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Privacy Policy

Privacy Policy

Privacy Policy Introduction and Overview

We have written this privacy policy (version 27.08.2024-122864558) in order to explain to you, in accordance with the provisions of the General Data Protection Regulation (EU) 2016/679 and applicable national laws, which personal data (data for short) we as the controller – and the processors commissioned by us (e.g. providers) – process, will process in the future and what legal options you have. The terms used are to be considered gender-neutral.
In short: We provide you with comprehensive information about any of your personal data we process.

Privacy policies usually sound very technical and use legal terminology. However, this privacy policy is intended to describe the most important things to you as simply and transparently as possible. So long as it aids transparency, technical terms are explained in a reader-friendly manner, links to further information are provided and graphics are used. We are thus informing in clear and simple language that we only process personal data in the context of our business activities if there is a legal basis for it. This is certainly not possible with brief, unclear and legal-technical statements, as is often standard on the internet when it comes to data protection. I hope you find the following explanations interesting and informative. Maybe you will also find some information that you have not been familiar with.
If you still have questions, we kindly ask you to contact the responsible body named below or in the imprint, follow the existing links and look at further information on third-party sites. You can of course also find our contact details in the imprint.

Scope

This privacy policy applies to all personal data processed by our company and to all personal data processed by companies commissioned by us (processors). With the term personal data, we refer to information within the meaning of Article 4 No. 1 GDPR, such as the name, email address and postal address of a person. The processing of personal data ensures that we can offer and invoice our services and products, be it online or offline. The scope of this privacy policy includes:

  • all online presences (websites, online shops) that we operate
  • Social media presences and email communication
  • mobile apps for smartphones and other devices

In short: This privacy policy applies to all areas in which personal data is processed in a structured manner by the company via the channels mentioned. Should we enter into legal relations with you outside of these channels, we will inform you separately if necessary.

Legal bases

In the following privacy policy, we provide you with transparent information on the legal principles and regulations, i.e. the legal bases of the General Data Protection Regulation, which enable us to process personal data.
Whenever EU law is concerned, we refer to REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016. You can of course access the General Data Protection Regulation of the EU online at EUR-Lex, the gateway to EU law, at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679.

We only process your data if at least one of the following conditions applies:

  1. Consent (Article 6 Paragraph 1 lit. a GDPR): You have given us your consent to process data for a specific purpose. An example would be the storage of data you entered into a contact form.
  2. Contract (Article 6 Paragraph 1 lit. b GDPR): We process your data in order to fulfill a contract or pre-contractual obligations with you. For example, if we conclude a sales contract with you, we need personal information in advance.
  3. Legal obligation (Article 6 Paragraph 1 lit. c GDPR): If we are subject to a legal obligation, we will process your data. For example, we are legally required to keep invoices for our bookkeeping. These usually contain personal data.
  4. Legitimate interests (Article 6 Paragraph 1 lit. f GDPR): In the case of legitimate interests that do not restrict your basic rights, we reserve the right to process personal data. For example, we have to process certain data in order to be able to operate our website securely and economically. Therefore, the processing is a legitimate interest.

Other conditions such as making recordings in the interest of the public, the exercise of official authority as well as the protection of vital interests do not usually occur with us. Should such a legal basis be relevant, it will be disclosed in the appropriate place.

In addition to the EU regulation, national laws also apply:

  • In Austria this is the Austrian Data Protection Act (Datenschutzgesetz), in short DSG.
  • In Germany this is the Federal Data Protection Act (Bundesdatenschutzgesetz), in short BDSG.

Should other regional or national laws apply, we will inform you about them in the following sections.

Contact details of the data protection controller

If you have any questions about data protection, you will find the contact details of the responsible person or controller below:
SMILE-Translations Organisation GmbH
Zögernsee 23
2000 Stockerau/Wien
Österreich

Authorised to represent: Franz Harnacker
E-Mail: fh@smile-translations.at
Phone: +43(0)699/10531177
Company details: https://www.smile-translations.at/impressum/

Storage Period

It is a general criterion for us to store personal data only for as long as is absolutely necessary for the provision of our services and products. This means that we delete personal data as soon as any reason for the data processing no longer exists. In some cases, we are legally obliged to keep certain data stored even after the original purpose no longer exists, such as for accounting purposes.

If you want your data to be deleted or if you want to revoke your consent to data processing, the data will be deleted as soon as possible, provided there is no obligation to continue its storage.

We will inform you below about the specific duration of the respective data processing, provided we have further information.

Rights in accordance with the General Data Protection Regulation

In accordance with Articles 13, 14 of the GDPR, we inform you about the following rights you have to ensure fair and transparent processing of data:

  • According to Article 15 DSGVO, you have the right to information about whether we are processing data about you. If this is the case, you have the right to receive a copy of the data and to know the following information:
    • for what purpose we are processing;
    • the categories, i.e. the types of data that are processed;
    • who receives this data and if the data is transferred to third countries, how security can be guaranteed;
    • how long the data will be stored;
    • the existence of the right to rectification, erasure or restriction of processing and the right to object to processing;
    • that you can lodge a complaint with a supervisory authority (links to these authorities can be found below);
    • the origin of the data if we have not collected it from you;
    • Whether profiling is carried out, i.e. whether data is automatically evaluated to arrive at a personal profile of you.
  • You have a right to rectification of data according to Article 16 GDPR, which means that we must correct data if you find errors.
  • You have the right to erasure (“right to be forgotten”) according to Article 17 GDPR, which specifically means that you may request the deletion of your data.
  • According to Article 18 of the GDPR, you have the right to restriction of processing, which means that we may only store the data but not use it further.
  • According to Article 20 of the GDPR, you have the right to data portability, which means that we will provide you with your data in a standard format upon request.
  • According to Article 21 DSGVO, you have the right to object, which entails a change in processing after enforcement.
    • If the processing of your data is based on Article 6(1)(e) (public interest, exercise of official authority) or Article 6(1)(f) (legitimate interest), you may object to the processing. We will then check as soon as possible whether we can legally comply with this objection.
    • If data is used to conduct direct advertising, you may object to this type of data processing at any time. We may then no longer use your data for direct marketing.
    • If data is used to conduct profiling, you may object to this type of data processing at any time. We may no longer use your data for profiling thereafter.
  • According to Article 22 of the GDPR, you may have the right not to be subject to a decision based solely on automated processing (for example, profiling).
  • You have the right to lodge a complaint under Article 77 of the GDPR. This means that you can complain to the data protection authority at any time if you believe that the data processing of personal data violates the GDPR.

In short: you have rights – do not hesitate to contact the responsible party listed above with us!

If you believe that the processing of your data violates data protection law or your data protection rights have been violated in any other way, you can complain to the supervisory authority. For Austria, this is the data protection authority, whose website can be found at https://www.dsb.gv.at/. In Germany, there is a data protection officer for each federal state. For more information, you can contact the Federal Commissioner for Data Protection and Freedom of Information (BfDI). The following local data protection authority is responsible for our company:

Austria Data protection authority

Manager:Dr. Matthias Schmidl
Address: 
Barichgasse 40-42, 1030 Wien
Phone number.: 
+43 1 52 152-0
E-mail address: 
dsb@dsb.gv.at
Website: 
https://www.dsb.gv.at/

Data transfer to third countries

We only transfer or process data to countries outside the scope of the GDPR (third countries) if you consent to this processing or if there is another legal permission. This is particularly true when processing is legally required or necessary for the performance of a contractual relationship, and in any case, only to the extent permitted by law. Your consent is in most cases the primary reason for us to process data in third countries. Processing of personal data in third countries such as the USA, where many software providers offer services and have their server locations, may mean that personal data is processed and stored in unexpected ways.

We explicitly point out that, according to the opinion of the European Court of Justice, there is currently only an adequate level of protection for data transfers to the USA if a US company processing personal data of EU citizens in the USA is an active participant in the EU-US Data Privacy Framework. More information can be found at: https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en

Data processing by US services that are not active participants in the EU-US Data Privacy Framework may result in data not being anonymized and processed, if applicable. Additionally, US government authorities may potentially have access to individual data. Furthermore, it may occur that collected data is linked with data from other services of the same provider, if you have a corresponding user account. Where possible, we try to use server locations within the EU, if offered.

We will inform you in the appropriate sections of this privacy policy in more detail about data transfers to third countries, if applicable.

Security of data processing operations

In order to protect personal data, we have implemented both technical and organisational measures. We encrypt or pseudonymise personal data wherever this is possible. Thus, we make it as difficult as we can for third parties to extract personal information from our data.

