Privacy Policy
Introduction and Overview
We have written this privacy statement (version 02/16/2022-311947292) in order to explain to you, in accordance with the requirements of the General Data Protection Regulation (EU) 2016/679 and applicable national laws, which personal data (data for short) we as the controller – and the processors (e.g. providers) commissioned by us – process, will process in the future and what lawful options you have. The terms used are to be understood as gender-neutral.
In short, we inform you comprehensively about data we process about you.
Privacy statements usually sound very technical and use legal terminology. This privacy statement, on the other hand, is intended to describe the most important things to you as simply and transparently as possible. To the extent that it is conducive to transparency, technical terms are explained in a reader-friendly manner, links to further information are provided and graphics are used. In this way, we inform you in clear and simple language that we only process personal data in the course of our business activities if there is a corresponding legal basis. This is certainly not possible by providing the most concise, unclear and legalistic explanations possible, as is often standard practice on the Internet when it comes to data protection. I hope you find the following explanations interesting and informative, and perhaps there is one or two pieces of information that you did not yet know.
If you still have questions, we would like to ask you to contact the responsible party named below or in the imprint, to follow the links provided and to look at further information on third-party sites. Our contact details can of course also be found in the imprint.
Scope of application
This data protection declaration applies to all personal data processed by us in the company and to all personal data processed by companies commissioned by us (order processors). By personal data, we mean information within the meaning of Art. 4 No. 1 DSGVO, such as a person’s name, e-mail address and postal address. The processing of personal data ensures that we can offer and invoice our services and products, whether online or offline. The scope of this privacy policy includes:
all online presences (websites, online stores) that we operate
social media presences and email communications
mobile apps for smartphones and other devices
In short, the data protection declaration applies to all areas in which personal data is processed in the company via the aforementioned channels in a structured manner. If we enter into legal relationships with you outside of these channels, we will inform you separately if necessary.
Legal basis
In the following privacy statement, we provide you with transparent information on the legal principles and regulations, i.e. the legal bases of the General Data Protection Regulation, which enable us to process personal data.
As far as EU law is concerned, we refer to REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016, which you can of course read online on EUR-Lex, the access to EU law, at https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=celex%3A32016R0679.
We only process your data if at least one of the following conditions applies:
Consent (Article 6(1)(a) DSGVO): You have given us your consent to process data for a specific purpose. An example would be the storage of your entered data of a contact form.
Contract (Article 6(1) lit. b) DSGVO): In order to fulfill a contract or pre-contractual obligations with you, we process your data. For example, if we conclude a purchase contract with you, we need personal information in advance.
Legal obligation (Article 6(1)(c) DSGVO): If we are subject to a legal obligation, we process your data. For example, we are legally obliged to keep invoices for accounting purposes. These usually contain personal data.
Legitimate interests (Article 6(1)(f) DSGVO): In the case of legitimate interests that do not restrict your fundamental rights, we reserve the right to process personal data. For example, we need to process certain data in order to operate our website in a secure and economically efficient manner. This processing is therefore a legitimate interest.
Other conditions, such as the performance of recordings in the public interest and the exercise of official authority, as well as the protection of vital interests, do not generally arise for us. If such a legal basis should nevertheless be relevant, it will be indicated at the appropriate place.
In addition to the EU Regulation, national laws also apply:
In Austria, this is the Federal Act on the Protection of Individuals with regard to the Processing of Personal Data (Data Protection Act), or DSG for short.
In Germany, the Federal Data Protection Act, or BDSG for short, applies.
If other regional or national laws apply, we will inform you about them in the following sections.
Contact details of the person responsible
If you have any questions regarding data protection, please find below the contact details of the responsible person or office:
flowciety GmbH
Edisonstraße 52, 12459 Berlin, Germany
e-mail: info@flowciety.de
phone: 0049 30 32 599 858
Imprint: https://www.flowciety.de/imprint/
Storage period
The fact that we only store personal data for as long as is absolutely necessary for the provision of our services and products applies as a general criterion at our company. This means that we delete personal data as soon as the reason for processing the data no longer exists. In some cases, we are required by law to store certain data even after the original purpose has ceased to exist, for example for accounting purposes.
Should you wish your data to be deleted or revoke your consent to data processing, the data will be deleted as soon as possible and insofar as there is no obligation to store it.
We will inform you about the specific duration of the respective data processing below, provided we have further information on this.
Rights according to the General Data Protection Regulation
According to Article 13 DSGVO, you are entitled to the following rights to ensure that data is processed fairly and transparently:
According to Article 15 DSGVO, you have the right to information about whether we are processing data about you. If this is the case, you have the right to receive a copy of the data and to know the following information:
For what purpose we are processing;
the categories, i.e. the types of data that are processed;
who receives this data and if the data is transferred to third countries, how security can be guaranteed;
how long the data will be stored;
the existence of the right to rectification, erasure or restriction of processing and the right to object to processing;
that you can lodge a complaint with a supervisory authority (links to these authorities can be found below);
The origin of the data if we have not collected it from you;
Whether profiling is carried out, i.e. whether data is automatically evaluated to arrive at a personal profile of you.
You have a right to rectification of data according to Article 16 GDPR, which means that we must correct data if you find errors.
You have the right to erasure (“right to be forgotten”) according to Article 17 GDPR, which specifically means that you may request the deletion of your data.
