PRIVACY POLICY
We are very pleased that you are interested in our company. Data protection is very important to the management of Oilquick Deutschland KG. It is generally possible to use the website of Oilquick Deutschland KG without supplying any personal data. However, if a data subject wishes to make use of special services provided by our company via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally seek the consent of the data subject.
The processing of personal data such as name, address, e-mail address or the telephone number of a data subject is always carried out in line with the country-specific data protection regulations applicable to the Oilquick Deutschland KG. By means of this Privacy Policy, our company would like to inform the public about the nature, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed of their rights by this Privacy Policy.
Oilquick Deutschland KG has, as the controller, implemented numerous technical and organisational measures to ensure the most complete protection of the personal data processed via this website. Nevertheless, since internet-based data transmissions can always be subject to security vulnerabilities, absolute protection cannot be guaranteed. For this reason, every data subject is at liberty to submit personal data to us by alternative means, for example by telephone
1. DEFINITIONS
The Privacy Policy of Oilquick Deutschland KG is based on the terms used by the European legislator when issuing the General Data Protection Regulation (GDPR). Our Privacy Policy is intended to be easy to read and understand for the public as well as our customers and business partners. To make sure of this, we would first like to explain the terminology used.
In this Privacy Policy, we use the following terms, among others:
(a) Personal data
Personal data means any information relating to an identified or identifiable natural person (in the following “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) Data subject
A data subject is any identified or identifiable natural person whose personal data are processed by the controller responsible for the processing.
c) Processing
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) Restriction of processing
Restriction of processing means the marking of stored personal data with the aim of limiting their processing in the future.
e) Profiling
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
f) Pseudonymisation
Pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
g) Controller or party responsible for the processing
Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
h) Processor
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
i) Recipient
Recipient means a natural or legal person, public authority, agency or another body to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.
j) Third party
Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
k) Consent
Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. Name und Anschrift des für die Verarbeitung Verantwortlichen
Verantwortlicher im Sinne der Datenschutz-Grundverordnung, sonstiger in den Mitgliedstaaten der Europäischen Union geltenden Datenschutzgesetze und anderer Bestimmungen mit datenschutzrechtlichem Charakter ist die:
Oilquick Deutschland KG
Bürgermeister-Schauer-Str. 1
82297 Steindorf
Deutschland
Tel.: +49 (0)8202 9618-0
E-Mail: info@oilquick.de
Website: www.oilquick.de
Name und Anschrift der Datenschutzbeauftragten
Dr. Claudia Noortwijck
Jahnstraße 102
D-88214 Ravensburg
Telefon: +49 (751) 36 05 – 300
E-Mail: noortwijck@merkel-gruppe.de
3. COOKIES
The internet pages of Oilquick Deutschland KG use cookies. Cookies are text files which are stored on a computer system via an internet browser.
Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string of characters by means of which internet pages and servers can be matched with the specific internet browser in which the cookie was stored. This enables the websites and servers visited to distinguish the individual browser of the data subject from other internet browsers which contain other cookies. A specific internet browser can be recognised and identified by means of the unique cookie ID.
By employing cookies, the Oilquick Deutschland KG can provide the users of this website with more user-friendly services, which would not be possible without the cookie setting.
By means of a cookie, the information and offers on our website can be optimised to suit the user. Cookies enable us, as already mentioned, to recognise the users of our website. The purpose of such recognition is to make it easier for users to use our website. For example, the user of a website utilising cookies does not have to enter his or her access data again every time he or she visits the website, because this task is taken over by the website and the cookie stored in the user’s computer system. Another example is the cookie of a shopping cart in the online shop. The online shop remembers the items that a customer has placed in the virtual shopping cart by means of a cookie.
The data subject can prevent our website from setting cookies at any time by selecting the relevant setting on the internet browser used, thereby permanently objecting to the setting of cookies. Furthermore, cookies already set can be deleted at any time via an internet browser or other software programmes. This is possible in all common internet browsers. If the data subject deactivates the setting of cookies in the internet browser used, not all the functions of our website may be fully usable.
4. COLLECTION OF GENERAL DATA AND INFORMATION
The website of Oilquick Deutschland KG collects a series of general data and information whenever a data subject or automated system calls up the website. This general data and information is stored in the server’s log files. The following data may be collected: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrer), (4) the sub-websites which are accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system and (8) other similar data and information that serve to avert danger in the event of attacks on our information technology systems.
