Introduction
With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context 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 offer").
The terms used are not gender-specific.
Status: 08 March 2022
Table of contents
- Person responsible
- Contact data protection officer
- Overview of processing operations
- Relevant legal bases
- Security measures
- Transfer and disclosure of personal data
- Data processing in third countries
- Use of cookies
- Provision of the online offer and web hosting
- Blogs and publication media
- Making contact
- Communication via messenger
- Application procedure
- Web analysis, monitoring and optimization
- Online marketing
- Presence in social networks (social media)
- Plugins and embedded functions and content
- Processing when using the reporting system
- Deletion of data
- Changes and updates to the privacy policy
- Rights of the data subjects
- Definitions of terms
Person responsible
Meffert AG Farbwerke
Sandweg 15
55543 Bad Kreuznach
Germany
Persons authorized to represent the company: Klaus Meffert (Chairman of the Executive Board), Dieter Meffert (Member of the Executive Board), Chairman of the Supervisory Board: Dr. Dietrich Bihr
E-Mail-Adresse: info@meffert.com
Telephone: +49 671-870-0
Imprint: https://www.meffert.com/servicemenue/impressum/
Contact Data Protection Officer
S&L ITcompliance GmbH
Florinstraße 18
56218 Mülheim-Kärlich
Phone: 0261 92736-0
E-mail: datenschutzbeauftragter@meffert.com
Overview of the processing operations
The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
- Event data (Facebook) ("event data" is data that can be transmitted by us to Facebook via Facebook pixels (via apps or in other ways), for example, and relates to people or their actions; the data includes, for example, information about visits to websites, interactions with content, functions, app installations, product purchases, etc.). The event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); event data does not include the actual content (such as comments written), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data is deleted by Facebook after a maximum of two years, the target groups formed from them are deleted when our Facebook account is deleted).
- Inventory data (e.g. names, addresses).
- Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, CV, certificates and other personal or qualification information provided by applicants with regard to a specific position or voluntarily).
- Content data (e.g. entries in online forms).
- Contact data (e.g. e-mail, telephone numbers).
- Meta/communication data (e.g. device information, IP addresses).
- Usage data (e.g. websites visited, interest in content, access times).
- Location data (information on the geographical position of a device or person).
Categories of data subjects
- Applicants.
- Interested parties.
- Communication partners.
- Users (e.g. website visitors, users of online services).
Purposes of the processing
- Provision of our online services and user-friendliness.
- Conversion measurement (measurement of the effectiveness of marketing measures).
- Application procedure (justification and possible subsequent implementation and possible subsequent termination of the employment relationship).
- Cross-device tracking (cross-device processing of user data for marketing purposes).
- Direct marketing (e.g. by email or post).
- Feedback (e.g. collecting feedback via an online form).
- Interest-based and behavioural marketing.
- Contact requests and communication.
- Profiling (creation of user profiles).
- Remarketing.
- Reach measurement (e.g. access statistics, recognizing returning visitors).
- Security measures.
- Tracking (e.g. interest/behavioural profiling, use of cookies).
- Provision of contractual services and customer service.
- Managing and responding to enquiries.
- Target group formation (determination of target groups relevant for marketing purposes or other output of content).
Relevant legal bases
In the following, we inform you of the legal basis of the General Data Protection Regulation (GDPR), on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, the national data protection regulations in your or our country of residence and domicile may apply. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.
- Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR) - The data subject has given their consent to the processing of their personal data for a specific purpose or several specific purposes.
- Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- 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.
- Application procedure as a pre-contractual or contractual relationship (Art. 9 para. 2 lit. b GDPR) - Insofar 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 requested from applicants as part of the application procedure so that the controller or the data subject can exercise their rights under labour law and social security and social protection law and fulfil their obligations in this regard. rights arising from labour law and social security and social protection law and to fulfil his or her obligations in this regard, their processing is carried out in accordance with Art. 9 para. 2 lit. b. GDPR. GDPR, in the case of the protection of vital interests of applicants or other persons pursuant to Art. 9 para. 2 lit. c. GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee's ability to work, for medical diagnosis, health or social care or treatment or for the management of health or social care systems and services pursuant to Art. 9 para. 2 lit. h. GDPR. GDPR. In the case of communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 para. 2 lit. 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. These include, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases, including profiling. It also 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. The data protection laws of the individual federal states may also apply.
Security measures
We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, 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, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, disclosure, safeguarding availability and separation of the data. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data threats. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and processes in accordance with the principle of data protection, through technology design and data protection-friendly default settings.
