This privacy statement explains the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offering and the related websites, functions and content, as well as external online presence, such as our Social Media Profile. (collectively referred to as “online offer”). With regard to the terms used, such as “personal data” or their “processing”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
|Street No.:||Mendelsohnstrasse 27|
|Post code, City, Country:||10405, Berlin, Germany|
|Commercial Register/No.:||Charlottenburg Berlin, HRB 140432 B|
|Managing Director:||Raphael Thiel|
Types of processed data:
- - Inventory data (names, addresses).
- - Contact details (email, telephone numbers).
- - Content data (text input).
- - Contract data (subject matter, term, customer category).
- - Payment details (bank details, payment history, credit cards, Paypal).
- - Usage data (visited websites, interest in content, access times).
- - Meta/communication data (device information, IP addresses).
Processing of special categories of data (Article 9 (1) GDPR):
No special categories of data are processed.
Categories of data subjects:
- - Customers / stakeholders / suppliers.
- - Visitors and users of the online offer.
- - In the following, we also refer to the persons concerned as “users”.
Purpose of processing:
- - Providing the online offer, its contents and functions.
- - Provision of contractual services, service and customer care.
- - Answering contact requests and communicating with users.
- - Marketing, advertising and market research.
- - Safety measures.
1. Relevant legal bases
3. Safety measures
3.1. We take appropriate technical measures in accordance with Art. 32 GDPR, taking into account state-of-the-art technology, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different likelihoods and severities of the risk to the rights and freedoms of natural persons and organisational measures to ensure a level of protection appropriate to the risk; measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and separation. We have also set up procedures to ensure the enjoyment of data subject rights, data deletion and data vulnerability. Furthermore, we already consider the protection of personal data during the development, or selection of hardware, software and procedures, according to the principle of data protection by technology design and via privacy-friendly default settings taken into account (Article 25 GDPR).
3.2. One of the security measures is the encrypted transfer of data between your browser and our server.
4. Collaboration with processors and third parties
4.1. If, in the context of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit data to them, or otherwise grant access to the data, this will only be done on the basis of an issue of legal permission (e.g. if a transmission of the data to third parties is required by payment service providers pursuant to Art. 6 (1) (b) GDPR to fulfil the contract), on the basis of your consent, ion the basis of a legal obligation provides for this, or on the basis of our legitimate interests (e.g. the use of agents, webhosters, etc.).
4.2. If we commission third parties to process data on the basis of a so-called “order-processing contract”, this will be done on the basis of Art. 28 GDPR.
5. Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or in the context of the use of third party services, or disclosure or transmission of data to third parties, this will only be done if it is to fulfil our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation, or on the basis of our legitimate interests. Subject to legal or contractual permissions, we will process or have the data processed in a third country only subject to the special conditions of Art. 44 et seq. GDPR. This means, for example, that the processing takes place on the basis of special guarantees, such as the officially recognised level of data protection (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).
6. Rights of data subjects
6.1. 6.1. You have the right to ask for confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with Art. 15 GDPR.
6.2. In accordance with, Art. 16 GDPR, you have the right to demand the completion of the data concerning you or the correction of incorrect data concerning you.
6.3. In accordance with Art. 17 GDPR, you have the right to demand that the relevant data be deleted immediately or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 GDPR.
6.4. You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with Art. 20 GDPR and request its transmission to other persons responsible.
6.5. In accordance with Art. 77 GDPR you have the right to file a complaint with the competent supervisory authority.
7. Right to revocation
You have the right to revoke consent in accordance with. Art. 7 (3) GDPR with effect for the future.
8. Right to objection
You can object to the future processing of your data in accordance with Art. 21 GDPR at any time. The objection may in particular be made against processing for direct marketing purposes.
9. Cookies and the right to object to direct advertising
10. Deletion of data
10.2. According to legal requirements, the storage takes place, in particular, for 6 years in accordance with § 257 (1) German Commercial Code HGB (trading books, inventories, opening balance sheets, annual accounts, trade letters, accounting documents, etc.) and for 10 years in accordance with § 147 (1) German Regulation on Taxation AO (books, records, management reports , accounting documents, commercial and business letters, documents relevant to taxation, etc.).
11. Provision of contractual services
11.1. We process stock data (e.g. names and addresses, as well as user contact data), contract data (e.g. services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services in accordance with Art. 6 (1) lit b. GDPR. The entries marked as obligatory in online forms are required for the conclusion of the contract.
