DATA PROTECTION

With the following privacy policy, we would like to inform you about which types of your personal data (hereinafter also referred to as "data") we process, for what purposes, and to what extent. This 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 offering").

The terms used are not gender-specific.

As of February 22, 2024

Table of Contents

  • Introduction
  • Person responsible
  • Overview of processing
  • Relevant legal bases
  • Security measures
  • Transfer and disclosure of personal data
  • Data processing in third countries
  • Use of cookies
  • Commercial and business services
  • Use of online marketplaces for e-commerce
  • Payment service providers
  • Provision of the online offer and web hosting
  • Registration, login and user account
  • Blogs and publication media
  • Contact us
  • Communication via messenger
  • Newsletters and electronic notifications
  • Advertising communication via email, post, fax or telephone
  • Sweepstakes and competitions
  • Web analysis, monitoring and optimization
  • Online marketing
  • Presences in social networks (social media)
  • Plugins and embedded functions and content
  • Deletion of data
  • Changes and updates to the privacy policy
  • Rights of data subjects
  • Definitions of terms
  • Accessibility

Person responsible

Clarissa v. Haller / vonHaller GmbH

Authorized representatives: Wilhelm & Felicitas von Haller

Email address: info@horsda.de

Imprint:

Overview of processing

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

Types of data processed

  • Event Data (Facebook) ("Event Data" is data that can be transmitted by us to Facebook, for example, via Facebook Pixel (via apps or other means) and that relates to individuals or their actions. This 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 contain the actual content (such as comments written), login information, or contact information (i.e., no names, email addresses, or phone numbers). Event Data is deleted by Facebook after a maximum of two years, and the target groups created from it are deleted when our Facebook account is deleted.
  • Inventory data (e.g. names, addresses).
  • Content data (e.g. entries in online forms).
  • Contact details (e.g. email, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Location data (information about the geographical position of a device or person).
  • Contract data (e.g. subject matter of the contract, term, customer category).
  • Payment data (e.g. bank details, invoices, payment history).

Categories of data subjects

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

Purposes of processing

  • Provision of our online offering and user-friendliness.
  • Conversion measurement (measuring the effectiveness of marketing measures).
  • Office and organizational procedures.
  • Cross-device tracking (processing of user data across devices for marketing purposes).
  • Direct marketing (e.g. by email or post).
  • Conducting prize draws and competitions.
  • Feedback (e.g. collecting feedback via online form).
  • Interest-based and behavioral marketing.
  • Contact requests and communication.
  • Profiling (creation of user profiles).
  • Remarketing.
  • Reach measurement (e.g. access statistics, recognition of recurring visitors).
  • Security measures.
  • Tracking (e.g. interest/behavior-based profiling, use of cookies).
  • Provision of contractual services and customer service.
  • Managing and responding to inquiries.
  • Target group building (determination of target groups relevant for marketing purposes or other output of content).

Relevant legal bases

Below, we disclose the legal basis of the General Data Protection Regulation (GDPR) on 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 apply in individual cases, we will inform you of these in the privacy policy.

  • Consent (Article 6 (1) (a) GDPR) - The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
  • Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.
  • Legal obligation (Art. 6 (1) (c) GDPR) - Processing is necessary to fulfill a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 (1) (f) GDPR) - Processing is necessary to protect the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject which require protection of personal data prevail.

National data protection regulations in Germany : In addition to the data protection regulations of the General Data Protection Regulation, national data protection regulations apply in Germany. This includes, in particular, the law on the protection against misuse of personal data during data processing (Federal Data Protection Act - BDSG). The BDSG contains, in particular, special provisions on the right to information, the right to erasure, the right of objection, 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. Furthermore, it regulates data processing for the purposes of the employment relationship (Section 26 BDSG), particularly with regard to the establishment, implementation, or termination of employment relationships, as well as the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

Security 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, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.

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

IP address abbreviation : If IP addresses are processed by us or by the service providers and technologies we use, and the processing of a full IP address is not required, the IP address is abbreviated (also known as "IP masking"). The last two digits, or the last part of the IP address after a period, are removed or replaced with placeholders. The abbreviation of the IP address is intended to prevent or significantly complicate the identification of a person based on their IP address.

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

Transfer and disclosure of personal data

As part of our processing of personal data, it may happen that the data is transmitted to or disclosed to other bodies, companies, legally independent organizational units, or individuals. 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 integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

Data transfer within the organization : We may transfer personal data to other departments within our organization or grant them access to this data. If this transfer is for administrative purposes, the data is based on our legitimate business interests, if it is necessary to fulfill our contractual obligations, or if the data subject has given their consent or is permitted by law.

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 transmission of data to other persons, bodies or companies, this will only be done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transmission, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, if certifications or binding internal data protection regulations exist (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 visited websites or domains and are stored by a browser on the user's computer. A cookie is primarily used to store information about a user during or after their visit to an online service. The stored information may include, for example, the language settings on a website, the login status, a shopping cart, or the location at which a video was viewed. The term "cookies" also includes other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also known as "user IDs").

The following cookie types and functions are distinguished:

  • Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their browser.
  • Persistent cookies: Persistent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user interests, which are used for reach measurement or marketing purposes, can be stored in such a cookie.
  • First-party cookies: First-party cookies are set by us ourselves.
  • 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 can be absolutely necessary for the operation of a website (e.g. to save logins or other user inputs or for security reasons).
  • Statistics, marketing, and personalization cookies : Cookies are also generally used to measure reach and when a user's interests or behavior (e.g., viewing certain content, using features, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that corresponds to their potential interests. This process is also referred to as "tracking," i.e., tracking the potential interests of users. If we use cookies or "tracking" technologies, we will inform you separately in our privacy policy or when obtaining your consent.

