Privacy Policy

Privacy Policy for Signagenow.tv. Note regarding privacy information for our software signagenow.io.

Please note that separate privacy terms apply to our SignageNow software (https://app.signagenow.io). You can view them here.

Note: The payment terms listed here also apply to the plan change and payment options for our software signagenow.io.

Privacy Policy

We are very pleased that you are interested in our company. Data protection is a top priority for the management of fleiter media GmbH. In general, you can use the fleiter media GmbH website without providing any personal data. However, if a data subject wishes to use specific services offered by our company via our website, the processing of personal data may be necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data—such as a data subject’s name, address, email address, or phone number—is always carried out in accordance with the General Data Protection Regulation and in compliance with the country-specific data protection regulations applicable to fleiter media GmbH. Through this Privacy Policy, our company aims to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, this Privacy Policy informs data subjects of their rights.

As the data controller, fleiter media GmbH has implemented numerous technical and organizational measures to ensure the most comprehensive possible protection of the personal data processed via this website. Nevertheless, internet-based data transmissions may inherently contain security vulnerabilities, meaning that absolute protection cannot be guaranteed. For this reason, any data subject is free to provide personal data to us via alternative means, such as by telephone.

1. Definitions

The privacy policy of fleiter media GmbH is based on the terminology used by European legislators and regulators when enacting the General Data Protection Regulation (GDPR). Our privacy policy is intended to be easy to read and understand for the general public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.

In this Privacy Policy, we use the following terms, among others:

a)    Personal Data

Personal data refers to any information relating to an identified or identifiable natural person (hereinafter “data subject”). A natural person is considered identifiable if they can be identified, directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

b)    Data subject

A data subject is any identified or identifiable natural person whose personal data is processed by the controller.

c)    Processing

Processing means any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or any other form of making available; alignment or combination; restriction; erasure; or destruction.

d)    Restriction of processing

Restriction of processing means the marking of stored personal data with the aim of limiting their future processing.

e)    Profiling

Profiling is any form of automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

f)     Pseudonymization

Pseudonymization is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures that ensure the personal data is not attributed to an identified or identifiable natural person.

g)    Controller

A controller is the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h)    Processor

A processor is a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.

i)      Recipient

A recipient is a natural or legal person, public authority, agency, or other body to whom personal data is disclosed, regardless of whether or not that entity is a third party. However, public authorities that may receive personal data in the course of a specific investigative mandate under Union law or the law of the Member States are not considered recipients.

j)      Third Party

A third party is a natural or legal person, public authority, agency, or other body other than the data subject, the controller, the processor, and the persons who, under the direct authority of the controller or the processor, are authorized to process the personal data.

k)    Consent

Consent means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and address of the data controller

The data controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union, and other provisions relating to data protection is:

fleiter media GmbH

Dieselstraße 23

59329 Wadersloh

Germany

Tel.: 0252392270

Email: digital@fleiter-media.de

Website: https://www.signagenow.tv
 

3. Cookies

The websites of fleiter media GmbH use cookies. Cookies are text files that are placed and stored on a computer system via a web browser.

Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier for the cookie. It consists of a string of characters that allows websites and servers to associate the specific web browser in which the cookie was stored. This enables the visited websites and servers to distinguish the individual browser of the data subject from other web browsers that contain different cookies. A specific web browser can be recognized and identified via the unique cookie ID.

By using cookies, fleiter media GmbH can provide users of this website with more user-friendly services that would not be possible without the use of cookies.

Cookies allow us to optimize the information and content on our website to better serve our users. As mentioned earlier, cookies enable us to recognize users of our website. The purpose of this recognition is to make it easier for users to navigate our website. For example, a user of a website that uses cookies does not have to re-enter their login credentials every time they visit the website, as this information is retrieved by the website and the cookie stored on the user’s computer system. Another example is the shopping cart cookie in an online store. The online store uses a cookie to remember the items a customer has placed in the virtual shopping cart.

The data subject can prevent the setting of cookies by our website at any time by adjusting the settings of the web browser being used, thereby permanently objecting to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via a web browser or other software programs. This is possible in all common web browsers. If the data subject disables the setting of cookies in the web browser they are using, not all functions of our website may be fully usable under certain circumstances.

