Danziger Str. 64
P: +49 (0) 30 2847 245 60
Domicile: Berlin, Germany
Company register: HRB 163676 B
District Court Berlin-Charlottenburg
VAT ID No: DE280749341
CEO: Andreas Spiess
CFO: Hundertus Dornieden
Chairman of the Supervisory Board: Dr. Hartmut Schüning
Types of data processed:
– Inventory data (e.g. names, addresses).
– Contact data (e.g., email address, phone numbers).
– Content data (e.g. text input, photographs, videos).
– Usage data (e.g., websites visited, interest in content, access times).
– Meta/communication data (e.g. device information, IP addresses).
Purpose of processing
– Provision of the online offer, its functions and contents.
– Response to contact requests and communication with users.
– Security measures.
– Reach measurement/marketing
“Personal data” refers to all information relating to an identified or identifiable natural person (hereinafter “data subject”); a natural person is regarded as identifiable, if he/she can be directly or indirectly identified, especially by means of association with an identifier such as a name, with an identification number, with location data, with an online ID (e.g. cookies) or with one or several special features reflecting the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person;
“Processing” means any operation carried out with or without the aid of automated procedures or any such series of operations in connection with personal data. The term is broad and covers virtually every aspect of dealing with data.
“Responsible party” refers to the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data.
Applicable legal bases
Cooperation with contract processors and third parties
If we disclose data to other persons and companies (contract processors or third parties) within the scope of our processing, transmit the data to them or otherwise grant them access to the data, this shall only take place on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as payment service providers, in accordance with Art. 6 Para. 1 lit. b GDPR is required for contract fulfilment), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we commission third parties with the processing of data on the basis of a so-called “order processing contract”, this is done on the basis of Art. 28 GDPR.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this only takes place if it occurs for the fulfilment of our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or leave the data in a third country only in the presence of the special requirements of Art. 44 ff. GDPR. This means, for example, processing is carried out on the basis of special guarantees, such as the officially recognised determination of a data protection level corresponding to the EU (e.g. for the USA by the “Privacy Shield”) or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).
Rights of the data subjects
You have the right to request confirmation as to whether the data concerned are being processed and to request information about these data as well as further information and a copy of the data in accordance with Art. 15 GDPR.
According to Art. 16 GDPR, you have the right to request the completion of data concerning you or the correction of inaccurate data concerning you.
In accordance with Art. 17 GDPR, you have the right to demand that relevant data be deleted immediately or, alternatively, to demand a restriction on the processing of the data in accordance with Art. 18 GDPR.
You have the right to request that the data concerning you that you have provided to us be received in accordance with Art. 20 GDPR and to request their transmission to other persons responsible.
According to Art. 77 GDPR you have the further right to lodge a complaint with the competent supervisory authority.
You have the right to revoke your consent according to Art. 7 3 Revoke GDPR with effect for the future.
Right to Object
You can object to the future processing of the data concerning you in accordance with Art. 21 GDPR at any time. The objection may be lodged in particular against processing for direct marketing purposes.
Cookies and right of objection to direct advertising
Cookies are small files that are stored on the user’s computer. Different data can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his/her visit to an online offering. Temporary cookies, “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offering and closes his/her browser. For example, the content of a shopping basket in an online shop or a login jam can be stored in a cookie of this nature. Cookies are referred to as “permanent” or “persistent” if they remain saved even after the browser is closed. For example, the login status can be saved if users visit it after several days have passed. Likewise, the interests of users may be stored in a cookie of this nature and used for range measurements or marketing purposes. Third-party cookies” are cookies that are offered by providers other than the responsible person who operates the online offer (otherwise, if the only cookies are run by the responsible person, they are referred to as “first-party cookies”).
We may use temporary and permanent cookies and clarify this within the framework of our data protection declaration.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Cookies already saved can be deleted in the system settings of the browser at any time. The exclusion of cookies can lead to functional restrictions of this online offer.
Deletion of data
In particular, pursuant to legal requirements in Germany, storage lasts for 6 years pursuant to § 257 para. 1 of the German Commercial Code (HGB) (trading books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting documents, etc.) as well as for 10 years pursuant to § 147 para. 1 AO [Tax Code] (books, records, management reports, accounting documents, commercial and business letters, documents relevant for taxation, etc.).