11.2. Users can optionally create a user account, in which they will be able to view their orders. As part of the registration, the necessary mandatory information will be communicated to the users. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, unless it is subject to retention for commercial or tax law reasons according to Art. 6 (1) lit. c GDPR. It is the responsibility of the users to secure their data upon termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract.
11.3. As part of the registration and new login as well as the use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user’s protection against misuse and other unauthorised use. This data is not transferred to third parties , unless it is necessary for the prosecution of our claims or there is a legal obligation in accordance with. Art. 6 (1) lit. c GDPR.
11.4. We process usage data (e.g. the web pages of our online offer visited, interest in our products) and content data (e.g. entries in the contact form or user profile) for advertising purposes in a user profile in order to show the user product references, for example, based on their previously used services.
11.5. The deletion takes place after the expiry of legal warranty and comparable obligations, the necessity of keeping the data is checked every three years; in the case of legal archiving obligations, the deletion takes place after its expiry (end of commercial law (6 years) and tax law (10 years) retention obligation); information remains in the customer account until its deletion.
12.1. When contacting us (via contact form or email), the information provided by the user to process the contact request and its development is processed as per Art. 6 (1) lit. b) GDPR.
12.2. User information can be stored in our Customer Relationship Management System (“CRM System”) or similar request organisation.
12.3. We use the CRM system “Ticket System”, an in-house development based on our legitimate interests (efficient and fast processing of user requests). We delete the requests if they are no longer required. We check the necessity for this every two years; we store inquiries from customers who have a customer account permanently and refer to the deletion on the details of the customer account. In the case of legal archiving obligations, the deletion takes place after its expiry (end of commercial law (6 years) and tax law (10 years) retention obligation).
13. Comments and posts
13.1. If users leave comments or other contributions, their IP addresses are stored for 7 days based on our legitimate interests within the meaning of Art. 6 (1) lit. f. GDPR.
13.2. This is for our own safety, lest someone should leave illegal content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.
14. Collection of access data and log files
14.1. Based on our legitimate interests within the meaning of Art. 6 (1) lit. f. GDPR, we collect data on every access to the server on which this service is located (so-called server log files). The access data includes the name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address, and the requesting provider,
14.2. Logfile information is stored for security reasons (e.g. to investigate abusive or fraudulent activities) for a maximum of seven days and then deleted. Data, the further retention of which is required for evidential purposes, shall be exempted from deletion until final clarification of the incident.
15. Online presence in social media
15.1. Based on our legitimate interests within the meaning of Art. 6 (1) lit. f. GDPR , we maintain online presence within social networks and platforms in order to communicate with the active customers, stakeholders, and users, and to inform them about our services. When calling the respective networks and platforms, the terms and conditions and the data processing guidelines of their respective operators apply.
16. Cookies & reach measurement
16.1. Cookies are information transmitted from our web server or third-party web servers to users’ web browsers and stored there for later retrieval. Cookies can be small files or other types of information storage.
16.2. We use “session cookies”, which are only stored for the duration of the current visit to our online presence (for example, to enable the storage of your login status or the shopping cart function, and thus the principle use of our online offer). In a session cookie, a randomly generated unique identification number is stored, a so-called session ID. In addition, a cookie contains information about its origin and the retention period. These cookies cannot save any other data. Session cookies are deleted once you have finished using our online offer and log out or close your browser.
16.4. If users do not want cookies stored on their computer they will be asked to disable the option in their browser’s system settings. Saved cookies can be deleted in the browser’s system settings. The exclusion of cookies can lead to functional restrictions of this online offer.
17. Google Analytics
17.2. Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation ( https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active ).
17.3. Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer, and to provide us with further services related to the use of this online offer and internet usage. In this case, pseudonymous usage profiles of the users can be created from the processed data.
17.4. We use Google Analytics to display advertisements displayed within Google and its affiliate advertising services; only those users who have shown an interest in our online offering or who have certain characteristics (for example, interests in specific topics or products determined by the web pages they have visited) that we submit to Google (so-called “remarketing” or “Google Analytics Audiences”). With Remarketing Audiences, we also want to make sure that our ads are in line with the potential interests of users and are not annoying.
17.5. We only use Google Analytics with activated IP anonymisation. This means that the IP address of the users will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.