Oilquick Deutschland KG does not, when utilising such general data and information, draw any conclusions about the data subject. Rather, this information is required in order to (1) correctly deliver the content of our website, (2) optimise the content of our website and the advertising for it, (3) ensure the long-term functionality of our information technology systems and the technology of our website, and (4) supply law enforcement authorities with the information necessary for prosecution in the event of a cyber attack. Oilquick Deutschland KG therefore evaluates these anonymously collected data and information firstly for statistical purposes and secondly for the purpose of increasing the data protection and data security of our company, with the ultimate aim of ensuring an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from any personal data supplied by a data subject.
5. REGISTRATION ON OUR WEBSITE
The data subject has the possibility to register on the controller’s website by supplying personal data. The personal data which are thereby transmitted to the controller are specified in the respective input mask used for registration. The personal data entered by the data subject are collected for his or her own purposes and stored for the controller’s internal use only. The controller may have the data forwarded to one or more processors, for example a parcel service provider, who will also use the personal data exclusively for an internal use which is imputable to the controller.
When the data subject registers on the controller’s website, the IP address assigned by the data subject’s internet service provider (ISP), the date and the time of registration are also stored. These data are stored for the purpose of preventing misuse of our services and, if necessary, to enable us to investigate criminal offences committed. Thus, the storage of these data is necessary for the protection of the data controller. These data are generally not passed on to third parties unless there is a legal obligation to do so or the passing on of data serves the purpose of criminal prosecution.
When the data subject registers by voluntarily providing personal data, this enables the controller to offer the data subject content or services which can, by their very nature, only be offered to registered users. Registered persons are free to alter the personal data they supplied upon registration at any time or to have them completely deleted from the controller’s database.
Upon request, the controller will inform any data subject any time which personal data concerning the data subject are stored. Furthermore, the controller will correct or delete personal data upon the request or notification of the data subject, insofar as this does not conflict with any statutory retention obligations. The entire staff of the controller are available as contact persons for the data subject in this context.
6. SUBSCRIPTION TO OUR NEWSLETTER
On the website of Oilquick Deutschland KG, users are given the opportunity to subscribe to our company newsletter. The personal data which are transmitted to the controller when the data subject subscribes to the newsletter are specified in the respective input mask provided for this purpose.
Oilquick Deutschland KG regularly informs its customers and business partners about offers of the company in a newsletter. A data subject can only receive our company newsletter if (1) the data subject has a valid e-mail address and (2) the data subject subscribes to our newsletter. A data subject who has entered his or her e-mail address for the newsletter for the first time will be sent a confirmation e-mail with a double opt-in procedure for legal reasons. This confirmation e-mail serves to check whether the owner of the e-mail address, the data subject, has authorised receipt of the newsletter.
Furthermore, during registration for the newsletter we store the IP address, assigned by the internet service provider (ISP), of the computer system used by the data subject when registering, and the date and time of registration. The collection of these data is necessary in order to be able to reconstruct the (possible) misuse of a data subject’s e-mail address at a later point in time, and therefore serves as a legal safeguard for the controller.
The personal data collected during registration for the newsletter are used solely for the purpose of dispatching our newsletter. Furthermore, subscribers to the newsletter can be informed by e-mail to the extent that this is necessary for the functioning of the newsletter service or for registering for it, as may happen in the event of changes to the newsletter service or changes in technical conditions. No personal data collected for the newsletter service are passed on to third parties. The subscription to our newsletter can be cancelled by the data subject at any time. Consent to the storage of personal data given to us by the data subject for the dispatch of newsletters can be revoked at any time. A link is included in every newsletter for the revocation of consent. Furthermore, it is also possible to unsubscribe from the newsletter at any time directly on the controller’s website or to inform the controller of this in another way.
7. NEWSLETTER TRACKING
The Oilquick Deutschland KG newsletters contain so-called tracking pixels. A tracking pixel is a thumbnail graphic which is embedded in e-mails sent in HTML format to enable log file recording and log file analysis. This enables a statistical evaluation of the success or failure of online marketing campaigns to be carried out. With the aid of the embedded tracking pixel, Oilquick Deutschland KG can determine whether and when an e-mail was opened by a data subject, and which links contained in the e-mail were called up by the data subject.
The controller stores and evaluates such personal data which are collected via the tracking pixels contained in the newsletters in order to optimise the newsletter dispatch and to better align the content of future newsletters with the interests of the data subject. These personal data are not passed on to third parties. Data subjects are entitled to revoke the separate declaration of consent to this which was submitted via the double opt-in procedure at any time. Following revocation, these personal data are deleted by the controller. Oilquick Deutschland KG automatically regards a cancellation of receipt of the newsletter as a revocation.
