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Data protection

introduction

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

The terms used are not gender-specific.

As of November 17, 2023

Overview of the content

  • introduction
  • Responsible person
  • Overview of the processing
  • Relevant legal bases
  • Security measures
  • Transfer and disclosure of personal data
  • Data processing in third countries
  • Use of cookies
  • Commercial and business services
  • Payment service providers
  • Credit check
  • Provision of online services and web hosting
  • contact
  • Newsletters and electronic notifications
  • Web analytics, monitoring and optimization
  • Online marketing
  • Presence on social networks (Social Media)
  • Plugins and embedded functions and content
  • Deletion of data
  • Changes and updates to the privacy policy
  • Rights of data subjects
  • Definitions of terms

Responsible person

Nimbus Innovations FZCO
Dubai Silicon Oasis, DDP, Building A1
Dubai, United Arab Emirates

Email address: info@shave-n-go.com

Overview of the processing

The following overview provides an overview of the types of data processed and the purposes of their processing, and refers to the data subjects.

Types of data processed

  • Inventory data (e.g. names, addresses).
  • Content data (e.g., entries in online forms).
  • Contact details (e.g. email, phone numbers).
  • Metadata/communication data (e.g., device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Location data (information about the geographic position of a device or person).
  • Contract details (e.g. subject matter of the contract, term, customer category).
  • Payment details (e.g. bank details, invoices, payment history).

Categories of affected persons

  • Business and contractual partners.
  • Interested parties.
  • Communication partner
  • Customers
  • Users (e.g., website visitors, users of online services).

Purposes of processing

  • Assessment of creditworthiness and creditworthiness.
  • Providing our online services and user experience.
  • Evaluation of visitor activities.
  • Office and organizational processes.
  • Cross-device tracking (processing of user data across devices for marketing purposes).
  • Direct marketing (e.g., via email or post).
  • Interest-based and behavior-oriented marketing.
  • Contact requests and communication.
  • Conversion measurement (measuring the effectiveness of marketing measures).
  • Profiling (creation of user profiles).
  • Audience measurement (e.g., access statistics, recognition of returning visitors).
  • Security measures.
  • Tracking (e.g., interest/behavioral profiling, use of cookies).
  • Provision of contractual services and customer service.
  • Managing and responding to inquiries.
  • Targeting (determining target groups that are relevant for marketing purposes or other content distribution).

Automated case-by-case decisions

  • Credit information (decision based on a credit check).

Relevant legal bases

Below, we inform you about the legal bases of the General Data Protection Regulation (GDPR) on which we process personal data. Please note that in addition to the GDPR regulations, national data protection laws may also apply in your or our country of residence or stay. Should more specific legal bases be relevant in individual cases, we will inform you of this in the privacy policy.

  • Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR) – The data subject has consented to the processing of his or her personal data for one or more specific purposes.
  • Contractual performance and pre-contractual measures (Art. 6 para. 1 sentence 1 lit. b. GDPR) – The processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR) – The processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Security measures

Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the varying likelihood and severity of risks to the rights and freedoms of natural persons, we implement appropriate technical and organisational measures in accordance with legal requirements to ensure a level of security appropriate to the risk.

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access to, input of, transmission of, and ensuring the availability and separation of the data. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data, and the response to a data breach. In addition, we consider the protection of personal data during the development or selection of hardware, software, and processes, in accordance with the principles of data protection by design and by default.

SSL encryption (https) : To protect the data you transmit via our online services, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in your browser's address bar.

Transfer and disclosure of personal data

As part of our processing of personal data, it may be necessary to transfer or disclose data to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, payment institutions involved in payment transactions, IT service providers, or providers of services and content integrated into a website. In these cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data to protect your data.

Data processing in third countries

Insofar as we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of using third-party services or disclosing or transferring data to other persons, bodies or companies, this is done only in accordance with the legal provisions.

Subject to explicit consent or contractual or legal obligations to transfer data, we only process or have data processed in third countries with a recognized level of data protection, contractual obligations through so-called standard contractual clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Articles 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Under the so-called “Data Privacy Framework” (DPF), the EU Commission, with its adequacy decision of July 10, 2023, has also recognized the level of data protection for certain US companies as adequate. The list of certified companies and further information on the DPF can be found on the US Department of Commerce website at https://www.dataprivacyframework.gov/. In our privacy policy, we inform you which service providers we use that are certified under the Data Privacy Framework.

Use of cookies

Cookies are small text files or other storage tags that store information on and read information from end devices. For example, they are used to save login status in a user account, the contents of a shopping cart in an online store, the content accessed, or the functions used in an online service. Furthermore, cookies can be used for various purposes, such as improving the functionality, security, and user experience of online services, as well as analyzing visitor traffic.