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

Storage period: Unless we provide you with explicit information about the storage period of permanent cookies (e.g. as part of a so-called cookie opt-in), please assume that the storage period can be up to two years.

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke your consent or to object to the processing of your data using cookie technologies (collectively referred to as "opt-out"). You can initially declare your objection using your browser settings, e.g., by deactivating the use of cookies (although this may also limit 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 objection information in the information about the service providers and cookies used.

Processing of cookie data based on consent : We use a cookie consent management procedure within the framework of which users’ consent to the use of cookies or the processing operations and providers named in the cookie consent management procedure can be obtained and managed and revoked by users. The declaration of consent is saved so that it does not have to be requested again and so that consent can be proven in accordance with legal obligations. The data 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 consent to a user or their device. Subject to individual information about the providers of cookie management services, the following information applies: The consent can be stored for up to two years. A pseudonymous user identifier is created and saved along with the time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and device used.

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

Commercial and business services

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

We process this data to fulfill our contractual obligations, to protect our rights, and for the purposes of the administrative tasks associated with this information, as well as for business organization. Within the framework of applicable law, we only pass on the data of our contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations, or with the consent of the data subjects (e.g., to participating telecommunications, transport, and other auxiliary services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). The contractual partners will be informed about other forms of processing, e.g., for marketing purposes, in this privacy policy.

We will inform our contractual partners which data is required for the aforementioned purposes before or as part of the data collection, e.g. in online forms, by special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.

We delete data after the expiration of statutory warranty and similar obligations, i.e., generally after four years, unless the data is stored in a customer account, e.g., for as long as it must be retained for legal archiving reasons (e.g., for tax purposes, usually for ten years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the terms of the order, generally after the end of the order.

To the extent that we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply to the relationship between users and the providers.

Customer account : Contracting parties can create an account within our online offering (e.g., customer or user account, "customer account" for short). If registration of a customer account is required, contracting parties will be informed of this, as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. During registration, as well as subsequent logins and use of the customer account, we store the customer's IP addresses along with the access times in order to verify registration and prevent any misuse of the customer account.

Once customers have terminated their account, the data relating to the account will be deleted, unless retention is required for legal reasons. It is the customer's responsibility to back up their data after the account has been terminated.

Shop and e-commerce : We process our customers' data to enable them to select, purchase, or order the selected products, goods, and related services, as well as to pay for and deliver them or execute them. If necessary to execute an order, we use service providers, in particular postal, forwarding, and shipping companies, to carry out the delivery or execution for our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such during the ordering or similar purchase process and includes the information needed for delivery, provision, and billing, as well as contact information for any follow-up questions.

  • Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject of the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: interested parties, business and contractual partners, customers.
  • Purposes of processing: provision of contractual services and customer service, contact requests and communication, office and organizational procedures, administration and response to requests, security measures.
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

Use of online marketplaces for e-commerce

We offer our services on online platforms operated by other service providers. In this context, the privacy policies of the respective platforms apply in addition to our privacy policy. This applies in particular with regard to the reach measurement and interest-based marketing methods used on the platforms.

  • Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject of the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: customers.
  • Purposes of processing: Provision of contractual services and customer service.
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

Services and service providers used:

Payment service providers

Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the data subjects efficient and secure payment options and, in addition to banks and credit institutions, we use other payment service providers (collectively "Payment Service Providers") for this purpose.

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 may transmit the data to credit agencies. This transmission is for the purpose of identity and credit checks. For more information, please refer to the terms and conditions and the privacy policy of the payment service providers.

Payment transactions are subject to the terms and conditions and privacy policy of the respective payment service providers, which can be accessed within the respective websites or transaction applications. We also refer to these for further information and to assert your rights of withdrawal, information, and other data subjects.

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

Services and service providers 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 whose servers (or servers managed by them) serve as the online offering. For these purposes, we may use infrastructure and platform services, computing capacity, storage space, and database services, as well as security and technical maintenance services.

The data processed in the context of providing the hosting service may include all information concerning users of our online offering that arises during use and communication. This typically includes the IP address, which is necessary to deliver the content of online offerings to browsers, and all entries made within our online offering or on websites.

Collection of access data and log files : We (or our web hosting provider) collect data on every access to the server (so-called server log files). Server log files may include the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, the 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 (particularly in the case of abusive attacks, so-called DDoS attacks) and to ensure the utilization of the servers and their stability.

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

Registration, login and user account

Users can create a user account. During registration, users are provided with the required mandatory information and processed for the purpose of providing the user account based on contractual obligations. The data processed includes, in particular, login information (name, password, and an email address). The data entered during registration is used for the purposes of using the user account and its purpose.

Users can be informed by email about events relevant to their user account, such as technical changes. If users terminate their user account, their data related to the user account will be deleted, subject to any statutory retention requirements. It is the users' 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 you use our registration and login functions, as well as your user account, we store your IP address and the time of each user action. This storage is based on our legitimate interests and those of the users in protecting against misuse and other unauthorized use. This data is generally not shared with third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), 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 service, security measures, administration and response to inquiries.
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Blogs and publication media

We use blogs or similar means of online communication and publication (hereinafter "publication medium"). Readers' data is processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers, or for security reasons. Furthermore, we refer to the information on the processing of visitors to our publication medium in this privacy policy.

