Privacy policy

This privacy policy informs you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as "data") within the framework of the provision of our services as well as within our online offering and the websites, functions and content associated with it, as well as external online presences, such as our social media profiles on Instagram or Facebook (hereinafter collectively referred to as "online offering"). With regard to the terminology used, such as "processing" or "controller", we refer to the definitions in Article 4 of theDatenschutzgrundverordnung (DSGVO).

Controller

Types of Data Processed

- Inventory data (e.g., personal master data, names or addresses).
- Contact data (e.g., email, telephone numbers).
- Content data (e.g., text entries, photographs, videos).
- Usage data (e.g., websites visited, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).

Categories of Data Subjects

Visitors and users of the online offering (hereinafter we collectively refer to the data subjects as "users").

Purpose of Processing

- Provision of the online offering, its functions and content.
- Responding to contact requests and communication with users.
- Security measures.
- Reach measurement/Marketing

Terms Used

"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. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

"Processing" means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data.

"Pseudonymisation" means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

"Profiling" means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

"Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

"Processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Relevant Legal Bases

In accordance with Article 13 DSGVO, we inform you of the legal bases of our data processing. For users from the scope of the Datenschutzgrundverordnung (DSGVO), i.e. the EU and the EEA, the following applies unless the legal basis is not mentioned in the privacy policy:
The legal basis for obtaining consent is Article 6 (1) lit. a and Article 7 DSGVO;
The legal basis for processing to fulfill our services and carry out contractual measures as well as respond to inquiries is Article 6 (1) lit. b DSGVO;
The legal basis for processing to fulfill our legal obligations is Article 6 (1) lit. c DSGVO;
In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6 (1) lit. d DSGVO serves as the legal basis.
The legal basis for the necessary processing for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Article 6 (1) lit. e DSGVO.
The legal basis for processing to protect our legitimate interests is Article 6 (1) lit. f DSGVO.
The processing of data for purposes other than those for which they were collected is determined according to the provisions of Article 6 (4) DSGVO.
The processing of special categories of data (according to Article 9 (1) DSGVO) is determined according to the provisions of Article 9 (2) DSGVO.

Security Measures

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

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access, input, transmission, ensuring availability and separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, deletion of data and response to data threats. In addition, we consider the protection of personal data already during the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.

Cooperation with Processors, Joint Controllers and Third Parties

If, in the context of our processing, we disclose data to other persons and companies (processors, joint controllers or third parties), transmit it to them or otherwise grant them access to the data, this is only done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as payment service providers, is necessary for contract fulfillment), users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we disclose data to other companies in our group of companies, transmit it or otherwise grant them access, this is done in particular for administrative purposes as a legitimate interest and, beyond that, on a basis that complies with legal requirements.

Transfers to Third Countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this occurs in the context of the use of third-party services or disclosure or transmission of data to other persons or companies, this only takes place if it is done to fulfill 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 express consent or contractually required transmission, we process or have the data processed only in third countries with a recognized level of data protection, including US processors certified under the "Privacy Shield", or on the basis of special guarantees, such as contractual obligation through so-called standard data protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Articles 44 to 49 DSGVO, EU Commission information page).

Rights of Data Subjects

You have the right to request confirmation as to whether relevant data is being processed and to request information about this data as well as further information and a copy of the data in accordance with legal requirements.

You have the right, in accordance with legal requirements, to request the completion of data concerning you or the correction of incorrect data concerning you.

You have the right, in accordance with legal requirements, to request that relevant data be deleted immediately or, alternatively, to request restriction of the processing of the data in accordance with legal requirements.

You have the right to request that the data concerning you that you have provided to us be received in accordance with legal requirements and to request its transmission to other controllers.

You also have the right, in accordance with legal requirements, to lodge a complaint with the competent supervisory authority.

Right to Withdraw Consent

You have the right to withdraw consent with effect for the future.

Right to Object

You may object at any time to the future processing of data concerning you in accordance with legal requirements. The objection may be made in particular against processing for direct marketing purposes.

Cookies and Right to Object to Direct Marketing

"Cookies" are small files that are stored on users' computers. Different information can be stored within the cookies. A cookie primarily serves to store information about a user (or the device on which the cookie is stored) during or after their visit to an online offering. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online offering and closes their browser. Such a cookie can store, for example, the contents of a shopping cart in an online shop or a login status. Cookies that remain stored even after the browser is closed are referred to as "permanent" or "persistent". For example, the login status can be stored if users visit them after several days. Likewise, the interests of users can be stored in such a cookie, which are used for range measurement or marketing purposes. "Third-party cookies" are cookies that are offered by providers other than the controller who operates the online offering (otherwise, if they are only their cookies, they are called "first-party cookies").

We can use temporary and permanent cookies and clarify this in our privacy policy.

