Privacy
Privacy policy
Introduction
With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes and to what extent. The data protection declaration 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 the “Online Offer”).
The terms used are not gender specific.
Status: February 18, 2021
Table of contents
- Introduction
- Responsible
- Processing overview
- Relevant legal bases
- Security measures
- Transmission of personal data
- Data processing in third countries
- Cookies use
- Business services
- Payment service provider
- Provision of the online offer and web hosting
- Communication via messenger
- Video conferencing, online meetings, webinars and screen sharing
- Cloud services
- Online marketing
- Presence in social networks (social media)
- Plugins and embedded functions and content
- Data deletion
- Modification and update of the privacy policy
- Rights of the data subjects
- Definitions
Responsible
Myriam Feichtinger / Letitflow Pilates
CH / Switzerland
E-mail address: letitflowpilates@gmail.com.
Imprint: https://letitflow-pilates.com.
Processing overview
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
- Event data (Facebook) (“Event data” is data that may be transmitted by us to Facebook, e.g. via Facebook Pixel (via apps or other means), and relates to persons or their actions; the data includes, for example, information about visits to websites, interactions with content, functions, app installations, product purchases, etc.; the event data is processed for the purpose of creating target groups for content and advertising information (Custom Audiences).Event data is processed for the purpose of creating target groups for content and advertising information (Custom Audiences); Event data does not include the actual content (such as written comments), no login information and no contact information (i.e. no names, email addresses and phone numbers). Event data is deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account).
- Inventory data (e.g., names, addresses).
- Content data (e.g. entries in online forms).
- Contact information (e.g., email, phone numbers).
- Meta/communication data (e.g. device information, IP addresses).
- Usage data (e.g. web pages visited, interest in content, access times).
- Contract data (e.g. subject matter of the contract, term, customer category).
- Payment data (e.g. bank details, invoices, payment history).
Special categories of data
- Data showing racial and ethnic origin.
Categories of persons concerned
- Employees (e.g., employees, applicants, former employees).
- Business and Contractual Partners.
- Users (e.g., website visitors, users of online services).
Processing purposes
- Affiliate tracking.
- Provision of our online offer and user-friendliness.
- Office and organizational procedures.
- Direct marketing (e.g. by e-mail or postal mail).
- Feedback (e.g. collecting feedback via online form).
- Contact requests and communication.
- Profiles with user-related information (creation of user profiles).
- Safety measures.
- Provision of contractual services and customer service.
- Managing and responding to inquiries.
Relevant legal bases
In the following, we share the legal basis of the General Data Protection Regulation (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 and domicile. If, in addition, more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.
- Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO)- The data subject has given his/her consent to the processing of personal data concerning him/her for a specific purpose or purposes.
- Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO)- The processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures which are carried out at the request of the data subject.
- Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO)- Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 (1) p. 1 lit. f. DSGVO)- Processing is necessary to protect the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
National data protection regulations in Switzerland: In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Switzerland. This includes, in particular, the Federal Data Protection Act (DSG). The DPA applies in particular if no EU/EEC citizens are involved and, for example, only data of Swiss citizens is processed.
Security measures
We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk 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.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, ensuring the availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to data compromise. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
SSL encryption (https): To protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.
Transmission of personal data
In the course of our processing of personal data, the data may be transferred to or disclosed to other entities, companies, legally independent organizational units or persons. 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 comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.
Data transfers within the organization: We may transfer or provide access to personal data to other entities within our organization. Insofar as this transfer is for administrative purposes, the transfer of data is based on our legitimate corporate and business interests or takes place insofar as it is necessary for the fulfillment of our contract-related obligations or if the consent of the data subjects or a legal permission exists.
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, entities or companies, this will only be done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transfer, we process or have the data processed only in third countries with a recognized level of data protection, contractual obligation by so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, EU Commission information page: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).
Cookies use
Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after his visit within an online offer. Stored information may include, for example, language settings on a website, login status, a shopping cart, or where a video was watched. The term cookies also includes other technologies that perform the same functions as cookies (e.g., when user information is stored on the basis of pseudonymous online identifiers, also referred to as “user IDs”).