8. CONTACT VIA THE WEBSITE
In accordance with statutory provisions, the website of Oilquick Deutschland KG contains details facilitating rapid electronic contact with our company and direct communication with us, including a general address of so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data supplied to the controller voluntarily by a data subject are stored for the purposes of processing or of contacting the data subject. These personal data are not passed on to third parties.
9. SUBSCRIPTION TO BLOGS ON THE WEBSITE
The blogs posted on the website of Oilquick Deutschland KG can be subscribed to by third parties. In particular, it is possible for a commenter to subscribe to the comments following their particular blog post.
If a data subject decides to subscribe to comments, the controller will send an automatic confirmation e-mail in order to verify, by means of the double opt-in procedure, that the holder of the e-mail address supplied has indeed chosen this option. The option to subscribe to comments can be terminated at any time.
10. ROUTINE DELETION AND BLOCKING OF PERSONAL DATA
The controller processes and store personal data of the data subject only for the period necessary to achieve the purpose of storage or where provided for by the European Directive and Regulation or other legislator in laws or regulations to which the controller is subject.
If the purpose of storage is no longer valid or when a storage period prescribed by the European Directive and Regulation or another competent legislator expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.
11. RIGHTS OF THE DATA SUBJECT
a) Right to confirmation
Every data subject has the right, granted by the European Directive and the Regulation, to obtain confirmation from the controller as to whether personal data concerning him or her are being processed. If a data subject wishes to exercise this right of confirmation, he or she may, at any time, contact any employee of the controller.
a) Right of access
Any data subject whose personal data are processed has the right, granted by the European legislator, to obtain at any time from the controller, free of charge, information on the personal data concerning him or her which have been stored, and a copy of such information. Furthermore, the European legislator has granted the data subject access to the following information:
the purposes of the processing
the categories of personal data which are processed
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organisations
if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration
the existence of a right to obtain the rectification or erasure of personal data concerning him or her, or the restriction of processing by the controller, or the right to object to such processing
the existence of a right to lodge a complaint with a supervisory authority
Where the personal data are not collected from the data subject: all the information which is available about the source of the data
the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and – in these cases at least – meaningful information about the logic involved and the scope and intended effects of such processing for the data subject
Furthermore, the data subject has the right to be informed as to whether personal data have been transferred to a third country or to an international organisation. If so, the data subject also has the right to be informed of the appropriate safeguards relating to such transfer.
If a data subject wishes to exercise this right of access, he or she may, at any time, contact any employee of the controller.
a) Right to rectification
Any data subject whose personal data are processed has the right, granted by the European legislator, to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Furthermore, taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.
d) Right to erasure (right to be forgotten)
Any data subject whose personal data are processed has the right, granted by the European legislator, to obtain from the controller without undue delay the erasure of personal data concerning him or her where one of the following grounds applies and if the processing is not necessary:
The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
The data subject withdraws consent on which the processing is based according to point (a) of Article 6(1) GDPR, or point (a) of Article 9(2) GDPR, and there is no other legal ground for the processing.
The data subject objects to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) GDPR.
The personal data have been unlawfully processed.
The personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.
If one of the above-mentioned grounds applies and a data subject wishes to have personal data which are stored at Oilquick Deutschland KG erased, he or she may, at any time, contact any employee of the controller. The employee of Oilquick Deutschland KG will arrange for the request for erasure to be fulfilled without delay.
If the personal data were made public by Oilquick Deutschland KG, and our company as the controller is obliged to erase the personal data pursuant to Article 17(1) GDPR, then Oilquick Deutschland KG shall, taking into account the available technology and the cost of implementation, take reasonable measures, including technical measures, to inform other data controllers which process the published personal data, that the data subject has requested that those other data controllers erase all links to the personal data or copies or replications of the personal data, unless the processing is necessary. The employee of Oilquick Deutschland KG will arrange for the necessary action to be taken in individual cases.
e) Right to restriction of processing
Any data subject whose personal data are processed has the right, granted by the European legislator, to obtain from the controller restriction of processing where one of the following applies:
The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
The data subject has objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of the above-mentioned preconditions is met and a data subject wishes to have the processing of personal data which are stored at Oilquick Deutschland KG restricted, he or she may, at any time, contact any employee of the controller. The employee of Oilquick Deutschland KG will arrange for the processing to be restricted.
f) Right to data portability
Any data subject whose personal data are processed has the right, granted by the European legislator, to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format. He or she also has the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent pursuant to point (a) of Article 6(1) GDPR or point (a) of Article 9(2) GDPR or on a contract pursuant to point (b) of Article 6(1) GDPR and where the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, when exercising his or her right to data portability pursuant to Art. 20(1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and where this does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact any employee of Oilquick Deutschland KG.
g) Right to object
Any data subject whose personal data are processed has the right, granted by the European legislator, to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1) GDPR. This also applies to any profiling based on those provisions.