According to Article 18 of the GDPR, you have the right to restriction of processing, which means that we may only store the data but not use it further.
According to Article 19 of the GDPR, you have the right to data portability, which means that we will provide you with your data in a common format upon request.
According to Article 21 DSGVO, you have the right to object, which entails a change in processing after enforcement.
If the processing of your data is based on Article 6(1)(e) (public interest, exercise of official authority) or Article 6(1)(f) (legitimate interest), you may object to the processing. We will then check as soon as possible whether we can legally comply with this objection.
If data is used to conduct direct advertising, you may object to this type of data processing at any time. We may then no longer use your data for direct marketing.
If data is used to conduct profiling, you may object to this type of data processing at any time. We may no longer use your data for profiling thereafter.
According to Article 22 of the GDPR, you may have the right not to be subject to a decision based solely on automated processing (for example, profiling).
In short, you have rights – do not hesitate to contact the controller listed above with us!
If you believe that the processing of your data violates data protection law or your data protection rights have been violated in any other way, you can complain to the supervisory authority. For Austria, this is the data protection authority, whose website can be found at https://www.dsb.gv.at/. In Germany, there is a data protection officer for each federal state. For more information, you can contact the Federal Commissioner for Data Protection and Freedom of Information (BfDI). The following local data protection authority is responsible for our company:
Berlin Data Protection Authority
State Commissioner for Data Protection: Maja Smoltczyk
Address: Friedrichstrasse 219, 10969 Berlin
Telephone: 030/138 89-0
E-mail address: mailbox@datenschutz-berlin.de
Website: https://www.datenschutz-berlin.de/
Data transfer to third countries
We only transfer or process data to countries outside the EU (third countries) if you consent to this processing, if this is required by law or contractually necessary, and in any case only to the extent that this is generally permitted. Your consent is in most cases the most important reason that we have data processed in third countries. Processing personal data in third countries such as the U.S., where many software vendors provide services and have their server locations, may mean that personal data is processed and stored in unexpected ways.
We explicitly point out that according to the opinion of the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. Data processing by US services (such as Google Analytics) may result in data not being processed and stored anonymously, where applicable. Furthermore, US government authorities may be able to access individual data. In addition, it may happen that collected data is linked with data from other services of the same provider, if you have a corresponding user account. Where possible, we try to use server locations within the EU, if this is offered.
We will inform you in more detail about data transfer to third countries, if applicable, at the appropriate places in this privacy policy.
Security of data processing
To protect personal data, we have implemented both technical and organizational measures. Where possible, we encrypt or pseudonymize personal data. In this way, we make it as difficult as possible, within the scope of our possibilities, for third parties to infer personal information from our data.
Article 25 of the GDPR refers to “data protection by technical design and by data protection-friendly default settings” and thus means that both software (e.g., forms) and hardware (e.g., access to the server room) should always be designed with security in mind and that appropriate measures should be taken. In the following, we will go into more detail on specific measures, if necessary.
Communication
Communication Summary
👥 Affected parties: Everyone who communicates with us by phone, e-mail, or online form.
📓 Data processed: e.g. telephone number, name, e-mail address, form data entered. You can find more details on this in the respective contact type used.
🤝 Purpose: Handling of communication with customers, business partners, etc.
📅 Storage period: Duration of the business case and legal requirements.
⚖️ Legal basis: Art. 6 para. 1 lit. a DSGVO (consent), Art. 6 para. 1 lit. b DSGVO (contract), Art. 6 para. 1 lit. f DSGVO (legitimate interests).
If you contact us and communicate by phone, e-mail or online form, personal data may be processed.
The data is processed for the handling and processing of your question and the related business transaction. The data during stored just as long or as long as required by law.
Persons affected
All those who seek contact with us via the communication channels provided by us are affected by the aforementioned processes.
Telephone
When you call us, the call data is stored pseudonymously on the respective terminal device and with the telecommunications provider used. In addition, data such as name and telephone number may subsequently be sent by e-mail and stored for the purpose of responding to your inquiry. The data is deleted as soon as the business case has been closed and legal requirements permit.
If you communicate with us by e-mail, data may be stored on the respective end device (computer, laptop, smartphone,…) and data is stored on the e-mail server. The data will be deleted as soon as the business case has been closed and legal requirements allow it.
Online forms
If you communicate with us using online forms, data is stored on our web server and may be forwarded to an e-mail address of ours. The data will be deleted as soon as the business case has been terminated and legal requirements permit.
Legal basis
The processing of data is based on the following legal bases:
Art. 6 para. 1 lit. a DSGVO (consent): You give us your consent to store your data and to further use it for purposes related to the business case;
Art. 6 (1) lit. b DSGVO (contract): there is a need for the performance of a contract with you or a processor such as the telephone provider or we need to process the data for pre-contractual activities, such as the preparation of an offer;
Art. 6 para. 1 lit. f DSGVO (Legitimate Interests): we want to operate customer inquiries and business communication in a professional framework. For this purpose, certain technical facilities such as e-mail programs, exchange servers and mobile operators are necessary in order to be able to operate the communication efficiently.
Web hosting introduction
Web hosting summary
👥 Parties concerned: Visitors to the website.
🤝 Purpose: professional hosting of the website and securing its operation.
📓 Processed data: IP address, time of website visit, browser used and other data. More details can be found below or with the respective web hosting provider used.