Information on consent : We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users unless otherwise required by law. Consent is not required, in particular, if the storage and reading of information, including cookies, is essential to provide the user with a telemedia service (i.e., our online service) that they have expressly requested. Users are clearly informed of their revocable consent, which includes information about the specific use of cookies.

Information on the legal basis for data processing : The legal basis for processing users' personal data using cookies depends on whether we request user consent. If users consent, the legal basis for processing their data is their explicit consent. Otherwise, the processing of data using cookies is based on our legitimate interests (e.g., operating our online service and improving its user-friendliness) or, if this occurs within the scope of fulfilling our contractual obligations, if the use of cookies is necessary for fulfilling our contractual obligations. We clarify the purposes for which we process cookies in this privacy policy or within the framework of our consent and processing procedures.

Storage duration : The following types of cookies are distinguished with regard to storage duration:

  • Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user leaves an online service and closes their device (e.g., browser or mobile app).
  • Persistent cookies : Persistent cookies remain stored even after the device is closed. This allows, for example, login status to be saved or preferred content to be displayed directly upon revisiting a website. User data collected using cookies can also be used for audience measurement. Unless we explicitly inform users about the type and storage duration of cookies (e.g., when obtaining consent), users should assume that cookies are persistent and can be stored for up to two years.

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the right to revoke any consent you have given or to object to the processing of your data by cookie technologies at any time (collectively referred to as "opt-out"). You can initially declare your objection via your browser settings, for example, by disabling the use of cookies (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via various services, particularly in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. Furthermore, you can find additional information on your right to object in the information on the service providers and cookies used.

Processing of cookie data based on consent : We use a cookie consent management procedure to obtain and manage user consent for the use of cookies and the processing activities and providers mentioned in the cookie consent management procedure, as well as to allow users to withdraw their consent. The consent declaration is stored to avoid having to request it again and to be able to demonstrate consent in accordance with legal obligations. Storage can take place server-side and/or in a cookie (so-called opt-in cookie, or using comparable technologies) to assign the consent to a user or their device. Subject to individual information regarding the providers of cookie management services, the following applies: The storage period for consent can be up to two years. A pseudonymous user ID is created and stored along with the time of consent, information about the scope of the consent (e.g., which categories of cookies and/or service providers), and the browser, system, and device used.

Commercial and business services

We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as “contractual partners”) within the framework of contractual and similar legal relationships as well as related measures and within the framework of communication with contractual partners (or pre-contractually), e.g. to answer inquiries.

We process this data to fulfill our contractual obligations, to protect our rights, and for the administrative tasks associated with this information, as well as for business organization. Within the framework of applicable law, we only disclose the data of contractual partners to third parties if this is necessary for the aforementioned purposes, to fulfill legal obligations, or if the data subjects have given their consent (e.g., to participating telecommunications, transport, and other support services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Contractual partners are informed about other forms of processing, e.g., for marketing purposes, within the framework of this privacy policy.

We inform our contractual partners before or during data collection which data is required for the aforementioned purposes, e.g. in online forms, through special markings (e.g. colors) or symbols (e.g. stars or similar), or personally.

We delete data after the expiry of statutory warranty periods and similar obligations, i.e., generally after 4 years, unless the data is stored, for example, in a customer account, and must be retained for legal archiving reasons (e.g., for tax purposes, generally 10 years). Data that the contractual partner has provided to us in connection with an order is deleted according to the order specifications, generally after the order has been completed.

Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and privacy policies of the respective third-party providers or platforms apply to the relationship between users and the providers.

Customer Account : Contractual partners can create an account within our online service (e.g., customer or user account, hereinafter referred to as "customer account"). If registration of a customer account is required, contractual partners will be informed accordingly, as well as about the information required for registration. Customer accounts are not public and cannot be indexed by search engines. During registration, subsequent logins, and use of the customer account, we store the customers' IP addresses along with the access times in order to verify the registration and prevent any misuse of the customer account.

When customers terminate their account, the data relating to that account will be deleted, unless its retention is required for legal reasons. It is the customer's responsibility to back up their data when their account is terminated.

Economic analysis and market research : For business reasons and in order to identify market trends as well as the wishes of contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc., whereby contractual partners, prospective customers, customers, visitors and users of our online service may be among the persons affected.

The analyses are conducted for the purposes of operational evaluation, marketing, and market research (e.g., to identify customer groups with different characteristics). Where available, we may consider the profiles of registered users along with their information, such as details of services used. The analyses are solely for our internal use and will not be disclosed externally, unless they are anonymous analyses with aggregated, i.e., anonymized, data. Furthermore, we respect user privacy and process data for analytical purposes as pseudonymously as possible and, where feasible, anonymously (e.g., as aggregated data).

