Privacy Policy

PRIVACY POLICY

We are very pleased about your interest in our company. Data protection has a particularly high priority for the management of ZD Solution KG. The use of the Internet pages of ZD Solution KG is generally possible without any indication of personal data. However, if a data subject wants to use special services of our company via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data, such as the name, address, email address, or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation and in compliance with the country-specific data protection regulations applicable to ZD Solution KG. By means of this privacy policy, our company would like to inform the public about the type, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects are informed of their rights by means of this privacy policy.

As the controller, ZD Solution KG has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions can in principle have security gaps, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transfer personal data to us by alternative means, for example by telephone.

  1. DEFINITIONS

The privacy policy of ZD Solution KG is based on the terms used by the European legislator when issuing the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.

In this privacy policy, we use, inter alia, the following terms:

  1. a) Personal data

Personal data means any information relating to an identified or identifiable natural person (‘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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

  1. b) Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

  1. c) Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

  1. d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

  1. e) Profiling

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.

  1. f) Pseudonymization

Pseudonymization is 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.

  1. g) Controller or controller responsible for the processing

The controller or person responsible for processing is 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. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

  1. h) Processor

A processor is a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.

  1. i) Recipient

A recipient is a natural or legal person, public authority, agency, or other body to which personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.

  1. j) Third Party

A third party is a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

  1. k) Consent

Consent of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

  1. NAME AND ADDRESS OF THE CONTROLLER

The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union, and other provisions related to data protection is:

ZD Solution KG

Bürgermeister-Schauer-Str. 1

82297 Steindorf

Germany

Tel.: +49 (0)8202 9618-0

Email: info@zd-solution.de

Website: www.zd-solution.de

Name and Address of the Data Protection Officer

Dr. Claudia Noortwijck
Jahnstraße 102
D-88214 Ravensburg

Phone: +49 (751) 36 05 – 300

Email: noortwijck@merkel-gruppe.de

  1. COOKIES

The Internet pages of ZD Solution KG use cookies. Cookies are text files that are stored on a computer system via an Internet browser.

Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

Through the use of cookies, ZD Solution KG can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The user of a website that uses cookies does not, for example, have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.

The data subject can prevent the setting of cookies by our website at any time by adjusting the settings of the internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates the setting of cookies in the internet browser used, not all functions of our website may be fully usable.

  1. COLLECTION OF GENERAL DATA AND INFORMATION

The website of ZD Solution KG collects a series of general data and information with every call of the website by a data subject or automated system. This general data and information is stored in the server log files. The following may be collected: (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the sub-websites that are accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) other similar data and information that serve to avert danger in the event of attacks on our information technology systems.

When using this general data and information, ZD Solution KG does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the contents of our website correctly, (2) optimize the contents of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, ZD Solution KG analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

  1. REGISTRATION ON OUR WEBSITE

The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for his own purposes. The controller may request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to the controller.

By registering on the website of the controller, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.

The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the controller’s employees are available to the data subject in this respect as contact persons.

  1. SUBSCRIPTION TO OUR NEWSLETTER

On the website of ZD Solution KG, users are given the opportunity to subscribe to our enterprise’s newsletter. The input mask used for this purpose determines what personal data are transmitted, when the newsletter is ordered from the controller.

ZD Solution KG informs its customers and business partners regularly by means of a newsletter about enterprise offers. The enterprise’s newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.

During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the email address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.

The personal data collected as part of a newsletter subscription will be used exclusively for sending our newsletter. Furthermore, newsletter subscribers may be informed via email if this is necessary for the operation of the newsletter service or for a related registration, as might be the case with changes to the newsletter offer or technical changes. Personal data collected as part of the newsletter service will not be shared with third parties. The subscription to our newsletter can be terminated by the data subject at any time. The consent to store personal data that the data subject has given us for the newsletter dispatch can be revoked at any time. For the purpose of revoking consent, a corresponding link can be found in each newsletter. It is also possible to unsubscribe from the newsletter directly on the website of the data controller or to inform the data controller in another way.

  1. NEWSLETTER TRACKING

The newsletters of ZD Solution KG contain so-called counting pixels. A counting pixel is a miniature graphic embedded in emails sent in HTML format to enable log file recording and log file analysis. This allows for a statistical evaluation of the success or failure of online marketing campaigns. Through the embedded counting pixel, ZD Solution KG can detect if and when an email was opened by a data subject and which links in the email were accessed by the data subject.