The following cookie types and functions are distinguished:
- Temporary cookies (also: session cookies):Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
- Permanent cookies:Permanent cookies remain stored even after the browser is closed. For example, login status can be saved or preferred content can be displayed directly when the user revisits a website. Likewise, the interests of users used for reach measurement or marketing purposes may be stored in such a cookie.
- First-party cookies:First-party cookies are set by ourselves.
- Third-party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
- Necessary (also: essential or absolutely necessary) cookies:Cookies may be absolutely necessary for the operation of a website (e.g. to store logins or other user input or for security reasons).
- Statistics, marketing and personalization cookies: Furthermore, cookies are generally also used in the context of range measurement and when a user’s interests or behavior (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that matches their potential interests. This process is also called “tracking”, i.e., following the potential interests of users. Insofar as we use cookies or “tracking” technologies, we will inform you separately in our data protection declaration or in the context of obtaining consent.
Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for the processing of your data is the declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.
Storage period: If we do not provide you with explicit information about the storage period of permanent cookies (e.g. in the context of a so-called cookie opt-in), please assume that the storage period can be up to two years.
General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent you have given or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection by means of your browser settings, e.g. by deactivating the use of cookies (whereby this may also limit the functionality of our online offer). An objection to the use of cookies for online marketing purposes may also be declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further instructions on how to object in the context of the information on the service providers and cookies used.
Processing of cookie data on the basis of consent: We use a cookie consent management procedure under which users’ consents to the use of cookies, or to the processing operations and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users. The declaration of consent is stored so that it does not have to be repeated and the consent can be proven in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies), in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. Here, a pseudonymous user identifier is formed and stored with the time of consent, information on the scope of consent (e.g., which categories of cookies and/or service providers), as well as the browser, system, and end device used.
- Types of data processed:Usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Data subjects:Users (e.g., website visitors, users of online services).
- Legal basis:Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
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 as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer inquiries.
We process this data to fulfill our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with this information as well as for business organization. Within the framework of applicable law, we only disclose the data of the contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or for the fulfillment of legal obligations or with the consent of the persons concerned (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.
We inform the contractual partners which data are required for the aforementioned purposes before or in the course of data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.
We delete the data after the expiry of legal warranty and comparable obligations, i.e., generally after 4 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 10 years). We delete data disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, in principle after the end of the order.
Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms shall apply in the relationship between the users and the providers.
Coaching: We process the data of our clients as well as interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to be able to provide our services to them. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship.
In the course of our activities, we may also process special categories of data, in this case in particular information on the health of clients, possibly with reference to their sex life or sexual orientation, as well as data revealing racial and ethnic origin, political opinions, religious or ideological beliefs or trade union membership. For this purpose, we obtain the explicit consent of the clients, if required, and otherwise process the special categories of data if this serves the health of the clients, the data are public or other legal permissions exist.
If it is necessary for the fulfillment of our contract, for the protection of vital interests or required by law, or if we have the consent of the client, we disclose or transfer the client’s data to third parties or agents, such as public authorities, billing offices, as well as in the area of IT, office or comparable services, in compliance with the requirements of professional law.
Travel-related services: We process the data of our customers and prospective customers (uniformly referred to as “customers”) in accordance with the underlying contractual relationship. We may also process the information on the characteristics and circumstances of persons or things belonging to them if this is necessary within the framework of the contractual relationship. This may include, for example, information on personal circumstances, movable tangible property, and financial situation.
Within the scope of our assignment, it may be necessary for us to process special categories of data within the meaning of Art. 9 para. 1 DSGVO, in particular process information about the health of a person. The processing is done to protect the health interests of the customers and otherwise only with the consent of the customers.
If required for the fulfillment of the contract or required by law, or consented to by customers or based on our legitimate interests, we disclose or transfer the data of customers, for example, to the service providers involved in the performance of travel services.
Further information on commercial 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 delivery or execution or performance.
The required information is identified as such in the context of the order, purchase order or comparable contract conclusion 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.
- Types of data processed:Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of contract, term, customer category).
- Special categories of personal data:Health data (Art. 9(1) DGSVO), Data concerning sex life or sexual orientation (Art. 9(1) DGSVO), Religious or philosophical beliefs (Art. 9(1) DGSVO), Data revealing racial or ethnic origin.
- Affected persons:Interested parties, business and contractual partners.