Oilquick Deutschland KG will no longer process the personal data in the event of objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
If Oilquick Deutschland KG processes personal data for the purpose of direct marketing, the data subject has the right to object at any time to the processing of personal data for such marketing. This also applies to any profiling to the extent that it relates to such direct marketing. If the data subject lodges an objection with Oilquick Deutschland KG against such processing for direct marketing purposes, Oilquick Deutschland KG will no longer process the personal data for these purposes.
In addition, the data subject has the right to object, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her which is carried out at Oilquick Deutschland KG for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) GDPR, unless such processing is necessary for the performance of a task carried out in the public interest.
In order to exercise the right to object, the data subject may at any time contact any employee of Oilquick Deutschland KG or another employee. The data subject is also free to exercise his or her right to object – in the context of the use of information society services – by automated means using technical specifications, notwithstanding Directive 2002/58/EC.
h) Automated decisions in individual cases including profiling
Any data subject whose personal data are processed has the right, granted by the European legislator, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, provided that the decision (1) is not necessary for entering into, or executing, a contract between the data subject and the controller, or (2) is authorised by Union or Member State law to which the controller is subject and such law lays down appropriate measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is made with the data subject’s explicit consent.
If the decision (1) is necessary for entering into or executing a contract between the data subject and the controller, or (2) is made with the data subject’s explicit consent, Oilquick Deutschland KG shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, including at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
If the data subject wishes to exercise rights with regard to automated decisions, he or she may, at any time, contact an employee of the controller.
i) Right to revoke consent to data processing
Any data subject whose personal data are processed has the right, granted by the European legislator, to revoke at any time consent given to the processing of personal data.
If the data subject wishes to assert rights with regard to revocation of consent, he or she may, at any time, contact an employee of the controller.
12. DATA PROTECTION DURING APPLICATIONS AND THE APPLICATION PROCESS
The controller collects and processes the personal data of applicants for the purpose of managing the application process. Processing may also be carried out electronically. This is the case in particular if an applicant sends the relevant application documents to the controller electronically, for example by e-mail or via a web form available on the website. If the controller concludes an employment contract with an applicant, the transmitted data are stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If the controller does not conclude an employment contract with the applicant, the application files are automatically deleted two months after notification of the rejection decision, unless the controller has another legitimate interest opposing such deletion. Another legitimate interest in this sense is, for example, a duty to provide evidence in proceedings under the General Equal Treatment Act (AGG).
13. PRIVACY POLICY ON THE USE OF ADOBE ANALYTICS (OMNITURE) / ADOBE MARKETING CLOUD
The controller has integrated components from Adobe into this website. Adobe Analytics (Omniture) or the Adobe Marketing Cloud (hereinafter referred to as “Omniture”) is a tool that facilitates more efficient online marketing as well as web analytics. Omniture is part of the Adobe Marketing Cloud. The Adobe Marketing Cloud enables real-time analysis of visitor flows on websites. Real-time analytics include project reports and allow ad-hoc analysis of website visitors. Customer interactions are presented in a way that gives the controller a better overview of the online activities of the users of this website by the data being displayed in simple and interactive dashboards, and converted into reports. This enables the controller to receive information in real time and thus identify problems more quickly.
The operator company of these services is Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Republic of Ireland.
Omniture sets a cookie on the data subject’s information technology system (cookies were explained above). The controller ensures by means of a server setting that the tracking data records transmitted to Adobe’s data centre are anonymised prior to any geolocation. Anonymisation is achieved by substituting the last part of the IP address. The controller has selected settings on the server which make the data subject’s IP address anonymous prior to any processing for geolocation and, independently, reach measurement. On behalf of the controller, Adobe will use the data and information obtained via our website to analyse the data subject’s user behaviour. Adobe will also use the data to compile reports on user activity on our behalf and to render other services for our company in connection with the use of our website. Adobe does not merge the data subject’s IP address with other personal data.
The data subject can prevent our website from setting cookies at any time, as explained above, by selecting the relevant setting on the internet browser used, thereby permanently objecting to the setting of cookies. Such a setting of the internet browser would also prevent Omniture from setting a cookie in the data subject’s information technology system. Moreover, cookies already set by Omniture can be deleted at any time via an internet browser or other software programmes.