SSL encryption (https): We use SSL encryption to protect your data transmitted via our online offering. You can recognise such encrypted connections by the prefix https:// in the address bar of your browser.
Transfer and disclosure of personal data
As part of our processing of personal data, data may be transferred to other bodies, companies, legally independent organisational units or persons or disclosed to them. The recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.
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 if the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this will only take 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 recognised level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 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 ).
Use of cookies
Cookies are text files that contain data from websites or domains visited 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 service. The information stored may include, for example, the language settings on a website, the login status, a shopping basket or the location where a video was watched. The term "cookies" also includes other technologies that fulfil the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also known as "user IDs")
A distinction is made between the following cookie types and functions:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their browser.
- Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or favourite content can be displayed directly when the user visits a website again. The interests of users who are used for reach measurement or 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: Cookies may be absolutely necessary for the operation of a website (e.g. to save logins or other user input or for security reasons).
- Statistical, marketing and personalisation cookies: Cookies are also generally used to measure reach and when a user's interests or behaviour (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to display content to users 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 privacy policy 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 for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the consent you have given. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offering and its improvement) or, if the use of cookies is necessary to fulfil our contractual obligations.
Storage period: If we do not provide you with explicit information on 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 any consent you have given or to object to the processing of your data by cookie technologies (collectively referred to as "opt-out"). You can initially declare your objection using your browser settings, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared using a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. You can also obtain further information on how to object in the context of the information on the service providers and cookies used.
Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the user's consent to the use of cookies or the processing and providers named in the cookie consent management procedure can be obtained, managed and revoked by the user. The declaration of consent is stored so that it does not have to be requested again and the consent can be proven in accordance with the legal obligation. The consent can be stored on the server and/or in a cookie (so-called opt-in cookie or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: Consent may be stored for up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used.
Provision of the online offer and web hosting
In order to provide our online offering securely and efficiently, we utilize 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 utilize infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.
The data processed as part of the provision of the hosting service may include all information relating to the users of our online service that is generated during use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or from websites.
Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.
The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks) and to ensure the utilization of the servers and their stability.
- Processed data types: 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).
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data is only 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. In addition, we refer to the information on the processing of visitors to our publication medium in the context of this data protection notice.
Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored on the basis of our legitimate interests. This is done for our security in case someone leaves illegal content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves may be prosecuted for the comment or post and are therefore interested in the identity of the author.
Furthermore, we reserve the right to process user data for the purpose of spam detection on the basis of our legitimate interests.
On the same legal basis, we reserve the right to store users' IP addresses for the duration of surveys and to use cookies in order to avoid multiple votes.
The personal information provided in the context of comments and contributions, any contact and website information as well as the content information will be permanently stored by us until the user objects.
- Processed data types: 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).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of Processing: Provision of contractual services and customer support, Feedback (e.g. collecting feedback via online form), Security measures, Managing and responding to enquiries.
- Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Making contact
When contacting us (e.g. by contact form, e-mail, telephone or via social media), the data of the enquiring persons will be processed insofar as this is necessary to answer the contact enquiries and any requested measures.
Contact enquiries are answered in the context of contractual or pre-contractual relationships in order to fulfil our contractual obligations or to respond to (pre)contractual enquiries and otherwise on the basis of legitimate interests in responding to the enquiries.
- Processed data types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Content data (e.g. entries in online forms).
- Data subjects: Communication partners.
- Purposes of processing: Contact enquiries and communication.
- Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Communication via Messenger
For the purpose of communication, we use messengers and therefore ask you to take note of the following information regarding the functionality of the messengers, encryption, the use of communication metadata, and your options for objection.
You can also contact us through alternative means, such as by phone or email. Please use the contact information provided to you or the contact information specified within our online offering.
In the case of end-to-end encryption of content (i.e., the content of your messages and attachments), we would like to point out that communication contents (i.e., the content of the message and attached images) are encrypted end-to-end. This means that the content of the messages is not visible, not even by the messenger providers themselves. Always use an up-to-date version of the messenger with encryption enabled to ensure the encryption of message contents.
However, we additionally inform our communication partners that while the messenger providers cannot view the content, they can learn when communication partners are communicating with us and technical information about the communication partners' devices, as well as, depending on the settings of their devices, location information (so-called metadata) can be processed.