If we ask users for consent to use cookies (e.g. in the context of cookie consent), the legal basis for this processing is Article 6 (1) lit. a DSGVO. Otherwise, users' personal cookies are processed in accordance with the following explanations within the scope of this privacy policy on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Article 6 (1) lit. f DSGVO) or if the use of cookies is necessary to provide our contractual services, pursuant to Article 6 (1) lit. b DSGVO, or if the use of cookies is necessary for the performance of a task carried out in the public interest or in the exercise of official authority, pursuant to Article 6 (1) lit. e DSGVO.

If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies may lead to functional restrictions of this online offering.

A general objection to the use of cookies used for online marketing purposes can be declared for a variety of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that in this case, not all functions of this online offering may be available.

Deletion of Data

The data processed by us will be deleted or restricted in their processing in accordance with legal requirements. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their purpose and the deletion does not conflict with any statutory retention obligations.

If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

Changes and Updates to the Privacy Policy

We ask you to regularly inform yourself about the content of our privacy policy. We adapt the privacy policy as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

Business-Related Processing

Additionally, we process
- Contract data (e.g., subject matter of contract, term, customer category).
- Payment data (e.g., bank details, payment history)
of our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.

Order Processing in the Online Shop and Customer Account

We process the data of our customers within the framework of the ordering processes in our online shop to enable them to select and order the selected products and services, as well as their payment and delivery or execution.

The processed data includes inventory data, communication data, contract data, payment data and the persons affected by the processing include our customers, prospects and other business partners. The processing is carried out for the purpose of providing contractual services within the framework of operating an online shop, billing, delivery and customer services. For this purpose, we use session cookies for storing the shopping cart contents and permanent cookies for storing the login status.

The processing is carried out to fulfill our services and carry out contractual measures (e.g. carrying out ordering processes) and insofar as it is required by law (e.g., legally required archiving of business transactions for commercial and tax purposes). The information marked as required is necessary for the establishment and fulfillment of the contract. We only disclose the data to third parties within the framework of delivery, payment or within the framework of legal permissions and obligations, as well as if this is done on the basis of our legitimate interests, about which we inform you within the framework of this privacy policy (e.g., to legal and tax advisors, financial institutions, freight companies and authorities).

Users can optionally create a user account, in which they can view their orders in particular. As part of the registration, the required mandatory information is communicated to users. User accounts are not public and cannot be indexed by search engines. If users have cancelled their user account, their data with regard to the user account will be deleted, subject to their retention being necessary for commercial or tax law reasons. Information in the customer account remains until its deletion with subsequent archiving in the case of a legal obligation or our legitimate interests (e.g., in case of legal disputes). It is the users' responsibility to secure their data upon termination before the end of the contract.

As part of registration and re-login as well as use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user's interest in protection against misuse and other unauthorized use. As a rule, this data is not passed on to third parties unless it is necessary to pursue our legitimate legal claims or there is a legal obligation to do so.

Deletion takes place after expiry of statutory warranty and other contractual rights or obligations (e.g., payment claims or performance obligations from contracts with customers), whereby the necessity of retaining the data is reviewed every three years; in the case of retention due to statutory archiving obligations, deletion takes place after their expiry.

External Payment Service Providers

We use external payment service providers through whose platforms users and we can conduct payment transactions. These payment service providers may include, each with a link to their privacy policy: Paypal (https://www.paypal.com/us/webapps/mpp/ua/privacy-full), Klarna (https://www.klarna.com/international/privacy-policy/), Skrill (https://www.skrill.com/en/footer/privacy-policy/), Giropay (https://www.giropay.de/legal/privacy-policy/), Visa (https://www.visa.com/legal/privacy-policy.html), Mastercard (https://www.mastercard.us/en-us/about-mastercard/what-we-do/privacy.html), American Express (https://www.americanexpress.com/us/legal-disclosures/online-privacy-statement.html), Stripe (https://stripe.com/privacy).

As part of the fulfillment of contracts, we use payment service providers on the basis of Article 6 (1) lit. b DSGVO. Otherwise, we use external payment service providers on the basis of our legitimate interests pursuant to Article 6 (1) lit. f DSGVO in order to offer our users effective and secure payment options.

The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related information. The information is necessary to carry out the transactions. However, the entered data is only processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, but only information confirming or negatively confirming the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the terms and conditions and privacy notices of the payment service providers.

The terms and conditions and privacy notices of the respective payment service providers apply to payment transactions, which can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and assertion of revocation, information and other data subject rights.

Administration, Financial Accounting, Office Organization, Contact Management

We process data in the context of administrative tasks as well as organization of our operations, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the context of providing our contractual services. The processing bases are Article 6 (1) lit. c DSGVO, Article 6 (1) lit. f DSGVO. Customers, prospects, business partners and website visitors are affected by the processing. The purpose and our interest in processing lies in administration, financial accounting, office organization, archiving of data, i.e. tasks that serve to maintain our business activities, perform our tasks and provide our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information provided for these processing activities.

We disclose or transmit data to the tax authorities, consultants such as tax consultants or auditors as well as other fee offices and payment service providers.

Furthermore, based on our business interests, we store information about suppliers, event organizers and other business partners, e.g. for the purpose of later contact. We generally store this predominantly company-related data permanently.

