” remarketing function in the Advertising Settings section at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you must be logged in to Facebook.

If you do not have a Facebook account, you can disable usage-based advertising from Facebook on the European Interactive Digital Advertising Alliance website: https://www.youronlinechoices.com/uk/your-ad-choices/.

Deep Media Advertiser Tag

On some of our pages we use the Deep Media Advertiser Tag, a service provided by Deep Media Technologies GmbH, Hohe Bleichen 8, 20354 Hamburg, Germany.

The Deep Media Advertiser Tag is a tag management system for managing technologies for marketing and optimisation purposes. It is used in particular to deliver advertising that is relevant and interesting to you and to improve campaign performance reports. The use of the advertiser tag may involve the processing of pseudonymised online identifiers, such as cookies and click IDs. Personal identification of the user is not possible for Deep Media Technologies GmbH.

Data is processed in this context by providers for which the user has given consent in the data protection settings of this website. Objections to the collection and storage of data can be made at any time with the respective provider. In the event of an objection, the data in question will not be passed on to Deep Media Technologies GmbH.

The legal basis for the data processing described above is Article 6 (1) point (a) GDPR. Further information on the use of data by Deep Media Technologies GmbH can be found on the following website of Deep Media Technologies GmbH: https://www.deepmedia.de/en/privacy-information-advertiser-tag/

Pinterest

On this website we use elements of the social network Pinterest, which is operated by Pinterest Europe Ltd, Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland.

When you visit a page that contains such an element, your browser establishes a direct connection to the Pinterest servers. This social media element transmits log data to the Pinterest server in the USA. This log data may include your IP address, the address of websites visited that also contain Pinterest features, browser type and settings, date and time of request, how you use Pinterest and cookies.

Insofar as consent has been obtained, this service is used on the basis of Art. 6(1) point (a) GDPR and Section 25 TTDSG. Consent may be revoked at any time. If consent has not been obtained, the use of the service is based on our legitimate interest in being as visible as possible on social media.

Further information about the purpose, scope, further processing and use of the data by Pinterest, as well as your rights in this regard and options for protecting your privacy, can be found in the Pinterest privacy information: https://policy.pinterest.com/en/privacy-policy.

8 Newsletter

Newsletter data

If you would like to receive newsletters offered on our website, we require an email address from you and information that allows us to verify that you are the owner of that email address and that you agree to receive the newsletter. No other data is collected unless it is on a voluntary basis. We use newsletter service providers to handle the newsletters, which are described below.

The processing of the data entered on the newsletter registration form is based exclusively on your consent (Art. 6(1) point (a) GDPR). You can revoke your consent to the storage of the data, the email address and their use for sending you the newsletter at any time, for example via the “Unsubscribe” link in the newsletter. The lawfulness of the data processing operations already carried out remains unaffected by the revocation.

The data you provide for the purpose of receiving the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and will be erased from the newsletter distribution list after you unsubscribe from the newsletter. Data that has been stored by us for other purposes remains unaffected by this.

After you have unsubscribed from the newsletter distribution list, your email address may be stored by us or the newsletter service provider on a blacklist in order to prevent future mailings. The data from the blacklist is only used for this purpose and is not merged with any other data. This serves both your interests and our interest in complying with legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1) point (f) GDPR). Storage on the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.

9 Plugins and tools

Google Fonts

Some of our pages use so-called Google Fonts, which are provided by Google, for uniform display of fonts. When you access a page, your browser loads the fonts required into your browser cache in order to display texts and fonts correctly.

The browser you use must connect to Google’s servers for this purpose. This notifies Google that the website has been accessed via your IP address. The use of Google Fonts is based on Art. 6(1) point (f) GDPR. The website operator has a legitimate interest in uniform presentation of the typeface on the website. Insofar as corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1) point (a) GDPR and Section 25(1) TTDSG, provided that the consent includes the storage of cookies or access to information on the user’s end device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent may be revoked at any time.

If your browser does not support Google Fonts, a default font will be used by your computer.

Further information about Google Fonts can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://policies.google.com/privacy?hl=en.

Google Fonts (local hosting)

Some of our pages use so-called Google Fonts, which are provided by Google, for uniform display of fonts. The Google Fonts are installed locally. No connection is made to Google servers.

Further information about Google Fonts can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://policies.google.com/privacy?hl=en.