Article 25 of the GDPR refers to “data protection by technical design and by data protection-friendly default” which means that both software (e.g. forms) and hardware (e.g. access to server rooms) appropriate safeguards and security measures shall always be placed. If applicable, we will outline the specific measures below.

TLS encryption with https

The terms TLS, encryption and https sound very technical, which they are indeed. We use HTTPS (Hypertext Transfer Protocol Secure) to securely transfer data on the Internet.
This means that the entire transmission of all data from your browser to our web server is secured – nobody can “listen in”.

We have thus introduced an additional layer of security and meet privacy requirements through technology design Article 25 Section 1 GDPR). With the use of TLS (Transport Layer Security), which is an encryption protocol for safe data transfer on the internet, we can ensure the protection of confidential information.
You can recognise the use of this safeguarding tool by the little lock-symbol , which is situated in your browser’s top left corner in the left of the internet address (e.g. examplepage.uk), as well as by the display of the letters https (instead of http) as a part of our web address.
If you want to know more about encryption, we recommend you to do a Google search for “Hypertext Transfer Protocol Secure wiki” to find good links to further information.

Communications

Communications Overview
👥 Affected parties: Anyone who communicates with us via phone, email or online form
🤝 Processed data: e. g. telephone number, name, email address or data entered in forms. You can find more details on this under the respective form of contact
📓 Purpose: handling communication with customers, business partners, etc.
📅 Storage duration: for the duration of the business case and the legal requirements
⚖️ Legal basis: Article 6 (1) (a) GDPR (consent), Article 6 (1) (b) GDPR (contract), Article 6 (1) (f) GDPR (legitimate interests)

If you contact us and communicate with us via phone, email or online form, your personal data may be processed.

The data will be processed for handling and processing your request and for the related business transaction. The data is stored for this period of time or for as long as is legally required.

Affected persons

The above-mentioned processes affect all those who seek contact with us via the communication channels we provide.

Telephone

When you call us, the call data is stored in a pseudonymised form on the respective terminal device, as well as by the telecommunications provider that is being used. In addition, data such as your name and telephone number may be sent via email and stored for answering your inquiries. The data will be erased as soon as the business case has ended and the legal requirements allow for its erasure.

Email

If you communicate with us via email, your data is stored on the respective terminal device (computer, laptop, smartphone, …) as well as on the email server. The data will be deleted as soon as the business case has ended and the legal requirements allow for its erasure.

Online forms

If you communicate with us using an online form, your data is stored on our web server and, if necessary, forwarded to our email address. The data will be erased as soon as the business case has ended and the legal requirements allow for its erasure.

Legal bases

Data processing is based on the following legal bases:

  • Art. 6 para. 1 lit. a GDPR (consent): You give us your consent to store your data and to continue to use it for the purposes of the business case;
  • Art. 6 para. 1 lit. b GDPR (contract): For the performance of a contract with you or a processor such as a telephone provider, or if we have to process the data for pre-contractual activities, such as preparing an offer;
  • Art. 6 para. 1 lit. f GDPR (legitimate interests): We want to conduct our customer inquiries and business communication in a professional manner. Thus, certain technical facilities such email programs, Exchange servers and mobile network operators are necessary to efficiently operate our communications.

Cookies

Cookies Overview
👥 Affected parties: visitors to the website
🤝 Purpose: depending on the respective cookie. You can find out more details below or from the software manufacturer that sets the cookie.
📓 Processed data: depends on the cookie used. More details can be found below or from the manufacturer of the software that sets the cookie.
📅 Storage duration: can vary from hours to years, depending on the respective cookie
⚖️ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What are cookies?

Our website uses HTTP-cookies to store user-specific data.
In the following we explain what cookies are and why they are used, so that you can better understand the following privacy policy.

Whenever you surf the Internet, you are using a browser. Common browsers are for example, Chrome, Safari, Firefox, Internet Explorer and Microsoft Edge. Most websites store small text-files in your browser. These files are called cookies.

It is important to note that cookies are very useful little helpers. Almost every website uses cookies. More precisely, these are HTTP cookies, as there are also other cookies for other uses. HTTP cookies are small files that our website stores on your computer. These cookie files are automatically placed into the cookie-folder, which is the “brain” of your browser. A cookie consists of a name and a value. Moreover, to define a cookie, one or multiple attributes must be specified.

Cookies store certain user data about you, such as language or personal page settings. When you re-open our website to visit again, your browser submits these “user-related” information back to our site. Thanks to cookies, our website knows who you are and offers you the settings you are familiar to. In some browsers, each cookie has its own file, while in others, such as Firefox, all cookies are stored in one single file.

The following graphic shows a possible interaction between a web browser such as Chrome and the web server. The web browser requests a website and receives a cookie back from the server. The browser then uses this again as soon as another page is requested.

HTTP cookie interaction between browser and web server

There are both first-party cookies and third-party cookies. First-party cookies are created directly by our site, while third-party cookies are created by partner-websites (e.g. Google Analytics). Each cookie must be evaluated individually, as each cookie stores different data. The expiry time of a cookie also varies from a few minutes to a few years. Cookies are not software programs and do not contain viruses, trojans or other malware. Cookies also cannot access your PC’s information.

This is an example of how cookie-files can look:

Name: _ga
Value: GA1.2.1326744211.152122864558-9
Purpose: Differentiation between website visitors
Expiry date: after 2 years

A browser should support these minimum sizes:

  • At least 4096 bytes per cookie
  • At least 50 cookies per domain
  • At least 3000 cookies in total

Which types of cookies are there?

The exact cookies that we use, depend on the used services, which will be outlined in the following sections of this privacy policy. Firstly, we will briefly focus on the different types of HTTP-cookies.

There are 4 different types of cookies:

Essential cookies
These cookies are necessary to ensure the basic functions of a website. They are needed when a user for example puts a product into their shopping cart, then continues surfing on different websites and comes back later in order to proceed to the checkout. These cookies ensure the shopping cart does not get deleted, even if the user closes their browser window.

Purposive cookies
These cookies collect information about user behaviour and whether the user receives any error messages. Furthermore, these cookies record the website’s loading time as well as its behaviour in different browsers.

Target-orientated cookies
These cookies ensure better user-friendliness. Thus, information such as previously entered locations, fonts sizes or data in forms stay stored.

Advertising cookies
These cookies are also known as targeting cookies. They serve the purpose of delivering customised advertisements to the user. This can be very practical, but also rather annoying.

Upon your first visit to a website you are usually asked which of these cookie-types you want to accept. Furthermore, this decision will of course also be stored in a cookie.

If you want to learn more about cookies and do not mind technical documentation, we recommend https://tools.ietf.org/html/rfc6265, the Request for Comments of the Internet Engineering Task Force (IETF) called “HTTP State Management Mechanism”.

Purpose of processing via cookies

The purpose ultimately depends on the respective cookie. You can find out more details below or from the software manufacturer that sets the cookie.

Which data are processed?

Cookies are little helpers for a wide variety of tasks. Unfortunately, it is not possible to tell which data is generally stored in cookies, but in the privacy policy below we will inform you on what data is processed or stored.

Storage period of cookies

The storage period depends on the respective cookie and is further specified below. Some cookies are erased after less than an hour, while others can remain on a computer for several years.

You can also influence the storage duration yourself. You can manually erase all cookies at any time in your browser (also see “Right of objection” below). Furthermore, the latest instance cookies based on consent will be erased is after you withdraw your consent. The legality of storage will remain unaffected until then.

Right of objection – how can I erase cookies?

You can decide for yourself how and whether you want to use cookies. Regardless of which service or website the cookies originate from, you always have the option of erasing, deactivating or only partially accepting cookies. You can for example block third-party cookies but allow all other cookies.

If you want to find out which cookies have been stored in your browser, or if you want to change or erase cookie settings, you can find this option in your browser settings:

Chrome: Clear, enable and manage cookies in Chrome

Safari: Manage cookies and website data in Safari

Firefox: Clear cookies and site data in Firefox

Internet Explorer: Delete and manage cookies

Microsoft Edge: Delete cookies in Microsoft Edge

If you generally do not want cookies, you can set up your browser in a way to notify you whenever a cookie is about to be set. This gives you the opportunity to manually decide to either permit or deny the placement of every single cookie. This procedure varies depending on the browser. Therefore, it might be best for you to search for the instructions in Google. If you are using Chrome, you could for example put the search term “delete cookies Chrome” or “deactivate cookies Chrome” into Google.

Legal basis

The so-called “cookie directive” has existed since 2009. It states that the storage of cookies requires your consent (Article 6 Paragraph 1 lit. a GDPR). Within countries of the EU, however, the reactions to these guidelines still vary greatly. In Austria, however, this directive was implemented in Section 165 (3) of the Telecommunications Act (2021). In Germany, the cookie guidelines have not been implemented as national law. Instead, this guideline was largely implemented in Section 15 (3) of the Telemedia Act (TMG), which has been replaced by the Digital Services Act (DSA) since May 2024.