Comments and posts : When users leave comments or other posts, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone posts illegal content (insults, prohibited political propaganda, etc.) in comments or posts. In this case, we ourselves may be held liable for the comment or post and are therefore interested in the identity of the author.

Furthermore, we reserve the right to process user information for the purpose of spam detection based on our legitimate interests.

On the same legal basis, we reserve the right, in the case of surveys, to store users' IP addresses for the duration of the survey and to use cookies to prevent multiple voting.

The personal information, any contact and website information as well as the content information provided in the comments and contributions will be stored by us permanently until the user objects.

  • Types of data processed: 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: Provision of contractual services and customer service, feedback (e.g. collecting feedback via online form), security measures, administration and response to inquiries.
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

Contact us

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

Contact enquiries within the framework of contractual or pre-contractual relationships are answered to fulfill our contractual obligations or to answer (pre-)contractual enquiries and, moreover, on the basis of our legitimate interests in answering the enquiries.

  • Types of data processed: 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: communication partners.
  • Purposes of processing: contact requests and communication.
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

Communication via messenger

We use messenger services for communication purposes and therefore ask you to note the following information on the functionality of the messenger services, encryption, the use of communication metadata and your options for objecting.

You can also contact us via alternative means, such as phone or email. Please use the contact options provided or those listed within our online offering.

In the case of end-to-end encryption of content (i.e., the content of your message and attachments), please note that the communication content (i.e., the content of the message and attached images) is encrypted end-to-end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messenger with encryption enabled to ensure the encryption of the message content.

However, we would also like to point out to our communication partners that although the providers of the messengers cannot see the content, they can learn that and when communication partners communicate with us, as well as technical information about the device used by the communication partners and, depending on the settings of their device, location information (so-called metadata) is processed.

Notes on legal bases: If we ask communication partners for permission before communicating with them via messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and they contact us on their own initiative, for example, we use messenger in our relationship with our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and fulfilling the needs of our communication partners in communicating via messenger. We would also like to point out that we will not transmit the contact details provided to us to the messenger for the first time without your consent.

Revocation, objection, and deletion: You can revoke your consent at any time and object to communication with us via messenger. In the case of communication via messenger, we delete the messages in accordance with our general deletion guidelines (e.g., 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 we have responded to any inquiries from the communication partners, provided no reference to a previous conversation is to be expected and there are no statutory retention periods that prevent deletion.

Reservation of reference to other communication channels: Finally, we would like to point out that, for reasons of your security, we reserve the right not to respond to inquiries via messenger. This applies, for example, if internal contractual details require special confidentiality or if a response via messenger does not meet formal requirements. In such cases, we will refer you to more appropriate communication channels.

  • Types of data processed: Contact data (e.g. email, telephone numbers), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: communication partners.
  • Purposes of processing: contact requests and communication, direct marketing (e.g. by email or post).
  • Legal basis: Consent (Art. 6 (1) (a) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

Services and service providers used:

Newsletters and electronic notifications

We send newsletters, emails, and other electronic notifications (hereinafter "newsletters") only with the recipient's consent or legal permission. If the newsletter's content is specifically described when registering for the newsletter, it is decisive for the user's consent. Furthermore, our newsletters contain information about our services and us.

To subscribe to our newsletter, it is generally sufficient to provide your email address. However, we may ask you to provide a name for the purpose of addressing you personally in the newsletter, or other information if this is necessary for the purposes of the newsletter.

Double opt-in process: Registration for our newsletter is generally carried out using a so-called double opt-in process. This means that after 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. Newsletter registrations are logged to provide evidence of the registration process in accordance with legal requirements. This includes storing 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.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove previously given consent. The processing of this data is limited to the purpose of 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. In the case of obligations to permanently observe objections, we reserve the right to store the email address on a block list (so-called "block list") for this purpose alone.

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

Notes on legal bases: The newsletter is sent based on the recipient's consent or, if consent is not required, on our legitimate interest in direct marketing, if and to the extent permitted by law, e.g., in the case of advertising to existing customers. If we commission a service provider to send emails, this is done on the basis of our legitimate interests. The registration process is recorded based on our legitimate interests to demonstrate that it was carried out in accordance with the law.

Measuring opening and click rates : The newsletters contain a so-called "web beacon," i.e., a pixel-sized file that is retrieved from our server when the newsletter is opened, or, if we use a shipping service provider, from its server. During this retrieval, technical information, 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 our newsletter based on technical data or target groups and their reading behavior based on their access locations (which can be determined using the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened, and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. The evaluations allow us to recognize the reading habits of our users and adapt our content to them, or to send different content based on our users' interests.

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

Unfortunately, a separate revocation of performance measurement is not possible. In this case, the entire newsletter subscription must be canceled or revoked. In this case, the stored profile information will be deleted.

Prerequisite for using free services : Consent to receive mailings may be made a condition for using free services (e.g., access to certain content or participation in certain promotions). If users wish to use the free service without subscribing to the newsletter, please contact us.

  • Types of data processed: Inventory data (e.g. names, addresses), 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).
  • Data subjects: communication partners, users (e.g. website visitors, users of online services).
  • Purposes of processing: direct marketing (e.g. by email or post), reach measurement (e.g. access statistics, recognition of recurring visitors), tracking (e.g. interest/behavior-related profiling, use of cookies), remarketing, conversion measurement (measurement of the effectiveness of marketing measures), provision of contractual services and customer service.
  • Legal basis: Consent (Art. 6 (1) (a) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
  • Opt-out: You can unsubscribe from our newsletter at any time, i.e., revoke your consent or object to further receipt. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or by using one of the contact options listed above, preferably email.

