Privacy Policy

Introduction

With the following data protection declaration we would like to inform you about which types of your personal data (hereinafter also referred to as “data”) we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both within the scope of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offering”).

The terms used are not gender specific.

Status: 5. August 2023

Table of contents

  • Introduction
  • Responsible person
  • Overview of processing
  • Contact data protection officer
  • Relevant legal bases
  • Security measures
  • Data processing in third countries
  • Data deletion
  • Use of cookies
  • Provision of online offerings and web hosting
  • Blogs and publication media
  • Contact and inquiries management
  • Application process
  • Cloud services
  • Newsletters and electronic notifications
  • Promotional communication via e-mail, mail, fax or telephone
  • Web analysis, monitoring and optimization
  • Presence in social networks (social media)
  • Changes and updates to the data protection declaration
  • Rights of data subjects
  • Definitions of terms

Responsible person

Konrad Hintermair / DevelopX GmbH
Große Reichenstraße 27
20457 Hamburg

Authorized representatives: Konrad Hintermair.

E-mail address: contact@developx.com.

Imprint: https://developx.com/en/imprint/.

Contact data protection officer

Dr. Sebastian Kraska: email@iitr.de.

Overview of processing

The following overview summarizes 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).
  • Applicant data (e.g. personal details, postal and contact addresses, the documents associated with the application and the information contained therein, such as cover letters, CVs, certificates and other information about their person or qualifications provided voluntarily by applicants with regard to a specific position) .
  • Content data (e.g. entries in online forms).
  • Contact details (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).

Categories of data subjects

  • Employees (e.g. employees, applicants, former employees).
  • Applicant.
  • Interested persons.
  • Communication partner.
  • Customers.
  • Users (e.g. website visitors, users of online services).

Purposes of processing

  • Provision of our online offering and user-friendliness.
  • Application process (justification and possible subsequent implementation as well as possible later termination of the employment relationship).
  • Office and organizational procedures.
  • Direct marketing (e.g. by email or post).
  • Feedback (e.g. collecting feedback via online form).
  • Marketing.
  • Contact inquiries and communication.
  • Profiles with user-related information (creating user profiles).
  • Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Provision of contractual services and customer service.

Relevant legal bases

Below you will find an overview of the legal basis of the GDPR on the basis of which we process personal data. Please note that in addition to the regulations of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If more specific legal bases apply in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR) – The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR) – Processing is necessary for the performance of a contract to which the data subject is a party or to carry out pre-contractual measures at the request of the data subject take place.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR) – Processing is necessary to safeguard the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject are infringing on the protection of personal data Data requirements predominate.
  • Application process as a pre-contractual or contractual relationship (Art. 9 Para. 2 lit. b GDPR) – As far as special categories of personal data within the meaning of Art. 9 Para. 1 GDPR (e.g. health data, such as severely disabled status or ethnic origin) are included in the application process. are requested from applicants so that the person responsible or the data subject can exercise his or her rights under labor law and social security and social protection law and fulfill his or her obligations in this regard, the processing takes place in accordance with Article 9 para 2 lit. b. GDPR, in the case of protecting the vital interests of applicants or other persons in accordance with Art. 9 Para. 2 lit. c. GDPR or for the purposes of health care or occupational medicine, for assessing the employee’s ability to work, for medical diagnostics, care or treatment in the health or social sector or for the administration of systems and services in the health or social sector in accordance with Article 9 Paragraph 2 lit. h. GDPR. In the case of communication of special categories of data based on voluntary consent, their processing takes place on the basis of Article 9 Paragraph 2 Letter a. GDPR.

National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national data protection regulations apply in Germany. This includes in particular the law to protect against misuse of personal data during data processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to deletion, the right to object, the processing of special categories of personal data, processing for other purposes and transmission and automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

Safety measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons to ensure a level of protection appropriate to the risk.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, ensuring availability and its separation. We have also set up procedures to ensure that the rights of those affected are exercised, data are deleted and responses are made to data threats. We also take the protection of personal data into account when developing or selecting hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

Shortening of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a full IP address is not necessary, the IP address is shortened (also referred to as “IP masking”). Here, the last two digits or the last part of the IP address after a period are removed or replaced with placeholders. Shortening the IP address is intended to prevent or make it significantly more difficult to identify a person based on their IP address.

SSL encryption (https): To protect your data transmitted via our online offering, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Data processing in third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing in the context of using third-party services or disclosing or transmitting data to other people, bodies or companies takes place, this only takes place in accordance with the legal requirements.

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

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as the consent permitted for processing is revoked or other permissions no longer apply (e.g. if the purpose for processing this data no longer applies or it is not necessary for the purpose).

Unless the data is deleted because it is required for other legally permissible purposes, its processing will be limited to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.