For absolutely necessary cookies, even if no consent has been given, there are legitimate interests (Article 6 (1) (f) GDPR), which in most cases are of an economic nature. We want to offer our visitors a pleasant user experience on our website. For this, certain cookies often are absolutely necessary.

This is exclusively done with your consent, unless absolutely necessary cookies are used. The legal basis for this is Article 6 (1) (a) of the GDPR.

In the following sections you will find more detail on the use of cookies, provided the used software does use cookies.

Customer Data

Customer Data Overview
👥Affected parties: Customers or business and contractual partners
🤝 Purpose: Performance of a contract for the provision of agreed services or prior to entering into such a contract, including associated communications.
📓 Data processed: name, address, contact details, email address, telephone number, payment information (such as invoices and bank details), contract data (such as duration and subject matter of the contract), IP address, order data
📅 Storage period: the data will be erased as soon as they are no longer required for our business purposes and there is no legal obligation to process them.
⚖️ Legal bases: Legitimate interests (Art. 6 Para. 1 lit. f GDPR), Contract (Art. 6 Para. 1 lit. b GDPR)

What is customer data?

In order to be able to offer our services and contractual services, we also process data from our customers and business partners. This data always includes personal data. Customer data is all information that is processed on the basis of contractual or pre-contractual agreements so that the offered services can be provided. Customer data is therefore all the information we collect and process about our customers.

Why do we process customer data?

There are many reasons why we collect and process customer data. The main reason is that we simply need specific data to provide our services. Sometimes for example your email address may be enough. But if you purchase a product or service, we may e. g. also need data such as your name, address, bank details or other contract data. This data will subsequently be used for marketing and sales optimisation so that we can improve our overall service for our customers and clients. Another important reason for data processing is our customer service, which is very important to us. We want you to have the opportunity to contact us at any time with questions about our offers. Thus, we may need certain data such as your email address at the very least.

What data is processed?

Exactly which data is stored can only be shown by putting them in categories. All in all, it always depends on which of our services you receive. In some cases, you may only give us your email address so that we can e. g. contact you or answer your questions. In other instances, you may purchase one of our products or services. Then we may need significantly more information, such as your contact details, payment details and contract details.

Here is a list of potential data we may receive and process:

  • Name
  • Contact address
  • Email address
  • Phone number
  • Your birthday
  • Payment data (invoices, bank details, payment history, etc.)
  • Contract data (duration, contents)
  • Usage data (websites visited, access data, etc.)
  • Metadata (IP address, device information)

How long is the data stored?

We erase corresponding customer data as soon as we no longer need it to fulfill our contractual obligations and purposes, and as soon as the data is also no longer necessary for possible warranty and liability obligations. This can for example be the case when a business contract ends. Thereafter, the limitation period is usually 3 years, although longer periods may be possible in individual cases. Of course, we also comply with the statutory retention requirements. Your customer data will certainly not be passed on to third parties unless you have given your explicit consent.

Legal Basis

The legal basis for the processing of your data is Article 6 Paragraph 1 Letter a GDPR (consent), Article 6 Paragraph 1 Letter b GDPR (contract or pre-contractual measures), Article 6 Paragraph 1 Letter f GDPR (legitimate interests) and in special cases (e. g. medical services) Art. 9 (2) lit. GDPR (processing of special categories).

In the case of protecting vital interests, data processing is carried out in accordance with Article 9 Paragraph 2 Letter c. GDPR. For the purposes of health care, occupational medicine, medical diagnostics, care or treatment in the health or social sectors or for the administration of systems and services in health or social sectors, the processing of personal data takes place in accordance with Art. 9 Para. 2 lit. h. GDPR. If you voluntarily provide data of these special categories, the processing takes place on the basis of Article 9 Paragraph 2 lit. a GDPR.

Web hosting

Web hosting Overview
👥 Affected parties: visitors to the website
📓 Purpose: professional hosting of the website and security of operations
🤝 Processed data: IP address, time of website visit, browser used and other data. You can find more details on this below or at the respective web hosting provider.
📅 Storage period: dependent on the respective provider, but usually 2 weeks
⚖️ Legal basis: Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is web hosting?

Every time you visit a website nowadays, certain information – including personal data – is automatically created and stored, including on this website. This data should be processed as sparingly as possible, and only with good reason. By website, we mean the entirety of all websites on your domain, i.e. everything from the homepage to the very last subpage (like this one here). By domain we mean example.uk or examplepage.com.

When you want to view a website on a screen, you use a program called a web browser. You probably know the names of some web browsers: Google Chrome, Microsoft Edge, Mozilla Firefox, and Apple Safari.

The web browser has to connect to another computer which stores the website’s code: the web server. Operating a web server is complicated and time-consuming, which is why this is usually done by professional providers. They offer web hosting and thus ensure the reliable and flawless storage of website data.

Whenever the browser on your computer establishes a connection (desktop, laptop, smartphone) and whenever data is being transferred to and from the web server, personal data may be processed. After all, your computer stores data, and the web server also has to retain the data for a period of time in order to ensure it can operate properly.

Illustration:

Browser and Webserver

Why do we process personal data?

The purposes of data processing are:

  1. Professional hosting of the website and operational security
  2. To maintain the operational as well as IT security
  3. Anonymous evaluation of access patterns to improve our offer, and if necessary, for prosecution or the pursuit of claims.li>

Which data are processed?

Even while you are visiting our website, our web server, that is the computer on which this website is saved, usually automatically saves data such as

  • the full address (URL) of the accessed website (e. g. https://www.examplepage.uk/examplesubpage.html?tid=122864558)
  • browser and browser version (e.g. Chrome 87)
  • the operating system used (e.g. Windows 10)
  • the address (URL) of the previously visited page (referrer URL) (e. g. https://www.examplepage.uk/icamefromhere.html/)
  • the host name and the IP address of the device from the website is being accessed from (e.g. COMPUTERNAME and 194.23.43.121)
  • date and time
  • in so-called web server log files

How long is the data stored?

Generally, the data mentioned above are stored for two weeks and are then automatically deleted. We do not pass these data on to others, but we cannot rule out the possibility that this data may be viewed by the authorities in the event of illegal conduct.

In short: Your visit is logged by our provider (company that runs our website on special computers (servers)), but we do not pass on your data without your consent!

Legal basis

The lawfulness of processing personal data in the context of web hosting is justified in Art. 6 para. 1 lit. f GDPR (safeguarding of legitimate interests), as the use of professional hosting with a provider is necessary to present the company in a safe and user-friendly manner on the internet, as well as to have the ability to track any attacks and claims, if necessary.

Webhosting Other

Contact data for our Webhosting:

Pinguin-Systeme.at KG
z.H. Hr. Wolfgang Leithner
Perfektastraße 61, Obj. 2, Top 2
1230 Wien
ÖSTERREICH / AUSTRIA

Email: office@pinguin-systeme.at

You can learn more about the data processing at this provider in their Privacy Policy.

Website Builders Introduction

Website Builders Privacy Policy Overview
👥 Affected parties: website visitors
🤝 Purpose: service optimisation
📓 Data processed: The data that is being processed includes but is not limited to technical usage information, browser activity, clickstream activity, session heat maps, contact details, IP addresses or geographic locations. You can find more details in the Privacy Policy below as well as in the providers’ Privacy Policies.
📅 Storage duration: depends on the provider
⚖️ Legal bases: Art. 6 (1) lit. f GDPR (legitimate interests), Art. 6 (1) lit. a GDPR (consent)

What are website builders?

We use a modular website builder for our website. This is a special form of Content Management System (CMS). Website builders enable website operators to create websites very easily and without any programming knowledge. In many cases, web hosts also offer website builders. Your personal data may be collected, stored and processed if a website builder is being used. In this Privacy Policy, you will find general information about data that is processed by such modular website builder systems. You can find more information in the respective provider’s Privacy Policy.

Why do we use website builders for our website?

The greatest advantage of modular website builders is their ease of use. We want to offer you a clear, simple and nicely designed website that we can easily operate and maintain by ourselves – without needing any external support. Nowadays website builders offer many helpful functions that we can use even without having any programming knowledge. This enables us to design our website according to our wishes and therefore, to give you an informative and pleasant experience on our website.

Which data are stored by website builders?