Legal basis information: If we ask communication partners for permission before communicating with them via messenger, the legal basis for processing their data is their consent. Otherwise, if we do not request consent and they contact us on their own, we use messengers in relation to our contractual partners and in the context of contract initiation as a contractual measure. In the case of other interested parties and communication partners, we use messengers based on our legitimate interests in fast and efficient communication and meeting the needs of our communication partners for communication via messenger. Furthermore, we inform you that we do not transmit the contact details provided to us to messengers without your consent.
Revocation, objection, and deletion: You can revoke any consent given at any time and object to communication with us via messenger at any time. In the case of communication via messenger, we delete the messages in accordance with our general deletion policies (i.e., for example, as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise, as soon as we can assume that any information requested by the communication partners has been answered, when there is no expectation of reference to a previous conversation, and deletion does not conflict with legal retention obligations.
Reservation of referring to other communication channels: Finally, we would like to point out that for reasons of your safety, we reserve the right not to answer inquiries via messenger. This is the case, for example, when contract details require special confidentiality or a response via messenger does not meet formal requirements. In such cases, we refer you to more appropriate communication channels.
Processed data types: Contact details (e.g., email, phone numbers), usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses). Affected persons: Communication partners. Purposes of processing: Contact inquiries and communication, direct marketing (e.g., via email or postal mail). Legal bases: 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 used:
- Facebook Messenger: Facebook Messenger with end-to-end encryption (activation of end-to-end encryption of the Facebook Messenger is required unless it is already activated by default); Service provider: https://www.facebook.com, Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, Parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Opt-Out: https://www.facebook.com/settings?tab=ads.
- WhatsApp: WhatsApp Messenger with end-to-end encryption; Service provider: WhatsApp Inc. WhatsApp Legal 1601 Willow Road Menlo Park, California 94025, USA; Website: https://www.whatsapp.com/; Privacy Policy: https://www.whatsapp.com/legal.
- Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2; Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy.
Application Procedure
The application procedure requires applicants to provide us with the necessary data for their assessment and selection. The required information is outlined in the job description or, in the case of online forms, in the provided fields.
Essential details include personal information such as name, address, contact details, and evidence of qualifications required for the position. Upon request, we are happy to specify additional information needed.
Applicants can submit their applications through an online form if available. The data is transmitted to us encrypted using state-of-the-art technology. Alternatively, applicants can submit applications via email. However, it should be noted that emails are generally not encrypted when sent over the internet. While emails are typically encrypted during transit, they may not be on the servers where they are sent and received. Therefore, we cannot take responsibility for the transmission of applications between the sender and our server.
For the purpose of applicant search, submission of applications, and candidate selection, we may use applicant management, recruitment software, and platforms, as well as services from third-party providers, in compliance with legal requirements.
Applicants are welcome to contact us regarding the submission method or send their applications by postal mail.
Processing of Special Categories of Data: If special categories of personal data in the sense of Article 9(1) of the GDPR (e.g., health data such as disability status or ethnic origin) are requested from applicants within the application process, their processing is carried out in accordance with Article 9(2)(b) of the GDPR for the exercise of rights and obligations in the field of employment and social security and social protection law, or based on Article 9(2)(c) for the protection of vital interests, or for the purposes of preventive or occupational medicine, the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment, or the management of health or social care systems, in accordance with Article 9(2)(h) of the GDPR. In the case of voluntary disclosure of special categories of data based on consent, their processing is carried out on the basis of Article 9(2)(a) of the GDPR.
Data Deletion: Data provided by applicants can be further processed for the purpose of employment if the application is successful. Otherwise, if the application for a job position is unsuccessful, applicant data will be deleted. Applicant data will also be deleted if an application is withdrawn, a right to withdrawal that applicants can exercise at any time. Deletion will take place, subject to a legitimate withdrawal by the applicants, no later than six months after the application process to allow us to answer any follow-up questions and comply with our obligations under equal treatment regulations. Invoices for any reimbursement of travel expenses will be archived in accordance with tax regulations.
Inclusion in an Applicant Pool: Inclusion in 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 can be revoked at any time for the future.
- Processed Data Types: Applicant data (e.g., personal information, postal and contact addresses, application documents, and the information contained therein, such as cover letter, resume, certificates, as well as other information voluntarily provided by applicants regarding their person or qualifications).
- Affected Individuals: Applicants.
- Purposes of Processing: Application process (establishment and, if applicable, later execution and possible termination of the employment relationship).
- Legal Bases: Application process as a pre-contractual or contractual relationship (Article 9(2)(b) GDPR).