4. Collection of General Data and Information

The fleiter media GmbH website collects a range of general data and information each time a data subject or an automated system accesses the website. This general data and information is stored in the server’s log files. The following may be collected: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the subpages accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet Protocol (IP) address, (7) the Internet service provider of the accessing system, and (8) other similar data and information that serve to prevent threats in the event of attacks on our information technology systems.

When using this general data and information, fleiter media GmbH does not draw any conclusions about the data subject. Rather, this information is required to (1) correctly deliver the content of our website, (2) optimize the content of our website and the advertising on it, (3) ensure the continued functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyberattack. This anonymously collected data and information is therefore evaluated by fleiter media GmbH both statistically and with the aim of enhancing data protection and data security within our company, ultimately to ensure an optimal level of protection for the personal data we process. The anonymous data from the server log files is stored separately from any personal data provided by a data subject.

5. Registration on Our Website

The data subject has the option to register on the data controller’s website by providing personal data. The specific personal data transmitted to the data controller in this process is determined by the respective input form used for registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the controller and for the controller’s own purposes. The controller may arrange for the transfer of such data to one or more processors, such as a parcel delivery service, which will also use the personal data exclusively for internal purposes attributable to the controller.

When a user registers on the data controller’s website, the IP address assigned by the user’s Internet service provider (ISP), as well as the date and time of registration, are also stored. This data is stored because it is the only way to prevent misuse of our services, and, if necessary, this data enables us to investigate criminal offenses that have been committed. In this respect, the storage of this data is necessary to protect the data controller. This data is generally not disclosed to third parties unless there is a legal obligation to do so or the disclosure serves the purpose of criminal prosecution.

The registration of the data subject, involving the voluntary provision of personal data, enables the data controller to offer the data subject content or services that, by their very nature, can only be provided to registered users. Registered users are free to modify the personal data provided during registration at any time or to have it completely deleted from the data controller’s database.

The data controller will, upon request, provide any data subject with information at any time regarding which personal data has been stored about them. Furthermore, the data controller will correct or delete personal data at the request or upon notification by the data subject, provided that no legal retention obligations prevent this. All employees of the data controller are available to the data subject as points of contact in this regard.

6. Subscription to Our Newsletter

On the fleiter media GmbH website, users are given the opportunity to subscribe to our company’s newsletter. The personal data transmitted to the data controller when subscribing to the newsletter is determined by the input form used for this purpose.

fleiter media GmbH informs its customers and business partners at regular intervals via a newsletter about the company’s offers. The data subject can generally only receive our company’s newsletter if (1) the data subject has a valid email address and (2) the data subject registers to receive the newsletter. For legal reasons, a confirmation email is sent to the email address initially provided by a data subject for the newsletter via a double opt-in procedure. This confirmation email serves to verify whether the owner of the email address, as the data subject, has authorized the receipt of the newsletter.

When you subscribe to the newsletter, we also store the IP address assigned by the Internet service provider (ISP) to the computer system used by the data subject at the time of registration, as well as the date and time of registration. The collection of this data is necessary to be able to trace any (potential) misuse of a data subject’s email address at a later date and therefore serves to provide legal protection for the data controller.

The personal data collected when subscribing to the newsletter is used exclusively for sending our newsletter. Furthermore, newsletter subscribers may be notified by email if this is necessary for the operation of the newsletter service or for related registration purposes, such as in the event of changes to the newsletter content or technical modifications. Personal data collected as part of the newsletter service is not disclosed to third parties. The data subject may cancel their subscription to our newsletter at any time. Consent to the storage of personal data that the data subject has provided to us for the purpose of sending the newsletter may be revoked at any time. A link for revoking consent is included in every newsletter. Furthermore, it is possible to unsubscribe from the newsletter at any time directly on the website of the data controller or to notify the data controller of this in another manner.

7. Newsletter Tracking

The newsletters sent by fleiter media GmbH contain so-called web beacons. A web beacon is a tiny graphic embedded in emails sent in HTML format to enable log file recording and analysis. This allows for a statistical evaluation of the success or failure of online marketing campaigns. Using the embedded web beacon, fleiter media GmbH can determine whether and when an email was opened by a data subject and which links contained in the email were clicked by the data subject.