In particular, pursuant to legal requirements in Austria, storage lasts for 7 years in accordance with § 132 para. 1 BAO (accounting documents, receipts/invoices, accounts, receipts, business papers, statement of income and expenditure, etc.), for 22 years in connection with properties and for 10 years for documents in connection with electronically provided services, telecommunications, radio and television services provided to non-entrepreneurs in EU Member States and for which the Mini-One-Stop-Shop (MOSS) is used.
Additionally, we process
– Contract data (e.g. subject matter of the contract, duration, customer category).
– Payment data (e.g. bank details, payment history).
from our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services that we use for the purpose of operating this online offering.
In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, potential customers and visitors to this online offering on the basis of our legitimate interests in an efficient and secure provision of this online offering according to Art. 6 para. 1 lit. f DSGVO in conjunction with Art. 28 DSGVO (conclusion of order processing contract).
Collection of access data and log files
We, or our hosting provider, collect data on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. of the GDPR regarding each access to the server on which this service is located (known as server log files). Access data includes the name of the requested website, file, date and time of access, amount of data transferred, notification of successful retrieval, browser type along with version, the operating system of the user, referrer URL (previously visited), IP address, and the requesting provider.
Log file information is stored for a maximum of seven days for security reasons (e.g. to investigate misuse or fraud) and then deleted. Data whose further storage is required for evidence purposes are excluded from deletion until the relevant incident has been finally clarified.
We process our customers’ data as part of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/ consulting or maintenance, implementation of campaigns and processes / handling, server administration, data analysis/ consulting services and training services.
We process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., email, telephone numbers), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter of the contract, term), payment data (e.g., bank details, payment history), usage and metadata (e.g. as part of the evaluation and performance measurement of marketing measures). We do not process special categories of personal data unless these are part of commissioned processing. This includes our customers, prospects, their customers, users, website visitors or employees, as well as third parties. The purpose of the processing is to provide contractual services, billing and our customer service. The legal basis of the processing results from Art. 6 para. 1 lit. b DSGVO (contractual services), Art. 6 para. 1 lit. f DSGVO (analysis, statistics, optimization, safety measures). We process data which are necessary to justify and fulfill the contractual services and point out the necessity of their disclosure. Disclosure to external parties only takes place if it is necessary within the framework of an order. When processing the data provided to us within the framework of an order, we act in accordance with the instructions of the client as well as with the legal requirements of order processing pursuant to Art. 28 DSGVO and process the data for no other purpose than the order.
We delete the data after expiry of legal warranty and comparable obligations. the necessity of keeping the data is checked every three years; in the case of legal archiving obligations, the deletion takes place after its expiry (6 years, pursuant to § 257 para. 1 HGB, 10 J, in accordance with § 147 para. 1 AO). In the case of data disclosed to us within the scope of an order by the customer, we delete the data in accordance with the specifications of the order, generally after the end of the order.
Administration, financial accounting, office organization, contact management
We process data within the framework of administrative tasks as well as the organization of our company, financial accounting and compliance with legal obligations, e.g. archiving. In this regard we process the same data that we process as part of the performance of our contractual services. The bases of processing are art. 6 para. 1 lit. c. GDPR, art. 6 para. 1 lit. f GDPR. Customers, prospective customers, business partners and website visitors are affected by the processing. The purpose of and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, namely, tasks which serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of data with regard to contractual services and contractual communication corresponds to the tasks specified in these processing activities.
In this regard, we disclose or transmit data to tax authorities, consultants, such as tax consultants or auditors, as well as other fee offices and payment service providers.
Furthermore, we store information regarding suppliers, event organizers and other business partners on the basis of our business interests, e.g. for the purpose of making contact at a later date. In principle, we store this data, which is mainly company-related, permanently.
Business analyses and market research
In order to operate our business economically, to be able to recognize market tendencies, wishes of the contracting parties and users, we analyze the data available to us to business transactions, contracts, inquiries, etc. We process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. DSGVO, whereby the persons concerned include customers, interested parties, business partners, visitors and users of the online offer.
The analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we can consider the profiles of registered users with information e.g. about their purchase processes. The analyses serve to increase user-friendliness, optimization of our offerings and economic efficiency. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarized values.
If these analyses or profiles are personal, they will be deleted or made anonymous upon user termination, otherwise after two years from the conclusion of the contract. For the rest, macroeconomic analyses and general trend determinations are prepared anonymously wherever possible.