Used Services and Service Providers:
- Monster: Recruiting platform and services; Service provider: Monster Worldwide Deutschland GmbH, Ludwig-Erhard-Straße 14, 65760 Eschborn, Germany; Website: https://www.monster.de; Privacy Policy: https://www.monster.de/datenschutz/datenschutz/home.aspx.
- Stepstone: Recruiting platform and services; Service provider: StepStone Deutschland GmbH, Völklinger Straße 1, 40219 Düsseldorf, Germany; Website: https://www.stepstone.de; Privacy Policy: https://www.stepstone.de/Ueber-StepStone/Rechtliche-Hinweise/datenschutzerklaerung/.
- Xing: Service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Website: https://www.xing.com; Privacy Policy: https://privacy.xing.com/de/datenschutzerklaerung.
Web Analysis, Monitoring, and Optimization
Web analysis, also referred to as "reach measurement," serves to evaluate the visitor flows of our online offering and can include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. Through reach analysis, we can identify, for example, the times when our online offering or its functions or content are most frequently used or invite reuse. Likewise, we can understand which areas require optimization.
In addition to web analysis, we can also employ testing procedures to test and optimize different versions of our online offering or its components.
For these purposes, user profiles can be created and stored in a file (so-called "cookie") or similar procedures with the same purpose can be used. This information may include viewed content, visited web pages, and elements used there, as well as technical details 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, these may also be processed depending on the provider.
The IP addresses of users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, clear user data (such as email addresses or names) are not stored in the context of web analysis, A/B testing, and optimization, but pseudonyms are used. That is, both we and the providers of the software used do not know the actual identity of the users, only the information stored in their profiles for the purposes of the respective procedures.
Legal basis information: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we also refer you to the information on the use of cookies in this privacy policy.
- Processed data types: Usage data (e.g., visited web pages, 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, detection of recurring visitors), tracking (e.g., interest/behavior-related profiling, use of cookies), conversion measurement (measurement of the effectiveness of marketing measures), profiling (creation of user profiles).
- Security measures: IP masking (pseudonymization of the IP address).
- Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
Used services and service providers:
- Google Analytics: Reach measurement and web analysis; 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/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy.
- Google Tag Manager: Google Tag Manager is a solution that allows us to manage so-called website tags through an interface and thus integrate other services into our online offering (additional information is provided in this privacy policy). The Tag Manager itself (which implements the tags) does not create profiles of users or store cookies. Google only learns the IP address of the user, which is necessary to execute the 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.
Online Marketing
We process personal data for the purpose of online marketing, including the promotion of advertising space or the display of advertising and other content (collectively referred to as "content") based on potential user interests, as well as the measurement of their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar procedures are used to store information relevant to the user for the display of the aforementioned content. This information may include viewed content, visited websites, used online networks, as well as communication partners and technical details 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 information may also be processed.
The IP addresses of users are also stored. However, we use available IP masking methods (i.e., pseudonymization by shortening the IP address) to protect users. In general, within the online marketing process, no clear data of users (such as email addresses or names) is stored, but pseudonyms are used. That is, neither we nor the providers of online marketing processes know the actual identity of the users, only the information stored in their profiles.
The information in the profiles is usually stored in cookies or similar methods. These cookies can later be read on other websites that use the same online marketing process, analyzed for the purpose of displaying content, supplemented with additional data, and stored on the server of the online marketing process provider.
Exceptionally, clear data can be assigned to the profiles. This is the case, for example, when users are members of a social network whose online marketing process we use, and the network links the profiles of users with the aforementioned information. Please note that users can make additional agreements with the providers, for example, through consent during registration.
In general, we only have access to aggregated information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e., for example, to a contract conclusion with us. The conversion measurement is solely used for the analysis of the success of our marketing measures.
Unless otherwise stated, please assume that the cookies used are stored for a period of two years.
Notes on legal bases: If we ask users for their consent to use third-party services, the legal basis for data processing is consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in 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.
Facebook Pixel and Audience Building (Custom Audiences): With the help of the Facebook Pixel (or similar functions for transmitting event data or contact information through interfaces in apps), Facebook can determine the visitors to our online offering as a target audience for displaying ads (so-called "Facebook Ads"). Accordingly, we use the Facebook Pixel to show the Facebook Ads we place only to users on Facebook and within the services of cooperating partners (the so-called "Audience Network" https://www.facebook.com/audiencenetwork/) who have shown an interest in our online offering or who exhibit certain characteristics (e.g., interest in specific topics or products apparent from visited websites) 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 do not appear intrusive. Additionally, the Facebook Pixel allows us to track the effectiveness of Facebook ads for statistical and market research purposes by seeing if users were redirected to our website after clicking on a Facebook ad (so-called "conversion tracking").
