Data Privacy

Privacy policy

This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the websites, functions and contents connected with it as well as external online presences, such as our Social Media Profile. (hereinafter jointly referred to as “online offer”). With regard to the terms used, e.g. “processing” or “responsible person”, we refer to the definitions in Art. 4 of the Basic Data Protection Regulation (DSGVO).

Person responsible:
Name/Fa.: Stefan Mueller sole proprietorship 
Street No.: Niederwindhagener Str. 56 
Zip code, City, Country: 53578, Windhagen, Germany 
Managing director/owner: Stefan Mueller 
phone number: 004915253963817
e-mail address: mueller@leenway.com

Data protection officer:
Name/Fa.: Stefan Mueller sole proprietorship 
Street No.: Niederwindhagener Str. 56 
Zip code, City, Country: 53578, Windhagen, Germany 
Managing director/owner: Stefan Mueller 
phone number: 004915253963817
e-mail address: mueller@leenway.com

Types of data processed:

  • inventory data (e.g., names, addresses).
  • Contact data (e.g., e-mail, telephone numbers).
  • Content data (e.g., text input, photographs, videos).
  • Contract data (e.g., object of contract, duration, customer category).
  • Payment data (e.g., bank details, payment history).
  • Usage data (e.g., websites visited, interest in content, access times).
  • Meta/communication data (e.g., device information, IP addresses).

Processing of special categories of data (Art. 9 para. 1 DSGVO):

No special categories of data are processed.

Categories of data subjects concerned by the processing:

  • Customers, interested parties, visitors and users of the online offer, business partners.
  • Visitors and users of the online offer.
    In the following, we refer to the data subjects collectively as “users”.

Purpose of the processing:

  • Provision of the online offer, its contents and store functions.
  • Provision of contractual services, service and customer care.
  • Answering contact requests and communication with users.
  • Marketing, advertising and market research.
  • Security measures.

Status: November/ 2020

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

1.2 “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means The term is broad and covers virtually all data handling.

1.3 The term “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.

2.Authoritative legal basis
In accordance with Art. 13 DSGVO we inform you about the legal basis of our data processing. If the legal basis is not stated in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 Para. 1 lit. a and Art. 7 DSGVO, the legal basis for processing for the purpose of fulfilling our services and implementing contractual measures and answering inquiries is Art. 6 Para. 1 lit. b DSGVO, the legal basis for processing for the purpose of fulfilling our legal obligations is Art. 6 Para. 1 lit. c DSGVO, and the legal basis for processing for the purpose of safeguarding our legitimate interests is Art. 6 Para. 1 lit. f DSGVO. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO serves as the legal basis.

  1. amendments and updates to the data protection declaration
    We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes make it necessary for you to take action to cooperate (e.g. to give your consent) or to receive other individual notification.
  1. security measures
    4.1 In accordance with Art. 32 DSGVO and taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the varying probability of occurrence and severity of the risk to the rights and freedoms of natural persons, we shall take appropriate technical and organizational measures to ensure a level of protection commensurate with the risk; these measures shall include in particular the safeguarding of the confidentiality, integrity and availability of data by controlling the physical access to the data as well as the access, input, forwarding, safeguarding of availability and its separation. Furthermore, we have established procedures to ensure that the rights of data subjects are exercised, data is deleted, and we respond to any threats to the data. Furthermore, we take the protection of personal data into account already during the development or selection of hardware, software and procedures, in accordance with the principle of data protection by designing technology and by using data protection-friendly default settings (Art. 25 DSGVO).

4.2 The security measures include in particular the encrypted transmission of data between your browser and our server.

  1. disclosure and transmission of data
    5.1 If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transfer them to them or otherwise grant them access to the data, this will only be done on the basis of a legal authorization (e.g. if a transfer of the data to third parties, such as payment service providers, in accordance with Art. 6 para. 1 lit. b DSGVO is necessary for the performance of the contract), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, hosting providers, tax, business and legal advisors, customer care, accounting, billing and similar services that allow us to efficiently and effectively fulfill our contractual obligations, administrative tasks and duties).

5.2 If we commission third parties to process data on the basis of a so-called “contract processing agreement”, this is done on the basis of Art. 28 DSGVO.