First of all, the exact data that is stored depends on the website builder that is being used. Each provider processes and collects different data from website visitors. However, technical usage information such as users’ operating system, browser, screen resolution, language and keyboard settings, hosting provider as well as the date of the website visit are usually collected. Moreover, tracking data (e. g. browser activity, clickstream activities, session heat maps, etc.) may also be processed. The same goes for personal data, since data such as contact information e. g. email address, telephone number (if you have provided it), IP address and geographic location data may also be processed and stored. In the respective provider’s Privacy Policy you can find out exactly which of your data is getting stored.

How long and where are the data stored?

Provided that we have any further information on this, we will inform you below about the duration of the data processing associated with the website builder we use. You can find detailed information on this in the provider’s Privacy Policy. Generally, we only process personal data for as long as is absolutely necessary to provide our services and products. The provider may store your data according to their own specifications, over which we have no influence.

Right to object

You always retain the right to information, rectification and erasure of your personal data. If you have any questions, you can also contact the responsible parties at the respective website builder system at any time. You can find the corresponding contact details either in our Privacy Policy or on the website of the respective provider.

What is more, in your browser you can clear, disable or manage cookies that providers use for their functions. Depending on the browser you use, this can be done in different ways. Please note, that this may lead to not all functions working as usual anymore.

Legal Bases

We have a legitimate interest in using a website builder system to optimise our online service and present it in an efficient and user-friendly way. The corresponding legal basis for this is Article 6 (1) (f) GDPR (legitimate interests). However, we only use the website builder system if you have consented to it.

If the processing of data is not absolutely necessary for the operation of the website, your data will only be processed on the basis of your consent. This particularly applies to tracking activities. The legal basis for this is Article 6 (1) (a) GDPR.

With this Privacy Policy, we have made you more familiar with the most important general information on data processing. If you want to find out more about this, you will find further information – if available – in the following section or in the Privacy Policy of the provider.

Elementor Privacy Policy

We use the website builder system Elementor for our website. The service provider is the Israeli company Elementor Ltd., located at Rehov Tuval 40, 5252247 Ramat Gan, Israel.

Your data may be transferred to Israel. Israel is outside the scope of the General Data Protection Regulation (GDPR). However, the European Commission has decided, based on Article 45(1) of the GDPR, that Israel provides a level of protection comparable to the GDPR standards. You can view the decision here: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32011D0061

To learn more about the data processed through the use of Elementor, please refer to the privacy policy at https://elementor.com/about/privacy/.

Cookie Consent Management Platform Overview
👥 Affected parties: Website visitors
🤝 Purpose: Obtaining and managing consent to certain cookies and thus the use of certain tools
📓 Processed data: data for managing cookie settings such as IP address, time of consent, type of consent and individual consent. You can find more details on this directly with the tool that is being used.
📅 Storage period: depends on the tool used, periods of several years can be assumed
⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is a cookie consent management platform?

We use a Consent Management Platform (CMP) software on our website that makes it easier for us and you to handle the scripts and cookies used correctly and securely. The software automatically creates a cookie pop-up, scans and controls all scripts and cookies, provides you with the cookie consent required under data protection law and helps you and us to keep track of all cookies. Most cookie consent management tools identify and categorize all existing cookies. As a website visitor, you then decide for yourself whether and which scripts and cookies you allow or not. The following graphic shows the relationship between browser, web server and CMP.

Consent Management Platform overview

Why do we use a cookie management tool?

Our goal is to offer you the best possible transparency in the area of ​​data protection. We are also legally obliged to do so. We want to inform you as well as possible about all tools and all cookies that can save and process your data. It is also your right to decide for yourself which cookies you accept and which you do not. In order to grant you this right, we first need to know exactly which cookies actually landed on our website. Thanks to a cookie management tool, which regularly scans the website for all cookies present, we know about all cookies and can provide you with GDPR-compliant information. You can then use the consent system to accept or reject cookies.

Which data are processed?

As part of our cookie management tool, you can manage each individual cookie yourself and have complete control over the storage and processing of your data. The declaration of your consent is stored so that we do not have to ask you every time you visit our website and we can also prove your consent if required by law. This is saved either in an opt-in cookie or on a server. The storage time of your cookie consent varies depending on the provider of the cookie management tool. Usually this data (e.g. pseudonymous user ID, time of consent, detailed information on the cookie categories or tools, browser, device information) is stored for up to two years.

Duration of data processing

We will inform you below about the duration of the data processing if we have further information. In general, we only process personal data for as long as is absolutely necessary for the provision of our services and products. Data stored in cookies are stored for different lengths of time. Some cookies are deleted after you leave the website, others may be stored in your browser for a few years. The exact duration of the data processing depends on the tool used, in most cases you should be prepared for a storage period of several years. In the respective data protection declarations of the individual providers, you will usually receive precise information about the duration of the data processing.

Right of objection

You also have the right and the option to revoke your consent to the use of cookies at any time. This works either via our cookie management tool or via other opt-out functions. For example, you can also prevent data collection by cookies by managing, deactivating or deleting cookies in your browser.

Information on special cookie management tools can be found – if available – in the following sections.

Legal basis

If you agree to cookies, your personal data will be processed and stored via these cookies. If we are allowed to use cookies with your consent (Article 6 paragraph 1 lit. a GDPR), this consent is also the legal basis for the use of cookies and the processing of your data. In order to be able to manage the consent to cookies and to enable you to give your consent, a cookie consent management platform software is used. The use of this software enables us to operate the website in an efficient and legally compliant manner, which is a legitimate interest (Article 6 paragraph 1 lit. f GDPR).

BorlabsCookie Privacy Policy

On our website we use BorlabsCookie, which is one of the tools that store your consent to cookies. The provider of this service is the German company Borlabs – Benjamin A. Bornschein, Rübenkamp 32, 22305 Hamburg, Germany. You can find out more about the data that is processed by the use of BorlabsCookie in their Privacy Policy at https://borlabs.io/privacy/.

Security & Anti-spam

Security & Anti-Spam Privacy Policy Overview
👥 Affected parties: website visitors
🤝 Purpose: for cyber security
📓 Processed data: Data such as your IP address, name or technical data such as browser version
More details can be found below and in the individual privacy policies.
📅 Duration of storage: In most cases, data is stored until it is no longer required in order to provide the service
⚖️ Legal bases: Article 6 paragraph 1 lit. a GDPR (consent), Article 6 paragraph 1 lit. f GDPR (legitimate interests)

What is Security & Anti-spam software?

So-called security & Anti-spam software can protect you and us from various spam or phishing emails and other potential cyber-attacks. Spam includes advertising emails from mass mailings that you did not sign up for yourself. Such emails are also called data garbage and can also cause costs. Other spam such as phishing emails, on the other hand, are messages that aim to gain trust via fake messages or websites in order to obtain personal information. Anti-spam software usually protects against unwanted spam messages or malicious emails that could inject viruses into our system. We also use general firewall and security systems that protect our devices from unwanted network attacks.

Why do we use Security & Anti-spam software?

We put great importance on our website’s security. After all, this is not just about our safety, but also about your safety. Unfortunately, cyber threats are now part of everyday life in the world of IT and the internet. Hackers e. g. often try to steal personal data from IT systems with the help of cyber attacks. And therefore a good defence system is absolutely necessary. A security system monitors all incoming and outgoing connections to our network or computer. In order to achieve even greater security against cyber attacks, we also use other external security services on our devices in addition to standardised security systems. Unauthorised data transmissions are thus better prevented and this is how we protect ourselves from cybercrime.

Which data are processed by Security & Anti-spam software?

The data that is collected and stored of course depends on the respective service. However, we always try to only use programs that collect data very sparingly or only store data that is necessary for the fulfilment of the offered service. In general, the service may store data such as name, address, IP address, email address and technical data such as browser type or browser version. Any performance and log data may also be collected in order to identify possible incoming threats in good time. This data will be processed as part of the provided services and in compliance with applicable laws. This also includes the GDPR for US providers (via the Standard Contractual Clauses). In some cases, security services also work with third parties who may store and/or process data under instructions and in accordance with privacy policies and other security measures. Data is usually stored using cookies.

Duration of data processing

We will inform you below about the duration of data processing, provided we have further information on this. For example, security programs store data until you or we revoke data storage. In general, personal data is only stored for as long as is absolutely necessary for the provision of the services. Unfortunately, in many cases, we do not have precise information from the providers about their data storage periods.

Right to object

You also have the right and the option to revoke your consent to the use of cookies or third-party security software at any time. This can be done either via our cookie management tool or via other opt-out functions. For example, you can also prevent data collection through cookies by managing, deactivating or erasing the cookies in your browser.

Since cookies may also be used with security services, we recommend you read our privacy policy on cookies. To find out exactly which of your data is stored and processed, you should read the privacy policies of the respective tools.