Purchasing and E-commerce : We process our customers' data to enable them to select, purchase, or order the chosen products, goods, and related services, as well as to process payment and delivery or fulfillment. If necessary for order fulfillment, we use service providers, in particular postal, freight forwarding, and shipping companies, to carry out delivery or fulfillment to our customers. For processing payment transactions, we use the services of banks and payment service providers. The required information is identified as such within the context of an order or a comparable procurement process and includes the information needed for delivery or provision and invoicing, as well as contact details to allow for any necessary consultations.

  • Types of data processed : Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. email, telephone numbers), contract data (e.g. subject matter of the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: prospective customers, business and contractual partners, customers.
  • Purposes of processing: Provision of contractual services and customer service, contact requests and communications, office and organizational processes, administration and answering of inquiries, security measures, evaluation of visitor actions, interest- and behavior-based marketing, profiling (creation of user profiles).
  • Legal basis : Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).

Payment service provider

Within the framework of contractual and other legal relationships, we offer the data subjects efficient and secure payment options based on legal obligations or otherwise on the basis of our legitimate interests, and for this purpose we use not only banks and credit institutions but also other payment service providers (hereinafter collectively referred to as “payment service providers”).

The data processed by payment service providers includes master data such as names and addresses, bank details such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract-related, total transaction, and recipient-related information. This information is necessary to process the transactions. However, the data you enter is processed and stored only by the payment service providers. This means we do not receive any account-related or credit card-specific information, but only confirmation or rejection of the payment. Under certain circumstances, the payment service providers transmit the data to credit agencies. The purpose of this transmission is to verify identity and creditworthiness. In this context, we refer you to the terms and conditions and privacy policies of the payment service providers.

Payment transactions are subject to the terms and conditions and privacy policies of the respective payment service providers, which can be accessed on their websites or transaction applications. We also refer you to these for further information and to exercise your rights of withdrawal, access, and other data subject rights.

  • Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons : Customers, potential customers.
  • Purposes of processing: Provision of contractual services and customer service.
  • Legal basis : Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).

Services and service providers:

Provision of online services and web hosting

To provide our online services securely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers they manage) the online services can be accessed. For this purpose, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security and technical maintenance services.

The data processed in connection with providing our hosting services may include all information relating to users of our online services and generated during their use and communication. This typically includes the IP address, which is necessary to deliver the content of online services to browsers, as well as all entries made within our online services or from websites.

Email sending and hosting: The web hosting services we use also include sending, receiving, and storing emails. For these purposes, the addresses of the recipients and senders, as well as other information related to email delivery (e.g., participating providers) and the content of the respective emails, are processed. This data may also be processed for spam detection purposes. Please note that emails are generally sent unencrypted over the internet. While emails are usually encrypted during transmission, they are not encrypted on the servers from which they are sent and received (unless end-to-end encryption is used). Therefore, we cannot assume any responsibility for the security of emails during transmission between the sender and their arrival on our server.

Collection of access data and log files : We (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may contain the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), and usually IP addresses and the requesting provider.

The server log files can be used for security purposes, e.g. to prevent server overloads (especially in the case of abuse attacks, so-called DDoS attacks), and to ensure the utilization of the servers and their stability.

  • Types of data processed : Content data (e.g., entries in online forms), usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Legal basis : Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).

contact

When you contact us (for example via contact form, email, telephone or social media), the information of the requesting persons will be processed to the extent necessary to respond to the contact requests and to carry out any requested measures.

Responding to contact requests within the framework of contractual or pre-contractual relationships is done to fulfill our contractual obligations or to answer (pre-)contractual inquiries, and otherwise on the basis of legitimate interests in answering the inquiries.

  • Types of data processed : Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons : Communication partners, interested parties.
  • Purposes of processing : Contact requests and communication, administration and answering of inquiries.
  • Legal basis : Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).

Services and service providers used:

  • Contact form : When users contact us via our contact form, email, or other communication channels, we process the data provided to us in this context in order to handle the communicated request. For this purpose, we process personal data within the framework of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfillment, and otherwise on the basis of our legitimate interests as well as the interests of our communication partners in responding to inquiries and our legal retention obligations.

Newsletters and electronic notifications

We only send newsletters, emails, and other electronic notifications (hereinafter referred to as "newsletters") with the recipient's consent or where legally permitted. If the content of a newsletter is specifically described during the registration process, this description is decisive for the user's consent. Otherwise, our newsletters contain information about our services and our company.