  1. transfers to third countries
    If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using the services of third parties or disclosure or transfer of data to third parties, this will only take place if it is done to fulfil our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we will only process or transfer the data in a third country if the special requirements of Art. 44 ff. DSGVO. This means that the processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to that of the EU (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).
  2. rights of the data subjects
    7.1 You have the right to obtain confirmation as to whether or not data in question is being processed and to receive information about this data and to request further information and a copy of the data in accordance with Art. 15 of the DPA.

7.2 You have accordingly. 7.2. you have the right to request the completion of the data concerning you or the correction of incorrect data concerning you, in accordance with art. 16 of the DPA.

7.3 You have the right to demand that data concerning you be deleted immediately in accordance with Art. 17 DSGVO, or alternatively, in accordance with Art. 18 DSGVO, to demand that the processing of the data be restricted.

7.4 You have the right to obtain the data concerning you that you have provided us with, in accordance with Art. 20 DSGVO, and to request that it be communicated to other persons responsible.

7.5 You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 DSGVO.

  1. right of withdrawal
    You have the right to revoke consents granted in accordance with Art. 7 para. 3 DSGVO with effect for the future.
  2. right of objection
    You may object to the future processing of data concerning you at any time in accordance with Art. 21 DSGVO. The objection may in particular be made against processing for the purposes of direct advertising.
  1. cookies and right of objection for direct advertising
    10.1 “Cookies” are small files that are stored on the user’s computer. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his visit to an online service. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the contents of a shopping cart in an online store or a login status can be stored. Cookies are described as “permanent” or “persistent” if they remain stored even after the browser is closed. For example, the login status can be saved if the user visits it after several days. Likewise, the interests of the users can be stored in such a cookie, which is used for range measurement or marketing purposes. Cookies from providers other than the person responsible for operating the online service are referred to as “third party cookies” (otherwise, if it is only their cookies, it is referred to as “first-party cookies”).

10.2 We use temporary and permanent cookies and clarify this in our privacy policy.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional limitations of this online offer.

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

  1. deletion of data
    11.1 The data processed by us will be deleted or restricted in their processing in accordance with articles 17 and 18 of the DSGVO. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory storage obligations. If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

11.2 Germany: In accordance with legal requirements, data is stored in particular for 6 years in accordance with § 257 Para. 1 HGB (commercial books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting vouchers, etc.) and for 10 years in accordance with § 147 Para. 1 AO (books, records, management reports, accounting vouchers, commercial and business letters, documents relevant for taxation, etc.).

11.3. Austria: According to legal requirements, the storage takes place in particular for 7 J according to § 132 para. 1 BAO (accounting documents, vouchers / invoices, accounts, records, business documents, statement of income and expenditure, etc.), for 22 years in connection with real estate and for 10 years for documents in connection with electronically provided services, telecommunication, radio and television services provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.

  1. order processing in the online store and customer account
    12.1 We process the data of our customers in the context of the order procedures in our online store, in order to enable them to select and order the selected products and services, as well as their payment and delivery, or execution.

12.2 The processed data includes inventory data, communication data, contract data, payment data and to the persons concerned our customers, interested parties and other business partners. The processing is carried out for the purpose of providing contractual services within the operation of an online store, billing, delivery and customer services. We use session cookies to store the contents of the shopping cart and permanent cookies to store the login status.

12.3 Processing shall be based on Art. 6 para. 1 lit. b (execution of order transactions) and c (legally required archiving) DSGVO. In this context, the information marked as required is required for the establishment and performance of the contract. We disclose the data to third parties only within the scope of delivery, payment or within the scope of the legal permissions and obligations to legal advisors and authorities. The data will only be processed in third countries if this is necessary for the fulfillment of the contract (e.g. upon customer request for delivery or payment).

12.4 Users can optionally create a user account, in which they can especially view their orders. During the registration process, the required mandatory data will be provided to the users. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, subject to their retention is necessary for reasons of commercial or tax law in accordance with Art. 6 para. 1 lit. c DSGVO. Data in the customer account shall remain in the customer account until its deletion with subsequent archiving in the event of a legal obligation. It is the responsibility of the users to save their data in case of termination before the end of the contract.

12.5 Within the scope of registration and renewed logins and use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user’s need for protection against misuse and other unauthorized use. This data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Art. 6 Para. 1 lit. c DSGVO.

12.6 Deletion takes place after the expiry of legal warranty and comparable obligations, the necessity of storing the data is reviewed every three years; in the case of legal archiving obligations, deletion takes place after their expiry (end of commercial (6 years) and tax (10 years) storage obligation); information in the customer account remains until its deletion.