Users can optionally create a user account. During the registration process, the required information will be communicated to the users. The data entered during registration will be used for the purpose of using the offer. The user can be informed via email about offer or registration information such as changes to the scope of the offer, or technical circumstances. If users have terminated their user account, their data with regard to the user account will be deleted, subject to their retention, for commercial or tax reasons, according to Art. 6 Para. 1 lit. c GDPR. It is up to the users to save their data before the end of the contract if they have given notice of termination. We are entitled to irretrievably delete all user data stored during the contract duration.
As part of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user activity. The data are stored on the basis of our legitimate interests as well as the user’s protection against misuse and other unauthorized use. A passing on of this data to third parties does not take place in principle, unless it is necessary for the pursuit of our claims or there is a legal obligation in accordance with. Art. 6 Para. 1 lit. c, GDPR. The IP addresses are anonymized or deleted after 7 days at the latest.
When contacting us (e.g. by contact form, email, telephone or via social media), the user’s details for the processing of the contact enquiry and its handling according to the terms and conditions of this agreement are processed. Art. 6 para. 1 lit. b) GDPR. User information can be stored in a Customer Relationship Management System (“CRM System”) or comparable request organization.
We delete the enquiries if they are no longer necessary. We review this requirement every two years; the statutory archiving obligations also apply.
Comments and posts
If users leave comments or other posts, their IP addresses will be stored on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR for 7 days. This takes place for our security, in case someone leaves illegal content in comments and posts (insults, forbidden political propaganda, etc.). In this case, we ourselves could be prosecuted for the comment or post and are therefore interested in the identity of the author.
The following notes are about our newsletter, its content and procedures regarding registration, distribution and statistical evaluation. They also explain your right to appeal. By subscribing to our newsletter, you agree to receive the newsletter and to the described procedures.
Content of the newsletter: We send newsletters, e-mails and other electronic notifications containing advertising information (hereinafter “newsletters”) only with the express consent of the recipient or with legal permission. If registration for the newsletter involves a concrete description of its content, then this description is the basis on which the user agrees to receive the newsletter. In addition, our newsletters contain information about us and our services.
Double opt-in and logging records: Subscription to our newsletter takes place using a process known as double opt-in. This means that upon registration, you will receive an email requesting confirmation of the subscription. The confirmation is required to ensure that no one else subscribes using your email address. A record of subscriptions to the newsletter is kept to fulfil the legal requirements for recording the subscription process. The record contains the time of subscription and confirmation as well as the relevant IP address. Any changes to the data registered with MailChimp will also be recorded.
Subscription details: To subscribe to the newsletter, simply enter your e-mail address. Optionally, we ask you to enter a name for the newsletter, so that we can address you personally.
The newsletters are dispatched and their performance measured on the basis of the recipients’ consent in accordance with Art. 6 para. 1 lit. a, Art. 7 GDPR in conjunction with Art. 7 para. 2 No. 3 UWG or on the basis of legal permission in accordance with § 7 para. 3 UWG.
The registration procedure is recorded on the basis of our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR. Our interest lies in the use of a user-friendly and secure newsletter system that serves our business interests as well as users’ expectations and also allows us to prove consent.
Cancellation/revocation – You can cancel your subscription to our newsletter at any time, i.e. revoke your consent. You will find an “unsubscribe” link at the end of each newsletter. We may store the e-mail addresses that have been unsubscribed for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of these data is limited to the purpose of a possible defence against claims. An individual application for deletion is possible at any time, provided that at the same time the former existence of consent is confirmed.
Jetpack (WordPress Stats)
Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. DSGVO) we use the plugin Jetpack (here the subfunction “WordPress Stats”), which includes Includes Visitor Access Statistical Evaluation Tool and Automattic Inc., 60 29th Street # 343, San Francisco, CA 94110, USA. Google Analytics uses “cookies,” which are text files that are stored on your computer and which help analyze your use of the website.
Facebook has become subject to the Privacy Shield agreement, thereby offering a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
On our behalf, Google will use this information to evaluate the use of our online offering by the user, to compile reports on the activities within this online offering and to provide us with other services related to the use of this online offering and the Internet. Pseudonymous usage profiles of users may be created from the processed data in this respect.