To subscribe to our newsletter, providing your email address is usually sufficient. However, we may ask you to provide a name for personalized addressing in the newsletter, or other information if necessary for the newsletter's purposes.

Double opt-in procedure : Registration for our newsletter is always carried out using a double opt-in procedure. This means that after registering, you will receive an email asking you to confirm your subscription. This confirmation is necessary to prevent anyone from subscribing using a different email address. Newsletter subscriptions are logged to document the registration process in accordance with legal requirements. This includes recording the registration and confirmation times as well as the IP address. Changes to your data stored with the email service provider are also logged.

Deletion and restriction of processing : We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them, in order to be able to prove previously given consent. The processing of this data is limited to the purpose of defending against potential claims. An individual deletion request is possible at any time, provided that the prior existence of consent is confirmed. In cases where we are obligated to permanently respect objections, we reserve the right to store the email address in a blacklist solely for this purpose.

The registration process is logged based on our legitimate interests for the purpose of documenting its proper execution. If we engage a service provider to send emails, this is done based on our legitimate interests in an efficient and secure email delivery system.

Legal basis : Newsletters are sent based on the recipient's consent or, if consent is not required, based on our legitimate interests in direct marketing, insofar as this is legally permissible, e.g., in the case of marketing to existing customers. If we commission a service provider to send emails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests in order to demonstrate that it was carried out lawfully.

Content : Information about us, our services, promotions and offers.

Analysis and performance measurement : The newsletters contain a so-called "web beacon," i.e., a pixel-sized file that is retrieved from our server when the newsletter is opened, or, if we use a mailing service provider, from their server. During this retrieval, technical information such as information about your browser and system, as well as your IP address and the time of retrieval, is collected.

This information is used to technically improve our newsletter based on technical data or target groups and their reading behavior based on their location (which can be determined using the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened, and which links are clicked. For technical reasons, this information can indeed be associated with individual newsletter recipients. However, it is neither our intention nor that of the email service provider to monitor individual users. Rather, the evaluations serve to understand the reading habits of our users and to adapt our content accordingly or to send different content depending on the interests of our users.

The evaluation of the newsletter and the measurement of its success are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves both our business interests and meets the expectations of the users.

Unfortunately, it is not possible to opt out of the performance measurement separately. In this case, the entire newsletter subscription must be cancelled or objected to.

  • Types of data processed : Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
  • Affected persons : Communication partners.
  • Purposes of processing : Direct marketing (e.g. by email or post).
  • Legal basis : Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
  • Opt-out : You can unsubscribe from our newsletter at any time, i.e., withdraw your consent or object to receiving further newsletters. You will find an unsubscribe link at the end of each newsletter, or you can alternatively use one of the contact options mentioned above, preferably by email.

Services and service providers:

Web analytics, monitoring and optimization

Web analytics (also known as "reach measurement") is used to evaluate visitor traffic to our online services and can include pseudonymized behavioral, interest-based, or demographic information about visitors, such as age or gender. Reach analysis allows us, for example, to identify when our online services, their features, or content are most frequently used or reused. It also helps us understand which areas require optimization.

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

For these purposes, so-called user profiles can be created and stored in a file (a so-called "cookie") or similar methods can be used for the same purpose. This information can include, for example, viewed content, visited websites and elements used there, as well as technical information such as the browser used, the computer system used, and information about usage times. If users have consented to the collection of their location data, this may also be processed, depending on the provider.

Users' IP addresses are also recorded. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, web analytics, A/B testing, and optimization do not store unique user data (such as email addresses or names), but rather pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the respective procedures.

Legal basis for processing : Where we request users' consent to use third-party services, the legal basis for processing their data is consent. Otherwise, user data is processed based on our legitimate interests (i.e., our interest in providing efficient, economical, and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Types of data processed : Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons : Users (e.g., website visitors, users of online services).
  • Purposes of processing : Reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behavior-based profiling, use of cookies), evaluation of visitor actions, profiling (creation of user profiles).
  • Security measures : IP masking (pseudonymization of the IP address).
  • Legal basis : Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).