  1. business management analyses and market research
    13.1 In order to run our business economically, to recognize market trends, customer and user wishes, we analyze the data available to us on business transactions, contracts, inquiries, etc. We process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. DSGVO, whereby the persons concerned include customers, interested parties, business partners, visitors and users of the online offer. The analyses are carried out for the purpose of business management evaluations, marketing and market research. In doing so, we can take into account the profiles of the registered users with information, e.g. on their purchase transactions. The analyses serve us to increase user-friendliness, to optimize our offer and business efficiency. The analyses serve only us and are not disclosed externally, unless they are anonymous analyses with summarized values.

13.2 If these analyses or profiles are personal, they will be deleted or made anonymous upon termination by the user, otherwise after two years from the conclusion of the contract. In all other respects, the macroeconomic analyses and general trend determinations are prepared anonymously wherever possible.

  1. the examination of a customer’s creditworthiness is permissible if there is otherwise a risk of non-payment, i.e. if the goods are delivered without payment having been received (i.e. if the customer chooses to purchase on account). There is no risk of non-payment, however, if the customer chooses e.g. the prepayment option or makes the payment via third-party providers such as Paypal.

It should also be noted that obtaining an automatic credit report is an “automated decision in individual cases” according to Art. 22 DSGVO, i.e. a legal decision without human involvement. This is permissible if the customer has consented or if this decision is necessary for the conclusion of the contract. Whether the decision is necessary has not yet been conclusively clarified, but is often taken as given, even by the author of this sample. However, if you wish to exclude any risk, you should obtain consent.

Consent is also necessary if the credit report is already being used to decide whether the option “on account” should be shown at all. Because it could have been that the customer would have decided anyway for the Vorkasse or Paypal and the credit investigation would not have been necessary.

Such a consent could be e.g. as follows:

I agree that a credit assessment will be carried out in order to decide in an automated procedure (Art. 22 DSGVO) whether the option of purchase on account is offered. Further information on the credit assessment, the credit agencies used and the procedure as well as the options for objection can be found in our [link]privacy policy[/link].

  1. credit rating information
    14.1 If we make advance payments (e.g. when purchasing on account), we reserve the right to obtain identity and creditworthiness information for the purpose of assessing the credit risk on the basis of mathematical-statistical procedures from specialized service providers (credit agencies) in order to protect our legitimate interests.

14.2 Within the scope of the credit report, we will transmit the following personal data of the customer (name, postal address, date of birth, information on the type of contract, bank details [Please provide further data if necessary]) to the following credit agencies:
Please indicate the credit inquiry agencies here, e.g.:] SCHUFA-Gesellschaft (SCHUFA Holding AG, Kormoranweg 5, 65201 Wiesbaden), data protection information: https://www.schufa.de/de/ueber-uns/daten-scoring/.

14.3 We process the information received from the credit agencies about the statistical probability of a payment default within the scope of a proper discretionary decision about the establishment, execution and termination of the contractual relationship. We reserve the right to refuse payment on account or any other advance payment in case of a negative result of the credit assessment.

14.4 The decision whether to make advance payment is made in accordance with Art. 22 DSGVO solely on the basis of an automated decision in the individual case, which is made by our software on the basis of information from the credit agency.

14.5 If we obtain your express consent, the legal basis for credit information and the transmission of the customer’s data to the credit agencies is the consent pursuant to Art. 6 Para. 1 lit. a, 7 DSGVO. If consent is not obtained, our legitimate interests in the security of your payment claim are the legal basis according to Art. 6 para. 1 lit. f. DSGVO.

  1. contact and customer service
    15.1 When contacting us (via contact form or e-mail), the user’s data will be processed for the purpose of handling the contact request and its processing in accordance with Art. 6 para. 1 lit. b) DSGVO.

15.2 The information provided by the user may be stored in our customer relationship management system (“CRM system”) or comparable inquiry organisation.

15.3 We will delete the inquiries if they are no longer required. We review the necessity every two years; we store requests from customers who have a customer account permanently and refer to the customer account details for deletion. Furthermore, the statutory archiving obligations apply.

  1. collection of access data and log files
    16.1 We raise on the basis of our legitimate interests as defined in Art. 6 para. 1 lit. f. DSGVO data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the accessed website, file, date and time of access, transferred data volume, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited site), IP address and the requesting provider.