Such personal data collected via the tracking pixels contained in the newsletters is stored and analyzed by the data controller to optimize newsletter distribution and to tailor the content of future newsletters even better to the data subject’s interests. This personal data is not disclosed to third parties. Data subjects are entitled at any time to revoke the separate declaration of consent provided via the double opt-in procedure. Following revocation, this personal data will be deleted by the data controller. Unsubscribing from the newsletter is automatically interpreted by fleiter media GmbH as a revocation.

8. Contacting Us via the Website

In accordance with legal requirements, the fleiter media GmbH website contains information that enables users to quickly contact our company electronically and communicate directly with us, including a general email address. If a data subject contacts the data controller via email or a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data, transmitted voluntarily by a data subject to the data controller, is stored for the purpose of processing the request or contacting the data subject. This personal data is not disclosed to third parties.

9. Routine Deletion and Blocking of Personal Data

The data controller processes and stores the data subject’s personal data only for the period necessary to achieve the purpose of storage, or to the extent provided for by the European legislative and regulatory authorities or another competent authority in laws or regulations to which the data controller is subject.

If the purpose of storage no longer applies or if a retention period prescribed by the European legislator or another competent legislator expires, the personal data is routinely blocked or deleted in accordance with legal requirements.

10. Rights of the Data Subject

a)    Right to Confirmation

Every data subject has the right, granted by the European legislator, to request confirmation from the controller as to whether personal data concerning them is being processed. If a data subject wishes to exercise this right to confirmation, they may contact a representative of the controller at any time.

b)    Right of access

Every data subject affected by the processing of personal data has the right, granted by the European legislator, to obtain from the controller, at any time and free of charge, information regarding the personal data stored about them and a copy of such information. Furthermore, the European legislator has granted the data subject the right to obtain the following information:

• the purposes of the processing
• the categories of personal data being processed
• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations
• if possible, the planned duration for which the personal data will be stored, or, if this is not possible, the criteria for determining this duration
• the existence of a right to rectification or erasure of the personal data concerning them, or to restriction of processing by the controller, or a right to object to such processing
• the existence of a right to lodge a complaint with a supervisory authority
• if the personal data are not collected from the data subject: any available information as to their source
• the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and—at least in those cases—meaningful information about the logic involved, as well as the significance and the intended consequences of such processing for the data subject

• Furthermore, the data subject has the right to be informed whether personal data has been transferred to a third country or to an international organization. If this is the case, the data subject also has the right to be informed of the appropriate safeguards relating to the transfer.

  If a data subject wishes to exercise this right of access, they may contact a representative of the data controller at any time.

c)    Right to Rectification

Every data subject affected by the processing of personal data has the right, granted by European legislation, to request the immediate rectification of inaccurate personal data concerning them. Furthermore, the data subject has the right to request the completion of incomplete personal data—including by means of a supplementary statement—taking into account the purposes of the processing.

If a data subject wishes to exercise this right to rectification, they may contact an employee of the controller at any time.

d)    Right to erasure (right to be forgotten)

Any data subject affected by the processing of personal data has the right, granted by European legislation, to request that the controller erase personal data concerning them without undue delay, provided that one of the following grounds applies and provided that the processing is not necessary:

• The personal data was collected or otherwise processed for purposes for which it is no longer necessary.
• The data subject withdraws their consent on which the processing was based pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR, and there is no other legal basis for the processing.
• The data subject objects to the processing pursuant to Article 21(1) of the GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
• The personal data has been processed unlawfully.
• The erasure of the personal data is necessary for compliance with a legal obligation under Union law or the law of the Member States to which the controller is subject.
• The personal data was collected in relation to information society services offered pursuant to Article 8(1) of the GDPR.

If any of the above reasons apply and a data subject wishes to request the erasure of personal data stored by fleiter media GmbH, they may contact a representative of the data controller at any time. The representative of fleiter media GmbH will ensure that the request for erasure is complied with without delay.

