Privacy
With the following privacy policy, we would like to explain to you what types of your personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer").
The terms used are not gender-specific.
Name and contact details of the controller article 4, paragraph 7, GDPR
hotelfabrik Group GmbH
with sole shareholder
Sinichbachstr. 60
I-39012 Meran/Sinich (BZ)
E-mail address: office@hotelfabrik.it
Phone: +39 0473 861500
Overview of processing
The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
- Inventory data
- Payment data
- Contact details
- Content data
- Contract data
- Usage data
- Meta, communication and process data
- Protocol data
Categories of affected persons
- Beneficiary and client
- Interested parties
- Communication partner
- Users
- Business and contractual partners
Purposes of the processing
- Provision of contractual services and fulfilment of contractual obligations.
- Communication.
- Safety measures.
- Direct marketing.
- Reach measurement.
- Tracking.
- Office and organisational procedures.
- Conversion measurement.
- Target group formation.
- Organisational and administrative procedures.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online services and user-friendliness.
- Information technology infrastructure.
- Public relations.
- Business processes and business management procedures.
Relevant legal bases
Relevant legal bases according to the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.
- Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given their consent to the processing of their personal data for one or more specific purposes.
- Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) - processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
Security measures
We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data threats. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and processes in accordance with the principle of data protection, through technology design and data protection-friendly default settings.
Transmission of personal data
As part of our processing of personal data, it may be transmitted to other bodies, companies, legally independent organisational units or persons or disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.
Data transfer within the organisation: We may transfer personal data to other departments or units within our organisation or grant them access to it. If the data transfer is for administrative purposes, it is based on our legitimate business and commercial interests or takes place if it is necessary to fulfil our contractual obligations or if the consent of the data subjects or a legal permission exists.
International data transfers
Data processing in third countries: If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this only takes place in accordance with the legal requirements. If the level of data protection in the third country has been recognised by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data will only be transferred if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 para. 2 lit. c) GDPR), express consent or in the case of contractual or legally required transfer (Art. 49 para. 1 GDPR). In addition, we will inform you of the basis for third country transfers with the individual providers from the third country, whereby the adequacy decisions take precedence. Information on third country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de. As part of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognised the level of data protection for certain companies from the USA as secure as part of the adequacy decision of 10 July 2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at www.dataprivacyframework.gov. As part of the data protection information, we will inform you which service providers we use are certified under the Data Privacy Framework.
Business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners"), in the context of contractual and comparable legal relationships and associated measures and with regard to communication with the contractual partners (or pre-contractual), for example to respond to enquiries.
We use this data to fulfil our contractual obligations. These include, in particular, the obligations to provide the agreed services, any updating obligations and remedies in the event of warranty and other service disruptions. In addition, we use the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations and the company organisation. We also process the data on the basis of our legitimate interests both in the proper and efficient management of our business and in security measures to protect our contractual partners and our business operations from misuse, jeopardising their data, secrets, information and rights (e.g. to involve telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. Contractual partners will be informed about other forms of processing, such as for marketing purposes, as part of this privacy policy.
We inform the contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.
We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after four years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal archiving reasons (e.g. for tax purposes, generally ten years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications and generally after the end of the order.
- Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers). Contract data (e.g. subject matter of the contract, term, customer category).
- Persons affected: Service recipients and clients; interested parties. Business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; communication; office and organisational procedures; organisational and administrative procedures. Business processes and business management procedures.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR); Legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Project and development services: We process the data of our customers and clients (hereinafter uniformly referred to as "customers") in order to enable them to select, purchase or commission the selected services or works and related activities as well as their payment and provision or execution or performance.
The required information is labelled as such in the context of the conclusion of the contract, order or comparable contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations. Insofar as we receive access to information from end customers, employees or other persons, we process this in accordance with the legal and contractual requirements; legal basis: contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). - Offer of software and platform services: We process the data of our users, registered users and any test users (hereinafter uniformly referred to as "users") in order to be able to provide them with our contractual services and on the basis of legitimate interests in order to ensure the security of our offer and to be able to develop it further. The required information is labelled as such in the context of the conclusion of an order, order or comparable contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations; legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Business processes and procedures
Personal data of service recipients and clients - including customers, clients or, in special cases, clients, patients or business partners as well as other third parties - are processed within the scope of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relationships. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting and project management.