16.2 For security reasons (e.g. to clarify misuse or fraudulent actions), log file information is stored for a maximum of seven days and then deleted. Data whose further storage is required for evidence purposes is excluded from deletion until the respective incident has been finally clarified.

  1. online presence in social media
    17.1 We maintain on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO online presences within social networks and platforms in order to be able to communicate with customers, interested parties and users active there and to inform them about our services. When calling up the respective networks and platforms, the terms and conditions and the data processing guidelines of their respective operators apply.

17.2 Unless otherwise stated in our privacy policy, we process the data of users if they communicate with us within social networks and platforms, e.g. write articles on our online presences or send us messages.

If the “Remarketing” or “Google Analytics Audiences” functions are used, the following passage on these functions must be added as a second point:

17.2 We use Google Analytics in order to display the advertisements placed within the advertising services of Google and its partners only to those users who have also shown an interest in our online offer or who exhibit certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) which we transmit to Google (so-called “remarketing” or “Google Analytics Audiences”). With the help of remarketing audiences, we also want to ensure that our ads match the potential interest of the users and do not appear to be annoying.

  1. google analytics
    18.1 Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) Google Analytics, a web analysis service of Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the website by the user is usually transferred to a Google server in the USA and stored there.

18.2 Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

18.3 Google will use this information on our behalf to evaluate the use of our website by users, to compile reports on the activities within this website and to provide us with further services associated with the use of this website and the use of the Internet. The processed data can be used to create pseudonymous user profiles of the users.

18.4 We use Google Analytics only with activated IP anonymization. This means that the IP address of the user is shortened by Google within member states of the European Union or in other states which are party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there.

18.5 The IP address transmitted by the user’s browser will not be merged with other Google data. Users can prevent the storage of cookies by adjusting their browser software accordingly; users can also prevent the collection of data generated by the cookie and related to their use of the online offer to Google and the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

18.6 You can find further information on data use by Google, setting and objection options on the websites of Google: https://www.google.com/intl/de/policies/privacy/partners (“Data use by Google when you use the websites or apps of our partners”), https://policies.google.com/technologies/ads (“Data use for advertising purposes”), https://adssettings.google.com/authenticated (“Manage information that Google uses to show you advertising”).

19 Google Re/Marketing Services
19.1 We use on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Article 6 paragraph 1 lit. f. DSGVO) the marketing and remarketing services (briefly “Google Marketing Services”) of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).

19.2. Google is certified under the Privacy Shield Agreement and thereby offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

19.3 The Google Marketing Services allow us to display ads for and on our website in a more targeted manner in order to show users only ads that potentially match their interests. For example, if a user is shown ads for products that he or she has been interested in on other websites, this is called “remarketing”. For these purposes, when users access our and other websites on which Google marketing services are active, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as “web beacons”) are embedded in the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (instead of cookies, comparable technologies can also be used). The cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file records which websites the user has visited, what content he is interested in and which offers he has clicked on, as well as technical information about the browser and operating system, referring websites, visiting time and other information about the use of the online offer. The IP address of the user is also recorded, whereby we inform within the framework of Google Analytics that the IP address is shortened within member states of the European Union or in other signatory states to the Agreement on the European Economic Area and only in exceptional cases is it transferred in full to a Google server in the USA and shortened there. The IP address is not merged with user data within other Google offers. Google may also combine the above-mentioned information with information from other sources. If the user subsequently visits other websites, the ads tailored to his interests can be displayed.

19.4 User data is processed pseudonymously as part of Google’s marketing services. This means that Google does not store and process the name or e-mail address of the user, for example, but processes the relevant data on a cookie-related basis within pseudonymous user profiles. I.e. from Google’s point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who that cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymization. The information collected by Google marketing services about users is transmitted to Google and stored on Google’s servers in the USA.

19.5 The Google marketing services used by us include the online advertising program “Google AdWords”. In the case of Google AdWords, each AdWords customer receives a different “conversion cookie”. Cookies can therefore not be tracked through the websites of AdWords customers. The information collected through the cookie is used to compile conversion statistics for AdWords customers who have opted in to conversion tracking. AdWords advertisers learn the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not receive information that personally identifies users.

19.6 We may include third-party ads based on Google’s “DoubleClick” marketing service. DoubleClick uses cookies to enable Google and its partner sites to serve ads based on users’ visits to that site or other sites on the Internet.

19.7 We may serve third party ads based on Google’s “AdSense” marketing service. AdSense uses cookies to enable Google and its partner sites to serve ads based on user visits to this site and other sites on the Internet.