Furthermore, the data subject can object to the collection of data generated by the Adobe cookie relating to the use of this website as well as to the processing of such data by Adobe, and can prevent such processing. To do this, the data subject needs to press the unsubscribe button under the link http://www.adobe.com/de/privacy/opt-out.html, which sets an opt-out cookie. The opt-out cookie set by means of this objection is stored on the information technology system which the data subject uses. If the cookies on the data subject’s system are deleted after an objection, the data subject needs to access the link again and set a new opt-out cookie.
However, when the opt-out cookie is set, it is possible that the internet pages of the controller will no longer be fully usable for the data subject.
Adobe’s applicable privacy policy can be found at
http://www.adobe.com/de/privacy.html.
14. PRIVACY POLICY ON THE USE OF GOOGLE ADSENSE
The controller has integrated Google AdSense into this website. Google AdSense is an online service which enables the placement of advertisements on third-party sites. Google AdSense is based on an algorithm which selects the advertisements displayed on third-party sites to match the content of that particular third-party site. Google AdSense allows interest-based targeting of internet users, which is achieved by generating individual user profiles.
The operating company of the Google AdSense component is Alphabet Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
The purpose of the Google AdSense component is to integrate advertisements into our website. Google-AdSense sets a cookie on the data subject’s information technology system). What exactly cookies are was explained above. Setting the cookie enables Alphabet Inc. to analyse the use of our website. Every time the data subject accesses one of the individual pages of this website operated by the controller which contains an integrated Google AdSense component, the internet browser on the data subject’s information technology system is automatically instructed by the respective Google AdSense component to transmit data to Alphabet Inc. for the purpose of online advertising and billing of commissions. In the course of this technical procedure, Alphabet Inc. obtains knowledge of personal data, such as the data subject’s IP address, which Alphabet Inc. uses, inter alia, to trace the origin of visitors and clicks and subsequently to enable billing of commissions.
The data subject can prevent our website from setting cookies at any time, as explained above, by selecting the relevant setting on the internet browser used, thereby permanently objecting to the setting of cookies. Such a setting of the internet browser would also prevent Alphabet Inc. from setting a cookie in the data subject’s information technology system. Moreover, cookies already set by Alphabet Inc. can be deleted at any time via the internet browser or other software programmes.
Google AdSense also uses so-called tracking pixels. A tracking pixel is a thumbnail graphic which is embedded in websites so as to enable log file recording and log file analysis, thus permitting a statistical evaluation to be carried out. With the aid of the embedded tracking pixel, Alphabet Inc. can determine whether and when a website was called up by a data subject, and which links were clicked on by the data subject. Tracking pixels serve, inter alia, to evaluate the flow of visitors to a website.
Via Google AdSense, personal data and information which includes the IP address and is necessary for the collection and billing of the advertisements displayed is transferred to Alphabet Inc. in the United States of America. This personal data is stored and processed in the United States of America. Alphabet Inc. may disclose these personal data collected by technical procedure to third parties.
Google-AdSense is explained more precisely under this link https://www.google.de/intl/de/adsense/start/.
15. PRIVACY POLICY ON THE USE OF GOOGLE ANALYTICS (WITH ANONYMISATION FUNCTION)
The controller has integrated the component Google Analytics (with anonymisation function) into this website. Google Analytics is a web analysis service. Web analysis means the collection, collation and evaluation of data concerning the behaviour of visitors to websites. A web analysis service collects, inter alia, data concerning the website from where the data subject arrived at a website (the so-called referrer), which sub-pages of the website were accessed and how often and for how long a sub-page was viewed. Web analysis is largely used to optimise a website and for cost-benefit analysis of internet advertising.
The operating company of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
For web analysis via Google Analytics, the controller uses the add-on „_gat._anonymizeIp“. By means of this add-on, the data subject’s IP address is shortened and anonymised by Google whenever our website is accessed from a member state of the European Union or from another state party to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyse the flow of visitors to our website. Google uses the data and information obtained in order, inter alia, to evaluate the use of our website, to compile online reports for us showing the activities on our website and to provide other services in connection with the use of our website.
Google Analytics sets a cookie on the data subject’s information technology system). What exactly cookies are was explained above. Setting the cookie enables Google to analyse the use of our website. Every time the data subject accesses one of the individual pages of this website operated by the controller which contains an integrated Google Analytics component, the internet browser on the data subject’s information technology system is automatically instructed by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. Within this technical procedure Google gains knowledge of personal data, such as the data subject’s IP address, which Google uses, inter alia, to trace the origin of visitors and clicks and subsequently to enable billing of commissions.