The data collected is used to fulfil contractual obligations and efficiently design operational processes. This includes the processing of business transactions, the management of customer relationships, the optimisation of sales strategies and the guarantee of internal accounting and financial processes. In addition, the data supports the protection of the rights of the controller and promotes administrative tasks and the organisation of the company.
Personal data may be passed on to third parties if this is necessary to fulfil the stated purposes or legal obligations - This text area must be activated with a premium licence.
- Processed data types: inventory data (e.g. full name, home address, contact information, customer number, - This text area must be activated with a Premium licence. - premiumtext premiumtext premiumtext premiumtext ); payment data (e.g. bank details, invoices, payment history - This text area must be activated with a premium licence. - premiumtext premiumtext premiumtext ); contact data (e.g. postal and e-mail addresses or - This text area must be activated with a Premium licence. - premiumtext premiumtext premiumtext premiumtext ); content data (e.g. textual or pictorial messages and contributions as well as the information relating to them, such as information on authorship - This text area must be activated with a Premium licence. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext ); Contract data (e.g. subject matter of the contract, term, customer category - This text area must be activated with a premium licence. - premiumtext premiumtext premiumtext ); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with - This text area must be activated with a premium licence. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext ). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, involved - This text area must be activated with a Premium licence. - premiumtext premiumtext premiumtext premiumtext ).
- Persons affected: Service recipients and clients; interested parties; communication partners. Business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; office and organisational procedures. Business processes and business management procedures.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Economic analyses and market research: The available data on business transactions, contracts, enquiries, etc. are analysed in order to fulfil business purposes and to identify market trends, the wishes of contractual partners and users. The group of data subjects may include contractual partners, interested parties, customers, visitors and users of the controller's online offering. The analyses are carried out for the purposes of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). Where available, profiles of registered users and their details of services used are taken into account. The analyses are used exclusively by the controller and are not disclosed externally, unless they are anonymous analyses with summarised, i.e. anonymised values. In addition, the privacy of the users is taken into account; the data is pseudonymised as far as possible for analysis purposes and, if feasible, processed anonymously (e.g. as summarised data); legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Provision of the online offer and web hosting
We process users' data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or end device.
- Processed data types: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved). Log data (e.g. log files relating to logins or the retrieval of data or access times).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files". The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks), and to ensure the utilisation of the servers and their stability; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further storage is required for evidentiary purposes is excluded from erasure until the respective incident has been finally clarified.
Use of cookies
The term "cookies" refers to functions that store information on users' end devices and read it from them. Cookies can also be used for various purposes, for example to ensure the functionality, security and convenience of online offers and to create analyses of visitor flows. We use cookies in accordance with the statutory provisions. If necessary, we obtain the user's consent in advance. If consent is not required, we rely on our legitimate interests. This applies if the storage and reading of information is essential in order to be able to provide expressly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about the scope and which cookies are used.
Information on legal bases under data protection law: Whether we process personal data using cookies depends on consent. If consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.
Storage period: With regard to the storage period, a distinction is made between the following types of cookies:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their end device (e.g. browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the log-in status can be saved and favourite content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. If we do not provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), they should assume that they are permanent and that the storage duration can be up to two years.
General information on revocation and objection (opt-out): Users can revoke the consents they have given at any time and also declare an objection to the processing in accordance with the legal requirements, also by means of the privacy settings of their browser.
- Processed data types: Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Data subjects: Users (e.g. website visitors, users of online services).
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing operations, procedures and services:
- Processing of cookie data on the basis of consent: We use a consent management solution in which user consent is obtained for the use of cookies or for the procedures and providers mentioned in the consent management solution. This procedure is used to obtain, log, manage and revoke consent, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on users' end devices. As part of this procedure, user consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure. Users also have the option of managing and revoking their consent. The declarations of consent are stored in order to avoid repeated requests and to be able to provide proof of consent in accordance with legal requirements. The storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information on the providers of consent management services is available, the following general information applies: Consent is stored for up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g. relevant categories of cookies and/or service providers) and information on the browser, the system and the end device used; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Contact and enquiry management
When contacting us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the data of the enquiring persons are processed insofar as this is necessary to answer the contact enquiries and any requested measures.
