Data protection

This privacy policy explains the nature, scope, and purpose of the processing of personal data (hereinafter referred to as “data”) in the context of providing our services, as well as within our online offering and the associated websites, functions, and content, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as the “online offering”). With regard to the terms used, such as “processing” or “controller,” we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Person responsible

Carli Willem Weise

c/o IP Management #39532

Ludwig-Erhard-Str. 18

20459 Hamburg

contact

Email: kontakt@primetradingfx.de

Types of data processed

– Inventory data (e.g., personal master data, names, or addresses).
– Contact data (e.g., email, telephone numbers).
– Content data (e.g., text entries, photographs, videos).
– Usage data (e.g., websites visited, interest in content, access times).
– Meta/communication data (e.g., device information, IP addresses).

Category of data subjects

Visitors and users of the online offer (hereinafter we refer to the data subjects collectively as “users”).

Purpose of processing

– Providing the online service, its functions, and content.
– Responding to contact requests and communicating with users.
– Security measures.
– Reach measurement/marketing

Terms used

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as the “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers virtually any type of data handling.

“Pseudonymisation” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that this additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

“Controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.

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

Relevant legal bases

In accordance with Art. 13 GDPR, we inform you of the legal basis for our data processing. For users from the scope of the General Data Protection Regulation (GDPR), i.e. the EU and the EEC, the following applies unless the legal basis is stated in the data protection declaration:
The legal basis for obtaining consent is Art. 6 (1) (a) and Art. 7 GDPR;
The legal basis for processing to fulfill our services and implement contractual measures as well as to answer inquiries is Art. 6 (1) (b) GDPR;
The legal basis for processing to fulfill our legal obligations is Art. 6 (1) (c) GDPR;
In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (d) GDPR serves as the legal basis.
The legal basis for processing necessary to perform a task carried out in the public interest or in the exercise of official authority vested in the controller is Art. 6 (1) (e) GDPR.
The legal basis for processing to protect our legitimate interests is Art. 6 (1) (f) GDPR.
The processing of data for purposes other than those for which it was collected is governed by the provisions of Art. 6 (4) GDPR.
The processing of special categories of data (according to Art. 9 (1) GDPR) is governed by the provisions of Art. 9 (2) GDPR.

Security measures

In accordance with legal requirements, taking into account the state of the art, implementation costs, and the nature, scope, circumstances, and purposes of processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

These measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as the access, input, and transfer of data, ensuring its availability, and separating it. Furthermore, we have established procedures that ensure the exercise of data subjects’ rights, the deletion of data, and the response to data threats. Furthermore, we consider the protection of personal data right from the development or selection of hardware, software, and processes, in accordance with the principle of data protection by design and through data protection-friendly default settings.

Cooperation with processors, joint controllers and third parties

If, as part of our processing, we disclose data to other persons and companies (contract processors, joint controllers or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g. if transmission of the data to third parties, such as payment service providers, is necessary to fulfill the contract), users 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 disclose data to other companies in our group, transmit it to them or otherwise grant them access to the data, this is done in particular for administrative purposes as a legitimate interest and, beyond that, on a basis that complies with legal requirements.

Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this occurs as part of the use of third-party services or the disclosure or transmission of data to other persons or companies, this will only occur if it is necessary to fulfil our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to statutory or contractual permissions, we will only process or have data processed in a third country if the statutory requirements are met. This means that processing is carried out, for example, on the basis of special guarantees, such as the officially recognised determination of a data protection level equivalent to that of the EU or compliance with officially recognised specific contractual obligations.

Rights of data subjects

You have the right to request confirmation as to whether or not data concerning you is being processed and to request information about this data as well as further information and a copy of the data in accordance with the statutory requirements.

In accordance with the statutory requirements, you have the right to request that the data concerning you be completed or that inaccurate data concerning you be corrected.

In accordance with the statutory requirements, you have the right to request that the data concerning you be deleted immediately or, alternatively, to request that the processing of the data be restricted in accordance with the statutory requirements.

You have the right to request that the data concerning you that you have provided to us be received in accordance with the statutory requirements and to request that this data be transmitted to other responsible parties.

Furthermore, you have the right to lodge a complaint with the competent supervisory authority in accordance with the statutory requirements.