We, together with Meta Platforms Ireland Limited, are jointly responsible for the collection or receipt, within the scope of a transmission (but not for further processing), of "event data" that Facebook collects through the Facebook Pixel and similar functions (e.g., interfaces) executed on our online offering for the following purposes: a) Display of content and advertising information corresponding to the presumed interests of users; b) Delivery of commercial and transaction-related messages (e.g., addressing users via Facebook Messenger); c) Improvement of ad delivery and personalization of features and content (e.g., improving the recognition of content or advertising information presumed to match user interests). We have entered into a specific agreement with Facebook ("Controller Addendum," https://www.facebook.com/legal/controller_addendum), which regulates, among other things, the security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill data subject rights (i.e., users can direct inquiries or deletion requests directly to Facebook). Note: When Facebook provides us with metrics, analyses, and reports (which are aggregated, i.e., do not contain information about individual users and are anonymous to us), this processing is not part of joint responsibility but based on a data processing agreement ("Data Processing Terms," https://www.facebook.com/legal/terms/dataprocessing), "Data Security Terms" (https://www.facebook.com/legal/terms/data_security_terms), and, regarding processing in the USA, based on standard contractual clauses ("Facebook EU Data Transfer Addendum," https://www.facebook.com/legal/EU_data_transfer_addendum). User rights (especially regarding information, deletion, objection, and complaints to the relevant supervisory authority) are not restricted by the agreements with Facebook.
- Processed data types: Usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses), location data (information about the geographic position of a device or person), event data (Facebook) ("Event data" refers to data that can be transmitted to Facebook by us, for example, via the Facebook Pixel (via apps or other means) and relates to individuals or their actions; the data includes information about website visits, interactions with content, features, app installations, product purchases, etc.; event data is processed for the purpose of creating target groups for content and advertising information (Custom Audiences); event data does not include actual content (such as written comments), login information, and contact information (i.e., no names, email addresses, and phone numbers). Event data is deleted by Facebook after a maximum of two years, along with the deletion of our Facebook account).
- Affected individuals: Users (e.g., website visitors, users of online services), interested parties.
- Purposes of processing: Tracking (e.g., interest/behavior-based profiling, use of cookies), remarketing, conversion measurement (measurement of the effectiveness of marketing measures), interest-based and behavior-based marketing, profiling (creation of user profiles), reach measurement (e.g., access statistics, detection of recurring visitors), target group formation (determination of 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 bases: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
- Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the opt-out options provided for each provider (so-called "opt-out"). If no explicit opt-out option has been provided, there is the possibility to disable cookies in the settings of your browser. However, this may restrict the functions of our online offering. Therefore, we additionally recommend the following opt-out options, which are offered summarily for respective regions: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-region: https://optout.aboutads.info.
Services and service providers used:
- Google Tag Manager: Google Tag Manager is a solution that allows us to manage website tags through an interface, enabling the integration of other services into our online offering (further details are provided in this privacy policy). The Tag Manager itself (which implements the tags) does not create user profiles or store cookies. Google only receives the user's IP address, which is necessary to execute the 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.
- Google Analytics: Online marketing and web analytics; 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/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Opt-out option: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for displaying ads: https://adssettings.google.com/authenticated.
- Facebook Pixel and audience building (Custom Audiences): Service provider: https://www.facebook.com, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, Parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Opt-out option: https://www.facebook.com/settings?tab=ads.
Presence in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users' rights.
Furthermore, user data is generally processed within social networks for market research and advertising purposes. For example, user profiles can be created based on user behaviour and the resulting interests of users. The user profiles can in turn be used, for example, to place adverts within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the user's computer, in which the user's usage behaviour and interests are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (especially 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 opt-out options, please 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 data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
Facebook: We are jointly responsible with Facebook Ireland Ltd. for the collection (but not the further processing) of data from visitors to our Facebook page (known as a "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see under "Things you and others do and provide" in the Facebook Data Policy: www.facebook.com/policy), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under "Device Information" in the Facebook Data Policy Statement: www.facebook.com/policy). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services, so-called "Page Insights", for page operators to gain insights into how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook ("Information on Page Insights", www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information on Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data).
- Processed data types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, 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 requests and communication, Tracking (e.g. profiling based on interests and behaviour, use of cookies), Remarketing, Web Analytics (e.g. access statistics, recognition of returning visitors).