As part of our data protection information, we can provide users with further information about the deletion and storage of data that specifically applies to the respective processing processes.

Use of cookies

Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after their visit to an online offering. The information stored can include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was watched. The term “cookies” also includes other technologies that fulfill the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also referred to as “user IDs”).

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their browser.
  • Persistent cookies: Persistent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The interests of users, which are used to measure reach or for marketing purposes, can also be stored in such a cookie.
  • First-party cookies: First-party cookies are set by us.
  • Third-party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or absolutely necessary) cookies: On the one hand, cookies can be absolutely necessary for the operation of a website (e.g. to save logins or other user input or for security reasons).
  • Statistics, marketing and personalization cookies: Cookies are also generally used as part of reach measurement and when the interests of a user or their behavior (e.g. viewing certain content, using functions, etc.) are recorded on individual websites in a user profile get saved. Such profiles are used, for example, to show users content that corresponds to their potential interests. This process is also referred to as “tracking”, i.e. tracking the potential interests of users. If we use cookies or “tracking” technologies, we will inform you separately in our data protection declaration or when obtaining consent.

Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this is the case and you agree to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and its improvement) or if the use of cookies is necessary to fulfill our contractual obligations.

Storage period: Unless we provide you with explicit information about the storage period of permanent cookies (e.g. as part of a so-called cookie opt-in), please assume that the storage period can be 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 option at any time to revoke your consent or to object to the processing of your data using cookie technologies ( collectively referred to as “opt-out”). You can first declare your objection using your browser settings, for example by deactivating the use of cookies (which may also limit the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be expressed using a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ become. You can also receive further objection information as part of the information about the service providers and cookies used.

Processing of cookie data on the basis of consent: We use a cookie consent management process, in which users consent to the use of cookies or the processing mentioned within the cookie consent management process and providers can be obtained and managed and revoked by users. The declaration of consent is saved so that it does not have to be asked again and to be able to prove consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or using comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information about the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. Here, a pseudonymous user identifier is created and stored with the time of consent, information about the scope of the consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and device used.

Cookie settings/objection option:

oveleon.de/cookiebar.html

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Use of cookies

Provision of online offerings and web hosting

In order to be able to provide our online offering securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offering can be accessed. For these purposes, 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 as part of the provision of the hosting offer may include all information relating to the users of our online offer that arises in the context of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the content of online offerings to browsers, and all entries made within our online offering or on 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 regarding the sending of emails (e.g. the providers involved) as well as the contents of the respective emails are processed. The aforementioned data may also be processed for SPAM detection purposes. We ask you to note that emails on the Internet are generally not sent encrypted. As a rule, emails are encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore assume no responsibility for the transmission path of emails between the sender and receipt on our server.

  • 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).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data will only be processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. Furthermore, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.

  • 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 data). information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and customer service, feedback (e.g. collecting feedback via online form).
  • Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Contact and inquiry management

When you contact us (e.g. via contact form, email, telephone or via social media), the information provided by the person making the request will be processed to the extent that this is necessary to answer the contact requests and any requested measures.

Answering contact inquiries within the framework of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to answer (pre-)contractual inquiries and otherwise on the basis of the 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).
  • Data subjects: Communication partners.
  • Purposes of processing: Contact requests and communication.
  • Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Application process

The application process requires that applicants provide us with the data required for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the information provided there.

Basically, the required information includes personal information such as name, address, contact details and evidence of the qualifications required for a position. Upon request, we will also be happy to provide information about what information is required.

If provided, applicants can submit their applications to us using an online form. The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications via email. However, we ask you to note that emails on the Internet are generally not sent encrypted. As a rule, emails are encrypted in transit, but not on the servers from which they are sent and received. We can therefore assume no responsibility for the transmission path of the application between the sender and receipt on our server.

For the purposes of finding applicants, submitting applications and selecting applicants, we may use applicant management and/or recruitment software and platforms and services from third-party providers in compliance with legal requirements.

Applicants are welcome to contact us about how to submit their application or send us the application by post.

Processing of special categories of data: If special categories of personal data within the meaning of Article 9 Para. 1 GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants as part of the application process, so that the person responsible or the data subject can do so If he or she can exercise the rights arising from labor law and social security and social protection law and fulfill his or her obligations in this regard, their processing will take place in accordance with Article 9 Paragraph 2 Letter b. GDPR, in the case of protecting the vital interests of applicants or other persons in accordance with Art. 9 Para. 2 lit. c. GDPR or for the purposes of health care or occupational medicine, for assessing the employee’s ability to work, for medical diagnostics, for care or treatment in the health or social sector or for the administration of systems and services in the health or social sector in accordance with Art. 9 Paragraph 2 Letter h. GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing takes place on the basis of Article 9 Paragraph 2 Letter a. GDPR.