Services and service providers used:

  • Google Analytics: Measuring the success of email campaigns and creating user profiles with a storage period of up to two years; 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 plug-in: https://tools.google.com/dlpage/gaoptout?hl=de , Settings for the display of advertisements: https://adssettings.google.com/authenticated .
  • Klaviyo: We use Klaviyo, a service for our email marketing, on our website. The service provider is the American company Klaviyo, 125 Summer St, Boston, MA 02110, USA. Klaviyo processes your data, among other places, in the USA. We would like to point out that, in the opinion of the European Court of Justice, there is currently no adequate level of protection for data transfer to the USA. This can entail various risks for the legality and security of data processing. Klaviyo uses so-called standard contractual clauses (= Art. 46 (2) and (3) GDPR) as the basis for data processing with recipients located in third countries (outside the European Union, Iceland, Liechtenstein, Norway, and therefore in particular in the USA) or for data transfer there. Standard contractual clauses (SCCs) are templates provided by the EU Commission and are intended to ensure that your data complies with European data protection standards even if it is transferred to and stored in third countries (such as the USA). Through these clauses, Klaviyo undertakes to comply with European data protection standards when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding standard contractual clauses here, among other places: https://eurlex.europa.eu/eli/dec_impl/2021/914/oj?locale=de. The Data Processing Agreement, which corresponds to the standard contractual clauses, can be found at https://www.klaviyo.com/legal/dpa. You can learn more about the data processed through the use of Klaviyo in the Privacy Policy at https://www.klaviyo.com/legal/privacy/privacy-notice .

Advertising communication via email, post, fax or telephone

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

Recipients have the right to revoke consent given or to object to advertising communication at any time.

After revocation or objection, we may store the data required to prove consent for up to three years based on our legitimate interests before deleting it. The processing of this data will be 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 also confirmed.

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

Sweepstakes and competitions

We process personal data of participants in prize draws and competitions only in compliance with the relevant data protection regulations, insofar as the processing is contractually necessary for the provision, implementation and processing of the prize draw, the participants have consented to the processing or the processing serves our legitimate interests (e.g. in the security of the prize draw or the protection of our interests against misuse through possible collection of IP addresses when submitting prize draw entries).

If entries from participants are published as part of the competition (e.g., as part of a vote or presentation of the competition entries or winners, or in the reporting on the competition), we would like to point out that the names of the participants may also be published in this context. Participants can object to this at any time.

If the competition takes place within an online platform or social network (e.g., Facebook or Instagram, hereinafter referred to as the "online platform"), the terms of use and privacy policy of the respective platforms also apply. In these cases, we point out that we are responsible for the information provided by participants in the competition and that inquiries regarding the competition should be directed to us.

Participants' data will be deleted as soon as the prize draw or competition has ended and the data is no longer required to inform the winners or because queries about the prize draw are expected. Participants' data will generally be deleted no later than six months after the end of the prize draw. Winners' data may be retained for longer, for example to answer queries about the prizes or to fulfill the prize draw services; in this case, the retention period depends on the type of prize and is up to three years for items or services, for example in order to process warranty claims. Participants' data may also be stored for longer, for example in the form of reports on the prize draw in online and offline media.

If data was collected for other purposes as part of the competition, its processing and retention period are governed by the data protection information for this use (e.g. in the case of registration for the newsletter as part of a competition).

  • Types of data processed: inventory data (e.g. names, addresses), content data (e.g. entries in online forms).
  • Data subjects: Participants in prize draws and competitions.
  • Purposes of processing: Conducting prize draws and competitions.
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR).

Web analysis, monitoring and optimization

Web analytics (also known as "reach measurement") is used to evaluate visitor traffic to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. Reach analysis allows us to determine, for example, when our online offering, its features, or content, are most frequently used or encourage reuse. We can also understand which areas require optimization.

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

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

Users' IP addresses are also stored. However, we use an IP masking process (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no user data (such as email addresses or names) is stored for web analysis, A/B testing, and optimization; instead, pseudonyms are used. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.

Notes on legal bases: 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 would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: reach measurement (e.g. access statistics, recognition 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 basis: Consent (Art. 6 (1) (a) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

Services and service providers used:

  • Google Analytics: reach measurement and web analysis; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 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 via an interface and thus integrate other services into our online offering (further information can be found in this privacy policy). The Tag Manager itself (which implements the tags) therefore does not create user profiles or store cookies. Google only receives the user's IP address, which is necessary to run Google Tag Manager. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 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 online marketing purposes, which may include, in particular, the marketing of advertising space or the presentation of advertising and other content (collectively referred to as "content") based on potential user interests and the measurement of its effectiveness.

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

Users' IP addresses are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no real user data (such as email addresses or names) is stored as part of the online marketing process; instead, pseudonyms are used. This means that neither we nor the providers of the online marketing process 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 processes. These cookies can generally also be read later on other websites that use the same online marketing process, analyzed for the purposes of displaying content, and supplemented with additional data and stored on the server of the online marketing process provider.

In exceptional cases, clear data may be assigned to profiles. This is the case, for example, if users are members of a social network whose online marketing methods we use, and the network links the users' profiles with the aforementioned information. Please note that users may enter into additional agreements with the providers, e.g., by providing consent during registration.

We generally only receive 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 led to a so-called conversion, i.e., to the conclusion of a contract with us. Conversion measurements are used solely to analyze the success of our marketing measures.