19.8 We may also use the “Google Optimizer” service. Google Optimizer allows us to track the effects of various changes to a website (e.g. changes to input fields, design, etc.) within the framework of so-called “A/B testing”. For these test purposes, cookies are stored on the users’ devices. Only pseudonymous user data is processed.

19.9 We may also use the “Google Tag Manager” to integrate and manage the Google analysis and marketing services on our website.

19.10. Further information on the use of data for marketing purposes by Google can be found on the overview page: https://policies.google.com/technologies/ads, the privacy policy of Google is at https://adssettings.google.com/authenticated.

Furthermore, when using the Facebook pixel, we use the additional function “extended matching” (here, data such as telephone numbers, email addresses or Facebook IDs of users) to create target groups (“Custom Audiences” or “Look Alike Audiences”) and send them to Facebook (encrypted). Further notes on “extended matching”: https://www.facebook.com/business/help/611774685654668).

We also use the “Custom Audiences from File” method of the social network Facebook, Inc. In this case, the email addresses of the newsletter recipients are uploaded to Facebook. The upload process is encrypted. The upload is used solely to determine recipients of our Facebook ads. We want to ensure that the ads are only displayed to users who have an interest in our information and services.

Note on opt-out: Please note that Facebook does not offer an opt-out at the time this pattern is created and you will need to implement it yourself. If you do not, you must remove this passage. The implementation can be done e.g. via Javascript (setting the opt-out link) and when loading the page via PHP (which checks whether the opt-out cookie has been set and only loads the Facebook pixel in case of a negative result). If a user visits the website, it must be checked whether the “Opt-Out” cookie is set. If so, the “Facebook pixel” must not be loaded.

Please include the following addition in case of your own opt-out:

To prevent the collection of your data using the Facebook pixel on our website, please click the following link: Facebook-Opt-Out Note: When you click the link, an “Opt-Out” cookie is stored on your device. If you delete the cookies in this browser, you will need to click the link again. Furthermore, the opt-out only applies within the browser you are using and only within our web domain where the link was clicked.

  1. facebook, custom audiences and facebook marketing services
    20.1 Within our online offer, the so-called “Facebook pixel” of the social network Facebook, which is operated by Facebook Inc, 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are located in the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), is used due to our legitimate interests in analysis, optimization and economic operation of our online offer and for these purposes.

20.2 Facebook is certified under the Privacy Shield Agreement and thereby offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

20.3 With the help of the Facebook pixel, Facebook is on the one hand able to determine the visitors to our online offer as a target group for the presentation of advertisements (so-called “Facebook Ads”). Accordingly, we use the Facebook Pixel to display the Facebook Ads placed by us only to those Facebook users who have also shown an interest in our online offering or who exhibit certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Facebook (so-called “custom audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook Ads correspond to the potential interest of users and do not appear to be annoying. The Facebook pixel also enables us to track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users are redirected to our website after clicking on a Facebook ad (so-called “conversion”).

20.4 The processing of data by Facebook is carried out within the framework of Facebook’s Data Usage Policy. Accordingly, general information on the display of Facebook Ads, in the Facebook Data Usage Policy: https://www.facebook.com/policy.php. Specific information and details about the Facebook pixel and its functionality can be found in the Facebook help area: https://www.facebook.com/business/help/651294705016616.

20.5 You may object to the collection by the Facebook pixel and use of your data to display Facebook Ads. To control what types of ads are displayed to you within Facebook, you can go to the page set up by Facebook and follow the instructions on usage-based advertising settings: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, meaning that they are applied to all devices, such as desktop computers or mobile devices.

20.6 You may also opt-out of the use of cookies for audience measurement and advertising purposes by visiting the Network Advertising Initiative opt-out page (http://optout.networkadvertising.org/) and additionally the U.S. website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).

  1. facebook social plugins
    21.1 We use on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Article 6 paragraph 1 lit. f. DSGVO) Social Plugins (“Plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The Plugins can display interaction elements or content (e.g. videos, graphics or text contributions) and can be recognized by one of the Facebook logos (white “f” on blue tile, the words “Like”, “Like” or a “thumbs up” sign) or are marked with the addition “Facebook Social Plugin”. The list and appearance of the Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/.