YouTube in privacy-enhanced mode

Certain websites embed videos from the website YouTube. The operator of the site is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

We use YouTube in privacy-enhanced mode. According to YouTube, this mode means that YouTube does not store any information about visitors to this website before they watch the video. However, disclosure of data to YouTube partners is not necessarily excluded by privacy-enhanced mode. YouTube establishes a connection to the Google DoubleClick network, regardless of whether you watch a video.

As soon as you start a YouTube video on our website, a connection to the YouTube servers is established. This tells the YouTube server which of our pages you have visited. If you are logged into your YouTube account, you enable YouTube to associate your browsing behaviour directly with your personal profile. You can prevent this by logging out of your YouTube account.

Furthermore, YouTube may store various cookies on your end device after starting a video or use similar recognition technologies (e.g. device fingerprinting). In this way, YouTube can obtain information about visitors to this website. This information is used, among other things, to compile video statistics, improve the user experience and prevent fraud attempts.

In some cases, further data processing operations may be triggered after the start of a YouTube video over which we have no control.

YouTube is used in the interest of providing an appealing presentation of our website. This constitutes a legitimate interest within the meaning of Art. 6(1) point (f) GDPR. Insofar as corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1) point (a) GDPR and Section 25(1) TTDSG, provided that the consent includes the storage of cookies or access to information on the user’s end device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent may be revoked at any time.

For more information about privacy on YouTube, please see its privacy policy at: https://policies.google.com/privacy?hl=en.

Vimeo

Certain websites use plugins from the video portal Vimeo. The provider is Vimeo Inc, 555 West 18th Street, New York, New York 10011, USA.

When you visit one of our pages that includes a Vimeo video, a connection to the Vimeo servers is established. This tells the Vimeo server which of our pages you have visited. Vimeo also obtains your IP address. This applies even if you are not logged in to Vimeo or do not have an account with Vimeo. The information collected by Vimeo is transmitted to the Vimeo server in the USA.

If you are logged in to your Vimeo account, you enable Vimeo to associate your browsing behaviour directly with your personal profile. You can prevent this by logging out of your Vimeo account.

Vimeo uses cookies or similar recognition technologies (e.g. device fingerprinting) to recognise website visitors.

The use of Vimeo is in the interest of providing an appealing presentation of our website. This constitutes a legitimate interest within the meaning of Art. 6(1) point (f) GDPR. Insofar as corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1) point (a) GDPR and Section 25(1) TTDSG, provided that the consent includes the storage of cookies or access to information on the user’s end device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent may be revoked at any time.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission and, according to Vimeo, on “legitimate business interests”. Details can be found here: https://vimeo.com/privacy.

Further information on the handling of user data can be found in Vimeo’s privacy policy at: https://vimeo.com/privacy.

Adobe Fonts

Some websites use web fonts from Adobe for uniform display of certain fonts. The provider is Adobe Systems Incorporated, 345 Park Avenue, San Jose, CA 95110-2704, USA (Adobe).

When you access this website, your browser loads the required fonts directly from Adobe so that they can be displayed correctly on your end device. In doing so, your browser establishes a connection to Adobe servers in the USA. This informs Adobe of the IP address you have used to access this website. According to Adobe, no cookies are stored when providing the fonts.

Storage and analysis of the data is based on Art. 6(1) point (f) GDPR. The website operator has a legitimate interest in uniform presentation of the typeface on the website. Insofar as corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1) point (a) GDPR and Section 25(1) TTDSG, provided that the consent includes the storage of cookies or access to information on the user’s end device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent may be revoked at any time.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.adobe.com/de/privacy/eudatatransfers.html.

For more information on Adobe Fonts, please visit: https://www.adobe.com/de/privacy/policies/adobe-fonts.html.

You can find Adobe’s privacy policy at: https://www.adobe.com/uk/privacy/policy.html

Google Maps

On certain web pages we use the Google Maps map service. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

To use the functions of Google Maps, it is necessary to save your IP address. This information is usually transferred to a Google server in the USA and stored there. The provider of this site has no control over this data transmission. If Google Maps is activated, Google may use Google Fonts for the purpose of uniform display of fonts. When you access Google Maps, your browser loads the required web fonts to your browser cache in order to display texts and fonts correctly.

Google Maps is used in the interest of providing an appealing presentation of our website and to make it easy to find the places we mention on the website. This constitutes a legitimate interest within the meaning of Art. 6(1) point (f) GDPR. Insofar as corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1) point (a) GDPR and Section 25(1) TTDSG, provided that the consent includes the storage of cookies or access to information on the user’s end device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent may be revoked at any time.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://privacy.google.com/businesses/gdprcontrollerterms/ and https://privacy.google.com/businesses/gdprcontrollerterms/sccs/.