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
Services used and service providers:
- Facebook: Social network; service provider: Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: www.facebook.com; Privacy Policy: www.facebook.com/about/privacy; Opt-Out: Settings for adverts: www.facebook.com/settings.
- Xing: Social network; Service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Website: www.xing.de; Privacy Policy:https://privacy.xing.com/de/datenschutzerklaerung.
- Instagram: Social network; Service provider: Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: www.instagram.com; Privacy Policy: instagram.com/about/legal/privacy.
- LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: www.linkedin.com; Privacy Policy: www.linkedin.com/legal/privacy-policy; Opt-Out: www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- TikTok: Social network / video platform; Service provider: musical.ly Inc., 10351 Santa Monica Blvd #310, Los Angeles, CA 90025 USA; Website: www.tiktok.com; Privacy Policy: https://www.tiktok.com/de/privacy-policy.
Plugins and embedded functions and content
We incorporate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may be, for example, graphics, videos or social media buttons and posts (hereinafter uniformly referred to as "content").
The integration always requires that the third-party providers of this content process the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content or function. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. Pixel tags can be used to analyse information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as being linked to such information from other sources.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, user data is processed on the basis of 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 privacy policy.
Facebook plugins and content: We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt in the context of a transmission (but not the further processing) of "event data" that Facebook collects or receives in the context of a transmission by means of the Facebook social plugins (and content embedding functions) that run on our online offer for the following purposes: a) Display of content and advertising information that corresponds to the presumed interests of the users; b) Delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) Improvement of ad delivery and personalisation of functions and content (e.g. improvement of the recognition of which content or advertising is relevant for which purpose). (e.g. addressing users via Facebook Messenger); c) improving the delivery of advertisements and personalisation of functions and content (e.g. improving the recognition of which content or advertising information presumably corresponds to the interests of users). We have concluded a special agreement with Facebook ("Addendum for Controllers", www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with measured values, analyses and reports (which are aggregated, i.e. do not contain any information about individual users and are anonymous to us), this processing is not carried out within the framework of joint responsibility, but on the basis of a data processing agreement ("Data Processing Terms", 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, on the basis of standard contractual clauses ("Facebook-EU Data Transfer Addendum, www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook.
- Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), event data (Facebook) ("event data" is data that can be transmitted by us to Facebook via Facebook pixels (via apps or other means), for example, and relates to individuals or their actions; the data includes, for example Information about visits to websites, interactions with content, functions, app installations, product purchases, etc.; the event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); event data does not include the actual content (such as comments written), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data is deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account), location data (information on the geographical position of a device or person), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), inventory data (e.g. names, addresses).
- Data subjects: Users (e.g. website visitors, users of online services), communication partners.
- Purposes of Processing: Provision of our online services and usability, Provision of contractual services and customer support, Contact requests and communication, Direct marketing (e.g. by e-mail or postal), Targeting (e.g. profiling based on interests and behaviour, use of cookies), Interest-based and behavioral marketing, Profiling (Creating user profiles), Feedback (e.g. collecting feedback via online form), Security measures, Managing and responding to enquiries.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR), consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR).
Services used 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 with which users can share content from this online offering within Facebook. The list and appearance of Facebook social plugins can be viewed here: developers.facebook.com/docs/plugins/; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: www.facebook.com; Privacy Policy: www.facebook.com/about/privacy; Opt-Out: Settings for adverts: https://www.facebook.com/settings?tab=ads.
- Google Fonts: We integrate the fonts ("Google Fonts") of the provider Google, whereby the user's data is used solely for the purpose of displaying the fonts in the user's browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform presentation and taking into account possible licensing restrictions for their integration. 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: fonts.google.com; Privacy Policy: policies.google.com/privacy.
- Google Maps: We integrate the maps of the "Google Maps" service provided by Google. The processed data may include, in particular, IP addresses and location data of users, which, however, are not collected without their consent (usually in the context of the settings of their mobile devices); 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: cloud.google.com/maps-platform; Privacy Policy: policies.google.com/privacy; Opt-Out: Opt-out plug-in: tools.google.com/dlpage/gaoptout, Settings for the display of adverts: https://adssettings.google.com/authenticated.
- Pinterest plugins and content: Pinterest plugins and content - This may include, for example, content such as images, videos or text and buttons with which users can share content from this online offering within Pinterest. Service provider: Pinterest Inc, 635 High Street, Palo Alto, CA, 94301, USA; Website: www.pinterest.com; Privacy Policy: https://about.pinterest.com/de/privacy-policy.