Right of withdrawal

You have the right to revoke any consent you have given with effect for the future.

Right of objection

You may object to the future processing of your data at any time in accordance with the statutory provisions. In particular, you may object to processing for direct marketing purposes.

Cookies and right to object to direct advertising

“Cookies” are small files that are stored on users’ computers. Different types of information can be stored within cookies. A cookie is primarily used to save information about a user (or the device on which the cookie is stored) during or after their visit to an online service. Temporary cookies, or “session cookies” or “transient cookies,” are cookies that are deleted after a user leaves an online service and closes their browser. Such a cookie can store, for example, the contents of a shopping cart in an online shop or a login status. “Permanent” or “persistent” cookies are cookies that remain stored even after the browser is closed. For example, the login status can be saved if the user visits the website several days later. Likewise, the interests of the user can be saved in such a cookie and used for reach measurement or marketing purposes. “Third-party cookies” are cookies offered by providers other than the controller operating the online service (otherwise, if they are only their cookies, they are referred to as “first-party cookies”).

We can use temporary and permanent cookies and explain this in our privacy policy.

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. Stored cookies can be deleted in the browser’s system settings. Excluding cookies can lead to functional restrictions of this online service.

A general objection to the use of cookies used for online marketing purposes can be declared for a variety of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/ . Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that in this case, not all functions of this website may be available.

Deletion of data

The data we process will be deleted or restricted in accordance with legal requirements. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and there are no statutory retention periods that prevent deletion.

If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons .

Changes and updates to the privacy policy

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

 

Business-related processing

In addition, we process
– contract data (e.g., subject matter of the contract, term, customer category)
– payment data (e.g., bank details, payment history)
from our customers, prospective customers, and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising, and market research.

 

Order processing in the online shop and customer account

We process our customers’ data as part of the ordering process in our online shop in order to enable them to select and order the selected products and services, as well as to pay for and deliver them or execute them.

The data processed includes inventory data, communication data, contract data, payment data, and the persons affected by the processing include our customers, interested parties, and other business partners. The data is processed for the purpose of providing contractual services as part of operating an online shop, billing, delivery, and customer services. We use session cookies to store the shopping cart contents and permanent cookies to store the login status.

The processing is carried out to fulfill our services and carry out contractual measures (e.g., processing orders) and to the extent required by law (e.g., legally required archiving of business transactions for trade and tax purposes). The information marked as required is necessary to establish and fulfill the contract. We only disclose data to third parties as part of delivery, payment or within the scope of legal permissions and obligations, as well as when doing so is based on our legitimate interests, about which we will inform you in this privacy policy (e.g., to legal and tax advisors, financial institutions, freight companies and authorities).

Users can optionally create a user account, in particular by viewing their orders. During registration, the required mandatory information is communicated to users. User accounts are not public and cannot be indexed by search engines. If users cancel their user account, their data will be deleted with regard to the user account, subject to their retention being necessary for commercial or tax law reasons. Information in the customer account will remain until it is deleted and subsequently archiving in the event of a legal obligation or our legitimate interests (e.g., in the event of legal disputes). It is the responsibility of the user to back up their data before the end of the contract if the contract is terminated. When registering, re-registering, or using our online services, we store the IP address and the time of each user action. This storage is based on our legitimate interests, as well as the user’s interest in protecting against misuse and other unauthorized use. This data will generally not be shared with third parties unless it is necessary to pursue our legal claims as a legitimate interest, or there is a legal obligation to do so.



Deletion occurs after expiration of statutory warranty and other contractual rights or obligations (e.g., payment claims or performance obligations arising from contracts with customers), whereby the necessity of retaining the data is reviewed every three years; in the case of retention due to statutory archiving obligations, deletion occurs after these expiration.