Such personal data collected through the counting pixels contained in the newsletters are stored and analyzed by the data controller to optimize newsletter delivery and better adapt the content of future newsletters to the interests of the data subject. This personal data is not passed on to third parties. Data subjects are entitled at any time to revoke the separate declaration of consent issued via the double opt-in procedure. After a revocation, this personal data will be deleted by the data controller. ZD Solution KG automatically interprets a cancellation of the newsletter subscription as a revocation.

  1. CONTACT OPTION VIA THE WEBSITE

Due to legal regulations, the website of ZD Solution KG contains information that enables quick electronic contact with our company and direct communication with us, which also includes a general address of the so-called electronic mail (email address). If a data subject contacts the data controller by email or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller is stored for the purpose of processing or contacting the data subject. There is no disclosure of this personal data to third parties.

  1. SUBSCRIPTION TO COMMENTS IN THE BLOG ON THE WEBSITE

The comments made in the blog of ZD Solution KG can generally be subscribed to by third parties. In particular, there is the possibility for a commenter to subscribe to the comments following their comment on a particular blog post.

If a data subject chooses the option to subscribe to comments, the data controller will send an automatic confirmation email to check in a double opt-in procedure whether the owner of the specified email address really opted for this option. The option to subscribe to comments can be terminated at any time.

  1. ROUTINE ERASURE AND BLOCKING OF PERSONAL DATA

The data controller processes and stores personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the data controller is subject.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data is routinely blocked or erased in accordance with legal requirements.

  1. RIGHTS OF THE DATA SUBJECT

  1. a) Right to Confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail themselves of this right of confirmation, they may, at any time, contact an employee of the controller.

  1. b) Right to Information

Every data subject shall have the right granted by the European legislator to obtain from the controller free information about their personal data stored at any time and a copy of this information. Furthermore, the European legislator grants the data subject access to the following information:
the purposes of the processing
the categories of personal data concerned
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing
the right to lodge a complaint with a supervisory authority
where the personal data are not collected from the data subject, any available information as to their source
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.

  1. c) Right to Rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.

  1. d) Right to Erasure (Right to be Forgotten)

Every person affected by the processing of personal data has the right granted by the European directive and regulation makers to demand from the controller that the personal data concerning them be deleted immediately if one of the following reasons applies and insofar as the processing is not necessary:
The personal data were collected or otherwise processed for purposes for which they are no longer necessary.
The data subject withdraws their consent on which the processing was based according to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, and there is no other legal basis for the processing.
The data subject objects to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21(2) GDPR.
The personal data have been unlawfully processed.
The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
The personal data have been collected in relation to the offer of information society services referred to in Art. 8(1) GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by ZD Solution KG, they may at any time contact an employee of the controller. An employee of ZD Solution KG will ensure that the erasure request is complied with immediately.

If the personal data have been made public by ZD Solution KG and our company is obliged pursuant to Art. 17(1) GDPR to erase the personal data, ZD Solution KG, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employee of ZD Solution KG will arrange the necessary in individual cases.

  1. e) Right to Restriction of Processing

Every data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
The data subject has objected to processing pursuant to Art. 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by ZD Solution KG, they may at any time contact any employee of the controller. The employee of ZD Solution KG will arrange the restriction of the processing.

  1. f) Right to Data Portability

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact any employee of ZD Solution KG.

  1. g) Right to Object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

ZD Solution KG shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.

If ZD Solution KG processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data for such marketing. This also applies to profiling insofar as it is related to such direct marketing. If the data subject objects to ZD Solution KG processing for direct marketing purposes, ZD Solution KG will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her which is carried out by ZD Solution KG for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To exercise the right to object, the data subject may directly contact any employee of ZD Solution KG or another employee. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject is also free to exercise his or her right to object by automated means using technical specifications.

  1. h) Automated Individual Decision-Making, Including Profiling

Every data subject shall have the right granted by the European legislators and regulators not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, unless the decision (1) is necessary for entering into, or performance of, a contract between the data subject and the data controller, or (2) is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is based on the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, ZD Solution KG shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

If the data subject wishes to exercise rights relating to automated decision-making, he or she may at any time contact an employee of the controller.

  1. i) Right to Withdraw Data Protection Consent

Each data subject shall have the right granted by the European legislators and regulators to withdraw his or her consent to the processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw consent, he or she may at any time contact an employee of the controller.