21.2. Facebook is certified under the Privacy-Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

21.3 If a user calls up a function of this online offer that contains such a plugin, his device establishes a direct connection with the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated into the online offer by the user. User profiles can be created from the processed data. We therefore have no influence on the extent of the data that Facebook collects with the help of this plugin and therefore inform the users according to our state of knowledge.

21.4 By integrating the plugins, Facebook receives the information that a user has called up the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to his or her Facebook account. If users interact with the plugins, for example, by pressing the Like button or making a comment, the corresponding information is transmitted directly from your device to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to find out his or her IP address and store it. According to Facebook, only an anonymized IP address is stored in Germany.

21.5 The purpose and scope of data collection and the further processing and use of data by Facebook, as well as the relevant rights and settings to protect the privacy of users, can be found in the Facebook privacy policy: https://www.facebook.com/about/privacy/.

21.6 If a user is a Facebook member and does not want Facebook to collect data about him or her via this online offer and link it to his or her membership data stored on Facebook, he or she must log out of Facebook and delete his or her cookies before using our online offer. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.


22nd range analysis with Matomo
22.1 Within the scope of Matomo’s coverage analysis, based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer in the sense of Art. 6 para. 1 lit. f. DSGVO) the following data is processed: the type of browser and browser version you use, the operating system you use, your country of origin, date and time of the server request, the number of visits, your length of stay on the website and the external links you activated. The IP address of the user is made anonymous before it is saved.
22.2 Matomo uses cookies, which are stored on the user’s computer and which enable an analysis of the use of our online offer by the users. Pseudonymous user profiles of the users can be created from the processed data. The cookies have a storage period of one week. The information generated by the cookie about your use of this website is only stored on our server and is not passed on to third parties.
22.3 Users can object to the anonymous data collection by the Matomo program at any time with effect for the future by clicking on the link below. In this case a so-called opt-out cookie will be stored in their browser, which means that Matomo will no longer collect any session data. However, if users delete their cookies, the opt-out cookie will also be deleted and must therefore be reactivated by users.
22.4 [Please set Matomo’s IFRAME with the opt-out cookie at this point (and enable IP anonymization in the settings area)].
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jetpack (WordPress Stats)
23.1 On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) the Plugin Jetpack (here the sub-function “WordPress Stats”), which integrates a tool for the statistical evaluation of visitor accesses and by Automattic, Inc. 132 Hawthorne Street San Francisco, CA 94107, USA. Jetpack uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site.
23.2 Automattic is certified under the Privacy Shield Agreement, which provides a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000CbqcAAC&status=Active).
23.3 The information generated by the cookie about your use of this Website is stored on a server in the USA. The processed data can be used to create user profiles, which are only used for analysis and not for advertising purposes. For more information, please refer to Automattic’s privacy policy: https://automattic.com/privacy/ and notes on Jetpack cookies: https://jetpack.com/support/cookies/.
etracker
24.1 We use on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Article 6 paragraph 1 lit. f. DSGVO) the “etracker” analysis service of etracker GmbH, Erste Brunnenstraße 1 20459 Hamburg.
24.2 User profiles can be created from the data processed by etracker under a pseudonym. Cookies may be used for this purpose. The cookies make it possible to recognize your browser. The data collected using etracker technologies will not be used to personally identify visitors to our website without the separately granted consent of the person concerned and will not be merged with personal data about the bearer of the pseudonym. Furthermore, the personal data is only processed for us, i.e. it is not merged with personal data collected within other online offers.
24.3 You can object to the collection and storage of data at any time with effect for the future. In order to object to the future collection and storage of your visitor data, you can obtain an opt-out cookie from etracker by clicking on the following link. This will ensure that no visitor data from your browser will be collected and stored by etracker in the future: http://www.etracker.de/privacy?et=Account-ID [Please enter your account ID here].
24.4 The opt-out sets an opt-out cookie with the name “cntcookie” from etracker. Please do not delete this cookie as long as you wish to maintain your opt-out. Further information can be found in the etracker privacy policy: http://www.etracker.com/de/datenschutz.html.

25th Criteo
25.1 We use on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Article 6 paragraph 1 lit. f. DSGVO) the services of the provider Criteo GmbH, Gewürzmühlstr. 11, 80538 Munich, Germany.