By means of the cookie, personal data such as the time of access, the location from where access was made and the frequency of visits to our website by the data subject are stored. With every visit to our website, these personal data, including the IP address of the internet connection used by the data subject, are transmitted to Google in the United States of America. These personal data are stored and processed in the United States of America. Google may pass these personal data collected by technical procedure on to third parties.
The data subject can prevent our website from setting cookies at any time, as explained above, by selecting the relevant setting on the internet browser used, thereby permanently objecting to the setting of cookies. Such a setting of the internet browser used would also prevent Google from setting a cookie in the data subject’s information technology system. Moreover, cookies already set by Google Analytics can be deleted at any time via the internet browser or other software programmes.
Furthermore, the data subject can object to the collection of data generated by the Google Analytics cookie relating to the use of this website as well as to the processing of such data by Google, and can prevent such processing. To do this, the data subject needs to download a browser add-on under the link https://tools.google.com/dlpage/gaoptout, and instal it. This browser add-on will instruct Google Analytics via JavaScript that no data or information about visits to websites may be transmitted to Google Analytics. Google will regard the installation of the browser add-on as an objection. If the data subject’s information technology system is later deleted, formatted or reinstalled, the data subject will need to reinstall the browser add-on in order to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person within his or her area of control, it will be possible to reinstall or reactivate the browser add-on.
Further information and Google’s valid privacy policy can be found at https://www.google.de/intl/de/policies/privacy/ and at http://www.google.com/analytics/terms/de.html. Google Analytics is explained more precisely under this link https://www.google.com/intl/de_de/analytics/.
16. PRIVACY POLICY ON THE USE OF GOOGLE REMARKETING
The controller has integrated the services of Google Remarketing into this website. Google Remarketing is a function of Google AdWords that enables a company to display advertisements to internet users who have previously visited the company’s website. The integration of Google Remarketing thus allows a company to create user-related advertising and consequently display advertisements to the internet user which are of interest to him or her.
The operating company of the services of Google Remarketing is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
The purpose of Google Remarketing is to display advertisements that are relevant to the user’s interests. Google Remarketing enables us to show advertisements via the Google advertising network which are tailored to the individual needs and interests of internet users, or to have them shown on other internet pages.
Google Remarketing sets a cookie on the data subject’s information technology system). What exactly cookies are was explained above. The cookie enables Google to recognise visitors to our website when they subsequently visit websites which are also members of the Google advertising network. With every visit to a website incorporating the Google Remarketing service, the data subject’s internet browser automatically identifies itself to Google. Within this technical procedure Google gains knowledge of personal data, such as the data subject’s IP address or surfing behaviour, which Google uses inter alia for the insertion of advertisements of interest to the data subject.
By means of the cookie, personal data such as the websites visited by the data subject are stored. Thus, with every visit to our website these personal data, including the IP address of the internet connection used by the data subject, are transmitted to Google in the United States of America. These personal data are stored and processed in the United States of America. Google may pass these personal data collected by technical procedure on to third parties.
The data subject can prevent our website from setting cookies at any time, as explained above, by selecting the relevant setting on the internet browser used, thereby permanently objecting to the setting of cookies. Such a setting of the internet browser used would also prevent Google from setting a cookie in the data subject’s information technology system. Moreover, cookies already set by Google Analytics can be deleted at any time via the internet browser or other software programmes.
Furthermore, the data subject has the option to object to interest-based advertising by Google. To do so, the data subject needs to call up the link www.google.de/settings/adsfrom each of the internet browsers he or she uses and select the preferred settings there.
Further information and Google’s valid privacy policy can be found at
https://www.google.de/intl/de/policies/privacy/.
16.1 GOOGLE ANALYTICS FOR FIREBASE
is a development platform for mobile and web applications. It provides tools and infrastructure to help a developer provide functions to users on different platforms more easily and efficiently. In our case, it serves to optimise our apps.
With the use of the app, the following personal data are collected: cookie, unique device identifier for advertising (Google advertising ID or IDFA, for example) and usage data.
Firebase authentication: personal data such as e-mail, surname and first name are collected.
Firebase cloud functions, Firebase cloud storage and Firebase Realtime Database: personal data such as usage data and various types of data as described in the service’s privacy policy are collected.