- Shariff: We use the data protection-safe "Shariff" buttons. "Shariff" was developed to enable more privacy on the internet and to replace the usual "Share" buttons of social networks. Instead of the user's browser, the server on which this online offer is located establishes a connection with the server of the respective social media platforms and queries the number of likes, for example. The user remains anonymous. You can find more information about the Shariff project from the developers of c't magazine: www.heise.de/ct/artikel/Shariff-Social-Media-Buttons-mit-Datenschutz-2467514.html; Service provider: Heise Medien GmbH & Co. KG, Karl-Wiechert-Allee 10, 30625 Hannover, Germany; Website: www.heise.de/ct/artikel/Shariff-Social-Media-Buttons-mit-Datenschutz-2467514.html; Privacy Policy: www.heise.de/Datenschutzerklaerung-der-Heise-Medien-GmbH-Co-KG-4860.html.
- 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: www.youtube.com; Privacy Policy: policies.google.com/privacy; Opt-Out: Opt-out plugin: tools.google.com/dlpage/gaoptout; Settings for the display of adverts: https://adssettings.google.com/authenticated.
Processing when using the reporting system
Purposes of the processing of personal data
Meffert AG Farbwerke processes the following types of personal data, among others, when entering and processing reports in the internal reporting system:
- Information for personal identification of the whistleblower, such as first and last name, gender, address, telephone number and e-mail address;
- Employment status at Meffert AG Farbwerke;
- Information on affected persons, i.e. natural persons who are designated in a report as a person who committed the offence or with whom the designated person is associated. Such information includes, for example, first and last name, gender, address, telephone number and e-mail address or other information that enables identification;
- Information about offences that may allow conclusions to be drawn about a natural person.
Meffert AG Farbwerke processes the personal data for the purpose of investigating the reports in order to prevent, detect and/or follow-up on violations of applicable law or company policies (such as measures to verify the validity of the allegations made in the report and, if necessary, to take action against the reported violation, including through internal enquiries, investigations, prosecutions, measures to (re-)recover funds or close the case).
Legal basis
- We only process information for the personal identification of the whistleblower if the whistleblower has given us consent in accordance with Art. 6 para. 1 lit. a GDPR. Accordingly, processing is only lawful if the data subject has given their consent to the processing of their personal data for one or more specific purposes.
- We process information on employee status, information on data subjects and other information that allows conclusions to be drawn about natural persons on the basis of Art. 6 para. 1 lit. f GDPR. This states that processing is lawful if 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.
- Depending on the specific individual case to be examined, our legitimate interest lies in the processing of reports in order to be able to carry out follow-up measures, such as measures to examine the validity of the allegations made in the report and, if necessary, to take action against the reported infringement, including through internal enquiries, investigations, criminal prosecution measures, measures to (re)recover funds or conclude the proceedings. Whether the interests or fundamental rights and freedoms of the data subject conflict with such data processing is examined on a case-by-case basis, including with regard to the breach.
- We may process personal data of employees on the basis of Section 26 (1) sentence 2 BDSG. According to this, personal data of employees within the meaning of Section 26 (8) BDSG may be processed to uncover criminal offences if there are factual indications to be documented that justify the suspicion that the person concerned has committed a criminal offence in the employment relationship, the processing is necessary for detection and the employee's legitimate interest in the exclusion of processing does not prevail, in particular the type and extent are not disproportionate with regard to the occasion.
General information on the recipients or categories of recipients
The personal data processed as part of a notification is processed by lawcode GmbH, Universitätsstraße 3, 56070 Koblenz, Germany, on behalf of and in accordance with the instructions of Meffert AG Farbwerke.
Personal data will only be transferred to third parties if there is a legal basis for this. This is the case in particular if the transfer serves to fulfil legal requirements according to which we are obliged to provide information, report or pass on data, if you have given us your consent to do so or if a weighing of interests justifies this.
In addition, external service providers, such as external data centres or telecommunications providers, process personal data on our behalf as processors.
Depending on the focus of responsibility of the report and for the effective initiation of follow-up measures, the personal data may be passed on to our relevant specialist departments.
Under certain circumstances, we may also pass on personal data to state security and/or law enforcement authorities, other competent authorities and/or persons obliged to maintain confidentiality, such as auditors/lawyers.