📅 Storage period: depending on the respective provider, but usually 2 weeks.
⚖️ Legal basis: Art. 6 para. 1 lit.f DSGVO (Legitimate Interests).
What is web hosting?
When you visit websites these days, certain information – including personal data – is automatically created and stored, including on this website. This data should be processed as sparingly as possible and only with justification. By website, by the way, we mean the entirety of all web pages on a domain, i.e. everything from the home page (homepage) to the very last subpage (like this one). By domain, we mean, for example, example.de or sampleexample.com.
If you want to view a website on a screen, you use a program called a web browser to do it. You probably know some web browsers by name: Google Chrome, Microsoft Edge, Mozilla Firefox, and Apple Safari.
This web browser needs to connect to another computer where the website’s code is stored: the web server. Running a web server is a complicated and costly task, which is why this is usually done by professional providers, the providers. These offer web hosting and thus ensure reliable and error-free storage of website data.
When the browser on your computer (desktop, laptop, smartphone) connects and during data transfer to and from the web server, personal data may be processed. On the one hand, your computer stores data, on the other hand, the web server also needs to store data for a while to ensure proper operation.
Why do we process personal data?
The purposes of data processing are:
Professional hosting of the website and securing its operation.
To maintain operational and IT security
Anonymous evaluation of access behavior to improve our offer and, if necessary, for law enforcement or prosecution of claims.
What data is processed?
Even while you are visiting our website right now, our web server, which is the computer on which this website is stored, usually automatically stores data such as
the complete Internet address (URL) of the website you are visiting
browser and browser version (e.g. Chrome 87)
the operating system used (e.g. Windows 10)
the address (URL) of the previously visited page (referrer URL) (e.g. https://www.beispielquellsite.de/vondabinichgekommen.html/)
the host name and IP address of the device being accessed (e.g. COMPUTERNAME and 194.23.43.121)
date and time
in files, the so-called web server log files
How long is data stored?
As a rule, the above data is stored for two weeks and then automatically deleted. We do not pass on this data, but we cannot rule out the possibility that this data may be viewed by the authorities in the event of unlawful conduct.
In short, your visit is logged by our provider (company that runs our website on special computers (servers)), but we do not share your data without your consent!
Legal basis
The lawfulness of the processing of personal data in the context of web hosting results from Art. 6 para. 1 lit. f DSGVO (protection of legitimate interests), because the use of professional hosting with a provider is necessary to present the company on the Internet in a secure and user-friendly manner and to be able to pursue attacks and claims from this if necessary.
Between us and the hosting provider there is usually a contract on commissioned processing pursuant to Art. 28 f. DSGVO, which ensures compliance with data protection and guarantees data security.
Website Building Block Systems Introduction
Website Building Block Systems Privacy Policy Summary
👥 Data subjects: Visitors to the website
🤝 Purpose: Optimization of our service performance.
📓 Processed data: Data such as technical usage information like browser activity, clickstream activity, session heatmaps, as well as contact details, IP address or your geographical location. More details can be found below in this privacy policy and in the privacy policy of the providers.
📅 Storage duration: depends on the provider.
⚖️ Legal basis: Art. 6 para. 1 lit. f DSGVO (Legitimate Interests), Art. 6 para. 1 lit. a DSGVO (Consent).
What are website building systems?
We use a website construction kit system for our website. Modular systems are special forms of a content management system (CMS). With a modular system, website operators can create a website very easily and without programming knowledge. In many cases, web hosts also offer building block systems. By using a modular system, personal data of you may also be collected, stored and processed. In this data protection text, we provide you with general information about data processing by modular systems. You can find more detailed information in the provider’s data protection statements.
Why do we use website building block systems for our website?
The biggest advantage of a modular system is its ease of use. We want to provide you with a clear, simple and concise website that we can easily operate and maintain ourselves – without external support. In the meantime, a modular system offers many helpful functions that we can use even without programming knowledge. This allows us to design our web presence according to our wishes and to offer you an informative and pleasant time on our website.
What data is stored by a modular system?
Exactly what data is stored depends, of course, on the website construction kit system used. Each provider processes and collects different data of the website visitor. However, as a rule, technical usage information such as operating system, browser, screen resolution, language and keyboard settings, hosting provider and the date of your website visit are collected. Furthermore, tracking data (e.g. browser activity, clickstream activity, session heatmaps, etc.) may also be processed. In addition, personal data may also be collected and stored. This is mostly contact data such as e-mail address, telephone number (if you have provided it), IP address and geographical location data. You can find out exactly what data is stored in the provider’s privacy policy.
How long and where is the data stored?
We will inform you about the duration of data processing below in connection with the website construction kit system used, provided we have further information on this. You can find detailed information about this in the provider’s privacy policy. In general, we only process personal data for as long as is absolutely necessary for the provision of our services and products. It may be that the provider stores data from you according to its own specifications, over which we have no control.
Right of objection
You always have the right to information, correction and deletion of your personal data. If you have any questions, you can also contact the person responsible for the website construction system used at any time. Contact details can be found either in our privacy policy or on the website of the relevant provider.
You can delete, deactivate or manage cookies that providers use for their functions in your browser. Depending on which browser you use, this works in different ways. Please note, however, that all functions may then no longer work as usual.