If the personal data has been made public by fleiter media GmbH and our company, as the controller pursuant to Art. 17(1) of the GDPR, is obligated to delete the personal data, fleiter media GmbH shall take appropriate measures, including technical measures, taking into account available technology and implementation costs, to inform other controllers processing the published personal data that the data subject has requested that these other data controllers delete all links to such personal data or copies or replicas of such personal data, insofar as the processing is not necessary. The fleiter media GmbH employee will take the necessary steps on a case-by-case basis.

e)    Right to restriction of processing

Any data subject whose personal data is being processed has the right, granted by European legislation, to request that the controller restrict processing if any of the following conditions apply:

• The data subject disputes the accuracy of the personal data, for a period enabling the controller to verify the accuracy of the personal data.
• The processing is unlawful, the data subject opposes the erasure of the personal data and requests instead the restriction of the use of the personal data.
• The controller no longer needs the personal data for the purposes of the processing, but the data subject needs it to establish, exercise, or defend legal claims.
• The data subject has objected to the processing pursuant to Article 21(1) of the GDPR, and it has not yet been determined whether the legitimate grounds of the controller override those of the data subject.

If any of the above conditions are met and a data subject wishes to request the restriction of personal data stored by fleiter media GmbH, they may contact a representative of the data controller at any time. The fleiter media GmbH representative will arrange for the processing to be restricted.

f)     Right to data portability

Every data subject whose personal data is being processed has the right, as granted by European legislation, to receive the personal data concerning them—which they have provided to a controller—in a structured, commonly used, and machine-readable format. They also have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, provided that the processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) of the GDPR or on a contract pursuant to Article 6(1)(b) of the GDPR, and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, when exercising their right to data portability pursuant to Article 20(1) of the GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another controller, provided that this is technically feasible and does not adversely affect the rights and freedoms of others.

To exercise the right to data portability, the data subject may contact a fleiter media GmbH representative at any time.

g)    Right to Object

Any data subject affected by the processing of personal data has the right, granted by European legislation, to object at any time, on grounds relating to their particular situation, to the processing of personal data concerning them that is carried out on the basis of Article 6(1)(e) or (f) of the GDPR. This also applies to profiling based on these provisions.

In the event of an objection, fleiter media GmbH will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject, or the processing is necessary for the establishment, exercise, or defense of legal claims.

If fleiter media GmbH processes personal data for the purpose of direct marketing, the data subject has the right to object at any time to the processing of personal data for the purpose of such marketing. This also applies to profiling insofar as it is related to such direct marketing. If the data subject objects to fleiter media GmbH regarding processing for direct marketing purposes, fleiter media GmbH will no longer process the personal data for these purposes.

In addition, the data subject has the right to object, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her that is carried out by fleiter media GmbH for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) of the GDPR, unless such processing is necessary for the performance of a task carried out in the public interest.

To exercise the right to object, the data subject may contact any employee of fleiter media GmbH or another employee directly. The data subject is also free, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise their right to object by means of automated procedures using technical specifications.

(h)    Automated individual decision-making, including profiling

• Every data subject whose personal data is being processed has the right, granted by the European legislator, not to be subject to a decision based solely on automated processing—including profiling—that produces legal effects concerning the data subject or similarly significantly affects the data subject, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is authorized by Union or Member State law to which the controller is subject, and that law provides for appropriate measures to safeguard the rights and freedoms and legitimate interests of the data subject, or (3) is based on the data subject’s explicit consent.
• If the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is it made with the data subject’s explicit consent, fleiter media GmbH shall take appropriate measures to safeguard the data subject’s rights and freedoms as well as their legitimate interests, including at least the right to obtain human intervention on the part of the controller, to present their own point of view, and to contest the decision.
• If the data subject wishes to exercise rights relating to automated decisions, they may contact an employee of the controller at any time.

i)    Right to Withdraw Consent Under Data Protection Law

Every data subject affected by the processing of personal data has the right, granted by European legislation, to withdraw their consent to the processing of personal data at any time.

If the data subject wishes to exercise their right to withdraw consent, they may contact a representative of the data controller at any time.