25.2 Criteo’s services allow us to display ads for and on our website in a more targeted manner in order to present users only with ads that potentially match their interests. For example, if a user is shown ads for products that he or she has been interested in on other websites, this is referred to as “remarketing”. For these purposes, when a user visits our website and other websites where Criteo is active, Criteo executes code directly from Criteo and (re)marketing tags (invisible graphics or code, also known as “web beacons”) are embedded in the website. These tags are used to store an individual cookie, i.e. a small file, on the user’s device (similar technologies may be used instead of cookies). This file records which websites the user has visited, what content he is interested in and which offers he has clicked on, as well as technical information on the browser and operating system, referring websites, visiting time and other information on the use of the online offer. Criteo may combine the above information with information from other sources. If the user subsequently visits other websites, advertisements tailored to the user’s interests may be displayed.

25.3 For more information and to opt-out of Criteo’s collection, please refer to Criteo’s Privacy Policy: https://www.criteo.com/de/privacy/.

26th Amazon Affiliate Program
26.1 We are entitled on the basis of our legitimate interests (i.e. interest in the economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO), we are participants in the Amazon EU partner program, which was designed to provide a medium for websites, by means of which advertising costs can be earned by placing advertisements and links to Amazon.de. Amazon uses cookies to be able to trace the origin of orders. Among other things, Amazon may recognize that you have clicked the affiliate link on this site.

26.2 For more information on Amazon’s use of data, please refer to the company’s privacy policy: http://www.amazon.de/gp/help/customer/display.html/ref=footer_privacy?ie=UTF8&nodeId=3312401.

  1. communication via mail, e-mail, fax or telephone
    27.1 For business and marketing purposes, we use remote means of communication, such as mail, telephone or e-mail. We process inventory data, address and contact data as well as contract data of customers, participants, interested parties and communication partners.

27.2 The processing is based on Art. 6 para. 1 lit. a, Art. 7 DSGVO, Art. 6 para. 1 lit. f DSGVO in connection with legal requirements for advertising communications. Contact will only be established with the consent of the contact partners or within the scope of the legal permissions and the processed data will be deleted as soon as they are not required and otherwise with objection/ revocation or omission of the basis for authorization or legal archiving obligations.

Note: Please indicate the contents of the newsletter and the evaluation of the opening and clicking behavior already in the registration, i.e. in the registration form, e.g:

Our newsletter contains information about our products, offers, promotions and our company. Information on data protection, revocation, logging and the measurement of success covered by the consent can be found in our [LINK]Privacy Policy[/Link].

If you use a shipping service provider, you will need to provide additional information on these and can use these examples as a guide (use of a service provider from the EU and one from a third country):

Dispatch service provider: Newsletters are sent by CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede, Germany, hereinafter referred to as “shipping service provider”. You can view the privacy policy of the mail-order service provider here: https://www.cleverreach.com/de/datenschutz/.

Dispatch service provider: Newsletters are sent via “MailChimp”, a newsletter dispatch platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. The privacy policy of the mail service provider can be viewed here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC d/b/a MailChimp is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with the European data protection level (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active).

Note on the legal basis: Please select the variant for Germany or Austria in the information on the legal basis. 
Please note that in Austria, due to a provision of the E-Commerce Act (ECG), the so-called “ECG list” must be taken into account. This list is maintained by the Regulatory Authority for Telecommunications and Broadcasting (RTR-GmbH): https://www.rtr.at/de/tk/TKKS_Spam. It contains those e-mail addresses to which e-mails may not be sent.
28th Newsletter
28.1 With the following notes we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your right to object. By subscribing to our newsletter, you agree to receive it and to the described procedures.

28.2 Content of the newsletter: We send newsletters, e-mails and other electronic notifications containing advertising information (hereinafter “newsletter”) only with the consent of the recipients or with a legal permission. If, in the course of registering for the newsletter, its contents are specifically described, they are decisive for the consent of the users. Furthermore, our newsletters contain information about our products, offers, promotions and our company.

28.3 Double-Opt-In and logging: The registration to our newsletter is done in a so-called Double-Opt-In procedure. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can register with foreign e-mail addresses. The newsletter registrations are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored by the shipping service provider are also logged.

28.4 Dispatch service provider: Newsletters are sent by “MailChimp”, a newsletter dispatch platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. The privacy policy of the mail service provider can be viewed here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC d/b/a MailChimp is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with the European data protection level (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active).

28.5 If we use a mail service provider, the mail service provider may use this data in pseudonymous form, i.e. without allocation to a user, according to its own information to optimize or improve its own services, e.g. for technical optimization of the dispatch and the presentation of the newsletter or for statistical purposes to determine from which countries the recipients come. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or pass them on to third parties.