Business Analysis and Market Research

In order to operate our business economically and to be able to recognize market trends, wishes of contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc. We process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Article 6 (1) lit. f DSGVO, whereby the data subjects include contractual partners, prospects, customers, visitors and users of our online offering.

The analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we may take into account the profiles of registered users with information, e.g. on the services they have used. The analyses serve us to increase user-friendliness, optimize our offering and business efficiency. The analyses serve us alone and are not disclosed externally unless they are anonymous analyses with aggregated values.

If these analyses or profiles are personal, they will be deleted or anonymized upon termination by users, otherwise after two years from conclusion of the contract. Furthermore, the overall business analyses and general trend determinations are created anonymously if possible.

Participation in Affiliate Partner Programs

Within our online offering, we use industry-standard tracking measures on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering) pursuant to Article 6 (1) lit. f DSGVO insofar as these are necessary for the operation of the affiliate system. In the following, we inform users about the technical background.

The services offered by our contractual partners can also be advertised and linked on other websites (so-called affiliate links or after-buy systems, if, for example, links or services of third parties are offered after conclusion of a contract). The operators of the respective websites receive a commission if users follow the affiliate links and subsequently make use of the offers.

In summary, it is necessary for our online offering that we can track whether users who are interested in affiliate links and/or the offers available with us subsequently make use of the offers on the initiative of the affiliate links or our online platform. For this purpose, the affiliate links and our offers are supplemented by certain values that can be a component of the link or otherwise, e.g. set in a cookie. The values include in particular the originating website (referrer), time, an online identifier of the operators of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as tracking-specific values such as advertising material ID, partner ID and categorizations.

The online identifiers of users that we use are pseudonymous values. This means that the online identifiers themselves do not contain any personal data such as names or email addresses. They only help us determine whether the same user who clicked on an affiliate link or was interested in an offer through our online offering has made use of the offer, i.e. for example concluded a contract with the provider. However, the online identifier is personal insofar as the partner company and we have the online identifier together with other user data. Only in this way can the partner company inform us whether that user has made use of the offer and we can, for example, pay out the bonus.

Contact

When contacting us (e.g. via contact form, email, telephone or via social media), the user's information is processed for handling the contact request and its processing pursuant to Article 6 (1) lit. b (in the context of contractual/pre-contractual relationships), Article 6 (1) lit. f (other inquiries) DSGVO. The user's information may be stored in a Customer Relationship Management System ("CRM System") or comparable inquiry organization.

We delete the inquiries if they are no longer necessary. We review the necessity every two years; furthermore, statutory archiving obligations apply.

Newsletter

With the following information, we inform you about the content of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your right to object. By subscribing to our newsletter, you agree to receive it and the procedures described.

Content of the newsletter: We send newsletters, emails and other electronic notifications with advertising information (hereinafter "newsletter") only with the consent of the recipients or legal permission. If the content of the newsletter is specifically described during registration for the newsletter, it is decisive for the users' consent. Otherwise, our newsletters contain information about our services and us.

Double opt-in and logging: Registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registration you will receive an email in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with someone else's email addresses. Registrations for the newsletter are logged in order to prove the registration process in accordance with legal requirements. This includes storing the registration and confirmation time, as well as the IP address. Changes to your data stored with the dispatch service provider are also logged.

Registration data: To register for the newsletter, it is sufficient to provide your email address. Optionally, we ask you to provide a name for personal address in the newsletter.

The dispatch of the newsletter and the success measurement associated with it are carried out on the basis of the recipients' consent pursuant to Article 6 (1) lit. a, Article 7 DSGVO in conjunction with § 7 (2) No. 3 UWG or, if consent is not required, on the basis of our legitimate interests in direct marketing pursuant to Article 6 (1) lit. f DSGVO in conjunction with § 7 (3) UWG.

The logging of the registration procedure is carried out on the basis of our legitimate interests pursuant to Article 6 (1) lit. f DSGVO. Our interest is directed towards using a user-friendly and secure newsletter system that serves both our business interests and meets users' expectations and also allows us to prove consent.

Cancellation/Revocation - You can cancel receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. We may store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.

Hosting and Email Dispatch

The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, email dispatch, security services and technical maintenance services that we use for the purpose of operating this online offering.

In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, prospects and visitors to this online offering on the basis of our legitimate interests in an efficient and secure provision of this online offering pursuant to Article 6 (1) lit. f DSGVO in conjunction with Article 28 DSGVO (conclusion of data processing agreement).

Collection of Access Data and Log Files

We, or our hosting provider, collect data on every access to the server on which this service is located (so-called server log files) on the basis of our legitimate interests within the meaning of Article 6(1)(f) GDPR. Access data includes the name of the accessed website, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for security reasons (e.g. to investigate abuse or fraud) for a maximum period of 7 days and then deleted. Data whose further retention is required for evidence purposes is exempt from deletion until final clarification of the respective incident.