More information about the handling of user data can be found in Google’s privacy policy: https://policies.google.com/privacy?hl=en.

Google reCAPTCHA

We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on certain web pages on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

The purpose of reCAPTCHA is to check whether the data input on this website (e.g. on a contact form) is made by a human or by an automated program. For this purpose, reCAPTCHA analyses the behaviour of the website visitor on the basis of various characteristics. This analysis begins automatically as soon as the website visitor accesses the website. For analysis purposes, reCAPTCHA evaluates various pieces of information (e.g. IP address, time spent by the website visitor on the website and mouse movements made by the user). The data collected during the analysis is forwarded to Google.

The reCAPTCHA analyses run entirely in the background. Website visitors are not made aware that analysis is taking place.

Storage and analysis of the data is based on Art. 6(1) point (f) GDPR. The website operator has a legitimate interest in protecting its website from misuse as a result of automated spying and SPAM. Insofar as corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1) point (a) GDPR and Section 25(1) TTDSG, provided that the consent includes the storage of cookies or access to information on the user’s end device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent may be revoked at any time.

For more information about Google reCAPTCHA, please see the Google Privacy Policy and the Google Terms of Service at the following links: https://policies.google.com/privacy?hl=de and https://policies.google.com/terms?hl=en.

10 Online-based communication (conference tools etc.)

Data processing

Among other things, we use online conference tools to communicate with our customers. The individual tools we use are listed below. If you communicate with us by video or audio conference over the internet, your personal data is collected and processed by us and the provider of the respective conference tool.

The conference tools collect all the data that you provide/enter to use the tools (email address and/or your telephone number). Furthermore, the conference tools process the duration of the conference, start and end (time) of participation in the conference, number of participants and other “contextual information” related to the communication process (metadata).

The provider of the tool also processes all technical data required for the handling of online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or speaker and type of connection.

If content is exchanged, uploaded or otherwise made available within the tool, this is also stored on the servers of the tool providers. Such content includes, but is not limited to, cloud recordings, chat/instant messages, voicemails, uploaded photos and videos, files, whiteboards and other information shared while using the service.

Please note that we do not have full control over the data processing operations of the tools used. Our options are largely determined by the company policy of the respective provider. For further information about data processing through conference tools, please refer to the privacy policies for the various tools used, which we have listed below.

Purpose and legal basis

The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6(1) point (b) GDPR). Furthermore, the tools are used for general simplification and acceleration of communication with us or our company (legitimate interest within the meaning of Art. 6(1) point (f) GDPR). Insofar as consent has been requested, the tools in question are used on the basis of that consent; consent may be revoked at any time with effect for the future.

Storage period

The data collected directly by us via the video and conference tools is erased from our systems as soon as you request us to do so, revoke your consent to its storage or the purpose for storing the data no longer applies. Stored cookies remain on your end device until you erase them. Statutory retention periods remain unaffected.

We have no control over the storage period for your data that is stored by the operators of the conference tools for their own purposes. For details, please contact the operators of the conference tools directly.

Conference tools used

We use the following conference tools:

Microsoft Teams

We use Microsoft Teams. The provider is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. For details about data processing, please refer to the Microsoft Teams privacy policy: https://privacy.microsoft.com/en-gb/privacystatement.

11 Our own services

Enquiry by email, telephone or fax

If you contact us by email, telephone or fax, your enquiry including all resulting personal data (name, content of the enquiry) is stored and processed by us for the purpose of dealing with your request. We do not pass on this data without your consent.

This data is processed on the basis of Art. 6(1) point (b) GDPR if your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in effective handling of the enquiries addressed to us (Art. 6(1) point (f) GDPR) or on your consent (Art. 6(1) point (a) GDPR) if this has been requested.

The data you send to us via contact requests is retained by us until you request us to erase it, revoke your consent to its storage or the purpose for storing the data no longer applies (e.g. when we have finished processing your request). Statutory provisions – in particular statutory retention periods – remain unaffected.

Postal marketing

If applicable, we use your address in compliance with all legal provisions for sending postal marketing.

The legal basis for this is our legitimate interest in direct marketing according to Art. 6(1) point (f)) GDPR. Insofar as corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1) point (a) GDPR; consent may be revoked at any time with effect for the future. More specific regulations may be communicated as part of the data collection process and take precedence over these regulations.

Your address is retained by us until the purpose for processing the data no longer applies. If you made a legitimate request for erasure or revoke your consent to postal advertising, your data will be erased unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, the data will be erased once these reasons no longer apply.