We use Google Analytics only with activated IP anonymisation. This means that the IP address of the user is shortened by Google within the member states of the European Union or in other countries that are party to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address sent to a Google server in the US and shortened there.
Further information on data use by Google, setting and objection options, can be found in Google’s data protection policy (https://policies.google.com/technologies/ads) and in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
Users’ personal data will be deleted or made anonymous after 14 months.
Facebook pixel, Custom Audiences and Facebook-Conversion
Based on our rightful interest in the analysis, optimization and efficient operation of our online offer, we have decided to use the so-called “Facebook pixel”, for our online offerings, provided by the social network, Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or, in case you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand canal Harbour, Dublin 2, Ireland (“Facebook”).
Facebook is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
With the help of Facebook pixel, Facebook is able to determine the visitors of our online offer as a target group for the presentation of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads we post only to Facebook users who have shown an interest in our website or who have certain features (e.g. interests in certain topics or products that are determined by the websites visited) that we transmit to Facebook (so-called “custom audiences”). With the help of the Facebook pixel, we want to make sure that our Facebook ads correspond to the potential interest of the users and are not annoying. The Facebook pixel also helps us understand the effectiveness of Facebook ads for statistical and marketing research purposes by showing and evaluating whether users are directed to our site after they have clicked a Facebook ad (so-called “conversion”).
Facebook processes the data in accordance with Facebook’s Data Usage Policy. Accordingly, general information on the display of Facebook ads can be found in the Facebook Data Usage Policy: https://www.facebook.com/policy.php. For specific information and details about the Facebook pixel and how it works, please visit the Facebook Help section: https://www.facebook.com/business/help/651294705016616.
You can object to collection by Facebook pixel and use of your data for Facebook ads. To set which types of ads you see within Facebook, you can go to the page set up by Facebook and follow the instructions for the usage-based advertising settings: https://www.facebook.com/settings?tab=ads. The settings are not dependent of platform, i.e. they are applied to all devices, such as desktop computers or mobile devices.
Online social media presence
We maintain online presences within social networks and platforms in order to communicate with active customers, interested parties and users and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and the data processing guidelines of their respective operators apply.
Integration of services and content from third parties
Within the framework of our online offers, we use so-called social plugins (“plugins”) provided by the social network Facebook, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), 1 lit. f. GDPR) we include content or service offerings of third parties so that we can incorporate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).
This always presupposes that the third-party providers of this content can see the IP address of users, since without the IP address they would not be able to send the content to the users’ browsers. The IP address is therefore necessary in order to display this content. We strive only to use content from providers who use the IP address to deliver content, and for nothing else. Third-party providers may also use “pixel tags” (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” enable the analysis of information such as the traffic of visitors on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring websites, visiting time and other information about the use of our online offering. It may also be linked to such information from other sources.
Using Facebook social plugins
Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of art. 6 para.1 lit. f. of the DSGVO). The plugins can display interaction elements or content (e.g. videos, graphics or text contributions) and are identified by a Facebook logo (white “f” on a blue tile, the term “Like”, or a “thumbs up” sign) or by the phrase “Facebook social plugin”. The list and the appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
Facebook is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
When a user accesses a feature of these online offerings that contain such a plug-in, his/her device establishes a direct connection to Facebook’s servers. The content of the plug-in is transmitted by Facebook directly to the user’s device and integrated into the online offer. Pseudonymous usage profiles of users may be created from the processed data in this respect. We therefore have no influence on the scope of the data which Facebook collects using this plugin and inform you according of our knowledge.
By including the plugin, Facebook receives the information that a user has accessed the corresponding page of the online offer. If you are logged into Facebook, Facebook can assign the visit to your Facebook account. If you interact with the plug-ins, for example, if you click the Like button or write a comment, the corresponding information is transmitted from your browser directly to Facebook and stored there. If you are not a member of Facebook, there is still the possibility that Facebook will receive your IP address and store it. According to Facebook, in Germany, only an anonymized IP address will be stored.
If a user is a Facebook member and does not want Facebook to collect data about him/her via this online offer and link it to his/her membership data stored on Facebook, s/he must log out of Facebook before using our online offer and delete his/her cookies. More settings and ways to revoke permission to use your data for advertising purposes are available in your Facebook profile settings:: https://www.facebook.com/settings?tab=ads or via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. The settings are not dependent of platform, i.e. they are applied to all devices, such as desktop computers or mobile devices.