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Affected persons: Communication partner.
- Purposes of processing: Communication; organisational and administrative procedures; feedback (e.g. collecting feedback via online form). Provision of our online services and user-friendliness.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing operations, procedures and services:
- Contact form: When contacting us via our contact form, by e-mail or other communication channels, we process the personal data transmitted to us to answer and process the respective request. This generally includes details such as name, contact information and any other information that is provided to us and is required for appropriate processing. We use this data exclusively for the stated purpose of establishing contact and communication; legal basis: fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Newsletter and electronic notifications
We send newsletters, emails and other electronic notifications (hereinafter "newsletter") exclusively with the consent of the recipient or on the basis of a legal basis. If the contents of the newsletter are mentioned in the context of a registration for the newsletter, these contents are decisive for the consent of the user. To subscribe to our newsletter, it is normally sufficient to provide your email address. However, in order to be able to offer you a personalised service, we may ask you to provide your name so that we can address you personally in the newsletter or to provide further information if this is necessary for the purpose of the newsletter.
Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a potential defence against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list solely for this purpose.
The registration process is logged on the basis of our legitimate interests for the purpose of verifying that it is carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system.
Contents:
Information about us, our services, promotions and offers.
- Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
- Affected persons: Communication partner.
- Purposes of processing: Direct marketing (e.g. by email or post).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Option to object (opt-out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options given above, preferably e-mail.
Further information on processing operations, procedures and services:
- Measurement of opening and click rates: The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from our server or its server, if we use a dispatch service provider, when the newsletter is opened. As part of this retrieval, technical information, such as details of the browser and your system, as well as your IP address and the time of retrieval are initially collected. This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked on. The information is assigned to the individual newsletter recipients and stored in their profiles until it is deleted. The analyses are used to recognise 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. The measurement of opening and click rates and the storage of the measurement results in the user profiles - This text area must be activated with a premium licence. Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Mailchimp: Email marketing, automation of marketing processes, collection. Storage and management of contact data, measurement of campaign performance, recording and analysis of recipients' interaction with content, personalisation of content; Service provider: Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://mailchimp.com; Privacy Policy: https://mailchimp.com/legal/; Data processing agreement: https://mailchimp.com/legal/; Basis for third country transfers: Data Privacy Framework (DPF). Further information: Special security measures: https://mailchimp.com/de/help/mailchimp-european-data-transfers/.
Web analysis, monitoring and optimisation
Web analysis (also referred to as "reach measurement") is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognise at what time our online offering or its functions or content are most frequently used or invite visitors to reuse them. It also enables us to understand which areas require optimisation.
In addition to web analysis, we may also use test procedures, for example to test and optimise different versions of our online offering or its components.
Unless otherwise stated below, profiles, i.e. data summarised for a usage process, can be created for these purposes and information can be stored in a browser or end device and then read out. The information collected includes, in particular, websites visited and the elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data from us or from the providers of the services we use, it is also possible to process location data.
In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored in the context of web analysis, A/B testing and optimisation, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective process.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
- Processed data types: Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online services and user-friendliness.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).
- Security measures: IP masking (pseudonymisation of the IP address).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Google Analytics: We use Google Analytics to measure and analyse the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or e-mail addresses. It is used to assign analysis information to an end device in order to recognise which content users have called up within one or more usage processes, which search terms they have used, which they have called up again or which they have interacted with our online offering. The time of use and its duration are also stored, as well as the sources of the users who refer to our online offering and technical aspects of their end devices and browsers.
Pseudonymised user profiles are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: City (and the city's inferred latitude and longitude), Continent, Country, Region, Subcontinent (and ID-based counterparts). For EU traffic, the IP address data is used exclusively for this derivation of geolocalisation data before it is immediately deleted. It is not logged, is not accessible and is not used for other purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymisation of the IP address); Privacy Policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms/; Basis for third country transfers: Data Privacy Framework (DPF); Opt-out: Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de; Settings for the display of adverts: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (Types of processing and processed data).