Services and service providers:

  • Google Analytics: We use Google Analytics to measure and analyze the use of our online services based on a pseudonymous user identifier. This identifier does not contain any unique data such as names or email addresses. It is used to assign analytics information to a device in order to identify which content users have accessed within one or more sessions, which search terms they have used, whether they have revisited our online services, or how they have interacted with them. The usage time and duration, as well as the sources of users who refer to our online services and technical aspects of their devices and browsers, are also stored. Pseudonymous user profiles can be created using information from the use of different devices, and cookies may be used. Analytics provides higher-level geographic location data by collecting the following metadata based on IP address lookups: “City” (and the city’s inferred latitude and longitude), “Continent”, “Country”, “Region”, “Subcontinent” (and their ID-based equivalents). To ensure the protection of user data in the EU, Google receives and processes all user data via domains and servers within the EU. User IP addresses are not logged and are truncated by default by removing the last two octets. This IP address truncation for EU users takes place on EU servers. Furthermore, all sensitive data collected from users in the EU is deleted before being collected via EU domains and servers. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/ ; Privacy policy: https://policies.google.com/privacy ; Data processing agreement: https://business.safety.google/adsprocessorterms/ Legal basis for data transfers to third countries: Data protection framework, standard contractual clauses ( https://business.safety.google/adsprocessorterms ); Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de ; Ad settings: https://adssettings.google.com/authenticated ; Further information: https://privacy.google.com/businesses/adsservices (types of processing and data processed).
  • Google Tag Manager: Google Tag Manager is a solution that allows us to manage website tags via an interface and thus integrate other services into our online offering (see further details in this privacy policy). The Tag Manager itself (which implements the tags) does not, for example, create user profiles or store cookies. Google only receives the user's IP address, which is necessary for the operation of Google Tag Manager; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com ; Privacy policy: https://policies.google.com/privacy ; Order processing agreement:
    https://business.safety.google/adsprocessorterms ; Basis for data transfers to third countries: Data Protection Framework, Standard Contractual Clauses ( https://business.safety.google/adsprocessorterms ); Further information: https://privacy.google.com/businesses/adsservices (types of processing and data processed).

Online marketing

We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the display of advertising and other content (hereinafter collectively referred to as “content”) based on potential user interests and the measurement of its effectiveness.

For these purposes, so-called user profiles are created and stored in a file (a so-called "cookie") or similar methods are used to store information about the user relevant to displaying the aforementioned content. This information may include, for example, viewed content, visited websites, used online networks, as well as communication partners and technical information such as the browser used, the computer system used, and usage times. If users have consented to the collection of their location data, this may also be processed.

Users' IP addresses are also recorded. However, we use available IP masking techniques (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no clear user data (such as email addresses or names) is stored as part of the online marketing process; instead, pseudonyms are used. This means that neither we nor the providers of the online marketing methods know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in cookies or using similar methods. These cookies can generally be read later on other websites that use the same online marketing method and analyzed for the purpose of displaying content, supplemented with further data, and stored on the server of the online marketing method provider.

In exceptional cases, specific data may be associated with profiles. This is the case, for example, when users are members of a social network whose online marketing methods we use, and the network links the users' profiles with the aforementioned data. We would like to point out that users may enter into additional agreements with the providers, for example, by giving their consent during the registration process.

Generally, we only receive access to aggregated information about the success of our ads. However, through conversion tracking, we can verify which of our online marketing methods have led to a conversion, i.e., a contract signed with us. Conversion tracking serves solely to analyze the success of our marketing efforts.

Unless otherwise stated, we assume that the cookies used will be stored for a period of two years.

Information on the legal basis : Where we request users' consent to the use of third-party providers, data processing is based on this consent. Otherwise, user data is processed based on our legitimate interests (i.e., our interest in providing efficient, economical, and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Types of data processed : Usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses), location data (information about the geographic location of a device or person).
  • Affected persons : Users (e.g. website visitors, users of online services), interested parties.
  • Purposes of processing : Tracking (e.g., interest/behavioral profiling, use of cookies), remarketing, visit action evaluation, interest- and behavior-based marketing, profiling (creation of user profiles), conversion measurement (measuring the effectiveness of marketing measures), reach measurement (e.g., access statistics, recognition of returning visitors), target group creation (determining target groups relevant for marketing purposes or other content output), cross-device tracking (cross-device processing of user data for marketing purposes).
  • Security measures : IP masking (pseudonymization of the IP address).
  • Legal basis : Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
  • Right to object (opt-out) : We refer you to the privacy policies of the respective providers and the objection options (so-called “opt-out”) specified therein. If no explicit opt-out option is provided, you can deactivate cookies in your browser settings. However, this may limit the functionality of our online service. We therefore also recommend the following opt-out options, which are summarized for the respective areas:
    a) Europe: https://www.youronlinechoices.eu .
    b) Canada: https://www.youradchoices.ca/choices .
    c) USA: https://www.aboutads.info/choices .
    d) Interterritorial:
    https://optout.aboutads.info .