Legal Basis

We use security services mainly on the basis of our legitimate interests (Art. 6 Para. 1 lit. f GDPR) in a good security system and protection against various cyber attacks.

Certain data processing requires your consent – in particular, the use of cookies and security functions. If you have agreed to the processing and storage of your data by integrated security services, your consent is the legal basis for data processing (Article 6 (1) (a) GDPR). Most of the services we use set cookies on your browser to store data. We, therefore, recommend you read our privacy policy on cookies carefully and consult the privacy policy or cookie policy of the relevant service provider.

Information on special tools – if available – can be found in the following sections.

Google reCAPTCHA Privacy Policy

Google reCAPTCHA Privacy Policy Overview
👥 Affected parties: website visitors
🤝 Purpose: Service optimisation and protection against cyber attacks
📓 Processed data: data such as IP address, browser information, operating system, limited location and usage data
You can find more details on this in the Privacy Policy below.
📅 Storage duration: depending on the retained data
⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is reCAPTCHA?

Our primary goal is to provide you an experience on our website that is as secure and protected as possible. To do this, we use Google reCAPTCHA from Google Inc. (1600 Amphitheater Parkway Mountain View, CA 94043, USA). With reCAPTCHA we can determine whether you are a real person from flesh and bones, and not a robot or a spam software. By spam we mean any electronically undesirable information we receive involuntarily. Classic CAPTCHAS usually needed you to solve text or picture puzzles to check. But thanks to Google’s reCAPTCHA you usually do have to do such puzzles. Most of the times it is enough to simply tick a box and confirm you are not a bot. With the new Invisible reCAPTCHA version you don’t even have to tick a box. In this privacy policy you will find out how exactly this works, and what data is used for it.

reCAPTCHA is a free captcha service from Google that protects websites from spam software and misuse by non-human visitors. This service is used the most when you fill out forms on the Internet. A captcha service is a type of automatic Turing-test that is designed to ensure specific actions on the Internet are done by human beings and not bots. During the classic Turing-test (named after computer scientist Alan Turing), a person differentiates between bot and human. With Captchas, a computer or software program does the same. Classic captchas function with small tasks that are easy to solve for humans but provide considerable difficulties to machines. With reCAPTCHA, you no longer must actively solve puzzles. The tool uses modern risk techniques to distinguish people from bots. The only thing you must do there, is to tick the text field “I am not a robot”. However, with Invisible reCAPTCHA even that is no longer necessary. reCAPTCHA, integrates a JavaScript element into the source text, after which the tool then runs in the background and analyses your user behaviour. The software calculates a so-called captcha score from your user actions. Google uses this score to calculate the likelihood of you being a human, before entering the captcha. reCAPTCHA and Captchas in general are used every time bots could manipulate or misuse certain actions (such as registrations, surveys, etc.).

Why do we use reCAPTCHA on our website?

We only want to welcome people from flesh and bones on our side and want bots or spam software of all kinds to stay away. Therefore, we are doing everything we can to stay protected and to offer you the highest possible user friendliness. For this reason, we use Google reCAPTCHA from Google. Thus, we can be pretty sure that we will remain a “bot-free” website. Using reCAPTCHA, data is transmitted to Google to determine whether you genuinely are human. reCAPTCHA thus ensures our website’s and subsequently your security. Without reCAPTCHA it could e.g. happen that a bot would register as many email addresses as possible when registering, in order to subsequently “spam” forums or blogs with unwanted advertising content. With reCAPTCHA we can avoid such bot attacks.

What data is stored by reCAPTCHA?

reCAPTCHA collects personal user data to determine whether the actions on our website are made by people. Thus, IP addresses and other data Google needs for its reCAPTCHA service, may be sent to Google. Within member states of the European Economic Area, IP addresses are almost always compressed before the data makes its way to a server in the USA. Moreover, your IP address will not be combined with any other of Google’s data, unless you are logged into your Google account while using reCAPTCHA. Firstly, the reCAPTCHA algorithm checks whether Google cookies from other Google services (YouTube, Gmail, etc.) have already been placed in your browser. Then reCAPTCHA sets an additional cookie in your browser and takes a snapshot of your browser window.

The following list of collected browser and user data is not exhaustive. Rather, it provides examples of data, which to our knowledge, is processed by Google.

  • Referrer URL (the address of the page the visitor has come from)
  • IP-address (z.B. 256.123.123.1)
  • Information on the operating system (the software that enables the operation of your computers. Popular operating systems are Windows, Mac OS X or Linux)
  • Cookies (small text files that save data in your browser)
  • Mouse and keyboard behaviour (every action you take with your mouse or keyboard is stored)
  • Date and language settings (the language and date you have set on your PC is saved)
  • All Javascript objects (JavaScript is a programming language that allows websites to adapt to the user. JavaScript objects can collect all kinds of data under one name)
  • Screen resolution (shows how many pixels the image display consists of)

Google may use and analyse this data even before you click on the “I am not a robot” checkmark. In the Invisible reCAPTCHA version, there is no need to even tick at all, as the entire recognition process runs in the background. Moreover, Google have not given details on what information and how much data they retain.

The following cookies are used by reCAPTCHA: With the following list we are referring to Google’s reCAPTCHA demo version at https://www.google.com/recaptcha/api2/demo.
For tracking purposes, all these cookies require a unique identifier. Here is a list of cookies that Google reCAPTCHA has set in the demo version:

Name: IDE
Value: WqTUmlnmv_qXyi_DGNPLESKnRNrpgXoy1K-pAZtAkMbHI-122864558-8
Purpose: This cookie is set by DoubleClick (which is owned by Google) to register and report a user’s interactions with advertisements. With it, ad effectiveness can be measured, and appropriate optimisation measures can be taken. IDE is stored in browsers under the domain doubleclick.net.
Expiry date: after one year

Name: 1P_JAR
Value: 2019-5-14-12
Purpose: This cookie collects website usage statistics and measures conversions. A conversion e.g. takes place, when a user becomes a buyer. The cookie is also used to display relevant adverts to users. Furthermore, the cookie can prevent a user from seeing the same ad more than once.
Expiry date: after one month

Name: ANID
Value: U7j1v3dZa1228645580xgZFmiqWppRWKOr
Purpose: We could not find out much about this cookie. In Google’s privacy statement, the cookie is mentioned in connection with “advertising cookies” such as “DSID”, “FLC”, “AID” and “TAID”. ANID is stored under the domain google.com.
Expiry date: after 9 months

Name: CONSENT
Value: YES+AT.de+20150628-20-0
Purpose: This cookie stores the status of a user’s consent to the use of various Google services. CONSENT also serves to prevent fraudulent logins and to protect user data from unauthorised attacks.
Expiry date: after 19 years

Name: NID
Value: 0WmuWqy122864558zILzqV_nmt3sDXwPeM5Q
Purpose: Google uses NID to customise advertisements to your Google searches. With the help of cookies, Google “remembers” your most frequently entered search queries or your previous ad interactions. Thus, you always receive advertisements tailored to you. The cookie contains a unique ID to collect users’ personal settings for advertising purposes.
Expiry date: after 6 months

Name: DV
Value: gEAABBCjJMXcI0dSAAAANbqc122864558-4
Purpose: This cookie is set when you tick the “I am not a robot” checkmark. Google Analytics uses the cookie personalised advertising. DV collects anonymous information and is also used to distinct between users.
Expiry date: after 10 minutes

Note: We do not claim for this list to be extensive, as Google often change the choice of their cookies.

How long and where are the data stored?

Due to the integration of reCAPTCHA, your data will be transferred to the Google server. Google have not disclosed where exactly this data is stored, despite repeated inquiries. But even without confirmation from Google, it can be assumed that data such as mouse interaction, length of stay on a website or language settings are stored on the European or American Google servers. The IP address that your browser transmits to Google does generally not get merged with other Google data from the company’s other services.
However, the data will be merged if you are logged in to your Google account while using the reCAPTCHA plug-in. Google’s diverging privacy policy applies for this.

How can I erase my data or prevent data retention?

If you want to prevent any data about you and your behaviour to be transmitted to Google, you must fully log out of Google and delete all Google cookies before visiting our website or use the reCAPTCHA software. Generally, the data is automatically sent to Google as soon as you visit our website. To delete this data, you must contact Google Support at https://support.google.com/?hl=en-GB&tid=122864558.

If you use our website, you agree that Google LLC and its representatives automatically collect, edit and use data.

Please note that when using this tool, your data can also be stored and processed outside the EU. Most third countries (including the USA) are not considered secure under current European data protection law. Data to insecure third countries must not simply be transferred to, stored and processed there unless there are suitable guarantees (such as EU’s Standard Contractual Clauses) between us and the non-European service provider.