11. Data Protection in Connection with Job Applications and the Application Process

The data controller collects and processes the personal data of applicants for the purpose of conducting the application process. This processing may also be carried out electronically. This is particularly the case when an applicant submits the relevant application documents to the data controller electronically, for example via email or through a web form on the website. If the data controller enters into an employment contract with an applicant, the submitted data will be stored for the purpose of managing the employment relationship in compliance with legal requirements. If the data controller does not conclude an employment contract with the applicant, the application documents will be automatically deleted two months after notification of the rejection decision, provided that no other legitimate interests of the data controller preclude such deletion. Other legitimate interests in this context include, for example, a duty to provide evidence in proceedings under the General Equal Treatment Act (AGG).

12. Privacy Policy Regarding the Use of Google AdSense

The data controller has integrated Google AdSense into this website. Google AdSense is an online service that facilitates the placement of advertisements on third-party websites. Google AdSense is based on an algorithm that selects advertisements displayed on third-party websites to match the content of those sites. Google AdSense allows for interest-based targeting of internet users, which is implemented by generating individual user profiles.

The operator of the Google AdSense component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The purpose of the Google AdSense component is to display advertisements on our website. Google AdSense places a cookie on the data subject’s computer system. What cookies are has already been explained above. By placing this cookie, Alphabet Inc. is able to analyze the use of our website. Each time a user visits one of the individual pages of this website—which is operated by the data controller and on which a Google AdSense component has been integrated—the web browser on the data subject’s computer is automatically prompted by the respective Google AdSense component to transmit data to Alphabet Inc. for the purposes of online advertising and commission billing. As part of this technical process, Alphabet Inc. obtains personal data, such as the data subject’s IP address, which Alphabet Inc. uses, among other things, to track the origin of visitors and clicks and, consequently, to enable commission billing.

As described above, the data subject may prevent our website from setting cookies at any time by adjusting the settings of the web browser being used, thereby permanently objecting to the setting of cookies. Such a setting in the web browser would also prevent Alphabet Inc. from setting a cookie on the data subject’s computer system. In addition, a cookie already set by Alphabet Inc. can be deleted at any time via the web browser or other software programs.

Google AdSense also uses so-called web beacons. A web beacon is a miniature graphic embedded in web pages to enable log file recording and log file analysis, thereby allowing for statistical evaluation. Using the embedded web beacon, Alphabet Inc. can determine whether and when a website was opened by a data subject and which links were clicked by the data subject. Web beacons are used, among other things, to evaluate the visitor traffic of a website.

Through Google AdSense, personal data and information—including IP addresses—that is necessary for tracking and billing the displayed advertisements is transferred to Alphabet Inc. in the United States of America. This personal data is stored and processed in the United States of America. Alphabet Inc. may share this personal data, collected through technical processes, with third parties.

Google AdSense is explained in more detail at this link: https://www.google.de/intl/de/adsense/start/.

13. Privacy Policy Regarding the Use of Google Analytics (with Anonymization Function)

The data controller has integrated the Google Analytics component (with anonymization function) into this website. Google Analytics is a web analytics service. Web analytics refers to the collection, gathering, and analysis of data regarding the behavior of website visitors. A web analytics service collects, among other things, data on which website a data subject came from to a website (so-called referrer), which subpages of the website were accessed, or how often and for how long a subpage was viewed. Web analytics is primarily used to optimize a website and for cost-benefit analysis of online advertising.

The operator of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The data controller uses the parameter “_gat._anonymizeIp” for web analytics via Google Analytics. This parameter causes Google to truncate and anonymize the IP address of the data subject's internet connection when accessing our website from a member state of the European Union or from another signatory state to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze visitor traffic on our website. Google uses the data and information collected, among other things, to evaluate the use of our website, to compile online reports for us that illustrate activity on our website, and to provide other services related to the use of our website.

Google Analytics places a cookie on the data subject’s computer system. What cookies are has already been explained above. By placing this cookie, Google is able to analyze the use of our website. Each time a user visits one of the individual pages of this website—which is operated by the data controller and on which a Google Analytics component has been integrated—the web browser on the data subject’s computer is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical process, Google obtains personal data, such as the data subject’s IP address, which Google uses, among other things, to track the origin of visitors and clicks and, consequently, to enable commission settlements.