 

Agency services

 

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. In doing so, 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., in the context of evaluating and measuring the success of marketing measures). We generally do not process special categories of personal data unless these are part of a commissioned processing operation. Those affected include our customers, interested parties and 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 for processing is Art. 6 (1) (b) GDPR (contractual services) and Art. 6 (1) (f) GDPR (analysis, statistics, optimization, security measures). We process data that is necessary to establish and fulfill the contractual services and indicate the necessity of providing it. Disclosure to external parties only occurs if it is required within the scope of an order. When processing data provided to us within the scope of an order, we act in accordance with the client’s instructions and the statutory requirements for order processing pursuant to Art. 28 GDPR and do not process the data for any purposes other than those specified in the order. We delete the data after statutory warranty and similar obligations have expired. The necessity of retaining the data is reviewed every three years; in the case of statutory archiving obligations, deletion occurs after these have expired (6 years, according to Section 257 (1) HGB, 10 years, according to Section 147 (1) AO). In the case of data that was disclosed to us by the client as part of an order, we delete the data in accordance with the specifications of the order, generally after the end of the order.

 

Therapeutic services and coaching

 

We process the data of our clients and interested parties and other clients or contractual partners (collectively referred to as “clients”) in accordance with Art. 6 (1) (b) GDPR in order to provide them with our contractual or pre-contractual services. The data processed in this process, the type, scope, purpose, and necessity of their processing are determined by the underlying contractual relationship. The data processed generally includes client inventory and master data (e.g., name, address, etc.), as well as contact details (e.g., email address, telephone, etc.), contract data (e.g., services used, fees, names of contact persons, etc.), and payment data (e.g., bank details, payment history, etc.). As part of our services, we may also process special categories of data in accordance with Art. 9 (1) GDPR, in particular information about the health of clients, possibly with reference to their sex life or sexual orientation, ethnic origin, or religious or ideological beliefs. To do so, we will obtain express consent from clients where necessary in accordance with Art. 6 (1) (a), Art. 7 and Art. 9 (2) (a) GDPR and otherwise process the special categories of data for the purposes of healthcare on the basis of Art. 9 (2) (h) GDPR and Section 22 (1) No. 1 (b) BDSG. If required for the fulfilment of the contract or by law, we will disclose or transmit client data as part of our communication with other specialists, to third parties who are necessarily or typically involved in the fulfilment of the contract, such as accounting offices or similar service providers, provided that this serves the provision of our services in accordance with Art. 6 (1) (b) GDPR, is prescribed by law in accordance with Art. 6 (1) (c) GDPR, serves our interests or those of the client in efficient and cost-effective healthcare as a legitimate interest in accordance with Art. 6 (1) (f) GDPR or in accordance with Art. 6 (1) (d). GDPR is necessary to protect the vital interests of the client or another natural person, or within the scope of consent pursuant to Art. 6 (1) (a), Art. 7 GDPR. The data will be deleted when it is no longer required to fulfill contractual or statutory duties of care or to deal with any warranty or similar obligations. The necessity of retaining the data will be reviewed every three years; otherwise, the statutory retention periods apply.

 

Contractual services

 

We process the data of our contractual partners and interested parties as well as other clients, customers, clients, or contractual partners (collectively referred to as “contractual partners”) in accordance with Art. 6 (1) (b) GDPR in order to provide them with our contractual or pre-contractual services. The data processed in this process, the type, scope, purpose, and necessity of their processing are determined by the underlying contractual relationship. The data processed includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g., email addresses and telephone numbers), contract data (e.g., services used, contract content, contractual communication, names of contact persons), and payment data (e.g., bank details, payment history). We generally do not process special categories of personal data unless these are components of commissioned or contractually agreed processing. We process data that is necessary to establish and fulfill the contractual services and point out the necessity of providing this data if this is not obvious to the contractual partners. Disclosure to external persons or companies only occurs if it is necessary within the framework of a contract. When processing the data provided to us within the framework of an order, we act in accordance with the instructions of the client and the legal requirements. When using our online services, we may save the IP address and the time of the respective user action. This storage is based on our legitimate interests, as well as the interests of the users in protection against misuse and other unauthorized use. This data is generally not passed on to third parties unless it is necessary to pursue our claims in accordance with Art. 6 (1) (f) GDPR or there is a legal obligation to do so in accordance with Art. 6 (1) (c) GDPR. The data is deleted when the data is no longer required to fulfill contractual or statutory duties of care or to deal with any warranty or similar obligations, whereby the necessity of retaining the data is reviewed every three years; otherwise, the statutory retention periods apply.