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

Notes on legal bases: 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 would also like to draw your attention to the information on the use of cookies in this privacy policy.

Facebook Pixel and Target Group Creation (Custom Audiences) : With the help of the Facebook pixel (or comparable functions for transmitting event data or contact information via interfaces in apps), Facebook is able to define visitors to our online offering as a target group for displaying advertisements (so-called "Facebook Ads"). Accordingly, we use the Facebook pixel to display the Facebook ads we place only to those users on Facebook and within the services of partners cooperating with Facebook (so-called "Audience Network" https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offering or who exhibit certain characteristics (e.g., interest in certain topics or products, which can be seen from 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 are not 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 measurement").

We are jointly responsible with Facebook Ireland Ltd. for the collection or receipt during transmission (but not the further processing) of "event data" that Facebook collects or receives during transmission using the Facebook pixel and similar functions (e.g., interfaces) that are implemented on our online offering for the following purposes: a) display of content and advertising information that corresponds to the presumed interests of users; b) delivery of commercial and transaction-related messages (e.g., addressing users via Facebook Messenger); c) improving ad delivery and personalizing 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", https://www.facebook.com/legal/controller_addendum ), which specifically regulates the security measures Facebook must observe ( https://www.facebook.com/legal/terms/data_security_terms ) and in which Facebook has agreed to fulfill the rights of those affected (i.e. users can, for example, direct information or deletion requests to Facebook). Note: If Facebook provides us with metrics, analyses and reports (which are aggregated, i.e., do not contain any information on individual users and are anonymous to us), this processing is not carried out within the framework of joint controllership, but on the basis of a data processing agreement ("Data Processing Terms", https://www.facebook.com/legal/terms/dataprocessing ), the "Data Security Terms" ( https://www.facebook.com/legal/terms/data_security_terms ) and, with regard to processing in the USA, on the basis of standard contractual clauses ("Facebook EU Data Transfer Addendum", https://www.facebook.com/legal/EU_data_transfer_addendum ). Users' rights (in particular the right to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook.

  • Types of data processed: Usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses), location data (information on the geographical position of a device or a person), event data (Facebook) ("Event data" is data that can be transmitted by us to Facebook, e.g., via Facebook Pixel (via apps or other means) and that relates to individuals or their actions. This 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 contain the actual content (such as comments written), login information, or contact information (i.e., no names, email addresses, or phone numbers). Event data is deleted by Facebook after a maximum of two years, and the target groups created from it are deleted when our Facebook account is deleted.
  • Data subjects: users (e.g. website visitors, users of online services), interested parties.
  • Purposes of processing: Tracking (e.g. interest/behavior-related profiling, use of cookies), remarketing, conversion measurement (measurement of the effectiveness of marketing measures), interest-based and behavior-related marketing, profiling (creation of user profiles), reach measurement (e.g. access statistics, recognition of recurring visitors), target group formation (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 (1) (a) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
  • Opt-out: We refer to the privacy policies of the respective providers and the opt-out options specified for the providers (so-called "opt-out"). If no explicit opt-out option has been provided, you have the option of deactivating cookies in your browser settings. However, this may limit the functions of our online offering. We therefore recommend the following additional opt-out options, which are summarized for each region: a) Europe: https://www.youronlinechoices.eu . b) Canada: https://www.youradchoices.ca/choices . c) USA: https://www.aboutads.info/choices . d) Cross-regional: https://optout.aboutads.info .

TikTok pixel and target group building. We use the TikTok pixel on our website, an analytics tool from TikTok (musical.ly Inc., 10351 Santa Monica Blvd #310, Los Angeles, CA 90025, USA), to measure the effectiveness of our advertising measures and create target groups for personalized advertising. The TikTok pixel enables us to track certain user actions, such as page views or purchases, and transmit this information to TikTok so that these users or users with similar interests can be targeted (so-called "custom audiences" or "lookalike audiences").

Types of data processed:

When using the TikTok pixel, the following data may be collected and processed:

  • Event data: Actions performed on our website (e.g., clicks, purchases, form submissions).
  • Device information: Information about the device used (e.g. operating system, browser type, IP address, language settings).
  • Usage data: Information about the pages visited, the length of time spent on the site, and interactions with content.
  • Location data: Geographical position (if enabled).

Purpose of processing:

  • Analysis and measurement of success of advertising campaigns (conversion tracking).
  • Creation of target groups for targeted advertisements (custom audiences).
  • Optimization of advertising content and ads based on usage behavior.

Legal basis:

The TikTok pixel is used based on your consent in accordance with Art. 6 (1) (a) GDPR. You can revoke your consent at any time by adjusting your cookie settings.

Data transmission and storage period:

The data collected by the TikTok pixel may be transferred to TikTok servers in the USA or other third countries and processed there. Please note that an adequate level of data protection under the GDPR may not exist in these countries. TikTok has committed to complying with the EU Commission's Standard Contractual Clauses (SCCs) to ensure an adequate level of data protection. Further information can be found in TikTok's privacy policy : https://www.tiktok.com/legal/privacy-policy .

The retention period for data depends on TikTok's internal guidelines. Data is generally stored for a period of up to two years.

Opt-out options:

You can object to the collection and processing of data by the TikTok pixel at any time. This can be done by taking the following measures:

  1. Adjust cookie settings: Deactivate the TikTok pixel via our cookie banner or the privacy settings on our website.
  2. Browser settings: Disable the use of cookies directly in your browser settings.
  3. External opt-out tools: Use platforms like YourOnlineChoices to adjust your online advertising preferences.