- Purposes of processing:Provision of contractual services and customer service, contact requests and communication, office and organizational procedures, management and response to requests.
- Legal basis:Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Payment service provider
In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other payment service providers in addition to banks and credit institutions for this purpose (collectively, “payment service providers”).
The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is necessary to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e., we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the GTC and the data protection information of the payment service providers.
The terms and conditions and the data protection notices of the respective payment service providers, which can be accessed within the respective websites or transaction applications, shall apply to the payment transactions. We also refer to these for further information and assertion of revocation, information and other data subject rights.
- Types of data processed:Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Affected persons:Customers, interested parties.
- Purposes of processing:contact requests and communication, affiliate tracking.
- Legal basis:Contract fulfillment and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Provision of the online offer and web hosting
In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services.
The data processed in the course of providing the hosting service may include all information concerning the users of our online service that is generated in the course of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.
E-mail sending and hosting: The web hosting services we use also include the sending, receiving and storing of e-mails. For these purposes, the addresses of the recipients and senders as well as further information concerning the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for SPAM detection purposes. We ask you to note that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. Therefore, we cannot assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.
Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data 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 may be used, on the one hand, for security purposes, e.g., to prevent server overload (especially in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability.
- Types of data processed:Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Data subjects:Users (e.g., website visitors, users of online services).
- Purposes of processing:Provision of contractual services and customer service.
- Legal basis:Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Services used and service providers:
- com:Hosting platform for blogs / websites; Service provider: Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA; website: https://wordpress.com; privacy policy: https: //automattic.com/de/privacy/.
Communication via messenger
We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, on encryption, on the use of the metadata of the communication and on your objection options.
You can also contact us by alternative means, e.g. via telephone or e-mail. Please use the contact options provided to you or the contact options specified within our online offer.
In the case of end-to-end encryption of content (i.e., the content of your message and attachments), please note that the communication content (i.e., the content of the message and attached images) is encrypted from end to end. This means that the content of the messages is not viewable, not even by the messenger providers themselves. You should always use an up-to-date version of messengers with encryption enabled to ensure that message content is encrypted.
However, we additionally point out to our communication partners that the providers of the messengers cannot view the content, but can learn that and when communication partners communicate with us as well as technical information about the device used by the communication partners and, depending on the settings of their device, also location information (so-called metadata) is processed.
Notes on legal bases: If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and they contact us, for example, on their own initiative, we use Messenger in relation to our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners in communication via Messenger. Furthermore, we would like to point out that we do not transmit the contact data provided to us to the messengers for the first time without your consent.
Revocation, objection and deletion: You can revoke a given consent at any time and object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete the messages in accordance with our general deletion guidelines (i.e., e.g., as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information provided by the communication partners, if no reference to a previous conversation is to be expected and the deletion does not conflict with any legal retention obligations.
Reservation of reference to other communication channels: Finally, we would like to point out that, for reasons of your security, we reserve the right not to answer requests via Messenger. This is the case if, for example, contractual internals require special secrecy or a reply via Messenger does not meet formal requirements. In such cases, we refer you to more adequate communication channels.
- Types of data processed:Contact data (e.g. e-mail, phone numbers), usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Affected persons:
- Purposes of processing:Contact requests and communication, direct marketing (e.g. by e-mail or postal mail).
- Legal basis:Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Services used and service providers:
- Facebook Messenger:Facebook Messenger with end-to-end encryption (Facebook Messenger end-to-end encryption requires activation if it should not be activated by default); service provider: https://www.facebook.com, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Possibility of objection (opt-out): https://www.facebook.com/settings?tab=ads.
- WhatsApp:WhatsApp Messenger with end-to-end encryption; service provider: WhatsApp Inc. WhatsApp Legal 1601 Willow Road Menlo Park, California 94025, USA; Website: https://www.whatsapp.com/; Privacy Policy: https: //www.whatsapp.com/legal.
Video conferencing, online meetings, webinars and screen sharing
We use platforms and applications of other providers (hereinafter referred to as “Third Party Providers”) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings. When selecting third-party providers and their services, we observe the legal requirements.
In this context, data of the communication participants are processed and stored on the servers of the third-party providers, insofar as they are part of communication processes with us. This data may include, in particular, registration and contact data, visual as well as vocal contributions, and entries in chats and shared screen content.