Legal basis
We have a legitimate interest in using a website construction kit system to optimize our online service and present it efficiently and in a user-friendly manner for you. The corresponding legal basis for this is Art. 6 para. 1 lit. f DSGVO (Legitimate Interests). Nevertheless, we only use the construction kit insofar as you have given your consent.
Insofar as the processing of data is not absolutely necessary for the operation of the website, the data will only be processed on the basis of your consent. This applies in particular to tracking activities. The legal basis in this respect is Art. 6 para. 1 lit. a DSGVO.
With this privacy policy, we have brought you closer to the most important general information around data processing. If you would like more detailed information in this regard, you will find further information – if available – in the following section or in the provider’s privacy policy.
WordPress.com Privacy Policy
We use WordPress.com, a website building system, for our website. The service provider is the American company Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA.
WordPress also processes data from you in the USA, among other places. We would like to point out that according to the opinion of the European Court of Justice, there is currently no adequate level of protection for the transfer of data to the USA. This may be accompanied by various risks to the legality and security of data processing.
As a basis for data processing with recipients located in third countries (outside the European Union, Iceland, Liechtenstein, Norway, thus especially in the USA) or a data transfer there, WordPress uses so-called standard contractual clauses (= Art. 46. para. 2 and 3 DSGVO). Standard Contractual Clauses (SCC) are templates provided by the EU Commission and are intended to ensure that your data complies with European data protection standards even if it is transferred to third countries (such as the USA) and stored there. Through these clauses, WordPress undertakes to comply with the European level of data protection when processing your relevant data, even if the data is stored, processed and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding standard contractual clauses here, among other places: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de
The Data Processing Agreements, which correspond to the standard contractual clauses, can be found at https://wordpress.com/support/data-processing-agreements/.
To learn more about the data processed through the use of WordPress.com, please see the Privacy Policy at https://automattic.com/de/privacy/.
Amazon Web Services Privacy Policy
We use for our cloud service Amazon Web Services (AWS), among others a web hosting provider. Service provider is the American company Amazon Web Services, Inc, 410 Terry Avenue North, Seattle WA 98109, USA.
Amazon also processes data from you in the USA, among other places. We would like to point out that according to the opinion of the European Court of Justice (ECJ), there is currently no adequate level of protection for the transfer of data to the USA. This may be accompanied by various risks to the legality and security of data processing.
As a basis for data processing with recipients located in third countries (outside the European Union, Iceland, Liechtenstein, Norway, thus especially in the USA) or a data transfer there, WordPress uses so-called standard contractual clauses (= Art. 46. para. 2 and 3 DSGVO). Standard Contractual Clauses (SCC) are templates provided by the EU Commission and are intended to ensure that your data complies with European data protection standards even if it is transferred to third countries (such as the USA) and stored there. Through these clauses, Amazon undertakes to comply with the European level of data protection when processing your relevant data, even if the data is stored, processed and managed in the US. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding standard contractual clauses here, among other places: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de
You can find the Amazon Data Processing Term (AWS GDPR DATA PROCESSING), which corresponds to the standard contractual clauses, at https://d1.awsstatic.com/legal/aws-gdpr/AWS_GDPR_DPA.pdf.
To learn more about the data processed through the use of Amazon Web Services (AWS), please see the Privacy Policy at https://aws.amazon.com/de/privacy.
Matomo Privacy Policy
We use Matomo, a website analytics software, on our website. The service provider is the New Zealand company InnoCraft Ltd, 7 Waterloo Quay PO625, 6140 Wellington, New Zealand. You can learn more about the data processed through the use of Matomo in the Privacy Policy at https://matomo.org/privacy-policy/ . Questions about privacy can be directed by email to privacy@matomo.org.
Email Marketing Introduction
Email marketing summary
👥 Data subjects: newsletter subscribers
🤝 Purpose: direct advertising by e-mail, notification of system-relevant events.
📓 Data processed: Data entered during registration but at least the e-mail address. More details can be found with the respective e-mail marketing tool used.
📅 Storage period: Duration of the existence of the subscription.
⚖️ Legal basis: Art. 6 para. 1 lit. a DSGVO (consent), Art. 6 para. 1 lit. f DSGVO (legitimate interests).
What is email marketing?
In order to keep you up to date, we also use the option of e-mail marketing. In doing so, if you have agreed to receive our emails or newsletters, data from you will also be processed and stored. E-mail marketing is a sub-area of online marketing. It involves sending news or general information about a company, products or services by e-mail to a specific group of people who are interested in them.
If you want to participate in our e-mail marketing (usually via newsletter), you usually just have to register with your e-mail address. To do this, you fill out an online form and submit it. However, it may also happen that we ask you for your title and name, for example, so that we can write to you personally.
In principle, the registration for newsletters works with the help of the so-called “double opt-in procedure”. After you have registered for our newsletter on our website, you will receive an e-mail to confirm your newsletter registration. This ensures that the e-mail address belongs to you and that no one has registered with a third-party e-mail address. We or a notification tool we use logs each individual subscription. This is necessary so that we can also prove the legally correct registration process. As a rule, the time of registration, the time of the registration confirmation and your IP address are stored. In addition, it is also logged when you make changes to your stored data.
Why do we use e-mail marketing?