Notes:

Please note that opting out may affect the functionality of our website or the use of certain features.

Services and service providers used:

  • Google Tag Manager: Google Tag Manager is a solution that allows us to manage so-called website tags via an interface and thus integrate other services into our online offering (further information can be found in this privacy policy). The Tag Manager itself (which implements the tags) therefore does not create user profiles or store cookies. Google only receives the user's IP address, which is necessary to run Google Tag Manager. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 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 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 ; objection option (opt-out): opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de , settings for the display of advertisements: https://adssettings.google.com/authenticated .
  • Google Ads and Conversion Measurement: We use the online marketing process "Google Ads" to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who are likely to be interested in the ads. We also measure the conversion of the ads. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page with a so-called "conversion tracking tag." However, we do not receive any information that could identify users. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com ; Privacy policy: https://policies.google.com/privacy .
  • Google Adsense with non-personalized ads: We use the Google Adsense service with non-personalized ads, with the help of which ads are displayed within our online offering and we receive remuneration for their display or other use. ; 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 .
  • Facebook Pixel and target group creation (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 .
  • Klaviyo:  We use Klaviyo, a service for our email marketing, on our website. The service provider is the American company Klaviyo, 125 Summer St, Boston, MA 02110, USA. Klaviyo processes your data, among other places, in the USA. We would like to point out that, in the opinion of the European Court of Justice, there is currently no adequate level of protection for data transfer to the USA. This can entail various risks for the legality and security of data processing. Klaviyo uses so-called standard contractual clauses (= Art. 46 (2) and (3) GDPR) as the basis for data processing with recipients located in third countries (outside the European Union, Iceland, Liechtenstein, Norway, and therefore in particular in the USA) or for data transfers there. Standard contractual clauses (SCCs) are templates provided by the EU Commission and are intended to ensure that your data complies with European data protection standards even if it is transferred to and stored in third countries (such as the USA). Through these clauses, Klaviyo undertakes to comply with European data protection standards when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding standard contractual clauses here, among other places: https://eurlex.europa.eu/eli/dec_impl/2021/914/oj?locale=de. The Data Processing Agreement, which corresponds to the standard contractual clauses, can be found at https://www.klaviyo.com/legal/dpa. You can learn more about the data processed through the use of Klaviyo in the Privacy Policy at https://www.klaviyo.com/legal/privacy/privacy-notice .

Presences in social networks (social media)

We maintain online presences within social networks and, in this context, process user data 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 could pose risks for users, for example, because it could make it more difficult to enforce their rights.

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

For a detailed description of the respective processing methods and the opt-out options, please refer to the privacy policies 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 like to point out that these can be most effectively asserted with the providers. Only the providers have access to the user data and can directly take appropriate measures and provide information. Should you still need assistance, please contact us.

Facebook : We, together with Facebook Ireland Ltd., are responsible for collecting (but not further processing) data from visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see "Things you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/policy ), as well as information about the devices users use (e.g., IP addresses, operating system, browser type, language settings, cookie data; see "Device Information" in the Facebook Data Policy: https://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 called "Page Insights" to page operators so that they can 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", https://www.facebook.com/legal/terms/page_controller_addendum ), which specifically regulates the security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of those affected (i.e., users can, for example, submit information or deletion requests directly to Facebook). Users' rights (in particular, the right 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 ).

  • Types of data processed: 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. interest/behavior-related profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of recurring visitors).
  • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

Services and service providers used:

  • Clubhouse: Social network with audio chat functionality; Provider's information: Solely to support incident investigations, Clubhouse temporarily records the audio in a chat room while the room is active and thereafter, if a user reports a breach of trust and security, while the room is active until the investigation is completed; Audio from muted speakers and listeners is never recorded, and all temporary audio recordings are encrypted; Personal data processed by Clubhouse may be processed for marketing purposes or shared with third parties; Service provider: Alpha Exploration Co., Inc.; Website: https://www.joinclubhouse.com/ ; Privacy policy: https://privacy.joinclubhouse.com/ .
  • Instagram: Social network; service provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; website: https://www.instagram.com ; privacy policy: https://instagram.com/about/legal/privacy .
  • 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: https://www.facebook.com ; privacy policy: https://www.facebook.com/about/privacy ; opt-out option: ad settings: https://www.facebook.com/settings?tab=ads .
  • TikTok: Social network/video platform; service provider: musical.ly Inc., 10351 Santa Monica Blvd #310, Los Angeles, CA 90025 USA; website: https://www.tiktok.com ; privacy policy: https://www.tiktok.com/de/privacy-policy .
  • YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Privacy policy: https://policies.google.com/privacy ; Opt-out option: https://adssettings.google.com/authenticated .

Plugins and embedded functions and content

We integrate 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 include, for example, graphics, videos, social media buttons, and posts (hereinafter collectively referred to as "content").