Privacy policy of Firebase:
https://www.firebase.com/terms/privacy-policy.html
17. LEGAL BASIS OF PROCESSING
For our company, Art. 6 I letter a of the GDPR serves as the legal basis for processing operations where we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, with processing operations which are necessary for the delivery of goods or the provision of another service or counter-service, the processing is based on Art. 6 letter b GDPR. The same applies to processing operations which are necessary for the implementation of pre-contractual measures, for example in the case of enquiries about our products or services. If our company is subject to a legal obligation which makes the processing of personal data necessary, such as for the fulfilment of tax obligations, the processing is based on Art. 6 I letter c GDPR. In rare cases, the processing of personal data might become necessary to protect vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were to be injured on our premises and as a result their name, age, health insurance details or other vital information needed to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6 I letter d GDPR.
Finally, processing could be based on Art. 6 I letter f GDPR. This clause is the legal basis for processing operations which do not have any of the aforementioned legal bases, if the processing is necessary to protect a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject are not overridden. We are permitted to carry out such processing operations in particular because they were specifically mentioned by the European legislator. The European legislator stated that a legitimate interest could exist if the data subject is a client of the controller (recital 47, second sentence GDPR).
18. LEGITIMATE INTERESTS IN PROCESSING PURSUED BY THE CONTROLLER OR A THIRD PARTY
Where the processing of personal data is based on Article 6 I letter f GDPR, our legitimate interest is the conduct of our business for the benefit of the well-being of all our employees and our shareholders.
19. DURATION FOR WHICH THE PERSONAL DATA WILL BE STORED
The criterion for the duration of storage of personal data is the relevant statutory retention period. After expiry of the period, the corresponding data are routinely deleted insofar as they are no longer required for the fulfilment of a contract or initiation of a contract.
20. LEGAL OR CONTRACTUAL REQUIREMENTS FOR THE PROVISION OF PERSONAL DATA; NECESSITY FOR CONCLUSION OF THE CONTRACT; OBLIGATION OF THE DATA SUBJECT TO PROVIDE PERSONAL DATA; POSSIBLE CONSEQUENCES OF FAILURE TO PROVIDE PERSONAL DATA
We would like to inform you that the provision of some personal data is required by law (e.g. tax regulations) or may also be required by contractual regulations (e.g. information about the contractual partner).
In order to conclude a contract, it is sometimes necessary for a data subject to provide us with personal data which subsequently have to be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with him or her. Failure to provide the personal data would mean that the contract with the data subject cannot be concluded.
Before any personal data are provided by the data subject, the data subject needs to contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what the consequences of not providing the personal data would be.
21. EXISTENCE OF AUTOMATED DECISION-MAKING
As a responsible company, we do not use automatic decision-making or profiling.
22. ANALYSIS TOOLS AND ADVERTISING
Google Analytics
This website uses functions of the web analysis service Google Analytics. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics used so-called “cookies”. These are text files which are stored on your computer and enable an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there.
The basis for the storage of Google Analytics cookies and the use of this analysis tool is Art. 6 (1) letter f GDPR. The website operator has a legitimate interest in analysing user behaviour in order to optimise both its website and its advertising.
IP anonymisation
On this website, we have enabled the IP anonymisation function. This means that Google will truncate your IP address within member states of the European Union or in other states which are party to the Agreement on the European Economic Area before forwarding it to the USA. Only in exceptional cases will the full IP address be forwarded to a Google server in the USA and truncated there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. The IP address transmitted by your browser for Google Analytics will not be merged with other Google data.
Browser plug-in
You can prevent the storage of cookies by setting your browser software accordingly; however, we would like to point out that in this case you may not be able to use all the functions of this website to their full extent. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data if you download and install the browser plug-in available under the following link:
https://tools.google.com/dlpage/gaoptout?hl=de.
Objection to data collection
You can prevent Google Analytics from collecting your data if you click on the following link. An opt-out cookie is set which prevents the collection of your data during future visits to this website: disable Google Analytics.
You can find more information about how Google Analytics treats user data in Google’s privacy policy:
https://support.google.com/analytics/answer/6004245?hl=de.
Processing
We have concluded a processing contract with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.
Demographic characteristics of Google Analytics
This website uses the “demographic characteristics” function of Google Analytics. Thus, reports can be compiled which contain statements about the age, gender and interests of the site visitors. These data stem from interest-based advertising from Google as well as visitor data from third-party providers. These data cannot be associated with any specific person. You can disable this function any time via the ad settings in your Google account, or generally forbid the collection of your data by Google Analytics as shown in the paragraph “Objection to data collection”.