Deletion of data: If the application is successful, the data provided by applicants can be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicant’s data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. The deletion will take place, subject to a justified revocation by the applicant, at the latest after a period of six months has elapsed, so that we can answer any follow-up questions about the application and fulfill our obligations to provide proof under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses are archived in accordance with tax law requirements.

Admission to an applicant pool: Admission to an applicant pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the ongoing application process and that they can revoke their consent at any time in the future.

  • Types of data processed: Applicant data (e.g. personal details, postal and contact addresses, the documents associated with the application and the information contained therein, such as cover letters, CVs, certificates and other personal information provided voluntarily by applicants with regard to a specific position or qualification).
  • Affected Persons: Applicants.
  • Purposes of processing: Application process (justification and possible subsequent implementation as well as possible subsequent termination of the employment relationship).
  • Legal basis: Application process as a pre-contractual or contractual relationship (Art. 9 Para. 2 lit. b GDPR).

Cloud services

We use software services accessible via the Internet and running on their providers’ servers (so-called “cloud services”, also referred to as “Software as a Service”) for the following purposes: document storage and management, calendar management, emailing, spreadsheets and presentations, exchanging documents, content and information with specific recipients or publishing web pages, forms or other content and information, as well as chatting and participating in audio and video conferences.

Within this framework, personal data can be processed and stored on the providers’ servers, provided that they are part of communication processes with us or are otherwise processed by us as set out in this data protection declaration. This data may include, in particular, user master data and contact details, data on processes, contracts, other processes and their content. The cloud service providers also process usage data and metadata, which they use for security purposes and service optimization.

If we use cloud services to provide forms or other documents and content to other users or publicly accessible websites, the providers may set cookies on the users’ devices for the purposes of web analysis or to remember user settings (e.g. in the case of media control). remember, save.

Notes on legal bases: If we ask for consent to use the cloud services, the legal basis for processing is consent. Furthermore, their use can be part of our (pre-)contractual services, provided the use of the cloud services has been agreed within this framework. Otherwise, user data will be processed based on our legitimate interests (i.e. interest in efficient and secure administration and collaboration processes).

  • 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 data). information, IP addresses).
  • Affected persons: Customers, employees (e.g. employees, applicants, former employees), interested parties, communication partners.
  • Purposes of processing: Office and organizational procedures.
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), fulfillment of the contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 P. 1 lit. f. GDPR).

Services and service providers used:

Newsletters and electronic notifications

We only send newsletters, emails and other electronic notifications (hereinafter “newsletter”) with the consent of the recipient or legal permission. If the contents are specifically described as part of a registration for the newsletter, they are decisive for the consent of the user. Our newsletters also contain information about our services and us.

In order to register for our newsletters, it is generally sufficient to provide your email address. However, we may ask you to provide a name so that you can be addressed personally in the newsletter, or other information if this is necessary for the purposes of the newsletter.

Double opt-in process: Registration for our newsletter is generally carried out using a so-called double opt-in process. This means that after registering you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can log in with someone else’s email address. Registrations for the newsletter are logged in order to be able to provide evidence of the registration process in accordance with legal requirements. This includes storing the registration and confirmation times as well as the IP address. Changes to your data stored by the shipping service provider are also logged.

Deletion and restriction of processing: We can store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time. In the event of obligations to permanently observe contradictions, we reserve the right to store the email address in a blacklist (so-called “blocklist”) solely for this purpose.

The registration process is recorded on the basis of our legitimate interests for the purpose of providing evidence of its proper execution. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure shipping system.

Notes on legal bases: The newsletter is sent on the basis of the consent of the recipient or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of advertising 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 based on our legitimate interests to demonstrate that it was carried out in accordance with the law.

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

Measurement of opening and click rates: 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 shipping service provider, from its server During this retrieval, technical information is first collected, such as information about the browser and your system, as well as your IP address and the time of retrieval.

This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their access locations (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. This information is assigned to the individual newsletter recipients and stored in their profiles until it is deleted. The evaluations help us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The measurement of the opening rates and click rates as well as the storage of the measurement results in the users’ profiles and their further processing are based on the users’ consent.

Unfortunately, it is not possible to revoke the success measurement separately; in this case, the entire newsletter subscription must be canceled or objected to. In this case, the saved profile information will be deleted.

  • 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).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g. by email or post).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
  • Option to object (opt-out): You can cancel your receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email.

Services and service providers used:

Advertising communication via email, post, fax or telephone

We process personal data for the purposes of advertising communication, which can take place via various channels, such as email, telephone, post or fax, in accordance with legal requirements.

The recipients have the right to revoke their consent at any time or to object to the advertising communication at any time.