  1. DATA PROTECTION IN THE APPLICATION PROCESS

The data controller collects and processes the personal data of applicants for the purpose of handling the application procedure. The processing may also be carried out electronically. This is particularly the case if an applicant submits corresponding application documents to the data controller by electronic means, for example by e-mail or via a web form on the website. If the data controller concludes an employment contract with an applicant, the transmitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the data controller, the application documents shall be automatically erased two months after notification of the refusal decision, provided that no other legitimate interests of the data controller oppose the erasure. Other legitimate interest in this sense is, for example, a burden of proof in proceedings under the General Equal Treatment Act (AGG).

  1. DATA PROTECTION PROVISIONS ABOUT THE APPLICATION AND USE OF ADOBE ANALYTICS (OMNITURE) / ADOBE MARKETING CLOUD

The controller has integrated components of the company Adobe on this website. Adobe Analytics (Omniture) and the Adobe Marketing Cloud (hereinafter referred to as “Omniture”) is a tool that enables more efficient online marketing and web analysis. Omniture is part of Adobe Marketing Cloud. Adobe Marketing Cloud enables real-time analysis of visitor flows on websites. The real-time analysis includes project reports and allows an ad-hoc analysis of website visitors. Customer interactions are presented in such a way that the controller gains a better overview of users’ online activities on this website by displaying the data in simple and interactive dashboards and converting them into reports. This enables the controller to obtain information in real-time and to identify problems more quickly.

The operating company for these services is Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Republic of Ireland.

Omniture sets a cookie on the information technology system of the data subject (cookies have been explained previously; relevant information can be found above). The controller ensures through a server setting that the tracking data sets transmitted to Adobe’s data center are anonymized before geolocation. The anonymization is implemented by replacing the last part of the IP address. The controller has made server-side settings which anonymize the IP address of the data subject before any respective processing for geolocation and range measurement, independently of each other. Adobe will use the data and information obtained via our website on behalf of the controller to analyze the user behavior of the data subject. Furthermore, Adobe will use the data to create reports about user activities on our behalf, as well as provide other services for our company related to the use of our website. The IP address of the data subject is not merged with other personal data by Adobe.

The data subject can prevent the setting of cookies by our website, as stated above, at any time by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Omniture from setting a cookie on the information technology system of the data subject. In addition, cookies already set by Omniture can be deleted at any time via an Internet browser or other software programs.

Furthermore, the data subject has the option to object to and prevent the collection of data generated by the Adobe cookie related to the use of this website and the processing of this data by Adobe. To do this, the data subject must press the opt-out button under the link http://www.adobe.com/de/privacy/opt-out.html, which sets an opt-out cookie. The opt-out cookie set with the objection is stored on the information technology system used by the data subject. If the cookies on the data subject’s system are deleted after an objection, the data subject must access the link again and set a new opt-out cookie.

However, by setting the opt-out cookie, it is possible that the website of the controller may no longer be fully usable for the data subject.

Adobe’s applicable privacy policy can be accessed at http://www.adobe.com/de/privacy.html.

  1. PRIVACY POLICY ON THE USE OF GOOGLE ADSENSE

The controller has integrated Google AdSense on this website. Google AdSense is an online service that enables the placement of advertising on third-party sites. Google AdSense is based on an algorithm that selects the advertisements displayed on third-party sites to match the content of the respective third-party site. Google AdSense allows interest-based targeting of the Internet user, which is implemented by generating individual user profiles.

The operating company of the Google AdSense component is Alphabet Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The purpose of the Google AdSense component is to integrate advertisements on our website. Google AdSense sets a cookie on the data subject’s information technology system. The definition of cookies has been explained above. By setting the cookie, Alphabet Inc. is enabled to analyze the use of our website. With each call-up to one of the individual pages of this website, which is operated by the controller and on which a Google AdSense component has been integrated, the Internet browser on the information technology system of the data subject will automatically be prompted by the respective Google AdSense component to transmit data to Alphabet Inc. for the purpose of online advertising and commission settlement. As part of this technical process, Alphabet Inc. gains knowledge of personal data, such as the IP address of the data subject, which serves Alphabet Inc., inter alia, to understand the origin of visitors and clicks and subsequently create commission settlements.

The data subject may prevent the setting of cookies by our website at any time by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Alphabet Inc. from setting a cookie on the information technology system of the data subject. Additionally, cookies already set by Alphabet Inc. may be deleted at any time via the Internet browser or other software programs.