Legal basis

If you have consented to the use of Google reCAPTCHA, your consent is the legal basis for the corresponding data processing. According to Art. 6 Paragraph 1 lit. a GDPR (consent) your consent is the legal basis for the processing of personal data, as can occur when processed by Google reCAPTCHA.

We also have a legitimate interest in using Google reCAPTCHA to optimise our online service and make it more secure. The corresponding legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests). Nevertheless, we only use Google reCAPTCHA if you have given your consent to it.

Google processes data from you, among other things, in the USA. Google is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA. More information can be found at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Additionally, Google uses so-called Standard Contractual Clauses (Article 46(2) and (3) GDPR). Standard Contractual Clauses (SCC) are template clauses provided by the EU Commission and are designed to ensure that your data complies with European data protection standards, even when transferred and stored in third countries (such as the USA). Through the EU-US Data Privacy Framework and the Standard Contractual Clauses, Google commits to maintaining the European data protection level 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: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.

You can find the Google Ads Data Processing Terms, which refer to the Standard Contractual Clauses, at: https://business.safety.google/intl/en/adsprocessorterms/

You can find out a little more about reCAPTCHA on Google’s web developer page at https://developers.google.com/recaptcha/. Google goes into the technical development of the reCAPTCHA in more detail here, but you will look in vain for detailed information about data storage and data protection issues. A good overview of the basic use of data by Google can be found in the in-house data protection declaration at https://policies.google.com/privacy?hl=en-GB.

UpdraftPlus Privacy Policy

We use UpdraftPlus, a security management tool, for our website. The service provider is the British company Updraft WP Software Ltd. 11 Barringer Way, St. Neots, PE19 1LW, Cambridgeshire, United Kingdom.

With the UK leaving the European Union, the GDPR is no longer applicable to data transfer there. However, on the basis of Art. 45 GDPR, the European Commission has decided that the UK offers an appropriate level of protection that can be compared to the GDPR. Data transfer there is therefore permitted. You can view the decision here (download): https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32021D1772

You can find out more about the data processed using UpdraftPlus in the privacy policy at https://updraftplus.com/data-protection-and-privacy-centre/.

Audio & Video

Audio & Video Privacy Policy Overview
👥 Affected parties: website visitors
🤝 Purpose: service optimisation
📓 Processed data: Data such as contact details, user behaviour, device information and IP addresses can be stored.
You can find more details in the Privacy Policy below.
📅 Storage period: data are retained for as long as necessary for the provision of the service
⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What are audio and video elements?

We have integrated audio and video elements to our website. Therefore, you can watch videos or listen to music/podcasts directly via our website. This content is delivered by service providers and is obtained from the respective providers’ servers.

Audio and video elements are integrated functional elements of platforms such as YouTube, Vimeo or Spotify. It is usually free of charge to use these portals, but they can also contain paid content. With the integrated elements, you can listen to or view any of their content on our website.

If you use audio or video elements on our website, your personal data may get transmitted to as well as processed and retained by service providers.

Why do we use audio & video elements on our website?

We of course want to provide you with the best offer on our website. And we are aware that content is no longer just conveyed in text and static images. Instead of just giving you a link to a video, we offer you audio and video formats directly on our website. These are entertaining or informative, but ideally they are both. Our service therefore gets expanded and it gets easier for you to access interesting content. In addition to our texts and images, we thus also offer video and/or audio content.

Which data are retained by audio & video elements?

When you visit a page on our website with e.g. an embedded video, your server connects to the service provider’s server. Thus, your data will also be transferred to the third-party provider, where it will be stored. Certain data is collected and stored regardless of whether you have an account with the third party provider or not. This usually includes your IP address, browser type, operating system and other general information about your device. Most providers also collect information on your web activity. This e.g. includes the session duration, bounce rate, the buttons you clicked or information about the website you are using the service on. This data is mostly stored via cookies or pixel tags (also known as web beacons). Any data that is pseudonymised usually gets stored in your browser via cookies. In the respective provider’s Privacy Policy, you can always find more information on the data that is stored and processed.

Duration of data processing

You can find out exactly how long the data is stored on the third-party provider’s servers either in a lower point of the respective tool’s Privacy Policy or in the provider’s Privacy Policy. Generally, personal data is only processed for as long as is absolutely necessary for the provision of our services or products. This usually also applies to third-party providers. In most cases, you can assume that certain data will be stored on third-party providers’ servers for several years. Data can be retained for different amounts of time, especially when stored in cookies. Some cookies are deleted after you leave a website, while others may be stored in your browser for a few years.

Right to object

You also retain the right and the option to revoke your consent to the use of cookies or third-party providers at any time. This can be done either via our cookie management tool or via other opt-out functions. You can e.g. also prevent data retention via cookies by managing, deactivating or erasing cookies in your browser. The legality of the processing up to the point of revocation remains unaffected.

Since the integrated audio and video functions on our site usually also use cookies, we recommend you to also read our general Privacy Policy on cookies. You can find out more about the handling and storage of your data in the Privacy Policies of the respective third party providers.

Legal basis

If you have consented to the processing and storage of your data by integrated audio and video elements, your consent is considered the legal basis for data processing (Art. 6 Para. 1 lit. a GDPR). Generally, your data is also stored and processed on the basis of our legitimate interest (Art. 6 Para. 1 lit. f GDPR) in maintaining fast and good communication with you or other customers and business partners. We only use the integrated audio and video elements if you have consented to it.

YouTube Privacy Policy

YouTube Privacy Policy Overview
👥 Affected parties: website visitors
🤝 Purpose: optimising our service
📓 Processed data: Data such as contact details, data on user behaviour, information about your device and IP address may be stored.
You can find more details on this in the privacy policy below.
📅 Storage period: data are generally stored for as long as is necessary for the purpose of the service
⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is YouTube?

We have integrated YouTube videos to our website. Therefore, we can show you interesting videos directly on our site. YouTube is a video portal, which has been a subsidiary company of Google LLC since 2006. The video portal is operated by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. When you visit a page on our website that contains an embedded YouTube video, your browser automatically connects to the servers of YouTube or Google. Thereby, certain data are transferred (depending on the settings). Google is responsible for YouTube’s data processing and therefore Google’s data protection applies.

In the following we will explain in more detail which data is processed, why we have integrated YouTube videos and how you can manage or clear your data.

On YouTube, users can watch, rate, comment or upload videos for free. Over the past few years, YouTube has become one of the most important social media channels worldwide. For us to be able to display videos on our website, YouTube provides a code snippet that we have integrated to our website.

Why do we use YouTube videos on our website?

YouTube is the video platform with the most visitors and best content. We strive to offer you the best possible user experience on our website, which of course includes interesting videos. With the help of our embedded videos, we can provide you other helpful content in addition to our texts and images. Additionally, embedded videos make it easier for our website to be found on the Google search engine. Moreover, if we place ads via Google Ads, Google only shows these ads to people who are interested in our offers, thanks to the collected data.

What data is stored by YouTube?

As soon as you visit one of our pages with an integrated YouTube, YouTube places at least one cookie that stores your IP address and our URL. If you are logged into your YouTube account, by using cookies YouTube can usually associate your interactions on our website with your profile. This includes data such as session duration, bounce rate, approximate location, technical information such as browser type, screen resolution or your Internet provider. Additional data can include contact details, potential ratings, shared content via social media or YouTube videos you added to your favourites.

If you are not logged in to a Google or YouTube account, Google stores data with a unique identifier linked to your device, browser or app. Thereby, e.g. your preferred language setting is maintained. However, many interaction data cannot be saved since less cookies are set.

In the following list we show you cookies that were placed in the browser during a test. On the one hand, we show cookies that were set without being logged into a YouTube account. On the other hand, we show you what cookies were placed while being logged in. We do not claim for this list to be exhaustive, as user data always depend on how you interact with YouTube.