Online marketing
We process personal data for the purpose of online marketing, which may include in particular the marketing of advertising space or the presentation of advertising and other content (collectively referred to as "content") based on the potential interests of users and the measurement of its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (the so-called "cookie") or similar procedures are used, by means of which the information about the user relevant for the presentation of the aforementioned content is stored. This may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information, such as the browser used, the computer system used and information on usage times and functions used. If users have consented to the collection of their location data, this can also be processed.
The IP addresses of users are also stored. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) for user protection. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that neither we nor the providers of the online marketing processes know the actual identity of the users, but only the information stored in their profiles.
The statements in the profiles are generally stored in the cookies or by means of similar procedures. These cookies can generally also be read later on other websites that use the same online marketing process and analysed for the purpose of displaying content and supplemented with further data and stored on the server of the online marketing process provider.
In exceptional cases, it is possible to assign clear data to the profiles, primarily if the users are, for example, members of a social network whose online marketing processes we use and the network links the user profiles with the aforementioned data. Please note that users can make additional agreements with the providers, for example by giving their consent during registration.
In principle, we only receive access to summarised information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyse the success of our marketing measures.
Unless otherwise stated, we ask you to assume that the cookies used are stored for a period of two years.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
Information on cancellation and objection:
We refer to the data protection notices of the respective providers and the opt-out options provided by the providers. If no explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. However, this may restrict the functions of our online offering. We therefore recommend the following additional opt-out options, which are summarised for the respective areas:
Europe: https://www.youronlinechoices.eu.
- Processed data types: Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of Processing: Web Analytics (e.g. access statistics, recognition of returning visitors); Targeting (e.g. profiling based on interests and behaviour, use of cookies); Custom Audiences; Marketing; Profiles with user-related information (Creating user profiles). Conversion measurement (measurement of the effectiveness of marketing measures).
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).
- Security measures: IP masking (pseudonymisation of the IP address).
- Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Google Ads and conversion measurement: online marketing process for the purpose of placing content and adverts within the service provider's advertising network (e.g. in search results, in videos, on websites, etc.) so that they are displayed to users who are presumed to be interested in the adverts. In addition, we measure the conversion of the adverts, i.e. whether users have taken them as an opportunity to interact with the adverts and use the advertised offers (so-called conversions). However, we only receive anonymous information and no personal information about individual users; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: marketingplatform.google.com; Privacy Policy: policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/. Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
Presence in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce user rights.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behaviour and the resulting interests of users. The latter may in turn be used, for example, to place adverts within and outside the networks that presumably correspond to the interests of the users. Cookies are therefore generally stored on users' computers, in which the user behaviour and interests of the users are stored. In addition, data can also be stored in the user profiles independently of the devices used by the users (especially if they are members of the respective platforms and are logged in there).
For a detailed description of the respective forms of processing and the opt-out options, please refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the latter have access to the user data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
- Processed data types: Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Communication; feedback (e.g. collecting feedback via online form). Public relations.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Instagram: Social network that allows you to share photos and videos, comment on and favourite posts, send messages, subscribe to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for third country transfers: Data Privacy Framework (DPF).
- Facebook pages: Profiles within the Facebook social network - We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (known as a "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see under "Things you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/privacy/policy/), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under "Device information" in the Facebook Data Policy: https://www.facebook.com/privacy/policy/). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services, so-called "Page Insights", for page operators to gain insights into how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook ("Information on Page Insights", www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information on Page Insights" (www.facebook.com/legal/terms/information_about_page_insights_data). The joint responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of data to the parent company Meta Platforms, Inc. in the USA; service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for third country transfers: Data Privacy Framework (DPF).
- LinkedIn: Social network - We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitors' data used to create the "page insights" (statistics) of our LinkedIn profiles. This data includes information about the types of content users view or interact with and the actions they take. Details are also collected about the devices used, such as IP addresses, operating system, browser type, language settings and cookie data, as well as information from the user profiles, such as job function, country, industry, hierarchy level, company size and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy.
We have concluded a special agreement with LinkedIn Ireland ("Page Insights Joint Controller Addendum", legal.linkedin.com/pages-joint-controller-addendum), which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfil the rights of the data subjects (i.e. users can, for example, send requests for information or deletion directly to LinkedIn). The rights of users (in particular the right to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection and transfer of data to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transfer of data to the parent company LinkedIn Corporation in the USA; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Basis for third country transfers: Data Privacy Framework (DPF). Option to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.