If users are referred to the third-party providers, or their software or platforms, in the course of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security, service optimization or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.
Notes on legal bases: If we ask users for their consent to use the third-party providers or certain functions (e.g., consent to a recording of conversations), the legal basis of the processing is consent. Furthermore, their use may be a component of our (pre)contractual services, provided that the use of the third-party providers has been agreed within this framework. Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners. In this context, we would additionally like to refer you to the information on the use of cookies in this privacy policy.
- Types of data processed:Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Data subjects:Communication partners, users (e.g., website visitors, users of online services).
- Purposes of processing:Provision of contractual services and customer service, contact requests and communication, office and organizational procedures, direct marketing (e.g. by e-mail or postal mail).
- Legal basis:Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Services used and service providers:
- Zoom:Video conferencing, web conferencing and webinars; Service provider: Zoom Video Communications, Inc, 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA; Website: https://zoom.us; Privacy Policy: https: //zoom.us/docs/de-de/privacy-and-legal.html; Standard Contractual Clauses (ensuring level of data protection in case of processing in third countries): https://zoom.us/docs/de-de/privacy-and-legal.html (Designated as Global DPA).
Cloud services
We use software services accessible via the Internet and running on the servers of their providers (so-called “cloud services”, also referred to as “software as a service”) for the following purposes: document storage and management, calendar management, emailing, spreadsheets and presentations, sharing documents, content and information with specific recipients or publishing web pages, forms or other content and information, as well as chats and participation in audio and video conferences.
In this context, personal data may be processed and stored on the servers of the providers insofar as these are part of communication processes with us or are otherwise processed by us as set out in the context of this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents. The cloud service providers also process usage data and metadata, which they use for security purposes and service optimization.
If we use cloud services to provide forms or other documents and content to other users or publicly accessible websites, the providers may store cookies on users’ devices for the purposes of web analytics or to remember users’ settings (e.g., in the case of media control).
Notes on legal bases: If we ask for consent to use the cloud services, the legal basis of the processing is consent. Furthermore, their use may be a component of our (pre)contractual services, provided that the use of the cloud services has been agreed within this framework. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient and secure management and collaboration processes)
- Types of data processed:Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Affected persons:Customers, employees (e.g., employees, applicants, former employees), interested parties, communication partners.
- Purposes of processing:Office and organizational procedures.
- Legal basis:Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Services used and service providers:
- Dropbox:Cloud storage services; Service provider: Dropbox, Inc., 333 Brannan Street, San Francisco, California 94107, USA; website: https://www.dropbox.com/de; privacy policy: https: //www.dropbox.com/privacy; standard contractual clauses (ensuring level of data protection for processing in third countries): https://www.dropbox.com/terms/business-agreement-2016.
- Google Cloud Services:Cloud storage services; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://cloud.google.com/; privacy policy: https://www.google.com/policies/privacy, security notices: https: //cloud.google.com/security/privacy; standard contractual clauses (ensuring level of data protection for processing in third countries): https://cloud.google.com/terms/data-processing-terms; https://cloud.google.com/terms/data-processing-terms.
Online marketing
We process personal data for online marketing purposes, which may include, in particular, marketing advertising space or displaying promotional and other content (collectively, “Content”) based on users’ potential interests and measuring its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which the user data relevant to the presentation of the aforementioned content is stored. This information may include, for example, content viewed, web pages 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. If users have consented to the collection of their location data, this can also be processed.
The IP addresses of the users are also stored. However, we use available IP masking methods (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms are. This means that we, as well as the providers of the online marketing methods, do not know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can later generally be read on other websites that use the same online marketing method and analyzed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing method provider.
Exceptionally, clear data can be assigned to profiles. This is the case if, for example, the users are members of a social network whose online marketing methods we use and the network links the users’ profiles with the aforementioned information. We ask you to note that users can make additional agreements with the providers, e.g. by giving their consent as part of the registration process.
We generally only receive access to aggregate information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e., for example, to a contract being concluded with us. Conversion measurement is used solely to analyze the success of our marketing efforts.
Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.
Notes on legal bases: If we ask users for their consent to use the third-party providers, the legal basis for processing data 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 refer you to the information on the use of cookies in this privacy policy.