Integration always requires that the third-party providers of this content process the user's IP address, as without the IP address they would not be able to send the content to their browser. The IP address is therefore required to display this content or functions. We endeavor 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. These "pixel tags" can be used to evaluate 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, the time of visit, and other information about the use of our online offering, as well as be 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 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 plugins and content : We are jointly responsible with Facebook Ireland Ltd. for the collection or receipt during transmission (but not the further processing) of "event data" that Facebook collects or receives during transmission using the Facebook social plugins (and content embedding functions) that run on our website for the following purposes: a) display of content and advertising information that corresponds to the presumed interests of users; b) delivery of commercial and transaction-related messages (e.g., addressing users via Facebook Messenger); c) improving ad delivery and personalizing 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", https://www.facebook.com/legal/controller_addendum ), which specifically regulates the security measures Facebook must observe ( https://www.facebook.com/legal/terms/data_security_terms ) and in which Facebook has agreed to fulfill the rights of those affected (i.e. users can, for example, direct information or deletion requests to Facebook). Note: If Facebook provides us with metrics, analyses and reports (which are aggregated, i.e. do not contain any information on individual users and are anonymous to us), this processing is not carried out within the framework of joint controllership, but on the basis of a data processing agreement ("Data Processing Terms", https://www.facebook.com/legal/terms/dataprocessing ), the "Data Security Terms" ( https://www.facebook.com/legal/terms/data_security_terms ) and, with regard to processing in the USA, on the basis of standard contractual clauses ("Facebook EU Data Transfer Addendum", https://www.facebook.com/legal/EU_data_transfer_addendum ). Users' rights (in particular the right to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook.

Instagram plugins and content : We are jointly responsible with Facebook Ireland Ltd. for the collection or receipt during transmission (but not the further processing) of "event data" that Facebook collects or receives during transmission using Instagram functions (e.g., content embedding functions) that are executed on our online offering for the following purposes: a) Displaying content and advertising information that corresponds to the presumed interests of users; b) Delivery of commercial and transaction-related messages (e.g., addressing users via Facebook Messenger); c) Improving ad delivery and personalizing 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", https://www.facebook.com/legal/controller_addendum ), which specifically regulates the security measures Facebook must observe ( https://www.facebook.com/legal/terms/data_security_terms ) and in which Facebook has agreed to fulfill the rights of those affected (i.e. users can, for example, direct information or deletion requests to Facebook). Note: If Facebook provides us with metrics, analyses and reports (which are aggregated, i.e. do not contain any information on individual users and are anonymous to us), this processing is not carried out within the framework of joint controllership, but on the basis of a data processing agreement ("Data Processing Terms", https://www.facebook.com/legal/terms/dataprocessing ), the "Data Security Terms" ( https://www.facebook.com/legal/terms/data_security_terms ) and, with regard to processing in the USA, on the basis of standard contractual clauses ("Facebook EU Data Transfer Addendum", https://www.facebook.com/legal/EU_data_transfer_addendum ). Users' rights (in particular the right to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook.

  • Types of data processed: 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, e.g., via Facebook Pixel (via apps or other means) and that relates to individuals or their actions. This data includes, for example, information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.; the event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); event data does not contain the actual content (such as comments written), login information, or contact information (i.e., no names, email addresses, or phone numbers). Event data is deleted by Facebook after a maximum of two years; the target groups created from it are deleted when our Facebook account is deleted), contact data (e.g., email, phone 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 offer and user-friendliness, provision of contractual services and customer service, contact requests and communication, direct marketing (e.g. by email or post), tracking (e.g. interest/behavior-related profiling, use of cookies), interest-based and behavior-related marketing, profiling (creation of user profiles), security measures, administration and response to inquiries.
  • Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR), consent (Art. 6 (1) (a) GDPR), contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).

Services and service providers used:

  • Facebook plugins and content: Facebook social plugins and content - This can include content such as images, videos or texts and buttons that users can use to share content from this website within Facebook. The list and appearance of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/ ; 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: https://www.facebook.com ; Privacy policy: https://www.facebook.com/about/privacy ; Opt-out option: Advertising settings: https://www.facebook.com/settings?tab=ads .
  • Instagram plugins and content: Instagram plugins and content – ​​This can include content such as images, videos, or text, and buttons that users can use to share content from this online offering within Instagram. Service provider: https://www.instagram.com , Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com ; Privacy policy: https://instagram.com/about/legal/privacy .
  • reCAPTCHA: We integrate the "reCAPTCHA" function to be able to recognize whether entries (e.g. in online forms) are made by humans and not by automatically acting machines (so-called "bots"). The data processed may include IP addresses, information about operating systems, devices or browsers used, language settings, location, mouse movements, keyboard strokes, time spent on websites, previously visited websites, interactions with ReCaptcha on other websites, possibly cookies, and the results of manual recognition processes (e.g. answering questions asked or selecting objects in images). Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://www.google.com/recaptcha/ ; Privacy policy: https://policies.google.com/privacy ; Opt-out option: Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de , Settings for the display of advertisements: https://adssettings.google.com/authenticated .
  • TikTok plugins and content: TikTok plugins and content – ​​This can include content such as images, videos, text, and buttons. Service provider: musical.ly Inc., 10351 Santa Monica Blvd #310, Los Angeles, CA 90025 USA; Website: https://www.tiktok.com ; Privacy policy: https://www.tiktok.com/de/privacy-policy .
  • YouTube videos: video content; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://www.youtube.com ; privacy policy: https://policies.google.com/privacy ; option to object (opt-out): opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de , settings for the display of advertisements: https://adssettings.google.com/authenticated .
  • Google Web Fonts: This website uses so-called web fonts provided by Google for the uniform display of fonts. When you visit a page, your browser loads the required web fonts into your browser cache in order to display texts and fonts correctly. For this purpose, the browser you use must establish a connection to Google's servers. This means that Google knows that our website was accessed via your IP address. Google Web Fonts is used in the interest of a uniform and appealing presentation of our online offerings. This represents a legitimate interest within the meaning of Art. 6 (1) (f) GDPR. If your browser does not support web fonts, a standard font from your computer will be used. Further information about Google Web Fonts can be found at https://developers.google.com/fonts/faq and in Google's privacy policy: https://policies.google.com/privacy?hl=de .
  • Klaviyo:  We use Klaviyo, a service for our email marketing, on our website. The service provider is the American company Klaviyo, 125 Summer St, Boston, MA 02110, USA. Klaviyo processes your data, among other places, in the USA. We would like to point out that, in the opinion of the European Court of Justice, there is currently no adequate level of protection for data transfer to the USA. This can entail various risks for the legality and security of data processing. Klaviyo uses so-called standard contractual clauses (= Art. 46 (2) and (3) GDPR) as the basis for data processing with recipients located in third countries (outside the European Union, Iceland, Liechtenstein, Norway, and therefore in particular in the USA) or for data transfers there. Standard contractual clauses (SCCs) are templates provided by the EU Commission and are intended to ensure that your data complies with European data protection standards even if it is transferred to and stored in third countries (such as the USA). Through these clauses, Klaviyo undertakes to comply with European data protection standards when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding standard contractual clauses here, among other places: https://eurlex.europa.eu/eli/dec_impl/2021/914/oj?locale=de. The Data Processing Agreement, which corresponds to the standard contractual clauses, can be found at https://www.klaviyo.com/legal/dpa. You can learn more about the data processed through the use of Klaviyo in the Privacy Policy at https://www.klaviyo.com/legal/privacy/privacy-notice .