Name: YSC
Value: b9-CV6ojI5Y122864558-1
Purpose: This cookie registers a unique ID to store statistics of the video that was viewed.
Expiry date: after end of session

Name: PREF
Value: f1=50000000
Purpose: This cookie also registers your unique ID. Google receives statistics via PREF on how you use YouTube videos on our website.
Expiry date: after 8 months

Name: GPS
Value: 1
Purpose: This cookie registers your unique ID on mobile devices to track GPS locations.
Expiry date: after 30 minutes

Name: VISITOR_INFO1_LIVE
Value: 95Chz8bagyU
Purpose: This cookie tries to estimate the user’s internet bandwith on our sites (that have built-in YouTube videos).
Expiry date: after 8 months

Further cookies that are placed when you are logged into your YouTube account:

Name: APISID
Value: zILlvClZSkqGsSwI/AU1aZI6HY7122864558-
Purpose: This cookie is used to create a profile on your interests. This data is then used for personalised advertisements.
Expiry date: after 2 years

Name: CONSENT
Value: YES+AT.de+20150628-20-0
Purpose: The cookie stores the status of a user’s consent to the use of various Google services. CONSENT also provides safety measures to protect users from unauthorised attacks.
Expiry date: after 19 years

Name: HSID
Value: AcRwpgUik9Dveht0I
Purpose: This cookie is used to create a profile on your interests. This data helps to display customised ads.
Expiry date: after 2 years

Name: LOGIN_INFO
Value: AFmmF2swRQIhALl6aL…
Purpose: This cookie stores information on your login data.
Expiry date: after 2 years

Name: SAPISID
Value: 7oaPxoG-pZsJuuF5/AnUdDUIsJ9iJz2vdM
Purpose: This cookie identifies your browser and device. It is used to create a profile on your interests.
Expiry date: after 2 years

Name: SID
Value: oQfNKjAsI122864558-
Purpose: This cookie stores your Google Account ID and your last login time, in a digitally signed and encrypted form.
Expiry date: after 2 years

Name: SIDCC
Value: AN0-TYuqub2JOcDTyL
Purpose: This cookie stores information on how you use the website and on what advertisements you may have seen before visiting our website.
Expiry date: after 3 months

How long and where is the data stored?

The data YouTube receive and process on you are stored on Google’s servers. Most of these servers are in America. At https://www.google.com/about/datacenters/locations/?hl=en you can see where Google’s data centres are located. Your data is distributed across the servers. Therefore, the data can be retrieved quicker and is better protected against manipulation.

Google stores collected data for different periods of time. You can delete some data anytime, while other data are automatically deleted after a certain time, and still other data are stored by Google for a long time. Some data (such as elements on “My activity”, photos, documents or products) that are saved in your Google account are stored until you delete them. Moreover, you can delete some data associated with your device, browser, or app, even if you are not signed into a Google Account.

How can I erase my data or prevent data retention?

Generally, you can delete data manually in your Google account. Furthermore, in 2019 an automatic deletion of location and activity data was introduced. Depending on what you decide on, it deletes stored information either after 3 or 18 months.

Regardless of whether you have a Google account or not, you can set your browser to delete or deactivate cookies placed by Google. These settings vary depending on the browser you use. The following instructions will show how to manage cookies in your browser:

Chrome: Clear, enable and manage cookies in Chrome

Safari: Manage cookies and website data in Safari

Firefox: Clear cookies and site data in Firefox

Internet Explorer: Delete and manage cookies

Microsoft Edge: Delete cookies in Microsoft Edge

If you generally do not want to allow any cookies, you can set your browser to always notify you when a cookie is about to be set. This will enable you to decide to either allow or permit each individual cookie.

Legal basis

If you have consented processing and storage of your data by integrated YouTube elements, this consent is the legal basis for data processing (Art. 6 para. 1 lit. a GDPR). Generally, your data is also stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f GDPR) to maintain fast and good communication with you or other customers and business partners. Nevertheless, we only use integrated YouTube elements if you have given your consent. YouTube also sets cookies in your browser to store data. We therefore recommend you to read our privacy policy on cookies carefully and to take a look at the privacy policy or the cookie policy of the respective service provider.

Google processes data from you, among other things, in the USA. Google is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA. More information can be found at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Additionally, Google uses so-called Standard Contractual Clauses (Article 46(2) and (3) GDPR). Standard Contractual Clauses (SCC) are template clauses provided by the EU Commission and are designed to ensure that your data complies with European data protection standards, even when transferred and stored in third countries (such as the USA). Through the EU-US Data Privacy Framework and the Standard Contractual Clauses, Google commits to maintaining the European data protection level 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: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.

You can find the Google Ads Data Processing Terms, which refer to the Standard Contractual Clauses, at: https://business.safety.google/intl/en/adsprocessorterms/

Since YouTube is a subsidiary company of Google, Google’s privacy statement applies to both. If you want to learn more about how your data is handled, we recommend the privacy policy at https://policies.google.com/privacy?hl=en.

Web Design Introduction

Web Design Privacy Policy Overview
👥 Affected parties: website visitors
🤝 Purpose: improvement of user experience
📓 Processed data: depends heavily on the services used. Usually, data such as IP address, technical data, language settings, browser version, screen resolution and browser name are processed. You can find more details directly with the respective web design tools.
📅 Storage duration: depends on the tools used
⚖️ Legal bases: Article 6 paragraph 1 lit. a GDPR (consent), Article 6 paragraph 1 lit. f GDPR (legitimate interests)

What is web design?

We use various tools on our website for the purpose of our web design. Contrary to common belief, web design is not just about making our website look nice, but rather also about functionality and performance. But of course, a good-looking website is also a major goal of professional web design. Web design is a part of media design and deals with the visual as well as the structural and functional design of a website. Our aim with our web design is to improve your experience on our site. In web design jargon, this is called User Experience (UX) and usability. User Experience entails all impressions and experiences that website visitors come across on a website. What is more, usability is part of the User Experience, as it determines how user-friendly a website is. This includes the clear structuring of content, subpages or products, along with how quickly and easily the website enables you to find what you are looking for. In order to offer you the best possible experience on our website, we also use so-called third-party web design tools. Therefore, all tools and services that help improve our website’s design are classified under the category “web design”. This may, for example, include fonts, various plugins or other integrated web design functions.

Why do we use web design tools?

The way you absorb information on a website depends very much on its structure, functionality and visual perception. Therefore, good and professional web design has become increasingly important for us. We are constantly working on improving our site as a way of further extending our services for you as a website visitor. Furthermore, a beautiful and functioning website also has economic advantages for us. Needless to say, you will only visit it and take advantage of our offers if you feel completely at ease.

What data is stored by web design tools?

When you visit our website, any web design elements integrated into our pages may process your data. The exact data that is processed depends on the tools used. Below you can see exactly which tools we use for our website. For more information about data processing, we recommend you also read the respective privacy policy of the respective tools. There you can usually find out which data is processed, whether cookies are used and how long the data is stored. Moreover, fonts such as Google Fonts, for example, also automatically transmit information such as your language settings, IP address, browser version, browser screen resolution and browser name to Google’s servers.

Duration of data processing

Data processing times are very individual and depend on the web design elements used. For example, when cookies are used, the retention period can be as little as a minute, but it may also be a few years. Please make yourself familiar with this topic. You may for example read our general section on cookies as well as the Privacy Policies of the tools used. There you can likely find out exactly which cookies are used and what information is stored there. For example, Google Font files are stored for one year, in order to improve the loading speed of a website. In principle, data is only kept for as long as is necessary to provide the service. But legal requirements may require data to be stored for longer.

Right to object

You also retain the right and the option to revoke your consent to the use of cookies or third-party providers at any time. You can do this either via our cookie management tool or via other opt-out functions. You can also prevent cookies from collecting your data by managing, deactivating or deleting the cookies in your browser. However, among web design elements (typically fonts) there is also data that cannot be erased easily. This is the case whenever data is automatically collected as soon as a page is accessed and then directly transmitted to a third party (e.g. Google). In these cases, please contact the support of the respective provider. In the case of Google, you can reach support at https://support.google.com/?hl=de.

Legal Basis

If you have consented to the use of web design tools, this consent serves as the legal basis for the relevant data processing. According to Article 6 (1) (a) GDPR (consent), your consent represents the legal basis for the processing of personal data, as it may occur when it is collected by web design tools. We also have a legitimate interest in web design to improve on our website. After all, only then can we provide you with a beautiful and professional web offer. The corresponding legal basis for this is Article 6 (1) (f) GDPR (legitimate interests). However, we strongly want to emphasise once more that we only use web design tools if you have given your consent.

You can find information on different web design tools – if available – in the following sections.

Google Fonts Local Privacy Policy

On our website we use Google Fonts, by the company Google Inc. The responsible entity for the European area is Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland). We have integrated Google fonts locally, i.e. on our web server and not on Google’s servers. This means that no connection to Google’s servers and therefore no data transfer or retention take place.

What are Google Fonts?

Google Fonts was previously called Google Web Fonts. It is an interactive list with over 800 fonts which Google offer for free use. With the use of Google Fonts, it is possible to utilise fonts without uploading them to your own server. In order to prevent any transfer of information to Google’s servers, we downloaded the fonts to our own server. This way we can comply with data privacy and do not transmit any data to Google Fonts.