Cookies are used to store personal information, such as the time of access, the location from which access originated, and the frequency of visits to our website by the data subject. Each time our website is visited, this personal data—including the IP address of the internet connection used by the data subject—is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may, under certain circumstances, disclose this personal data collected through technical means to third parties.

As described above, the data subject may prevent our website from setting cookies at any time by adjusting the settings of the web browser being used, thereby permanently objecting to the setting of cookies. Such a setting in the web browser would also prevent Google from setting a cookie on the data subject’s computer system. In addition, a cookie already set by Google Analytics can be deleted at any time via the web browser or other software programs.

Furthermore, the data subject has the option to object to the collection of data generated by Google Analytics regarding the use of this website, as well as to the processing of such data by Google, and to prevent such collection and processing. To do so, the data subject must download and install a browser add-on from the link https://tools.google.com/dlpage/gaoptout. This browser add-on uses JavaScript to inform Google Analytics that no data or information regarding website visits may be transmitted to Google Analytics. Google interprets the installation of the browser add-on as an objection. If the data subject’s information technology system is deleted, formatted, or reinstalled at a later date, the data subject must reinstall the browser add-on to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person within their control, it is possible to reinstall or reactivate the browser add-on.

Further information and Google’s current privacy policy can be found at https://www.google.de/intl/de/policies/privacy/ and http://www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail at this link: https://www.google.com/intl/de_de/analytics/.

14. Privacy Policy Regarding the Use of Google Remarketing

The data controller has integrated Google Remarketing services into this website. Google Remarketing is a feature of Google AdWords that enables a company to display advertisements to Internet users who have previously visited the company’s website. The integration of Google Remarketing therefore allows a company to create user-specific advertisements and consequently display ads relevant to the user’s interests.

The operator of Google Remarketing services is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The purpose of Google Remarketing is to display ads tailored to users’ interests. Google Remarketing enables us to display ads through the Google Display Network or on other websites that are tailored to the individual needs and interests of internet users.

Google Remarketing places a cookie on the data subject’s computer system. What cookies are has already been explained above. By placing the cookie, Google is able to recognize visitors to our website when they subsequently visit websites that are also part of the Google advertising network. Each time a website on which the Google Remarketing service has been integrated is accessed, the data subject’s web browser automatically identifies itself to Google. As part of this technical process, Google obtains personal data, such as the user’s IP address or browsing behavior, which Google uses, among other things, to display interest-based advertising.

Cookies are used to store personal information, such as the web pages visited by the data subject. Consequently, each time our website is visited, personal data—including the IP address of the internet connection used by the data subject—is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may share this personal data, collected through technical means, with third parties.

As described above, the data subject can prevent our website from setting cookies at any time by adjusting the settings of the web browser being used, thereby permanently objecting to the setting of cookies. Such a setting in the Internet browser used would also prevent Google from setting a cookie on the data subject’s information technology system. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.

In addition, the data subject has the option to opt out of Google’s interest-based advertising. To do so, the data subject must visit the link www.google.de/settings/ads from each of the web browsers they use and configure the desired settings there.

Further information and Google’s applicable privacy policy can be found at https://www.google.de/intl/de/policies/privacy/.

15. Privacy Policy Regarding the Use of LinkedIn

The data controller has integrated components from LinkedIn Corporation into this website. LinkedIn is an internet-based social network that enables users to connect with existing business contacts and establish new ones. Over 400 million registered users access LinkedIn in more than 200 countries. This makes LinkedIn currently the largest platform for business contacts and one of the most visited websites in the world.

The operator of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible for data protection matters outside the United States.

Each time our website, which includes a LinkedIn component (LinkedIn plug-in), is accessed, this component causes the browser used by the data subject to download a corresponding display of the LinkedIn component. Further information about LinkedIn plug-ins is available at https://developer.linkedin.com/plugins. As part of this technical process, LinkedIn learns which specific subpage of our website the data subject is visiting.