Services and service providers:

  • Facebook Pixel and Custom Audiences : Using the Facebook Pixel (or comparable functions for transmitting event data or contact data via interfaces in apps), Facebook can identify visitors to our website as a target audience for displaying advertisements (so-called "Facebook ads"). Accordingly, we use the Facebook Pixel to show the Facebook ads we place only to those users on Facebook and within the services of partners that collaborate with Facebook (the so-called "Audience Network," https://www.facebook.com/audiencenetwork/) who have also shown interest in our website or exhibit certain characteristics (e.g., interest in specific topics or products resulting from the websites they have visited) that we transmit to Facebook (so-called "Custom Audiences"). With the help of the Facebook Pixel, we also want to ensure that our Facebook ads correspond to the potential interests of users and are not perceived as intrusive. With the help of the Facebook pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by determining whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion measurement”); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com ; Privacy policy: https://www.facebook.com/about/privacy ; Legal basis for transfers to third countries: The General Data Protection Regulation (GDPR), standard contractual clauses
  • The EU Data Transfer Addendum ( https://www.facebook.com/legal/EU_data_transfer_addendum ) serves as the basis for the processing of event data of EU citizens in the USA in the case of data processing by Facebook on behalf of a controller and is included in the “Facebook Platform Terms of Service” ( https://developers.facebook.com/terms ) regarding Facebook’s own processing of event data in connection with ad placement; Further information: The “Data Protection Policy” ( https://www.facebook.com/legal/terms/dataprocessing/update) applies to event data that Facebook processes on behalf of a controller to provide reports and analyses for companies; In addition, the “Controller Addendum” serves as the joint controllership agreement (Article 26(1), third sentence, GDPR), which is relevant in the case of Facebook’s independent processing of event data for targeting purposes and for improving and securing Facebook products.
  • Google Ad Manager: We use the “Google Marketing Platform” (and services like “Google Ad Manager”) to place ads on the Google advertising network (e.g., in search results, videos, on websites, etc.). The Google Marketing Platform is characterized by its ability to display ads in real time based on inferred user interests. This allows us to target ads for our online offerings more precisely and present users only with ads that potentially match their interests. For example, when a user is shown ads for products they have shown interest in on other online platforms, this is called “remarketing.” Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com ; privacy policy: https://policies.google.com/privacy ; further information: types of processing and data processed: https://privacy.google.com/businesses/adsservices Data Processing Terms for Google Advertising Products: Information on services ; Data Processing Terms between Data Controllers: https://business.safety.google/adscontrollerterms ; When Google acts as a data processor, Data Processing Terms for Google Advertising Products and Standard Contractual Clauses for data transfers to third countries: https://business.safety.google/adsprocessorterms; Basis for transfers to third countries: Data Protection Framework, Standard Contractual Clauses ( https://business.safety.google/adsprocessorterms ).
  • Google Ads and Conversion Tracking : We use the online marketing method “Google Ads” to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads (so-called “conversion”). We also measure the conversion of these ads. However, we only receive the anonymous total number of users who clicked on our ad and were redirected to a page marked with a so-called “conversion tracking tag.” We do not receive any information that could identify individual users. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com ; privacy policy: https://policies.google.com/privacy Further information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices ; Data processing terms for Google advertising products: Information on services; Data processing terms between data controllers: https://business.safety.google/adscontrollerterms; Basis for transfers to third countries: Data protection framework, standard contractual clauses ( https://business.safety.google/adsprocessorterms ).

Presence on social networks (Social Media)

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

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

Furthermore, user data is typically processed within social networks for market research and advertising purposes. For example, user profiles can be created based on usage patterns and the resulting user interests. These user profiles can then be used to place advertisements both within and outside the networks that are likely to match the users' interests. For these purposes, cookies are usually stored on users' computers, recording their usage patterns and interests. In addition, data can also be stored in user profiles independently of the devices used by the user (especially if the users are members of the respective platforms and are logged in).

For a detailed description of the respective processing methods and the options for objection (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.

In the event of requests for information or the assertion of data subject rights, we would also like to point out that these can be most effectively addressed directly with the service providers. Only the providers have access to user data and can take appropriate measures and provide information directly. However, if you still require assistance, please feel free to contact us.

  • Types of data processed : Inventory data (e.g. names, addresses), contact data (e.g. email addresses, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons : Users (e.g., website visitors, users of online services).
  • Purposes of processing : Contact requests and communication, tracking (e.g. interest/behavioral profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
  • Legal basis : Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).

Services and service providers:

Plugins and embedded functions and content

We integrate functional and content-related elements into our online services that may originate from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may include, for example, graphics, videos, social media buttons, and posts (hereinafter collectively referred to as "content").