Deletion of data

The data we process will be deleted in accordance with legal requirements as soon as the consent to processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or it is no longer required for the purpose).

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

Further information on the deletion of personal data can also be found in the individual data protection notices of this data protection declaration.

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.

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

Rights of data subjects

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

  • Right of objection: You have the right to object at any time to the processing of personal data concerning you based on Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these 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 the purposes of such advertising; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw consent at any time.
  • Right to information: You have the right to request confirmation as to whether 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 legal requirements.
  • Right to rectification: You have the right, in accordance with the statutory provisions, to request that the data concerning you be completed or that inaccurate data concerning you be corrected.
  • Right to erasure and restriction of processing: You have the right, in accordance with the statutory provisions, 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 statutory provisions.
  • Right to data portability: You have the right to receive the data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transmitted to another controller.
  • Complaint to a supervisory authority: You also have the right, in accordance with the statutory provisions, 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 believe that the processing of personal data concerning you violates the GDPR.

Definitions of terms

This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined primarily in Art. 4 GDPR. The legal definitions are binding. The following explanations, however, are intended primarily to facilitate understanding. The terms are sorted alphabetically.

  • Cross-device tracking: Cross-device tracking is a form of tracking in which user behavior and interest information is collected across devices in so-called profiles by assigning users an online identifier. This allows user information to be analyzed for marketing purposes, regardless of the 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" is a method in which the last octet, i.e., the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing procedures, especially in online marketing.
  • Interest-based and behavioral marketing: Interest-based and/or behavioral marketing refers to the process of determining users' potential interests in ads and other content as precisely as possible. This is done based on information about their previous behavior (e.g., visiting and staying on certain websites, purchasing behavior, or interactions with other users), which is stored in a so-called profile. Cookies are typically used for these purposes.
  • Conversion measurement: Conversion measurement (also known as "visit action analysis") is a method used to determine the effectiveness of marketing measures. This typically involves storing a cookie on users' devices within the websites where the marketing measures are carried out and then retrieving it on the target website. For example, this allows us to understand whether the ads we place on other websites were successful.
  • Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiling: "Profiling" refers to any form of automated processing of personal data consisting of the use of personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information relating to age, gender, location and movement data, interaction with websites and their content, purchasing behavior, social interactions with other people) (e.g., interests in certain content or products, click behavior on a website, or location). Cookies and web beacons are often used for profiling purposes.
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate visitor traffic to an online offering and can include visitor behavior or interest in specific information, such as website content. With the help of reach analysis, website owners can, for example, identify when visitors visit their website and what content they are interested in. This allows them to, for example, better tailor website content to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to identify returning visitors and thus obtain more precise analyses of the use of an online offering.
  • Remarketing: "Remarketing" or "retargeting" is the term used when, for example, for advertising purposes, the products a user was interested in on a website are noted in order to remind the user of these products on other websites, e.g. in advertisements.
  • Location data: Location data is generated when a mobile device (or other device with the technical capabilities for location determination) connects to a cell tower, a Wi-Fi network, or similar technical intermediaries and location determination functions. Location data is used to indicate the geographically identifiable position of the respective device on Earth. Location data can be used, for example, to display map functions or other location-dependent information.
  • Tracking: "Tracking" refers to the tracking of user behavior across multiple online offerings. Typically, behavioral and interest information related to the online offerings used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
  • Controller: The “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of the processing of personal data.
  • Processing: "Processing" is any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and encompasses virtually every type of data handling, including collection, analysis, storage, transmission, or deletion.
  • Target group creation: Target group creation (or "custom audiences") is the process of defining target groups for advertising purposes, e.g., displaying advertisements. For example, based on a user's interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which they viewed the products. "Lookalike audiences" (or similar target groups), on the other hand, are the process of displaying content deemed suitable to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are typically used to create custom audiences and lookalike audiences.

Accessibility Statement

We want to design our online shop so that it is accessible to everyone.
We use the SEA Accessibility tool to review and improve accessibility. We adhere to the international standards of the EAA , ADA , and WCAG guidelines.

Should you nevertheless notice any barriers, we would appreciate your feedback so that we can further improve our offering.