17.6. The IP address submitted by the user’s browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; users may also prevent the collection by Google of the data generated by the cookie and related to their use of the online offer and the processing of such data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
17.7. For more information about data usage by Google, setting and opt-out options, visit Google’s websites: https://www.google.com/intl/en/policies/privacy/partners (“Google uses your data when you use websites or apps from our affiliates “), https://policies.google.com/technologies/ads (“Use of data for promotional purposes”), https://adssettings.google.com/authenticated (“Managing information that Google uses to show you advertising”).
17.8. Incidentally, the personal data will be anonymised or deleted after the expiry of 14 months
18. Google Re/marketing services
18.1. On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 (1) lit. GDPR) we use the marketing and remarketing services (“Google Marketing Services “) of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA, (“Google”).
18.2. Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation ( https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active ).
18.3. Google Marketing Services allows us to better target advertisements for and on our website so that we only present ads to users that potentially match their interests. For example, if a user sees advertisements for products he or she has been interested in on other websites, this is called “remarketing”. For these purposes, upon the direct call-up of our site and other websites by Google on which Google Marketing Services are active, a code will be executed by Google and so-called (re-)marketing tags (invisible graphics or code, also called “Web Beacons “) incorporated into the website. With their help, the user can store an individual cookie, i.e. a small file (instead of cookies, comparable technologies can also be used). The cookies can be set by different domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. In this file it is noted which web pages the user visited, the content the user is interested in, and the offers the user has clicked, as well as technical information about the browser and operating system, referring web pages, visit time, and other information on the use of the online offer. The IP address of the users is also recorded, whereby in the context of Google Analytics we inform you that the IP address is shortened within member states of the European Union or other parties to the Agreement on the European Economic Area, and only in exceptional cases is transmitted to a Google server in the US and shortened there. The IP address will not be merged with data of the user within other offers from Google. The above information may also be linked by Google with similar information from other sources. If the user then visits other websites, they can be displayed according to his/her interests, with the ads tailored accordingly.
18.4. The data of the users is pseudonym-processed in the context of the Google marketing services. For example, Google does not store and process users’ names or email addresses, but processes the relevant data in a cookie-related manner within pseudonymous user profiles. That is, from the perspective of Google, the ads are not managed and displayed to a specifically identified person, but to the cookie owner, regardless of who that cookie owner is. This does not apply if a user has explicitly allowed Google to process the data without this pseudonymisation. The information collected about users through Google Marketing Services is transmitted to Google and stored on Google’s servers in the United States.
18.5. Among the Google marketing services we use is the online advertising program “Google AdWords”. In the case of Google AdWords, each advertiser receives a different “conversion cookie”. Cookies can not be tracked through AdWords advertisers’ websites. The information collected through the cookie is used to generate conversion statistics for AdWords advertisers who have opted for conversion tracking. Advertisers will see the total number of users who clicked on their ad and were redirected to a conversion tracking tag page. However, they do not receive information that personally identifies users.
18.8. If you wish to opt-out of interest-based advertising through Google Marketing Services, you can take advantage of Google’s settings and opt-out options: https://adssettings.google.com/authenticated.
19.1. With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures related to it, and your right of objection. By subscribing to our newsletter, you agree to the receipt and the procedures described.
19.2. Content of the newsletter: We send newsletters, emails and other electronic notifications with advertising information (hereinafter “newsletter”) only with the consent of the recipient or an issue of legal permission. As far as sign-up to a newsletter with concretely described content is concerned,the consent of the users is authoritative. For that matter, our newsletters contain information about our products, offers, promotions and our company.
19.3. Double opt-in and logging: The registration for our newsletter takes place in a so-called double opt-in procedure. This means you will receive an email after logging in to ask for confirmation of your registration. This confirmation is necessary so that nobody can register with the email addresses of others. The registration for the newsletter will be logged in order to prove the registration process according to the legal requirements. This includes the storage of the login and the confirmation time, as well as the IP address. Likewise, changes to your data stored with the shipping service provider will be logged.
19.5. Furthermore, the shipping service provider may, according to its own information, use this data in a pseudonymous form, i.e. without assignment to a user, to optimise or improve its own services, for example, for the technical optimisation of shipping and the presentation of newsletters, or for statistical purposes in order to determine which countries the recipients come from. However, the shipping service provider does not use the data of our newsletter recipients to itself address them or to pass this data on to third parties.