The integration of third-party content providers always requires them to process the user's IP address, as they cannot send the content to the user's browser without it. The IP address is therefore necessary for displaying this content or functionality. We strive to use only content from providers who use the IP address solely for delivering the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. These pixel tags can be used to analyze information such as visitor traffic on the pages of this website. The pseudonymized information may also be stored in cookies on the user's device and may include technical information about the browser and operating system, referring websites, the time of the visit, and other information related to the use of our online services, as well as be combined with such information from other sources.

Information on the legal basis : Where we request users' consent to the use of third-party providers, the legal basis for processing the data is consent. Otherwise, user data is processed based on our legitimate interests (i.e., our interest in providing efficient, economical, and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Types of data processed : Usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses), location data (information about the geographic location of a device or person), content data (e.g., entries in online forms), inventory data (e.g., names, addresses), contact data (e.g., email addresses, telephone numbers).
  • Affected persons : Users (e.g. website visitors, users of online services), communication partners.
  • Purposes of processing : Provision of our online service and user experience, provision of contractual services and customer service, handling contact requests and communication, tracking (e.g. interest/behavioral profiling, use of cookies), interest-based and behavioral marketing, profiling (creation of user profiles), security measures, management and response to inquiries.
  • Legal basis : Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR), consent (Art. 6 para. 1 sentence 1 lit. a GDPR), performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR).

Services and service providers:

  • Facebook Plugins and Content : Facebook social plugins and content – ​​This may include, for example, content such as images, videos, or text, and buttons that allow users to share content from this online service within Facebook. The list and appearance of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/ – We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt, as part of a transmission (but not for further processing), of “event data” that Facebook collects or receives as part of a transmission via the Facebook social plugins (and content embedding functions) implemented on our online service, for the purposes of: a) displaying content and advertising information relevant to the presumed interests of users; b) providing commercial and transactional messages (e.g., targeting users via Facebook Messenger); c) improving ad delivery and personalizing features and content (e.g., improving the recognition of which content or advertising information is likely to correspond to users' interests). We have entered into a special agreement with Facebook (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum ) which specifically regulates which security measures Facebook must comply with ( https://www.facebook.com/legal/terms/data_security_terms ) and in which Facebook has committed to respecting the rights of data subjects (i.e., users can, for example, provide information or submit deletion requests directly to Facebook). Note: When Facebook provides us with metrics, analytics, and reports (which are aggregated, meaning they do not contain information about individual users and are anonymous to us), this processing is not under joint controllership but is governed by a data processing agreement (“Data Processing Terms”, https://www.facebook.com/legal/terms/dataprocessing ), the “Data Security Terms” ( https://www.facebook.com/legal/terms/data_security_terms ), and, with regard to processing in the USA, by standard contractual clauses (“Facebook EU Data Transfer Addendum”, https://www.facebook.com/legal/EU_data_transfer_addendum ”). Users' rights (in particular, the rights to access, erasure, objection, and lodging a complaint with the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com ; Privacy Policy: https://www.facebook.com/about/privacy .
  • Google Fonts : We integrate fonts (“Google Fonts”) from the provider Google, whereby user data is used exclusively for the purpose of displaying the fonts in the user's browser. This integration is based on our legitimate interests in the technically secure, maintenance-free, and efficient use of fonts, their uniform display, and in compliance with any applicable licensing restrictions. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://fonts.google.com/ ; privacy policy: https://policies.google.com/privacy .
  • YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://www.youtube.com ; Privacy policy: https://policies.google.com/privacy ; Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de ; Ad settings: https://adssettings.google.com/authenticated .

Deletion of data

The data we process will be deleted in accordance with legal requirements as soon as your consent to the processing is withdrawn or other authorizations cease to apply (for example, if the purpose of processing this data no longer exists or it is no longer necessary for that purpose).

If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted to those purposes. This means that the data will be blocked and not processed for any other purpose. This applies, for example, to data that must be retained for commercial or tax law reasons, or whose storage is necessary for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person.

Further information on the deletion of personal data can be provided in the individual data protection notices of this privacy policy.

Changes and updates to the privacy policy

We ask that you regularly review the content of our privacy policy. We will update the privacy policy as soon as changes in our data processing activities make this necessary. We will inform you if the changes require your active participation (e.g., consent) or other individual notification.

When we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time, and please check the information before contacting us.

Rights of data subjects

As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:

  • Right to object : You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) of the GDPR, including profiling based on those provisions. Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right of withdrawal for consents: You have the right to withdraw any consent you have given at any time.
  • Right of access : You have the right to request information about whether personal data concerning you is being processed, and to receive information about this data as well as further information and a copy of the data in accordance with legal requirements.
  • Right to rectification : You have the right, in accordance with legal regulations, to request that data concerning you be completed or that inaccurate data concerning you be rectified.
  • Right to erasure and restriction of processing: In accordance with legal regulations, you have the right to request that your personal data be erased without undue delay, or alternatively, in accordance with legal regulations, to request the restriction of the processing of your data.
  • Right to data portability : You have the right to receive the data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with legal requirements, or to request its transmission to another controller.
  • Right to lodge a complaint with a supervisory authority : You also have the right, in accordance with legal provisions, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you believe that the processing of personal data relating to you infringes the GDPR.