 

External payment service providers

 

We use external payment service providers via whose platforms users and we can carry out payment transactions (e.g., each with a link to the privacy policy, Paypal (https://www.paypal.com/de/webapps/mpp/ua/privacy-full), Klarna (https://www.klarna.com/de/datenschutz/), Skrill (https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/), Giropay (https://www.giropay.de/rechtliches/datenschutz-agb/), Visa (https://www.visa.de/datenschutz), Mastercard (https://www.mastercard.de/de-de/datenschutz.html), American Express (https://www.americanexpress.com/de/content/privacy-policy-statement.html). In the context of the fulfilment of contracts, we use the payment service providers on the basis of Art. 6 (1) (b) GDPR. Furthermore, we use external payment service providers on the basis of our legitimate interests in accordance with Art. 6 (1) (f) GDPR. to offer our users effective and secure payment options. The data processed by the payment service providers includes inventory data such as name and address, bank details such as account numbers or credit card numbers, passwords, TANs and checksums as well as contract, amount and recipient-related information. This information is required to carry out the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, but only information confirming or rejecting the payment. Under certain circumstances, the payment service providers will transmit the data to credit agencies. This transmission is for the purpose of identity and credit checks. For this purpose, we refer to the terms and conditions and data protection information of the payment service providers. The terms and conditions and data protection information of the respective payment service providers apply to payment transactions and can be accessed on the respective websites or transaction applications. We also refer to these for further information and to assert rights of revocation, information and other data subject rights.

 

Administration, financial accounting, office organization, contact management

We process data as part of administrative tasks and the organization of our operations, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process as part of the provision of our contractual services. The processing bases are Art. 6 (1) (c) GDPR, Art. 6 (1) (f) GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose of and our interest in the processing lies in administration, financial accounting, office organization, archiving of data, i.e. tasks that serve to maintain our business activities, perform our tasks and provide our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information stated in these processing activities. In doing so, we disclose or transmit data to the tax authorities, consultants such as tax consultants or auditors as well as other fee offices and payment service providers. Furthermore, we store information on suppliers, event organizers and other business partners on the basis of our business interests, e.g. for the purpose of later contact. We generally store this data, which is mostly company-related, permanently.

Business analyses and market research

In order to operate our business economically and to identify market trends and the wishes of our contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc. We process inventory data, communication data, contractual data, payment data, usage data and metadata on the basis of Art. 6 (1) (f) GDPR, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offering. The analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we may take into account the profiles of registered users with information, e.g. on the services they have used. The analyses serve us to increase user-friendliness, optimise our offering and improve business efficiency. The analyses serve us solely and are not disclosed externally, unless they are anonymous analyses with summarized values. If these analyses or profiles are personal, they are deleted or anonymised upon termination of the user’s contract, otherwise after two years from the conclusion of the contract. Otherwise, the overall business analyses and general trend determinations are created anonymously wherever possible.

 

Participation in affiliate partner programs

 

Within our online offering, we use industry-standard tracking measures based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering) in accordance with Art. 6 (1) (f) GDPR, insofar as these are necessary for the operation of the affiliate system. Below we will inform users about the technical background. The services offered by our contractual partners can also be advertised and linked on other websites (so-called affiliate links or after-buy systems, if, for example, links or services from third parties are offered after a contract has been concluded). The operators of the respective websites receive a commission when users follow the affiliate links and subsequently take advantage of the offers. In summary, it is necessary for our online offering that we can track whether users who are interested in affiliate links and/or the offers available from us subsequently take advantage of the offers at the instigation of the affiliate links or our online platform. For this purpose, the affiliate links and our offers are supplemented with certain values ​​that can be part of the link or set otherwise, e.g. in a cookie. The values ​​include in particular the source website (referrer), time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as tracking-specific values ​​such as advertising material ID, partner ID and categorizations. The online identifiers of users we use are pseudonymous values. This means that the online identifiers themselves do not contain any personal data such as names or email addresses. They only help us to determine whether the same user who clicked on an affiliate link or showed interest in an offer via our online offer has accepted the offer, i.e. concluded a contract with the provider. However, the online identifier is personal insofar as the partner company and we have the online identifier together with other user data. This is the only way the partner company can tell us whether the user has accepted the offer and whether we can, for example, pay out the bonus.