19.6. Registration data: To subscribe to the newsletter, it is sufficient to enter your email address.
19.7. Success measurement - The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file which is called up by the server of the shipping service provider when the newsletter is opened. This call will initially collect technical information, such as information about the browser and your system, as well as your IP address and time of retrieval. This information is used to improve the technical performance of services based on their specifications or audience and their reading habits, based on their locations (which can be determined using the IP address) or access times. Statistical surveys also include determining if the newsletters are opened, when they are opened, and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our endeavour nor that of the shipping service provider to observe individual users. The evaluations serve us much more to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
19.8. The dispatch of the newsletter and the success measurement are made on the basis of consent from the recipients as per Art. 6 (1) lit. a, Art. 7 GDPR in conjunction with § 7 (2) No. 3 German Fair Trade Practices Act UWG, or on the basis of statutory permission pursuant to § 7 (3) UWG.
19.9. The logging of the registration process is based on our legitimate interests in accordance with. Art. 6 (1) lit. f GDPR and serves as proof of consent to the receipt of the newsletter.
19.10. Termination/Revocation - Newsletter recipients may terminate the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. At the same time, this will revoke their consent to success measurement. A separate revocation of the performance measurement is unfortunately not possible, in this case, the entire newsletter subscription must be terminated. Upon unsubscribing from the newsletter, the personal data will be deleted, unless its retention is legally required or justified, in which case its processing is limited only to these exceptional purposes. In particular, we may save the email addresses sent for up to three years based on our legitimate interests before deleting them for purposes of sending out the newsletter in order to provide evidence of prior consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that at the same time the former existence of a consent is confirmed.
20. Integration of services and content from third parties
20.1. Based on our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 (1) lit. GDPR), we make use of content or services offered by third-party providers in order to integrate their content and services such as videos or fonts (collectively referred to as “content”). This always presupposes that the third-party providers of this content detect the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavour to use only content whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to 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 include, but is not limited to, technical information about the browser and operating system, referring web sites, visit time, and other information regarding the use of our online offer.
20.2. The following presentation provides an overview of third-party providers as well as their contents, as well as links to their privacy statements, which contain further notes on the processing of data and, in some cases already mentioned here, objection options (so-called opt-out):
- - As already mentioned here, objection options (so-called opt-out): If our customers use the payment services of third parties (for example, PayPal or Sofortüberweisung), the terms and conditions and the privacy notices of the respective third party providers apply, these being available within the respective websites or transactional applications.
- - Third-party platform “YouTube” videos Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Data protection: https://policies.google.com/privacy , opt-out: https://adssettings.google.com/authenticated .
- - Our online offer includes features of the Google+ service. These features are offered through the third party Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. If you’re logged in to your Google+ account, you can link the contents of our pages to your Google+ profile by clicking the Google+ button. This allows Google to associate your visit to our pages with your user account. We point out that we as the provider of the pages are not aware of the content of the transmitted data and their use by Google+. Data protection: https://policies.google.com/privacy , opt-out: https://adssettings.google.com/authenticated.
- - Within our online offer use the marketing functions (so-called “LinkedIn Insight Tag”) of the LinkedIn network. The Provider is the LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, United States. Each time you visit one of our pages that contains LinkedIn features it will connect to LinkedIn servers. LinkedIn is informed that you have visited our website with your IP address. In particular, the LinkedIn Insight Tag allows us to analyse the success of our campaigns within LinkedIn, or to target audiences based on how users interact with our online offering. If you are registered with LinkedIn, LinkedIn will be able to associate your interaction with our online offering with your user account. Even if you click LinkedIn’s “Recommend Button” and are logged in to your LinkedIn account, LinkedIn will be able to associate your visit to our website with you and your user account. LinkedIn is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation ( https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active ). Data protection: https://www.linkedin.com/legal/privacy-policy , opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- - Within our online offer functions of the service, or, more so, the platform Twitter may be involved (hereinafter referred to as “Twitter”). Twitter is an offer from Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, United States. Features include displaying our posts on Twitter within our online offering, linking to our profile on Twitter, as well as the ability to interact with Twitter’s posts and features, and measuring whether users are using the ads we’ve posted on Twitter to access our online offer (so-called conversion measurement). Twitter is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation ( https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active ). Data protection: https://twitter.com/privacy, opt-out: https://twitter.com/personalization.