Definitions of terms

This section provides an overview of the terms used in this privacy policy. Many of the terms are derived from the law and are primarily defined in Article 4 of the GDPR. The legal definitions are binding. The following explanations, however, are mainly intended to aid understanding. The terms are listed alphabetically.

  • Conversion tracking : “Conversion tracking” refers to a method used to determine the effectiveness of marketing measures. This typically involves storing a cookie on users' devices within the websites where the marketing activities take place, and then retrieving it again on the target page. This allows us, for example, to track whether the ads we placed on other websites were successful.
  • Credit report : Automated decisions are based on automated data processing without human intervention (for example, the automatic rejection of a purchase on account, an online loan application, or an online job application process without human intervention). According to Article 22 of the GDPR, such automated decisions are only permissible if the data subjects consent, if they are necessary for the performance of a contract, or if national laws permit such decisions.
  • Cross-device tracking: Cross-device tracking is a form of tracking in which user behavior and interest information is collected across devices in so-called profiles by assigning users an online identifier. This allows user information to be analyzed for marketing purposes regardless of the browsers or devices used (e.g., mobile phones or desktop computers). With most providers, the online identifier is not linked to unique data such as names, postal addresses, or email addresses.
  • IP masking : “IP masking” is a method in which the last octet, i.e., the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymizing processing methods, especially in online marketing.
  • Interest-based and behavioral marketing : Interest-based and/or behavioral marketing refers to the practice of predicting users' potential interests as accurately as possible in advertisements and other content. This is done based on information about their past behavior (e.g., visiting specific websites and the time spent on them, purchasing behavior, or interaction with other users), which is stored in a so-called profile. Cookies are typically used for this purpose.
  • Conversion tracking : Conversion tracking is a method used to determine the effectiveness of marketing campaigns. This typically involves storing a cookie on users' devices within the websites where the marketing activities take place, and then retrieving it again on the target page. This allows us, for example, to track whether the ads we placed on other websites were successful.
  • Personal data : “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiling : “Profiling” is any form of automated processing of personal data where such data is used to analyze, evaluate, or predict certain personal aspects of a natural person (e.g., interests in specific content or the use of certain services). Depending on the type of profiling, this can include information about age, gender, location and movement data, interactions with websites and their content, purchasing behavior, social interactions with other people, etc. Cookies and web beacons are often used for profiling purposes.
  • Audience measurement : Audience measurement (also known as web analytics) is used to evaluate the visitor traffic of an online service and can include visitors' behavior or interests in specific information, such as website content. With the help of audience measurement, website operators can see, for example, when visitors access their website and what content they are interested in. This allows them, for instance, to better tailor the website content to their visitors' needs. For audience measurement purposes, pseudonymous cookies and web beacons are frequently used to recognize returning visitors and thus obtain more accurate analyses of the use of an online service.
  • Remarketing : The term “remarketing” or “retargeting” refers to the practice of recording, for example for advertising purposes, which products a user has shown interest in on a website, in order to remind the user of these products on other websites, e.g. in advertisements.
  • Location data : Location data is generated when a mobile device (or any other device with the technical capabilities for location tracking) connects to a cell tower, Wi-Fi network, or similar location-determining technology. Location data is used to display the geographically determined position on Earth where the device is located. For example, location data can be used to display map features or other location-based information.
  • Tracking : The term "tracking" refers to the ability to monitor user behavior across multiple online services. Typically, behavioral and interest information related to the online services used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
  • Controller : A “controller” is the natural or legal person, public authority, agency or other body which, alone or jointly with others, decides on the purposes and means of processing personal data.
  • Processing : “Processing” means any operation or set of operations performed on personal data, whether automated or not. The term is broad and encompasses virtually any handling of data, be it collection, analysis, storage, transmission, or erasure.
  • Audience building : Audience building (or “Custom Audiences”) refers to defining target groups for advertising purposes, such as displaying ads. Based on a user's interest in specific products or topics online, it can be inferred that this user is interested in ads for similar products or the online store where they viewed the products. “Lookalike Audiences” (or similar audiences) are created when content deemed suitable is shown to users whose profiles or interests are likely to match those of the users for whom the profiles were created. Cookies and web beacons are typically used to create Custom Audiences and Lookalike Audiences.
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