After revocation or objection, we can store the data required to prove consent for up to three years based on our legitimate interests before deleting it. The processing of this data is limited to the purpose of possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g. by email or post).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Web analysis, monitoring and optimization

Web analysis (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and can include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at what time our online offering or its functions or content are used most frequently or invite reuse. We can also understand which areas require optimization.

In addition to web analysis, we can also use testing procedures, for example 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 (so-called “cookie”) or similar procedures can be used for the same purpose. This information may include, for example, content viewed, websites visited and elements used there and technical information such as the browser used, the computer system used and information about times of use. If users have consented to the collection of their location data, this can also be processed, depending on the provider.

The users’ IP addresses are also stored. However, we use an IP masking process (i.e. pseudonymization by shortening the IP address) to protect users. In general, as part of web analysis, A/B testing and optimization, no clear user data (such as email addresses or names) is stored, but rather pseudonyms. This means that we and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data will be processed based on our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors), profiles with user-related information (creation of user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Services and service providers used:

  • Google Analytics: reach measurement and web analysis; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy.
  • Google Optimize: Use of Google Analytics data for the purposes of improving areas of our online offering and improving the alignment of our marketing measures with the potential interests of users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website:https://optimize.google.com; Privacy policy: https://policies.google.com/privacy; Option to object (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de,  Settings for displaying advertisements: https://adssettings.google.com/authenticated.
  • Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offering (refer to further information in this data protection declaration). The Tag Manager itself (which implements the tags) is therefore used, for example: For example, user profiles have not yet been created or cookies have been stored. Google only learns the user’s IP address, which is necessary to run Google Tag Manager. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy.

Presences in social networks (social media)

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

We would like to point out that user data may be processed outside the European Union. This can result in risks for users because, for example, it could make it more difficult to enforce users’ rights.

Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on usage behavior and the resulting interests of users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behavior and interests of the users are stored. Furthermore, data can also be stored in the usage profiles regardless of the devices used by the users (particularly if the users are members of the respective platforms and are logged in to them).

For a detailed description of the respective forms of processing and the options for objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of the rights of those affected, we would also like to point out that these can most effectively be asserted with the providers. Only the providers have access to user data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

  • Types of data processed: 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).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Contact inquiries and communication, feedback (e.g. collecting feedback via online form), marketing.
  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Services and service providers used:

Changes and updates to the data protection declaration

We ask you to regularly inform yourself about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

If we provide addresses and contact information for companies and organizations in this data protection declaration, please note that the addresses may change over time and ask you to check the information before contacting us.

Rights of data subjects

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

  • Right to object: You have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data, which is carried out on the basis of Article 6 (1) (e) or (f) of the GDPR; This also applies to profiling based on these provisions. If your personal data is processed for the purpose of direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; This also applies to profiling insofar as it is connected to such direct advertising.
  • Right to revoke consent: You have the right to revoke your consent at any time.
  • Right to information: You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: In accordance with legal requirements, you have the right to request that the data concerning you be completed or that incorrect data concerning you be corrected.
  • Right to deletion and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be deleted immediately or, alternatively, to request that the processing of the data be restricted in accordance with the legal requirements.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with legal requirements or to request that it be transmitted to another person responsible.
  • Complaint to a supervisory authority: In accordance with the legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State in which you usually reside, the supervisory authority of your place of work or the place of the alleged violation to lodge a complaint if you believe that the processing of your personal data violates the GDPR.

Supervisory authority responsible for us:

The Hamburg Commissioner for Data Protection and Freedom of Information
Ludwig-Erhard-Str 22, 7. OG
20459 Hamburg
mailbox@datenschutz.hamburg.de
https://datenschutz-hamburg.de/pages/kontakt/

Definitions of terms

This section provides an overview of the terms used in this data protection declaration. Many of the terms are taken from the law and are defined primarily in Article 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended primarily to provide understanding. The terms are sorted alphabetically.

  • 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. Therefore, IP masking is a means of pseudonymizing processing procedures, especially in online marketing
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); A natural person is considered identifiable if he or she can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special features, which are an expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any type of automated processing of personal data, which consists in the use of such personal data to identify certain personal aspects relating to a natural person (depending on the type of profile creation, different information regarding demographics, behavior and interests, such as interaction with websites and their content, etc.) can be analyzed, evaluated or predicted (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, identify at what time visitors visit their website and what content they are interested in. This allows you, for example, to better adapt the content of the website to the needs of your visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyzes of the use of an online offering.
  • Controller: The “controller” is the natural or legal person, public authority, agency or other body that alone or jointly with others decides on the purposes and means of processing personal data.
  • Processing: “Processing” means any operation or series of operations carried out on personal data, whether or not by automated means. The term is wide-ranging and includes practically every handling of data, be it collecting, evaluating, storing, transmitting or deleting.