We naturally want to stay in touch with you and always present you with the most important news about our company. To do this, we use, among other things, e-mail marketing – often just referred to as “newsletters” – as an essential part of our online marketing. If you agree to it or if it is permitted by law, we will send you newsletters, system e-mails or other notifications by e-mail. When we use the term “newsletter” in the following text, we mainly mean regularly sent e-mails. Of course, we do not want to bother you in any way with our newsletters. That’s why we really always try to provide only relevant and interesting content. For example, you will learn more about our company, our services or products. Since we are always improving our offers, our newsletter will also tell you when there is news or when we are offering special, lucrative promotions. If we use a service provider that offers a professional mailing tool for our e-mail marketing, we do so in order to be able to offer you fast and secure newsletters. The purpose of our email marketing is basically to inform you about new offers and also to get closer to our business goals.
What data is processed?
When you become a subscriber to our newsletter via our website, you confirm by email that you are a member of an email list. In addition to IP address and e-mail address, your salutation, name, address and telephone number may also be stored. However, only if you agree to this data storage. The data marked as such are necessary for you to participate in the service offered. Providing this information is voluntary, but failure to provide it will result in you not being able to use the service. In addition, information about your device or your preferred content on our website may be stored. You can find out more about the storage of data when you visit a website in the section “Automatic data storage”. We record your declaration of consent so that we can always prove that this complies with our laws.
Duration of data processing
If you unsubscribe your email address from our email/newsletter distribution list, we may store your address for up to three years based on our legitimate interests so that we can still prove your consent at the time. We may only process this data if we need to defend ourselves against any claims.
However, if you confirm that you have given us your consent to subscribe to the newsletter, you can submit an individual deletion request at any time. If you permanently object to the consent, we reserve the right to store your e-mail address in a blacklist. As long as you have voluntarily subscribed to our newsletter, we will of course also keep your e-mail address.
Right of objection
You have the possibility to cancel your newsletter subscription at any time. All you have to do is revoke your consent to the newsletter subscription. This usually takes only a few seconds or one or two clicks. Most of the time, you will find a link to cancel your newsletter subscription right at the end of each email. If you really can’t find the link in the newsletter, please contact us by mail and we will cancel your newsletter subscription immediately.
Legal basis
The sending of our newsletter is based on your consent (Article 6 (1) a DSGVO). This means that we may only send you a newsletter if you have actively signed up for it beforehand. If applicable, we may also send you advertising messages on the basis of Section 7 (3) of the German Unfair Competition Act (UWG), provided that you have become our customer and have not objected to the use of your e-mail address for direct advertising.
Information on specific email marketing services and how they process personal data – if available – can be found in the following sections.
CleverReach Privacy Policy
We use CleverReach, a service for our email marketing, on our website. The service provider is the German company CleverReach GmbH & Co. KG, Schafjückenweg 2, 26180 Rastede, Germany. You can learn more about the data processed through the use of CleverReach in the Privacy Policy at https://www.cleverreach.com/de/datenschutz/.
Social Media Introduction
Social Media Privacy Policy Summary
👥 Data subjects: Visitors to the website.
🤝 Purpose: Presentation and optimization of our service, contact with visitors, interested parties, etc., advertising.
📓 Processed data: Data such as telephone numbers, email addresses, contact details, user behavior data, information about your device and your IP address.
You can find more details on this with the respective social media tool used.
📅 Storage duration: depending on the social media platforms used.
⚖️ Legal basis: Art. 6 para. 1 lit. a DSGVO (consent), Art. 6 para. 1 lit. f DSGVO (legitimate interests).
What is social media?
In addition to our website, we are also active on various social media platforms. In this context, user data may be processed so that we can target users who are interested in us via the social networks. In addition, elements of a social media platform may also be embedded directly in our website. This is the case, for example, when you click on a so-called social button on our website and are redirected directly to our social media presence. So-called social media or social media are websites and apps through which registered members can produce content, share content openly or in specific groups, and network with other members.
Why do we use social media?
For years, social media platforms have been the place where people communicate and connect online. Our social media presences allow us to bring our products and services closer to prospective customers. The social media elements embedded on our website help you to be able to switch to our social media content quickly and without complications.
The data that is stored and processed through your use of a social media channel is primarily for the purpose of being able to perform web analyses. The aim of these analyses is to be able to develop more precise and personalized marketing and advertising strategies. Depending on your behavior on a social media platform, appropriate conclusions can be drawn about your interests with the help of the evaluated data and so-called user profiles can be created. This also enables the platforms to present you with tailored advertisements. In most cases, cookies are set in your browser for this purpose, which store data about your usage behavior.
We generally assume that we remain responsible under data protection law, even if we use services of a social media platform. However, the European Court of Justice has ruled that in certain cases the operator of the social media platform may be jointly responsible with us within the meaning of Art. 26 DSGVO. Insofar as this is the case, we point this out separately and work on the basis of an agreement in this regard. The essence of the agreement is then reproduced below for the platform concerned.
Please note that when using the social media platforms or our built-in elements, data from you may also be processed outside the European Union, as many social media channels, for example Facebook or Twitter, are American companies. This may make it less easy for you to claim or enforce your rights regarding your personal data.
What data is processed?
Exactly what data is stored and processed depends on the respective provider of the social media platform. But usually it is data such as phone numbers, email addresses, data you enter in a contact form, user data such as which buttons you click, who you like or follow, when you visited which pages, information about your device and your IP address. Most of this data is stored in cookies. Especially if you yourself have a profile at the visited social media channel and are logged in, data can be linked to your profile.