Google AdSense also uses so-called tracking pixels. A tracking pixel is a miniature graphic embedded in Internet pages that allows a log file recording and log file analysis, through which a statistical analysis can be performed. Based on the embedded tracking pixel, Alphabet Inc. can determine if and when a website was opened by a data subject and which links were clicked by the data subject. Tracking pixels serve, among other things, to analyze the flow of visitors to a website.

Through Google AdSense, personal data and information, which also includes the IP address and is necessary for the collection and accounting of the displayed advertisements, is transferred to Alphabet Inc. in the United States of America. These personal data are stored and processed in the United States of America. Alphabet Inc. may disclose the personal data collected through this technical procedure to third parties.

Google AdSense is further explained under this link https://www.google.de/intl/de/adsense/start/.

  1. PRIVACY POLICY ON THE USE OF GOOGLE ANALYTICS (WITH ANONYMIZATION FUNCTION)

On this website, the controller has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.

The operating company of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The data controller uses the addition ‘_gat._anonymizeIp’ for web analysis via Google Analytics. By means of this addition, the IP address of the data subject’s Internet connection is shortened and anonymized by Google when accessing our websites from a member state of the European Union or another contracting state to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze visitor flows on our website. Google uses the data and information obtained, among other things, to evaluate the use of our website, to compile online reports for us showing the activities on our websites, and to provide other services related to the use of our website.

Google Analytics places a cookie on the data subject’s information technology system. Cookies have been explained above. By setting the cookie, Google enables an analysis of the use of our website. With each call-up to one of the individual pages of this website, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically be prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical procedure, Google gains knowledge of personal data, such as the IP address of the data subject, which serves Google, inter alia, to trace the origin of visitors and clicks and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits to our website by the data subject. With each visit to our websites, such personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected through the technical procedure to third parties.

The data subject can prevent the setting of cookies by our website, as stated above, at any time by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a cookie on the information technology system of the data subject. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.

Furthermore, the data subject has the possibility to object to the collection of data generated by Google Analytics relating to the use of this website and the processing of this data by Google, and to prevent such collection. To do this, the data subject must download and install a browser add-on from the link https://tools.google.com/dlpage/gaoptout. This browser add-on informs Google Analytics via JavaScript that no data and information about website visits may be transmitted to Google Analytics. The installation of the browser add-on is considered an objection by Google. If the data subject’s information technology system is later deleted, formatted, or reinstalled, the data subject must reinstall the browser add-on to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person within their sphere of influence, it is possible to reinstall or reactivate the browser add-on.

Further information and Google’s applicable privacy policy can be found at https://www.google.de/intl/de/policies/privacy/ and at http://www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail at this link https://www.google.com/intl/de_de/analytics/.

  1. PRIVACY POLICY ON THE USE OF GOOGLE REMARKETING

The data controller has integrated Google Remarketing services on this website. Google Remarketing is a feature of Google AdWords that allows a company to display advertising to internet users who have previously visited the company’s website. The integration of Google Remarketing therefore allows a company to create user-related advertising and consequently display interest-relevant advertisements to the internet user.

The operating company of Google Remarketing services is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The purpose of Google Remarketing is to display interest-relevant advertising. Google Remarketing enables us to display advertisements via the Google advertising network or to have them displayed on other websites, which are tailored to the individual needs and interests of internet users.

Google Remarketing sets a cookie on the information technology system of the data subject. What cookies are has already been explained above. By setting the cookie, Google enables a recognition of the visitor to our website when they subsequently visit websites that are also members of the Google advertising network. With each visit to a website on which the service of Google Remarketing has been integrated, the internet browser of the data subject automatically identifies itself to Google. In the course of this technical procedure, Google receives knowledge of personal data, such as the IP address or surfing behavior of the user, which Google uses, among other things, to display interest-relevant advertising.

The cookie is used to store personal information, such as the websites visited by the data subject. Each time our websites are visited, personal data, including the IP address of the internet connection used by the data subject, is transferred to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected through the technical procedure to third parties.

The data subject can prevent the setting of cookies by our website, as stated above, at any time by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a cookie on the information technology system of the data subject. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.

Furthermore, the data subject has the possibility to object to interest-based advertising by Google. To do this, the data subject must access the link www.google.de/settings/ads from each of the internet browsers they use and make the desired settings there.

Further information and Google’s applicable privacy policy can be found at https://www.google.de/intl/de/policies/privacy/.

16.1 GOOGLE ANALYTICS FOR FIREBASE

is a development platform for mobile and web applications. It provides tools and infrastructure that are intended to enable a developer to provide functions more easily and efficiently on various platforms for users. In our case, it serves to optimize our apps.