Explanation of the terminology used

We always strive to make our privacy policy as clear and comprehensible as possible. However, this is not always easy, especially when it comes to technical and legal matters. It is often sensible to use legal terms (such as ‘personal data)’ or certain technical terms (such as ‘cookies’ or ‘IP address’). But we don’t want to use such terms without any explanation. This is why you will find an alphabetical list of important terms used below. These are terms we may not yet have sufficiently explained in the privacy policy. In case we have adopted any of these terms from the GDPR which are definitions, we will also list the GDPR texts here and add our own further explanations if necessary.

Supervisory authority

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“supervisory authority” means an independent public authority which is established by a Member State pursuant to Article 51;

Explanation: “Supervisory authorities” are always independent government institutions that are also authorised to give instructions in certain cases. They serve to carry out the so-called state supervision and are located in ministries, special departments or other authorities. For data protection in Austria, there is an Austrian Data Protection Authority. For Germany, there is a separate supervisory authority for each federal state.

Processor

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

Explanation: As a company and a website owner, we are responsible for all your data we process (i. e. the ‘controller’). In addition to the controller, there may also be so-called processors. This includes any company or person who processes personal data on our behalf. In addition to service providers such as tax consultants, processors can also be hosting or cloud providers, payment or newsletter providers or large companies such as Google or Microsoft.

Supervisory authority concerned

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“supervisory authority concerned” means a supervisory authority which is concerned by the processing of personal data because:

a)

the controller or processor is established on the territory of the Member State of that supervisory authority;

b)

data subjects residing in the Member State of that supervisory authority are substantially affected or likely to be substantially affected by the processing; or

c)

a complaint has been lodged with that supervisory authority;

Explanation: In Germany, each federal state has its own supervisory authority for data protection. If your company headquarters (head office) is in Germany, your point of contact is the respective supervisory authority of the respective federal state. In Austria there is only one Data Protection Authority for the whole country.

 

Biometric data

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“biometric data” means personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopic data;

Explanation: They are biological markers that are classified by biometric data and thus hold personal data which can be obtained with the help of technical processes. These include DNA, fingerprints, the geometry of different body parts, body size, but also handwriting or the sound of a voice.

Filing system

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“filing system” means any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis;

Explanation: Any organised storage of data on a computer’s disk is referred to as a “filing system”. For example, if we store your name and email address on a server for our newsletter, this data would be located in a so-called “filing system”. One of the most important tasks of a “filing system” is to quickly be able to search and find specific data and, of course, to store the data securely.

Information society service

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“information society service” means a service as defined in point (b) of Article 1(1) of Directive (EU) 2015/1535 of the European Parliament and of the Council (19);

Explanation: Basically, the term “information society” refers to a society based on information and communication technologies. As a website visitor, in particular, you are familiar with all kinds of online services. Most online services are classified as “information society services”. A classic example of this is an online transaction, such as buying goods over the Internet.

Third party

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“third party” means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;

Explanation: The GDPR basically only explains what a “third party” is not. In practice, any “third party” who also has an interest in personal data, but not the persons mentioned above, are authorities or institutions. For example, a parent company can act as a “third party”. In this case, the subsidiary company is the controller and the parent company is the “third party”. However, this does not mean that the parent company may automatically view, collect or store personal data of the subsidiary.

Restriction of processing

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“restriction of processing” means the marking of stored personal data with the aim of limiting their processing in the future;

Explanation: It is part of your rights that you can ask processors at any time to restrict your personal data for further processing operations. For this purpose, certain personal data such as your name, your date of birth or your address are marked in a way to limit further processing. For example, you could restrict processing to prevent your data from being used for personalised advertising.

Consent

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

Explanation: With websites, such consent is usually given via a cookie consent tool. You’ve most certainly come across these. Whenever you visit a website for the first time, you will usually be asked via a banner whether you agree or consent to the data processing. You can usually also make individual settings and thus decide for yourself which level of data processing you want to allow. If you do not give your consent, no personal data may be processed. Consent can of course also be given in writing, i.e. not via a tool.

Recipient

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“recipient” means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

Explanation: Any person or establishment that receives personal data is considered a recipient. We and our processors are therefore also so-called recipients. Only authorities that have an investigation mandate are not considered recipients.

Data concerning health

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“Data concerning health” means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;

Explanation: Health data includes all stored information relating to your own health. It is often data that is also noted in patient files. This includes, for example, which medication you are using, X-rays, your entire medical history or your vaccination statuses.

Cross-border processing

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“Cross-border processing” either

a)

processing of personal data which takes place in the context of the activities of establishments in more than one Member State of a controller or processor in the Union where the controller or processor is established in more than one Member State; or

b)

processing of personal data which takes place in the context of the activities of a single establishment of a controller or processor in the Union but which substantially affects or is likely to substantially affect data subjects in more than one Member State.

Explanation: If a company or other organisation e. g. has branches in Spain and Croatia where personal data is processed in connection with the branches’ activities, this constitutes “cross-border processing” of personal data. Even if the data is only processed in one country (as in this example in Spain) but the effects for the data subject are also recognisable in another country, it is also considered “cross-border processing”.

International Organisation

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“international organisation” means an organisation and its subordinate bodies governed by public international law, or any other body which is set up by, or on the basis of, an agreement between two or more countries.

Explanation: The best-known examples of international organisations are probably the European Union and the United Nations. In the GDPR, there is a distinction between third countries and international organisations in relation to data transfer. Within the EU, data traffic of personal data does not pose a problem as all EU countries are bound by the provisions of the GDPR. On the other hand, data transfer to third countries or international organisations is subject to certain requirements.

Personal Data

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“personenal data” means any information relating to an identified or identifiable natural person (‘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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Explanation: Personal data is all data that can identify you as a person. This is usually data such as:

  • name
  • address
  • email address
  • postal address
  • phone number
  • birthday
  • identification numbers such as social security number, tax identification number, ID card number or matriculation number
  • banking data such as account number, credit information, account balances and more.

According to the European Court of Justice (ECJ), your IP address is also personal data. IT experts can use your IP address to determine at least the approximate location of your device and subsequently your location as the connection owner. Therefore, storing an IP address also requires a legal basis within the scope of the GDPR. There are also so-called “special categories” of personal data, which are particularly worthy of protection. These include:

  • racial and ethnic origin
  • political opinions
  • religious or ideological beliefs
  • Union membership
  • genetic data such as data obtained from blood or saliva samples
  • biometric data (this is information about psychological, physical or behavioural characteristics that can identify an individual).
    health Data
  • Data relating to sexual orientation or sex life

Profiling

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

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

Explanation: Profiling collects various personal data about an individual in order to learn more about that individual. On the internet, profiling is often used for advertising purposes or for credit checks. Web and advertising analysis programs e. g. collect data about your behaviour and interests on a website. This results in a special user profile that can be used to target advertising to specific target groups.

 

Enterprise

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“Enterprise” means a natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships or associations regularly engaged in an economic activity;

Explanation: For example, we are an enterprise and also carry out an economic activity through our website by offering and selling services and/or products. As a formal characteristic, every enterprise has a legal entity such as a GmbH or an AG.

Controller

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

Explanation: In our example, we are responsible for the processing of your personal data and are therefore the “controller”. If we pass on collected data to other service providers for processing, they are considered “contract processors”. For this, a “Data Processing Agreement (DPA)” must be concluded.

 

Processing

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Note: When we talk about processing in our Privacy Policy, we talk about any type of data processing. As mentioned above in the original GDPR declaration, this includes not only the collection but also the storage and processing of data.

Representative

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“representative” means a natural or legal person established in the Union who, designated by the controller or processor in writing pursuant to Article 27, represents the controller or processor with regard to their respective obligations under this Regulation;

Explanation: A “representative” can therefore be any person who has been appointed in writing by us (controller) or one of our service providers (processors). Non-EU companies that process EU citizens’ data must designate a representative within the EU. For example, if a web analytics provider has its headquarters in the United States, it must appoint a “representative” within the European Union to represent its data processing obligations.

Closing Remarks

Congratulations! If you are reading these lines, you have most likely familiarised yourself with our entire Privacy Policy – or at least scrolled down here. As you can see from the scope of our Privacy Policy, we do not take the protection of your personal data lightly.
We find it important to inform you about the processing of your personal data to the best of our abilities. In doing so, we not only want to tell you which data is processed but also explain to you why we use various software programs. In general, Privacy Policies have very technical and legal jargon. However, since most of you are not web developers or solicitors, we wanted to take a different approach and explain the facts in simple and clear language. Of course, this is not always possible due to the subject matter. Therefore, you can also find a more detailed explanation of the most important terms at the end of the Privacy Policy.
If you have any questions about data protection on our website, please do not hesitate to contact us or the responsible body. We wish you all the best and hope to soon welcome you to our website again.

All texts are copyrighted.

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