- Types of data processed:Usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Data subjects:Users (e.g., website visitors, users of online services).
- Purposes of processing:marketing, profiles with user-related information (creating user profiles).
- Security measures:IP masking (pseudonymization of the IP address).
- Legal basis:Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
- Opt-out:We refer to the data protection notices of the respective providers and the opt-out options given for the providers. If no explicit opt-out option has been specified, you have the option of disabling cookies in your browser settings. However, this may restrict functions of our online offer. We therefore additionally recommend the following opt-out options, which are offered in summary form directed at respective territories: a) Europe: https://www.youronlinechoices.eu. (b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Inter-area: https://optout.aboutads.info.
Services used and service providers:
- Google Analytics:Online marketing and web analytics; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com/intl/de/about/analytics/; privacy policy: https://policies.google.com/privacy; opt-out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
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 users active there or to offer information about us.
We would like to point out that in the process, user data may be processed outside the area of the European Union. This may give rise to risks for users because, for example, it could make it more difficult to enforce users’ rights.
Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to display advertisements within and outside the networks that presumably correspond to the users’ interests. For these purposes, cookies are usually stored on the users’ computers, in which the usage behavior and interests of the users are stored. Furthermore, data may also be stored in the usage profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the privacy statements and information provided by the operators of the respective networks.
Also in the case of requests for information and the assertion of data subject rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data in each case and can take appropriate measures and provide information directly. If you still need help, then you can contact us.
Facebook: We are jointly responsible with Facebook Ireland Ltd. for the collection (but not the further processing) of data from visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content users view or interact with, or the actions they take (see under “Things You and Others Do and Provide” in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by the users (e. g. B. IP addresses, operating system, browser type, language settings, cookie data; see under “Device Information” in the Facebook Data Policy Statement: https://www.facebook.com/policy). As explained in the Facebook Privacy Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, called “Page Insights,” to Page operators to provide them with insights into how people interact with their Pages and with content associated with them. We have concluded a special agreement with Facebook (“Information on Page Insights”, https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill 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”(https://www.facebook.com/legal/terms/information_about_page_insights_data).
- Types of data processed:Contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Data subjects:Users (e.g., website visitors, users of online services).
- Purposes of processing:Contact requests and communication, feedback (e.g. collecting feedback via online form), marketing.
- Legal basis:Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Services used and service providers:
- Clubhouse:Social network with audio chat feature; Provider details: solely to support incident investigation, Clubhouse temporarily records audio in a chat room while the room is active and thereafter, if a user reports a breach of trust and security, while the room is active until the investigation is complete; audio from muted speakers and listeners is never recorded, and all temporary audio recordings are encrypted; personal data processed by Clubhouse may be processed for marketing purposes or shared with third parties; Service provider: Alpha Exploration Co, Inc; website: https://www.joinclubhouse.com/; Privacy Policy: https://privacy.joinclubhouse.com/.
- Instagram:Social network; service provider: Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; website: https://www.instagram.com; privacy policy: https: //instagram.com/about/legal/privacy.
- Facebook:Social network; service provider: Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy policy: https: //www.facebook.com/about/privacy; Opt-out: Ads settings: https: //www.facebook.com/settings?tab=ads.
- LinkedIn:Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; website: https://www.linkedin.com; privacy policy: https://www.linkedin.com/legal/privacy-policy; opt-out: https: //www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Pinterest:Social network; Service provider: Pinterest Inc, 635 High Street, Palo Alto, CA, 94301, USA,; website: https://www.pinterest.com; privacy policy: https: //about.pinterest.com/de/privacy-policy; opt-out: https: //about.pinterest.com/de/privacy-policy.
- TikTok:Social network / video platform; Service provider: musical.ly Inc, 10351 Santa Monica Blvd #310, Los Angeles, CA 90025 USA; Website: https://www.tiktok.com; Privacy policy: https: //www.tiktok.com/de/privacy-policy.
- Vimeo:Social network and video platform; Service provider: Vimeo Inc, Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA; Website: https://vimeo.com; Privacy Policy: https: //vimeo.com/privacy.
- YouTube:Social network and video platform; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; privacy policy: https://policies.google.com/privacy; opt-out: https: //adssettings.google.com/authenticated.