If the data subject is logged into LinkedIn at the same time, LinkedIn recognizes which specific subpage of our website the data subject is visiting each time the data subject visits our website and for the entire duration of their visit to our website. This information is collected by the LinkedIn component and assigned by LinkedIn to the data subject’s respective LinkedIn account. If the data subject clicks a LinkedIn button integrated into our website, LinkedIn assigns this information to the data subject’s personal LinkedIn user account and stores this personal data.

LinkedIn receives information via the LinkedIn component whenever the data subject visits our website, provided that the data subject is logged into LinkedIn at the time of accessing our website; this occurs regardless of whether the data subject clicks on the LinkedIn component or not. If the data subject does not wish for this information to be transmitted to LinkedIn, they can prevent the transmission by logging out of their LinkedIn account before visiting our website.

LinkedIn offers the option at https://www.linkedin.com/psettings/guest-controls to unsubscribe from email messages, SMS messages, and targeted ads, as well as to manage ad settings. LinkedIn also uses partners such as Quantcast, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua, and Lotame, which may set cookies. Such cookies can be rejected at https://www.linkedin.com/legal/cookie-policy. LinkedIn’s current privacy policy is available at https://www.linkedin.com/legal/privacy-policy. LinkedIn’s cookie policy is available at https://www.linkedin.com/legal/cookie-policy.

16. Privacy Policy Regarding the Use of Matomo

The data controller has integrated the Matomo component into this website. Matomo is an open-source web analytics tool. Web analytics refers to the collection, gathering, and analysis of data regarding the behavior of website visitors. A web analytics tool collects, among other things, data on which website a data subject came from to a website (so-called referrer), which subpages of the website were accessed, or how often and for how long a subpage was viewed. Web analytics is primarily used to optimize a website and for cost-benefit analysis of online advertising.

The software is operated on the controller’s server; the log files, which are sensitive under data protection law, are stored exclusively on this server.

The purpose of the Matomo component is to analyze visitor traffic on our website. The data controller uses the data and information collected, among other things, to evaluate the use of this website and to compile online reports that illustrate activity on our website.

Matomo places a cookie on the data subject’s computer system. What cookies are has already been explained above. Placing the cookie enables us to analyze the use of our website. Each time a page on this website is accessed, the Matomo component automatically prompts the web browser on the data subject’s computer system to transmit data to our server for the purpose of online analysis. As part of this technical process, we receive personal data, such as the data subject’s IP address, which we use, among other things, to track the origin of visitors and clicks.

Cookies are used to store personal information, such as the time of access, the location from which access originated, and the frequency of visits to our website. Each time you visit our website, this personal data—including the IP address of the internet connection used by the data subject—is transmitted to our server. We store this personal data. We do not disclose this personal data to third parties.

The data subject may prevent the setting of cookies by our website, as described above, at any time by adjusting the settings of the web browser used, thereby permanently objecting to the setting of cookies. Such a setting in the web browser would also prevent Matomo from setting a cookie on the data subject’s information technology system. In addition, a cookie already set by Matomo can be deleted at any time via a web browser or other software programs.

Furthermore, the data subject has the option to object to and prevent the collection of data generated by Matomo relating to the use of this website. To do so, the data subject must set “Do Not Track” in their browser.

However, setting the opt-out cookie may result in the data subject being unable to fully use the data controller’s website.

Further information and Matomo’s applicable privacy policy can be found at https://matomo.org/privacy/.

17. Payment Method: Privacy Policy for Klarna as a Payment Method

The data controller has integrated Klarna components into this website. Klarna is an online payment service provider that enables purchases on account or flexible installment payments. Klarna also offers additional services, such as buyer protection and identity and credit checks.

The operator of Klarna is Klarna Bank AB, Sveavägen 46, 111 34 Stockholm, Sweden.

If the data subject selects either “Purchase on account” or “Installment purchase” as a payment option during the ordering process in our online store, the data subject’s data is automatically transmitted to Klarna. By selecting one of these payment options, the data subject consents to the transfer of personal data required to process the purchase on account or installment purchase, or for identity and credit checks. 