 

Amazon Affiliate Program

 

Based on our legitimate interests (i.e. interest in the economic operation of our online offering within the meaning of Art. 6 (1) (f) GDPR), we participate in the Amazon EU affiliate program. This program was designed to provide a medium for websites through which advertising costs can be earned by placing advertisements and links to Amazon.de (so-called affiliate system). This means that as an Amazon partner, we earn from qualified purchases. Amazon uses cookies to trace the origin of orders. Among other things, Amazon can recognize that you clicked on the partner link on this website and subsequently purchased a product from Amazon. Further information on data usage by Amazon and options for objection can be found in the company’s privacy policy: https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010 . Note: Amazon and the Amazon logo are trademarks of Amazon.com, Inc. or one of its affiliates.

 

Digistore24 partner program

 

Based on our legitimate interests (i.e. interest in the economic operation of our online offering within the meaning of Art. 6 (1) (f) GDPR), we participate in the partner program of Digistore24 GmbH, St.-Godehard-Straße 32, 31139 Hildesheim, Germany, which was designed to provide a medium for websites through which advertising costs can be earned by placing advertisements and links to Digistore24 (so-called affiliate system). Digistore24 uses cookies to trace the origin of the contract. Among other things, Digistore24 can recognize that you clicked on the partner link on this website and subsequently concluded a contract with or via Digistore24. Further information on data usage by Digistore24 and options for objection can be found in the company’s privacy policy: https://www.digistore24.com/page/privacyl .

 

Data protection information in the application process

 

We process applicant data only for the purpose and within the framework of the application process in accordance with legal requirements. Applicant data is processed to fulfill our (pre)contractual obligations within the framework of the application process within the meaning of Art. 6 (1) (b) GDPR Art. 6 (1) (f) GDPR if data processing is necessary for us, for example, in the context of legal proceedings (in Germany, Section 26 BDSG also applies). The application process requires applicants to provide us with their applicant data. The necessary applicant data is marked if we offer an online form; otherwise it can be found in the job descriptions and generally includes personal information, postal and contact addresses and the documents belonging to the application, such as cover letter, CV and references. Applicants can also voluntarily provide us with additional information. By submitting their application to us, applicants agree to the processing of their data for the purposes of the application process in accordance with the manner and scope set out in this data protection declaration. If special categories of personal data within the meaning of Art. 9 (1) GDPR are voluntarily disclosed as part of the application process, these will also be processed in accordance with Art. 9 (2) (b) GDPR (e.g. health data, such as severe disability or ethnic origin). If special categories of personal data within the meaning of Art. 9 (1) GDPR are requested from applicants as part of the application process, these will also be processed in accordance with Art. 9 (2) (a) GDPR (e.g. health data if this is necessary for the exercise of the profession). If made available, applicants can submit their applications to us using an online form on our website. The data will be transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications via email. However, we ask you to note that emails are generally not sent encrypted and applicants must ensure that they are encrypted themselves. We therefore cannot assume any responsibility for the transmission path of the application between the sender and its receipt on our server. We therefore recommend using an online form or sending it by mail. Instead of applying via the online form and email, applicants still have the option of sending us their application by mail.










If your application is successful, we may further process the data provided by applicants for the purposes of the employment relationship. Otherwise, if the application for a job offer is unsuccessful, the applicants’ data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Subject to a legitimate withdrawal by the applicant, deletion will occur after a period of six months so that we can answer any follow-up questions regarding the application and fulfill our documentation obligations under the Equal Treatment Act. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements.

 

Registration function

 

Users can create a user account. During registration, the required mandatory information is communicated to the user and processed on the basis of Art. 6 (1) (b) GDPR for the purpose of providing the user account. The data processed includes, in particular, login information (name, password, and email address). The data entered during registration is used for the purpose of using the user account and its purpose. Users can be informed by email about information relevant to their user account, such as technical changes. If users cancel their user account, their data relating to the user account will be deleted, subject to any statutory retention periods. It is the user’s responsibility to back up their data before the end of the contract upon termination. We are entitled to irretrievably delete all user data stored during the term of the contract. When using our registration and login functions and when using the user account, we save the IP address and the time of the respective user action. This storage is based on our legitimate interests, as well as the user’s interest in protecting against misuse and other unauthorized use. This data will generally not be shared with third parties unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Art. 6 (1) (c) GDPR. IP addresses will be anonymized or deleted after 7 days at the latest.