- Xing:Social network; Service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; website: https://www.xing.de; privacy policy: https: //privacy.xing.com/de/datenschutzerklaerung.
Plugins and embedded functions and content
We incorporate into our online offering functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). This may include, for example, graphics, videos or city maps (hereinafter uniformly referred to as “Content”).
The integration always requires that the third-party providers of this content process the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus required for the display of these contents or functions. We endeavor to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit, and other information about the use of our online offering, as well as being linked to such information from other sources.
Notes on legal bases: If we ask users for their consent to use the third-party providers, the legal basis for processing data 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 refer you to the information on the use of cookies in this privacy policy.
Facebook plugins and content: We are jointly responsible with Facebook Ireland Ltd. for the collection or receipt in the course of a transmission (but not the further processing) of “Event Data” that Facebook collects or receives in the course of a transmission by means of the Facebook social plugins (and content embedding features) running on our Online Offer for the following purposes: a) Displaying content as well as advertising information that corresponds to the presumed interests of the users; b) Delivery of commercial and transactional messages (e.g., addressing users via Facebook Messenger); c) Improving ad delivery and personalization of features and content (e.g., improving the identification of which content or advertising information is likely to be of interest to users). We have entered into a special agreement with Facebook (“Responsible Party Addendum”, https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the data subject rights (i.e., users can, for example, provide information or make deletion requests directly to Facebook). Note: When Facebook provides us with metrics, analytics, and reports (which are aggregated, i.e., do not receive information about individual users and are anonymous to us), this processing is not done under shared responsibility, but rather on the basis of a data processing agreement (“Data Processing Terms “, https://www.facebook.com/legal/terms/dataprocessing) , the “Data security conditions” (https://www.facebook.com/legal/terms/data_security_terms) as well as with regard to processing in the U.S. based on standard contractual clauses (“Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). 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.
Instagram plugins and content: We are jointly responsible with Facebook Ireland Ltd. for the collection or receipt in the course of a transmission (but not the further processing) of “Event Data” that Facebook collects or receives in the course of a transmission by means of Instagram features (e.g., content embedding features) running on our Online Service for the following purposes: a) Displaying content as well as advertising information that corresponds to the presumed interests of the users; b) Delivery of commercial and transactional messages (e.g., addressing users via Facebook Messenger); c) Improving ad delivery and personalization of features and content (e.g., improving the identification of which content or advertising information is likely to be of interest to users). We have entered into a special agreement with Facebook (“Responsible Party Addendum”, https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the data subject rights (i.e., users can, for example, provide information or make deletion requests directly to Facebook). Note: When Facebook provides us with metrics, analytics, and reports (which are aggregated, i.e., do not receive information about individual users and are anonymous to us), this processing is not done under shared responsibility, but rather on the basis of a data processing agreement (“Data Processing Terms “, https://www.facebook.com/legal/terms/dataprocessing) , the “Data security conditions” (https://www.facebook.com/legal/terms/data_security_terms) as well as with regard to processing in the U.S. based on standard contractual clauses (“Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). 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.
- Types of data processed:Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), event data (Facebook) (“event data” is data that can be transmitted by us to Facebook, e.g. via Facebook Pixel (via apps or in other ways), and relates to persons or their actions; the data includes, e.g.. Information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.; Event data is processed for the purpose of forming target groups for content and advertising information (Custom Audiences); Event data does not include the actual content (such as written comments), no login information and no contact information (i.e. no names, email addresses and phone numbers). Event data is deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms).
- Data subjects:Users (e.g., website visitors, users of online services).
- Purposes of processing:Provision of our online offer and user experience, provision of contractual services and customer service, marketing, profiles with user-related information (creation of user profiles), security measures, administration and response to requests.
- Legal basis:Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO), consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. GDPR).
Services used and service providers:
- Facebook plugins and content:Facebook social plugins and content – This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online offering within Facebook. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/; Service provider: Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Opt-out: Settings for advertisements: https://www.facebook.com/settings?tab=ads.
- Instagramplugins and content:Instagram plugins and content – This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within Instagram. Service Provider: https://www.instagram.com, Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Privacy Policy: https: //instagram.com/about/legal/privacy.