All data collected via a social media platform is also stored on the servers of the providers. Thus, only the providers also have access to the data and can give you the appropriate information or make changes.
If you want to know exactly what data is stored and processed by the social media providers and how you can object to the data processing, you should carefully read the respective privacy policy of the company. Also, if you have questions about data storage and data processing or want to assert corresponding rights, we recommend that you contact the provider directly.
Duration of data processing
We will inform you about the duration of data processing below, provided we have further information on this. For example, the social media platform Facebook stores data until it is no longer needed for its own purpose. However, customer data that is matched with our own user data is already deleted within two days. In general, we only process personal data for as long as is absolutely necessary for the provision of our services and products. If it is required by law, as in the case of accounting, for example, this storage period may be exceeded.
Right of objection
You also have the right and the possibility to revoke your consent to the use of cookies or third-party providers such as embedded social media elements at any time. This works either via our cookie management tool or via other opt-out functions. For example, you can also prevent data collection through cookies by managing, disabling or deleting cookies in your browser.
Since social media tools may use cookies, we also recommend that you read our general privacy policy on cookies. To find out exactly what data is stored and processed by you, you should read the privacy statements of the respective tools.
Legal basis
If you have consented that data from you can be processed and stored by integrated social media elements, this consent is considered the legal basis for data processing (Art. 6 para. 1 lit. a DSGVO). In principle, if consent is given, your data will also be stored and processed on the basis of our legitimate interest (Art. 6 (1) (f) DSGVO) in fast and good communication with you or other customers and business partners. Nevertheless, we only use the tools insofar as you have given your consent. Most social media platforms also set cookies in your browser to store data. That is why we recommend that you read our privacy text about cookies carefully and view the privacy policy or cookie policy of the respective service provider.
Information on specific social media platforms – if available – can be found in the following sections.
Twitter privacy policy
Twitter privacy policy summary
👥 Data subjects: Visitors to the website.
🤝 Purpose: Optimization of our service performance.
📓 Data processed: Data such as user behavior data, information about your device and your IP address.
More details can be found below in the privacy policy.
📅 Storage period: collected data from other websites is deleted by Twitter after 30 days at the latest.
⚖️ Legal basis: Art. 6 para. 1 lit. a DSGVO (consent), Art. 6 para. 1 lit. f DSGVO (legitimate interests).
What is Twitter?
We have incorporated functions from Twitter on our website. These are, for example, embedded tweets, timelines, buttons or hashtags. Twitter is a short message service and a social media platform of the company Twitter Inc, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland.
To our knowledge, in the European Economic Area and in Switzerland, no personal data or data relating to your web activities are transmitted to Twitter by the mere inclusion of the Twitter function. Only when you interact with the Twitter functions, such as clicking on a button, can data be sent to Twitter, stored there and processed. We have no influence on this data processing and bear no responsibility for it. Within the scope of this privacy policy, we want to give you an overview of what data Twitter stores, what Twitter does with this data and how you can protect yourself from the data transmission to a large extent.
For some, Twitter is a news service, for others a social media platform and still others speak of a microblogging service. All these terms have their justification and mean more or less the same thing.
Both private individuals and companies use Twitter to communicate with interested people via short messages. Twitter only allows 280 characters per message. These messages are called “tweets.” Unlike Facebook, for example, the service does not focus on expanding a network for “friends”, but wants to be understood as a worldwide and open news platform. On Twitter, you can also have an anonymous account and tweets can be deleted by the company on the one hand and by the users themselves on the other.
Why do we use Twitter on our website?
Like many other websites and companies, we try to offer our services and communicate with our customers through different channels. Especially Twitter has grown on us as a useful “little” news service. Time and again we tweet or retweet exciting, funny or interesting content. We realize that you can’t follow every channel separately. After all, you also have something else to do. That’s why we have included Twitter functions on our website. You can follow our Twitter activity “on the spot” or follow a direct link to our Twitter page. Through the integration, we want to strengthen our service and user-friendliness on our website.
What data is stored by Twitter?
On some of our subpages you will find the built-in Twitter functions. When you interact with the Twitter content, such as clicking on a button, Twitter may collect and store data. This is the case even if you do not have a Twitter account yourself. Twitter calls this data “log data.” It includes demographic data, browser cookie IDs, your smartphone’s ID, hashed email addresses, and information about which pages you visited on Twitter and what actions you took. Twitter, of course, stores more data if you have a Twitter account and are logged in. Most of the time, this storage happens via cookies. Cookies are small text files that are usually set in your browser and transmit different information to Twitter.
We will now show you which cookies are set when you are not logged in to Twitter but visit a website with built-in Twitter features. Please consider this list as an example. We can in no way guarantee a claim to completeness here, as the choice of cookies always changes and depends on your individual actions with Twitter content.
These cookies were used in our test:
Name: personalization_id
Wert: “v1_cSJIsogU51SeE311947292”
Purpose: This cookie stores information about how you use the website and through which advertisements you may have come to Twitter.
Expiration date: after 2 years
Name: lang
Value: en
Purpose: This cookie stores your default or preferred language.
Expiration date: after end of session
Name: guest_id
Value: 311947292v1%3A157132626
Purpose: This cookie is set to identify you as a guest.