 

Contact us

 

When you contact us (e.g., via contact form, email, telephone, or social media), the user’s information will be processed to process the contact request and its handling in accordance with Art. 6 (1) (b) (within the framework of contractual/pre-contractual relationships) and Art. 6 (1) (f) (other inquiries) GDPR. User information may be stored in a customer relationship management system (“CRM system”) or similar inquiry organization. We delete inquiries if they are no longer required. We review their necessity every two years; statutory archiving obligations also apply.

 

Newsletter

 

With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures as well as your right of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described. Content of the newsletter: We send newsletters, emails and other electronic notifications with advertising information (hereinafter “newsletter”) only with the consent of the recipient or legal permission. If the content of the newsletter is specifically described when registering for the newsletter, this is decisive for the user’s consent. Otherwise, our newsletters contain information about our services and us. Double opt-in and logging: Registration for our newsletter is carried out using a so-called double opt-in process. This means that after registration you will receive an email asking you to confirm your registration. This confirmation is necessary to ensure that no one can register using someone else’s email address. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes saving the time of registration and confirmation, as well as the IP address. Changes to your data stored by the shipping service provider are also logged. Registration data: To register for the newsletter, it is sufficient if you provide your email address. Optionally, we ask you to provide a name so that we can address you personally in the newsletter. The newsletter is sent and the associated performance measurement is based on the consent of the recipient in accordance with Art. 6 (1) (a), Art. 7 GDPR in conjunction with Section 7 (2) No. 3 UWG or, if consent is not required, on the basis of our legitimate interests in direct marketing in accordance with Art. 6 (1) (f) GDPR in conjunction with Section 7 (3) UWG. The registration process is logged on the basis of our legitimate interests in accordance with Art. 6 (1) (f) GDPR. Our interest is in using a user-friendly and secure newsletter system that serves our business interests and meets the expectations of users, while also allowing us to provide evidence of consent.











Cancellation/Revocation – You can cancel your subscription to our newsletter at any time, i.e., revoke your consent. A link to unsubscribe from the newsletter can be found at the end of each newsletter. We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time.

 

Newsletter – Shipping service provider

 

The newsletter is sent via the shipping service provider [NAME, ADDRESS, COUNTRY]. You can view the shipping service provider’s data protection regulations here: [LINK TO THE DATA PROTECTION PROVISIONS]. The shipping service provider is used on the basis of our legitimate interests in accordance with Art. 6 (1) (f) GDPR and a data processing agreement in accordance with Art. 28 (3) (1) GDPR. The shipping service provider can use the recipients’ data in pseudonymous form, i.e. without assignment to a user, to optimise or improve its own services, e.g. for the technical optimisation of the dispatch and presentation of the newsletter or for statistical purposes. However, the shipping service provider does not use the data of our newsletter recipients to write to them directly or to pass the data on to third parties.

 

Newsletter – Measuring Success

 

The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from that service provider’s server. During this retrieval, technical information such as information about the browser and your system, as well as your IP address and the time of retrieval, is initially collected. This information is used to technically improve the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the access times. Statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our aim nor, if used, that of the shipping service provider, to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. Unfortunately, it is not possible to revoke the performance measurement separately; in this case, the entire newsletter subscription must be canceled.

 

Hosting and email sending

 

The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, email delivery, security services, and technical maintenance services, which we use to operate this website. We, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, metadata, and communication data of customers, interested parties, and visitors to this website based on our legitimate interest in the efficient and secure provision of this website in accordance with Art. 6 (1) (f) GDPR in conjunction with Art. 28 GDPR (conclusion of a data processing agreement).

 

Collection of access data and log files

 

We, or rather our hosting provider, collect data about every access to the server on which this service is located (so-called server log files) based on our legitimate interests within the meaning of Art. 6 (1) (f) GDPR. The access data includes the name of the website accessed, the file, the date and time of access, the amount of data transferred, a notification of successful access, the browser type and version, the user’s operating system, the referrer URL (the previously visited page), the IP address, and the requesting provider. Log file information is stored for security reasons (e.g., to investigate misuse or fraud) for a maximum of 7 days and then deleted. Data whose further retention is necessary for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified.