By using the apps, the following personal data is collected: cookie, unique device identifier for advertising (Google Advertising ID or IDFA, for example), and usage data.

Firebase Authentication: Personal data such as email, last name, and first name are collected.

Firebase Cloud Functions, Firebase Cloud Storage, and Firebase Realtime Database: Personal data such as usage data and various types of data, as described in the service’s privacy policy, are collected.

Firebase Privacy Policy: https://www.firebase.com/terms/privacy-policy.html

  1. LEGAL BASIS FOR PROCESSING

Article 6 I lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, with processing operations necessary for the delivery of goods or the provision of any other service or consideration, the processing is based on Article 6 I lit. b GDPR. The same applies to such processing operations that are necessary for carrying out pre-contractual measures, for example in cases of inquiries about our products or services. If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Article 6 I lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our company and their name, age, health insurance data, or other vital information would have to be passed on to a doctor, hospital, or other third parties. Then the processing would be based on Article 6 I lit. d GDPR. Ultimately, processing operations could be based on Article 6 I lit. f GDPR. This legal basis is used for processing operations that are not covered by any of the aforementioned legal bases if the processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights, and freedoms of the data subject do not prevail. Such processing operations are particularly permitted to us because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

  1. LEGITIMATE INTERESTS IN PROCESSING PURSUED BY THE CONTROLLER OR A THIRD PARTY

Where the processing of personal data is based on Article 6 I lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

  1. DURATION FOR WHICH THE PERSONAL DATA IS STORED

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

  1. LEGAL OR CONTRACTUAL REQUIREMENTS FOR PROVIDING PERSONAL DATA; NECESSITY FOR CONTRACT CONCLUSION; OBLIGATION OF THE DATA SUBJECT TO PROVIDE PERSONAL DATA; POSSIBLE CONSEQUENCES OF NON-PROVISION

We inform you that the provision of personal data is partly required by law (e.g., tax regulations) or can also result from contractual provisions (e.g., information about the contractual partner). Sometimes it may be necessary for the conclusion of a contract that a data subject provides us with personal data, which must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with them. Failure to provide the personal data would result in the contract with the data subject not being concluded. Before providing personal data by the data subject, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and what consequences the non-provision of personal data would have.

  1. EXISTENCE OF AUTOMATED DECISION-MAKING

As a responsible company, we refrain from automated decision-making or profiling.

  1. ANALYSIS TOOLS AND ADVERTISING

Google Analytics

This website uses functions of the web analysis service Google Analytics 4. Provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics 4 works with artificial intelligence. Google has developed algorithms that can create a forecast of future user behavior based on usage data such as page views, scrolls to the end of the page, clicks on external links, website searches, viewing an embedded YouTube video, or file downloads. This is possible across devices because the algorithms can recognize the user solely based on their specific behavior. The analysis tool only becomes active and your data is stored after consent has been given according to Art. 6 Para. 1 lit. a GDPR for the purpose of data processing. The website operator has a legitimate interest in analyzing user behavior to optimize both its web offering and advertising.

IP Anonymization
We have activated the IP anonymization function on this website. As a result, your IP address will be truncated by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activities, and to provide other services related to website and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

Browser Plugin
You can prevent the storage of cookies by adjusting your browser software accordingly; however, we point out that in this case you may not be able to use all functions of this website to their full extent. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google as well as the processing of this data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

Objection to Data Collection
You can prevent the collection of your data by Google Analytics by clicking on the following link. An opt-out cookie will be set to prevent the collection of your data on future visits to this website: Deactivate Google Analytics.

More information about the handling of user data at Google Analytics can be found in Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=en.

Order Processing
We have concluded a contract for order processing with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

Demographic Features in Google Analytics
This website uses the ‘demographic features’ function of Google Analytics. This allows reports to be generated that contain statements about the age, gender, and interests of site visitors. This data comes from interest-based advertising from Google and visitor data from third-party providers. This data cannot be attributed to any specific individual. You can disable this feature at any time through the ad settings in your Google account or generally prohibit the collection of your data by Google Analytics as described in the section ‘Objection to data collection’.