Expiration date: after 2 years
Name: fm
Value: 0
Purpose: Unfortunately, we could not find out the purpose of this cookie.
Expiration date: after end of session
Name: external_referer
Wert: 3119472922beTA0sf5lkMrlGt
Purpose: This cookie collects anonymous data, such as how often you visit Twitter and how long you visit Twitter.
Expiration date: After 6 days
Name: eu_cn
Value: 1
Purpose: This cookie stores user activity and is used for various advertising purposes by Twitter.
Expiration date: After one year
Name: ct0
Wert: c1179f07163a365d2ed7aad84c99d966
Purpose: Unfortunately, we have not found any information about this cookie.
Expiration date: after 6 hours
Name: _twitter_sess
Wert: 53D%253D–dd0248311947292-
Purpose: This cookie allows you to use functions within the Twitter website.
Expiration date: after end of session
Note: Twitter also works with third-party vendors. That is why we also detected the three Google Analytics cookies _ga, _gat, _gid during our test.
Twitter uses the collected data on the one hand to better understand user behavior and thus improve its own services and advertising offers, and on the other hand the data also serves internal security measures.
How long and where is the data stored?
When Twitter collects data from other websites, it is deleted, aggregated or otherwise obscured after a maximum of 30 days. Twitter’s servers are located on various server centers in the United States. Accordingly, it can be assumed that the collected data is collected and stored in America. After our research, we could not clearly determine whether Twitter also has its own servers in Europe. In principle, Twitter can store the collected data until it is no longer useful to the company, you delete the data or there is a legal deletion period.
How can I delete my data or prevent data storage?
Twitter repeatedly emphasizes in its privacy policy that it does not store data from external website visits if you or your browser are located in the European Economic Area or Switzerland. However, if you interact with Twitter directly, Twitter will of course store data from you.
If you have a Twitter account, you can manage your data by clicking on “More” under the “Profile” button. Then click on “Settings and privacy”. Here you can manage the data processing individually.
If you do not have a Twitter account, you can go to twitter.com and then click on “Individualization”. Under the “Individualization and data” item, you can manage your collected data.
Most of the data is stored via cookies, as mentioned above, and you can manage, disable or delete them in your browser. Please note that you only “edit” cookies in the browser you choose. This means that if you use a different browser in the future, you will have to manage your cookies there again according to your wishes. Under the section “Cookies” you will find the corresponding links to the respective instructions of the most popular browsers.
You can also manage your browser in such a way that you are informed for each individual cookie. Then you can always decide individually whether to allow a cookie or not.
Twitter also uses the data for personalized advertising inside and outside of Twitter. In the settings, you can disable personalized advertising under “Individualization and data”. If you use Twitter on a browser, you can disable personalized advertising at https://optout.aboutads.info/?c=2&lang=EN.
Legal basis
If you have consented that data from you can be processed and stored by integrated social media elements, this consent is considered the legal basis for data processing (Art. 6 para. 1 lit. a DSGVO). In principle, your data will also be stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f DSGVO) in fast and good communication with you or other customers and business partners. Nevertheless, we only use the integrated social media elements insofar as you have given your consent. Most social media platforms also set cookies in your browser to store data. That is why we recommend that you read our privacy text about cookies carefully and view the privacy policy or cookie policy of the respective service provider.
Twitter also processes data from you in the USA, among other places. We would like to point out that according to the opinion of the European Court of Justice, there is currently no adequate level of protection for the transfer of data to the USA. This may be associated with various risks to the legality and security of data processing.
As a basis for data processing with recipients located in third countries (outside the European Union, Iceland, Liechtenstein, Norway, i.e. in particular in the USA) or a data transfer there, Twitter uses so-called standard contractual clauses (= Art. 46. para. 2 and 3 DSGVO). Standard Contractual Clauses (SCC) are templates provided by the EU Commission and are intended to ensure that your data comply with European data protection standards even if they are transferred to third countries (such as the USA) and stored there. Through these clauses, Twitter undertakes to comply with the European level of data protection when processing your relevant data, even if the data is stored, processed and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding standard contractual clauses here, among other places: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de
More information on Twitter’s standard contractual clauses can be found at https://gdpr.twitter.com/en/controller-to-controller-transfers.html.
We hope we have given you a basic overview of data processing by Twitter. We do not receive any data from Twitter, nor do we bear any responsibility for what Twitter does with your data. If you have any further questions about this topic, we recommend that you read Twitter’s privacy statement at https://twitter.com/de/privacy.
Online Marketing Introduction
Online marketing privacy policy summary
👥 Data subjects: Visitors to the website
🤝 Purpose: Evaluation of visitor information to optimize the web offering.
📓 Data processed: Access statistics containing data such as access locations, device data, access duration and time, navigation behavior, click behavior, and IP addresses. Personal data such as name or email address may also be processed. More details on this can be found with the respective online marketing tool used.
📅 Storage duration: depending on the online marketing tools used.
⚖️ Legal basis: Art. 6 para. 1 lit. a DSGVO (Consent), Art. 6 para. 1 lit.f DSGVO (Legitimate Interests).
What is online marketing?