General information on the retention period
Data is generally stored until the follow-up measures have been completed. As a rule, the data from a report will be deleted after 3 years after the procedure has been finally concluded, unless the initiation of further legal steps requires further storage (e.g. initiation of criminal proceedings or disciplinary proceedings). Personal data in connection with reports will be deleted by us immediately if we consider them to be obviously unfounded.
Deletion of data
The data processed by us will be deleted in accordance with the legal requirements as soon as the consent given for processing is revoked or other authorisations cease to apply (e.g. if the purpose for processing this data no longer applies or it is not required for the purpose).
If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for the assertion, exercise or defence of legal claims or to protect the rights of another natural or legal person.
Changes and updates to the privacy policy
We ask you to inform yourself regularly about the content of our privacy policy. We will amend the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your co-operation (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organisations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting us.
Further information on the deletion of personal data can also be found in the individual data protection notices of this privacy policy.
Rights of the data subjects
As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 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) GDPR, including profiling based on those provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw your consent at any time.
- Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed and access to this data as well as further information and a copy of the data in accordance with the legal requirements.
- Right to rectification: You have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you in accordance with the legal requirements.
- Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the legal requirements.
- 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 the legal requirements or to request that it be transferred to another controller.
- Complaint to the supervisory authority: You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.
Definitions of terms
This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined above all in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are listed in alphabetical order.
- Cross-device tracking: Cross-device tracking is a form of tracking in which user behaviour and interest information is recorded across devices in so-called profiles by assigning users an online identifier. This allows user information to be analysed for marketing purposes, regardless of the browser or device used (e.g. mobile phones or desktop computers). For most providers, the online identifier is not linked to clear data such as names, postal addresses or email addresses.
- IP masking: "IP masking" refers to 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 pseudonymising processing procedures, particularly in online marketing
- Interest-based and behavioural marketing: Interest-based and/or behavioural marketing is when the potential interests of users in advertisements and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behaviour (e.g. visiting certain websites and lingering on them, purchasing behaviour or interaction with other users), which is stored in a so-called profile. Cookies are generally used for these purposes.
- Conversion measurement: Conversion measurement (also referred to as "visit action analysis") is a process that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user's device within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the adverts we have placed on other websites have been 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. 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" refers to any form of automated processing of personal data that involves the use of such personal data to analyze, assess, or predict certain personal aspects related to a natural person. Depending on the type of profiling, this may include information concerning age, gender, location data, movement data, interaction with websites and their content, shopping behavior, and social interactions with other people. For the purposes of profiling, cookies and web beacons are often used.
- Reach measurement: Reach measurement (also referred to as web analytics) is used to evaluate the visitor flows of an online offering and can encompass the behavior or interests of visitors in specific information, such as content from websites. With the help of reach analysis, website owners can, for example, identify when visitors access their website and what content they are interested in. This allows them to better tailor the content of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for the purpose of reach analysis to recognize recurring visitors and obtain more precise analyses of the usage of an online offering.
- Remarketing: The term "remarketing" or "retargeting" is used when, for advertising purposes, it is noted which products a user has shown interest in on a website in order to remind the user of these products on other websites, for example, through advertisements.
- Location data: Location data is generated when a mobile device (or another device with the technical capabilities for location determination) connects to a cell tower, Wi-Fi, or similar technical means and functions of location determination. Location data indicates the geographically identifiable position on Earth where the respective device is located. Location data can be used, for example, to display map functions or other location-dependent information. It is important to note that the responsible and compliant use of location data aligns with privacy policies and regulations.
- Tracking: "Tracking" refers to the monitoring of user behavior across multiple online offerings. Typically, behavioral and interest information related to the utilized online offerings is stored in cookies or on servers of the providers of tracking technologies (known as profiling). Subsequently, this information can be used, for example, to display advertisements to users that are likely to match their interests.
- Controller: The term "controller" refers to the natural or legal person, authority, agency, or other body that alone or jointly with others determines the purposes and means of processing personal data.
- Processing: "Processing" encompasses any operation or series of operations, whether or not carried out using automated means, related to personal data. The term broadly covers any handling of data, including collection, evaluation, storage, transmission, or deletion.
- Audience Building: Audience building (or "Custom Audiences") occurs when target audiences are determined for advertising purposes, such as displaying advertisements. For instance, based on a user's interest in specific products or topics on the internet, it can be inferred that the user may be interested in advertisements for similar products or the online store where they viewed the products. "Lookalike Audiences" refer to displaying content to users whose profiles or interests are presumed to match those of the users for whom the profiles were created. Typically, cookies and web beacons are used for the purpose of creating Custom Audiences and Lookalike Audiences.