Storage Duration
Data stored by Google at the user and event level that is linked to cookies, user identifiers (e.g., User ID) or advertising IDs (e.g., DoubleClick cookies, Android advertising ID) will be anonymized or deleted after 26 months. Details can be found at the following link: https://support.google.com/analytics/answer/7667196?hl=en

Google Analytics Remarketing

Our websites use the functions of Google Analytics Remarketing in conjunction with the cross-device capabilities of Google AdWords and Google DoubleClick. The provider is Google Ireland Limited (‘Google’), Gordon House, Barrow Street, Dublin 4, Ireland.

This feature allows the advertising target groups created with Google Analytics Remarketing to be linked with the cross-device functions of Google AdWords and Google DoubleClick. In this way, interest-based, personalized advertising messages that have been adapted to you based on your previous usage and surfing behavior on one device (e.g. mobile phone) can also be displayed on another of your devices (e.g. tablet or PC).

If you have given your consent, Google will link your web and app browsing history with your Google account for this purpose. This way, the same personalized advertising messages can be displayed on every device you sign in to with your Google account.

To support this feature, Google Analytics collects Google-authenticated IDs of users that are temporarily linked to our Google Analytics data to define and create audiences for cross-device ad promotion.

You can permanently object to cross-device remarketing/targeting by deactivating personalized advertising in your Google account; follow this link: https://www.google.com/settings/ads/onweb/.

The aggregation of the collected data in your Google account is based solely on your consent, which you can give or revoke at Google (Art. 6 (1) (a) GDPR). For data collection operations that are not merged into your Google account (for example, because you do not have a Google account or have objected to the merger), the collection of data is based on Art. 6 (1) (f) GDPR. The legitimate interest arises from the fact that the website operator has an interest in the anonymous analysis of website visitors for advertising purposes.

Further information and the privacy policy can be found in the

Google Privacy Policy at: https://policies.google.com/technologies/ads?hl=en.

Google AdWords and Google Conversion Tracking

This website uses Google AdWords. AdWords is an online advertising program of Google Ireland Limited (‘Google’), Gordon House, Barrow Street, Dublin 4, Ireland.

As part of Google AdWords, we use so-called conversion tracking. When you click on an ad served by Google, a cookie is set for conversion tracking. Cookies are small text files that the Internet browser stores on the user’s computer. These cookies expire after 30 days and are not used for personal identification of users. If the user visits certain pages of this website and the cookie has not yet expired, Google and we can recognize that the user clicked on the ad and was redirected to this page.

Each Google AdWords customer receives a different cookie. The cookies cannot be tracked across AdWords customers’ websites. The information collected using the conversion cookie is used to create conversion statistics for AdWords customers who have opted for conversion tracking. Customers learn the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not receive any information that can personally identify users. If you do not wish to participate in tracking, you can easily disable the Google conversion tracking cookie via your internet browser under user settings. You will then not be included in the conversion tracking statistics.

The storage of ‘conversion cookies’ and the use of this tracking tool are based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in analyzing user behavior to optimize both its web offer and its advertising.

More information about Google AdWords and Google Conversion Tracking can be found in Google’s privacy policy: https://policies.google.com/privacy?hl=en.

You can configure your browser to inform you about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or generally, and activate the automatic deletion of cookies when closing the browser. Disabling cookies may limit the functionality of this website.

Facebook Pixel

Our website uses Facebook’s visitor action pixel for conversion measurement, Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (‘Facebook’).

This allows the behavior of site visitors to be tracked after they have been redirected to the provider’s website by clicking on a Facebook advertisement. This allows the effectiveness of Facebook advertisements to be evaluated for statistical and market research purposes and future advertising measures to be optimized.

The collected data is anonymous for us as the operator of this website; we cannot draw any conclusions about the identity of the 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 advertising purposes in accordance with the Facebook Data Usage Policy. This allows Facebook to enable the display of advertisements on Facebook pages as well as outside of Facebook. This use of the data cannot be influenced by us as the site operator.

The use of Facebook Pixel is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in effective advertising measures including social media.

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

You can also deactivate the remarketing function ‘Custom Audiences’ in the settings for advertisements 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 deactivate usage-based advertising from Facebook on the website of the European Interactive Digital Advertising Alliance: http://www.youronlinechoices.com/uk/your-ad-choices.

Alternatively, you can set a cookie here that deactivates tracking via the Facebook pixel. This only works for the current browser and the current device. If you delete the cookies in the browser you are currently using, the Facebook opt-out cookie will also be deleted. Deactivate Facebook Tracking

This privacy policy was created by the privacy policy generator of the external DPO Münster in cooperation with RC GmbH, which recycles used notebooks, and the file-sharing lawyers from WBS-LAW.