Online marketing refers to all measures carried out online to achieve marketing goals such as increasing brand awareness or closing a deal. Furthermore, our online marketing measures aim to draw people’s attention to our website. So, in order to be able to show our offer to many interested people, we engage in online marketing. This usually involves online advertising, content marketing or search engine optimization. To enable us to use online marketing efficiently and in a targeted manner, personal data is also stored and processed. On the one hand, the data helps us to show our content only to those people who are really interested in it, and on the other hand, we can measure the advertising success of our online marketing measures.
Why do we use online marketing tools?
We want to show our website to everyone who is interested in what we have to offer. We are aware that this is not possible without consciously set measures. That is why we do online marketing. There are various tools that make it easier for us to work on our online marketing measures and, in addition, always provide suggestions for improvement via data. This allows us to target our campaigns more precisely to our target group. So the purpose of these online marketing tools we use is ultimately to optimize our offering.
What data is processed?
In order for our online marketing to work and the success of the measures can be measured, user profiles are created and data is stored, for example, in cookies (these are small text files). With the help of this data, we can not only place advertisements in the classic sense, but also directly on our website, display our content in the way you prefer. For this purpose, there are various third-party tools that offer these functions and accordingly also collect and store data from you. In the named cookies are stored, for example, which web pages you have visited on our website, how long you have viewed these pages, which links or buttons you click or from which website you have come to us. In addition, technical information may also be stored. For example, your IP address, which browser you use, from which device you visit our website or the time when you accessed our website and when you left it again. If you have consented that we may also determine your location, we may also store and process this.
Your IP address is stored in pseudonymized form (i.e. shortened). Unique data that directly identifies you as a person, such as your name, address or e-mail address, is also only stored in pseudonymized form as part of the advertising and online marketing processes. We can therefore not identify you as a person, but we have only the pseudonymized stored information in the user profiles.
Under certain circumstances, the cookies can also be deployed on other websites that work with the same advertising tools, analyzed and used for advertising purposes. The data may then also be stored on the servers of the advertising tools providers.
In exceptional cases, unique data (name, e-mail address, etc.) may also be stored in the user profiles. This storage occurs, for example, if you are a member of a social media channel that we use for our online marketing measures and the network links previously received data with the user profile.
With all the advertising tools we use that store data from you on their servers, we only ever receive aggregated information and never data that makes you recognizable as an individual. The data only shows how well set advertising measures worked. For example, we see which measures have persuaded you or other users to come to our website and purchase a service or product there. Based on the analyses, we can improve our advertising offer in the future and adapt it even more precisely to the needs and wishes of interested persons.
Duration of data processing
We will inform you about the duration of data processing below, provided we have further information on this. In general, we process personal data only as long as it is absolutely necessary for the provision of our services and products. Data that is stored in cookies is stored for different lengths of time. Some cookies are deleted as soon as you leave the website, others may be stored in your browser for several years. In the respective privacy statements of the individual providers, you will usually receive detailed information about the individual cookies used by the provider.
Right of objection
You also have the right and the possibility to revoke your consent to the use of cookies or third-party providers at any time. This works either via our cookie management tool or via other opt-out functions. For example, you can also prevent data collection through cookies by managing, disabling or deleting cookies in your browser. The lawfulness of the processing until the revocation remains unaffected.
Since online marketing tools may generally use cookies, we also recommend that you read our general privacy policy on cookies. To find out exactly which of your data is stored and processed, you should read the privacy statements of the respective tools.
Legal basis
If you have consented that third-party providers may be used, the legal basis of the corresponding data processing is this consent. According to Art. 6 (1) lit. a DSGVO (consent), this consent constitutes the legal basis for the processing of personal data as may occur when collected by online marketing tools.
On our part, there is also a legitimate interest in measuring online marketing measures in anonymized form in order to optimize our offer and our measures with the help of the data obtained. The corresponding legal basis for this is Art. 6 Para. 1 lit. f DSGVO (Legitimate Interests). Nevertheless, we only use the tools if you have given your consent.
Information on specific online marketing tools – if available – can be found in the following sections.
HubSpot privacy policy
We use HubSpot, a digital marketing tool, on our website. The service provider is the American company HubSpot, Inc, 25 First St 2nd Floor Cambridge, MA, USA. The company also has a registered office in Ireland, among other places, with the address 1 Sir John Rogerson’s Quay, Dublin 2, Ireland.
HubSpot also processes data from you in the USA, among other places. We would like to point out that according to the opinion of the European Court of Justice, there is currently no adequate level of protection for the transfer of data to the USA. This may be associated with various risks to the legality and security of data processing.
As a basis for data processing with recipients located in third countries (outside the European Union, Iceland, Liechtenstein, Norway, i.e. in particular in the USA) or a data transfer there, HubSpot uses so-called standard contractual clauses (= Art. 46. para. 2 and 3 DSGVO). Standard Contractual Clauses (SCC) are templates provided by the EU Commission and are intended to ensure that your data complies with European data protection standards even if it is transferred to third countries (such as the USA) and stored there. Through these clauses, HubSpot undertakes to comply with the European level of data protection when processing your relevant data, even if the data is stored, processed and managed in the US. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding standard contractual clauses here, among other places: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de
The Data Processing Agreement, which corresponds to the standard contractual clauses, can be found at https://legal.hubspot.com/dpa.
To learn more about the data that is processed through the use of HubSpot, see the Privacy Policy at https://legal.hubspot.com/de/privacy-policy .
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