- YouTube videos:Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://www.youtube.com; privacy policy: https://policies.google.com/privacy; opt-out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
- Vimeo:Video Content; Service Provider: Vimeo Inc, Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA; Website: https://vimeo.com; Privacy Policy: https://vimeo.com/privacy; Opt-Out: We point out that Vimeo may use Google Analytics and refer to the privacy policy(https://policies.google.com/privacy) as well as the opt-out options for Google Analytics(https://tools.google.com/dlpage/gaoptout?hl=de) or Google’s settings for data use for marketing purposes(https://adssettings.google.com/).
Inquiries with MEETOVO
On our pages, the plugins of the provider MEETOVO, Lukas & Christof Bludau GbR, Kasernenstraße 12, 21073 Hamburg, Germany are integrated for online inquiries. We have concluded a contract for commissioned data processing with this provider, which complies with the legal requirements of Art. 28 DSGVO. Strictest confidentiality of your data is thus maintained at all times.
If you call up a function of our online offer that contains such a plugin, a direct connection is established between your browser and the provider’s server each time you call up the integrated plugin. The latter thereby receives the information that you have visited our site with your IP address. If you book an inquiry via the embedded form, the personal data you entered for the inquiry (e-mail address, first and last name, mobile phone number) will be transmitted to the provider and stored on its servers. All other form inputs are already transmitted as they are entered. The collection of this data is necessary for the execution of the request. Without this processing, you will not be able to make any requests.
This processing is carried out according to. Art. 6 par. 1 lit b. DSGVO for the fulfillment of our contractual obligations and services as well as on the basis of our legitimate interests in the implementation of a fast and effective inquiry in the sense of Art. 6 para. 1 lit f. DSGVO.
The provider will delete your data if it is no longer required. The provider shall review the necessity every two years. For the rest, however, the deletion takes place no later than 5 years after the last request. For more information, please see the provider’s privacy policy at: https://meetovo.de/datenschutz
Data deletion
The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose).
Unless the data is deleted because it is required for other and legally permissible purposes, its processing will be limited to these purposes. I.e., the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural person or legal entity.
Further information on the deletion of personal data can also be found in the individual data protection notices of this data protection declaration.
Modification and update of the privacy policy
We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
Where we provide addresses and contact information for companies and organizations in this privacy statement, please note that the addresses may change over time and please check the information before contacting us.
Rights of the data subjects
As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
- Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6 para. 1 lit. e or f DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.
- Right to revoke consent:You have the right to revoke any consent you have given at any time.
- Right of access:You have the right to request confirmation as to whether or not data in question is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
- Right to rectification:In accordance with the law, you have the right to request that data concerning you be completed or that inaccurate data concerning you be rectified.
- Right to erasure and restriction of processing:You have the right, in accordance with the law, to request that data relating to you be erased immediately or, alternatively, to request restriction of the processing of the data in accordance with the law.
- Right to data portability:You have the right to receive data relating to you that you have provided to us in a structured, common and machine-readable format, or to request that it be transferred to another controller, in accordance with the law.
- Complaint to supervisory authority:You also have the right, in accordance with the law, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
Definitions
This section provides you with an overview of the terms used in this privacy statement. Many of the terms are taken from the law and defined especially in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended primarily to aid understanding. The terms are sorted alphabetically.
- Affiliate tracking:Affiliate tracking logs links that the linking websites use to direct users to websites with product or other offers. The operators of the respective linking websites may receive a commission if users follow these so-called affiliate links and subsequently take advantage of the offers (e.g. buy goods or use services). For this purpose, it is necessary for the providers to be able to track whether users who are interested in certain offers subsequently take advantage of the affiliate links. Therefore, for affiliate links to work, they need to be supplemented with certain values that become a part of the link or are otherwise stored, for example, in a cookie. The values include, in particular, the source website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user as well as tracking-specific values, such as, for example, ad media ID, partner ID and categorizations.
- IP masking:IP masking is a method of deleting the last octet, i.e., the last two numbers of an IP address, so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing procedures, especially in online marketing
- Personal data:“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Profiles with user-related information:The processing of “profiles with user-related information”, or “profiles” for short, includes any type of automated processing of personal data that consists of using such personal data to analyze, evaluate or to predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
- Controller:A “controller” is 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.
- Processing:“Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is wide-ranging and encompasses practically every handling of data, be it collection, evaluation, storage, transmission or deletion.