28.6. registration data: In order to subscribe to the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to enter a name for personal contact in the newsletter.

28.7 Success measurement – The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a mailing service provider, from their server. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and time of retrieval are initially collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined by means of the IP address) or the access times. Statistical surveys also include determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor that of the mailing service provider, if used, to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

28.8. Germany: The dispatch of the newsletter and the measurement of success are based on the consent of the recipients according to Art. 6 Par. 1 lit. a, Art. 7 DSGVO in connection with § 7 Par. 2 No. 3 UWG or on the basis of the legal permission according to § 7 Par. 3 UWG.

28.9. Austria: The dispatch of the newsletter and the measurement of success are based on the consent of the recipients according to Art. 6 Par. 1 lit. a, Art. 7 DSGVO in connection with § 107 Par. 2 TKG or on the basis of the legal permission according to § 107 Par. 2 and 3 TKG.

28.10. The logging of the registration procedure is based on our legitimate interests in accordance with Art. 6 para. 1 lit. f DSGVO and serves as proof of consent to receive the newsletter.

28.11. Newsletter recipients can cancel the receipt of our newsletter at any time, i.e. revoke their consent. A link to cancel the newsletter can be found at the end of each newsletter. At the same time their consent to the performance measurement expires. A separate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled. When you unsubscribe from the newsletter, your personal data will be deleted, unless their storage is legally required or justified, in which case their processing will be limited to these exceptional purposes only. In particular, we may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before we delete them for the purpose of sending the newsletter, in order to be able to prove that we have previously given our consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time.

  1. integration of third party services and content
    29.1 We set within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Article 6 paragraph 1 lit. f. DSGVO), we use content or service offers from third parties in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”). This always presupposes that the third-party providers of such content are aware of the IP address of the users, as without the IP address they would not be able to send the content to their browsers. The IP address is therefore necessary for the display of this content. We make every effort to use only such content whose respective providers use the IP address only to deliver the content. Third party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information on the browser and operating system, referring web pages, visiting time and other details on the use of our online offer, as well as being able to be linked to such information from other sources.

29.2 The following presentation offers an overview of third party providers and their contents, including links to their data protection declarations, which contain further information on the processing of data and, in some cases already mentioned here, the possibility of objection (so-called opt-out)

  • If our customers use the payment services of third parties (e.g. PayPal or Sofortüberweisung), the terms and conditions and the privacy policy of the respective third party provider apply, which can be accessed within the respective websites or transaction applications.
  • External fonts from Google, LLC, https://www.google.com/fonts (“Google Fonts”). The integration of Google Fonts is done by a server call at Google (usually in the USA). Privacy policy: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated.
  • Maps of the “Google Maps” service provided by the third party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
  • Videos from the “YouTube” platform of the third-party provider Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
  • Within our online offer, functions of the service Google+ are integrated. These functions are offered by the third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. If you are logged in to your Google+ account, you can link the contents of our pages to your Google+ profile by clicking the Google+ button. This allows Google to associate your visit to our pages with your user account. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by Google+. Privacy policy: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated.
  • Within our online offer, functions of the Instagram service are integrated. These functions are offered by Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA. If you are logged in to your Instagram account, you can link the content of our pages to your Instagram profile by clicking the Instagram button. This allows Instagram to associate your visit to our sites with your account. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by Instagram. Privacy policy: http://instagram.com/about/legal/privacy/.
  • We use social plugins of the social network Pinterest, which is operated by Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA (“Pinterest”). When you visit a page that contains such a plugin, your browser establishes a direct connection to the Pinterest servers. The plugin transfers protocol data to the Pinterest server in the USA. This log data may include your IP address, the address of websites visited that also contain Pinterest functions, type and settings of the browser, date and time of the request, your use of Pinterest and cookies. Privacy Policy: https://about.pinterest.com/de/privacy-policy.

Within our online offer, functions of the service or platform Twitter can be integrated (hereinafter referred to as “Twitter”). Twitter is an offer of Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The functions include the presentation of our contributions within Twitter within our online offer, the link to our profile on Twitter, the possibility to interact with the contributions and the functions of Twitter, as well as the measurement of whether users reach our online offer via the advertisements placed by us on Twitter (so-called conversion measurement). Twitter is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active). Privacy policy: https://twitter.com/de/privacy, Opt-Out: .

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