 

Google Analytics

 

Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 (1) (f) GDPR), we use Google Analytics, a web analysis service provided by Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offering by users is usually transferred to a Google server in the USA and stored there. Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law ( https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active ). Google will use this information on our behalf to evaluate the use of our online offering by users, to compile reports on activities within this online offering and to provide us with other services related to the use of this online offering and internet usage. Pseudonymous user profiles of users may be created from the processed data. We only use Google Analytics with activated IP anonymization. This means that the user’s IP address will be shortened by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. The IP address transmitted by the user’s browser will not be merged with other Google data. Users can prevent cookies from being saved by setting their browser software accordingly; users can also prevent Google from collecting the data generated by the cookie and relating to their use of the website and from processing this data by Google by downloading and installing the browser plug-in available under the following link:  http://tools.google.com/dlpage/gaoptout?hl=de . Further information on Google’s data usage, settings, and opt-out options can be found in Google’s privacy policy ( https://policies.google.com/privacy ) and in the settings for the display of Google ads (https://adssettings.google.com/authenticated ). Users’ personal data will be deleted or anonymized after 14 months.

 

Google Adsense with personalized ads

 

Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 (1) (f) GDPR), we use the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”). Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law ( https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active ). We use the AdSense service, with the help of which advertisements are displayed on our website and we receive remuneration for their display or other use. For these purposes, usage data such as the click on an advertisement and the user’s IP address are processed, whereby the IP address is truncated by the last two digits. Therefore, user data is processed pseudonymously. We use Adsense with personalized ads. Google draws conclusions about users’ interests based on the websites they visit or apps they use and the user profiles created in this way. Advertisers use this information to tailor their campaigns to these interests, which is beneficial for users and advertisers alike. For Google, ads are personalized when collected or known data determines or influences the ad selection. This includes, among other things, previous searches, activities, website visits, app usage, demographic and location information. In detail, this includes: demographic targeting, targeting based on interest categories, remarketing, and targeting based on customer match lists and audience lists uploaded to DoubleClick Bid Manager or Campaign Manager. For more information about Google’s use of data, settings, and opt-out options, please see Google’s privacy policy ( https://policies.google.com/technologies/ads ) and the settings for displaying ads by Google ( https://adssettings.google.com/authenticated ).

 

Facebook Pixel, Custom Audiences and Facebook Conversion

 

Based on our legitimate interests in the analysis, optimization, and economic operation of our online offering, and for these purposes, we use the so-called “Facebook Pixel” of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or, if 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 and thus guarantees compliance with European data protection law ( https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active ). With the help of the Facebook Pixel, Facebook is able to determine visitors to our online offering as a target group for the display of advertisements (so-called “Facebook Ads”). Accordingly, we use the Facebook pixel to only display the Facebook ads we place to Facebook users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products determined based on the websites visited) that we transmit to Facebook (so-called “custom audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interests of users and do not appear annoying. With the help of the Facebook pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion”). The processing of data by Facebook takes place in accordance with Facebook’s data usage policy. Accordingly, general information on the display of Facebook ads can be found in Facebook’s data usage policy:  https://www.facebook.com/policy . Specific information and details about the Facebook pixel and how it works can be found in the Facebook help section: https://www.facebook.com/business/help/651294705016616 . You can object to the collection by the Facebook pixel and the use of your data to display Facebook ads. To set which types of ads are displayed to you within Facebook, you can visit the page set up by Facebook and follow the instructions there regarding the settings for usage-based advertising:  https://www.facebook.com/settings?tab=ads . The settings are platform-independent, meaning they are applied to all devices, such as desktop computers and mobile devices.









You can also object to the use of cookies for reach measurement and advertising purposes via the Network Advertising Initiative deactivation page ( http://optout.networkadvertising.org/ ) and additionally the US website ( http://www.aboutads.info/choices ) or the European website ( http://www.youronlinechoices.com/uk/your-ad-choices/ ).