Duration of storage
Data which Google stores at user and event level and which are related to cookies, user identifiers (e.g. User ID) or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) are anonymised or deleted after 26 months. You can find details on this under the following link:
https://support.google.com/analytics/answer/7667196?hl=de
Google Analytics Remarketing
Our websites use the functions of Google Analytics Remarketing in conjunction with the multi-device functions of Google AdWords and Google DoubleClick. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
This function makes it possible to link the advertising target groups compiled by means of Google Analytics Remarketing with the multi-device functions of Google AdWords and Google DoubleClick. In this way, interest-based, personalised advertising messages which were customised to you according to your previous usage and surfing behaviour on one end device (e.g. mobile phone) can also be displayed on another one of your end devices (e.g. tablet or PC).
If you have given your consent, Google will link your web and app browsing history to your Google account for this purpose. In this way, the same personalised advertising messages can be displayed on each of your end devices to which you log in with your Google account.
To support this feature, Google Analytics captures Google-authenticated IDs of users and temporarily links them with our Google Analytics data in order to define and create target groups for multi-device advertising.
You can permanently object to multi-device remarketing/targeting by disabling personalised advertising in your Google account; to do so, follow this link:
https://www.google.com/settings/ads/onweb/.
The aggregation of the collected data in your Google account is based, pursuant to Art. 6 (1) letter a GDPR, only on your consent, which you may give to or withdraw from Google. In the case of data collection processes not aggregated in your Google account (e.g. because you do not have a Google account or have objected to the aggregation), the collection of data is based on Art. 6 (1) letter f GDPR. The legitimate interest results from the fact that the website operator has an interest in the anonymised analysis of website visitors for advertising purposes.
Further information and the data protection provisions can be found in Google’s privacy policy at:
https://policies.google.com/technologies/ads?hl=de.
Google AdWords and Google conversion-tracking
This website uses Google AdWords. AdWords is an online advertising program provided by Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Within Google AdWords, we use so-called conversion-tracking. When you click on an ad placed by Google, a cookie is set for conversion tracking. Cookies are small text files which the internet browser stores on the user’s computer. These cookies lose their validity after 30 days and do not serve the personal identification of users. If the user visits certain pages of this website and the cookie has not yet expired, Google and ourselves can recognise that the user has clicked on the ad and been redirected to this page.
Every Google AdWords customer receives a different cookie. The cookies cannot be tracked via the websites of AdWords customers. The information collected with the aid of the conversion cookie is used to create conversion statistics for AdWords customers who have opted for conversion tracking. Customers learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information with which users can be personally identified. If you do not wish to participate in the tracking, you can object to this use by easily disabling the Google conversion-tracking cookie via your internet browser under the user settings. You will then not be included in the conversion-tracking statistics.
The storage of conversion cookies and the use of this tracking tool is carried out on the basis of Art. 6 (1) letter f GDPR. The website operator has a legitimate interest in analysing user behaviour in order to optimise both its website and its advertising.
More information on Google AdWords and Google conversion-tracking can be found in Google’s privacy policy:
https://policies.google.com/privacy?hl=de.
You can set your browser in such a way that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be restricted.
Facebook pixels
For conversion measurement, our website uses the visitor action pixel from Facebook, Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”).
In this way, the behaviour of website visitors can be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This allows the effectiveness of Facebook ads to be evaluated for statistical and market research purposes and in order to optimise future advertising measures.
The data collected are anonymous for us as the operator of this website; we cannot draw any conclusions about the identity of the users. The data are however stored and processed by Facebook, so that a correlation with the relevant user profile is possible and Facebook can use the data for its own advertising purposes, in accordance with the Facebook data use policy. This allows Facebook to place ads on Facebook pages as well as outside of Facebook. We, as website operator, cannot influence this use of the data.
The use of Facebook pixels is carried out on the basis of Art. 6 (1) letter f GDPR. The website operator has a legitimate interest in effective advertising measures including social media.
You can find more information about protecting your privacy in Facebook’s privacy policy:
https://de-de.facebook.com/about/privacy/.
You can also disable the “Custom Audiences” remarketing function in the advertising settings area under https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screenTo do so, you must be logged in to Facebook.
If you do not have a Facebook account, you can disable Facebook’s usage-based advertising on the European Interactive Digital Advertising Alliance website: http://www.youronlinechoices.com/de/praferenzmanagement/.
Alternatively, you can set a cookie here which deactivates tracking by means of the Facebook pixel. This only works for the current browser and current end device. If you delete the cookies in the browser you are currently using, the Facebook opt-out cookie will also be deleted. Disable Facebook tracking
This privacy policy was created by the data protection declaration generator of the external DPO Münster in cooperation with RC GmbH, which recycles used notebooks, and the file sharing lawyers of WBS-LAW.
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