Contact via social networks (Xing, LinkedIn, Facebook etc.)

If you contact us via social networks, your request, including all personal data resulting from it (name, request), is stored and processed by us for the purpose of dealing with your enquiry. We do not pass on this data without your consent.

This data is processed on the basis of Art. 6(1) point (b) GDPR if your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on your consent (Art. 6(1) point (a) GDPR) and/or on our legitimate interests (Art. 6(1) point (f) GDPR), as we have a legitimate interest in effective handling of the enquiries addressed to us.

The data you send to us via contact requests is retained by us until you request us to erase it, revoke your consent to its storage or the purpose for storing the data no longer applies (e.g. when we have finished processing your request). Statutory provisions – in particular statutory retention periods – remain unaffected.

Competitions

Participation in competitions is on a voluntary basis. In this context, we process your personal data for the purpose of running the competition, drawing and notifying the winners and distributing the prizes.

The processing is carried out exclusively on the basis of the consent given (Art. 6(1) point (a) GDPR and Section 25(1) TTDSG); consent may be revoked at any time.

The data collected in this context is erased on completion of the competition. Legal retention periods and other legal grounds that prevent erasure remain unaffected.

Video surveillance at our locations

We operate video surveillance at certain locations.

Video surveillance is indicated at the relevant locations by appropriate signage.

Video surveillance is carried out for the purpose of ensuring compliance with house rules, preventing criminal offences and preserving evidence in the event of criminal actions.

The processing of this data is based on Art. 6(1) point (f) GDPR; the legitimate interest is derived from the purposes specified above.

The basic storage period is 3 days or the duration of any proceedings by investigating authorities.

The stored video material is passed on to investigating authorities, security services, the police or insurance companies (in the case of documented damage), as appropriate.

12 Events

Photos of the event and of participants

Images (photos, videos) may be taken at our events.

Image material of natural persons is personal data in the sense of data protection law and is also specially protected by other laws.

Visual material of publicly advertised events may be created, stored, published and otherwise used for editorial contributions or other documentation purposes on the basis of our legitimate interest pursuant to Art. 6(1) point (f) GDPR, provided that the interests of the persons depicted do not prevail.

Insofar as we obtain your consent for the creation and use of the image material for specific purposes, the processing is based on that consent in accordance with Art. 6(1) point (a) GDPR. This may be revoked at any time without giving reasons with effect for the future.

The visual material is retained by us until you request us to erase it, revoke your consent to its processing or the purpose for storing it no longer applies. Statutory provisions – in particular statutory retention periods – remain unaffected by this.

13 Tools for file exchange / secure emailing

OneDrive

We use OneDrive, including for sharing files. The provider is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland (hereinafter “OneDrive”).

OneDrive also allows us to include an upload area on a website where you can upload content, where appropriate. When you upload content, it is stored on the OneDrive servers. When you access our website, a connection to OneDrive is also established so that OneDrive can determine that you have visited it.

The use of OneDrive is based on Art. 6(1) point (f) GDPR. The website operator has a legitimate interest in providing a reliable upload area on the website. Insofar as corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1) point (a) GDPR; consent may be revoked at any time.

14 Survey tools / Surveys

Data processing

We may use online tools for surveys, etc. If you participate in a survey etc., your personal data is collected and processed by us and the provider of the respective tool.

The tools collect all the data that you provide to use the tools (survey data, your contact details if applicable). Furthermore, the tools process the duration of use, start and end (time) of participation and metadata about the communication process.

Please note that we do not have full control over the data processing operations of the tools used. Our options are largely determined by the company policy of the respective provider. For further information about data processing by the tools, please refer to the privacy policies of the tools used, which we have listed below.

Purpose and legal basis

The tools are used to obtain survey results, etc. Participation is voluntary and based on Art. 6(1) point (a) GDPR.

Consent may be revoked at any time with effect for the future.

Storage period

The data collected directly by us via the tools is erased from our systems as soon as you request us to erase it, revoke your consent to its storage or the purpose for storing the data no longer applies. Stored cookies remain on your end device until you erase them. Statutory retention periods remain unaffected.

We have no influence over the storage period of your data that is stored by the operators of the tools for their own purposes. For details, please contact the operators of the tools directly.

15 Latest version and amendment of this privacy policy

Changes and further developments of this website or other websites and services operated by us and changes in legal or official requirements may make amendments to this privacy policy necessary.

You will find the latest version of the policy on the website under the heading “Data protection” or “Privacy policy”.

Version: June 2023.