The personal data transmitted to Klarna generally includes first name, last name, address, date of birth, gender, email address, IP address, telephone number, mobile phone number, and other data necessary to process an invoice or installment purchase. Personal data related to the specific order is also necessary for the fulfillment of the purchase agreement. In particular, this may involve the mutual exchange of payment information, such as bank account details, card number, expiration date, and CVC code, as well as the number of items, item numbers, details regarding goods and services, prices and taxes, information on past purchasing behavior, or other details regarding the data subject’s financial situation.

The transmission of data is intended, in particular, for identity verification, payment administration, and fraud prevention. The data controller will transfer personal data to Klarna, in particular, when there is a legitimate interest in the transfer. The personal data exchanged between Klarna and the data controller is transferred by Klarna to credit bureaus. This transfer is intended for identity and creditworthiness verification.

Klarna also discloses personal data to affiliated companies (the Klarna Group) and service providers or subcontractors to the extent necessary to fulfill contractual obligations or where the data is to be processed on their behalf.

To decide on the establishment, performance, or termination of a contractual relationship, Klarna collects and uses data and information regarding the data subject’s past payment behavior as well as probability values for their future behavior (so-called scoring). The scoring calculation is performed based on scientifically recognized mathematical and statistical methods. 

The data subject has the right to withdraw their consent to the processing of personal data at any time by notifying Klarna. Such a withdrawal does not affect personal data that must be processed, used, or transferred for the purpose of (contractual) payment processing.

Klarna’s current privacy policy is available at https://cdn.klarna.com/1.0/shared/content/policy/data/de_de/data_protection.pdf.

18. Payment Method: Privacy Policy Regarding PayPal as a Payment Method

The data controller has integrated PayPal components into this website. PayPal is an online payment service provider. Payments are processed through so-called PayPal accounts, which are virtual personal or business accounts. PayPal also allows users to make virtual payments via credit card if they do not have a PayPal account. A PayPal account is managed via an email address, which is why there is no traditional account number. PayPal enables users to initiate online payments to third parties or to receive payments. PayPal also acts as a trustee and offers buyer protection services.

The European operating company of PayPal is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal L-2449, Luxembourg.

If the data subject selects “PayPal” as the payment method during the ordering process in our online store, the data subject’s information is automatically transmitted to PayPal. By selecting this payment option, the data subject consents to the transmission of personal data necessary for payment processing.

The personal data transmitted to PayPal generally includes first name, last name, address, email address, IP address, telephone number, mobile phone number, or other data necessary for payment processing. Personal data related to the respective order is also necessary for the fulfillment of the purchase contract.

The purpose of the data transfer is payment processing and fraud prevention. The data controller will transfer personal data to PayPal in particular when there is a legitimate interest in the transfer. The personal data exchanged between PayPal and the data controller may be transferred by PayPal to credit bureaus. The purpose of this transfer is identity and creditworthiness verification.

PayPal may disclose personal data to affiliated companies, service providers, or subcontractors to the extent necessary to fulfill contractual obligations or where the data is to be processed on its behalf.

The data subject has the right to withdraw consent for the processing of personal data at any time by notifying PayPal. Such a revocation does not affect personal data that must be processed, used, or transmitted for the mandatory (contractual) processing of payments.

PayPal’s current privacy policy can be accessed at https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

19. Payment Method: Privacy Policy for Sofortüberweisung as a Payment Method

The data controller has integrated components of Sofortüberweisung into this website. Sofortüberweisung is a payment service that enables cashless payment for products and services on the Internet. Sofortüberweisung implements a technical process through which the online merchant immediately receives a payment confirmation. This enables a merchant to deliver goods, services, or downloads to the customer immediately after the order is placed.

The operator of Sofortüberweisung is Klarna Bank AB, Sveavägen 46, 111 34 Stockholm, Sweden.

If the data subject selects “Sofortüberweisung” as the payment method during the ordering process in our online store, the data subject’s data is automatically transmitted to Sofortüberweisung. By selecting this payment option, the data subject consents to the transmission of personal data necessary for payment processing.

When completing a purchase via Sofortüberweisung, the buyer provides their PIN and TAN to Sofort GmbH. After verifying the account balance and retrieving additional data to confirm sufficient funds, Sofortüberweisung then executes a transfer to the online merchant. The online merchant is then automatically notified that the financial transaction has been completed.

The personal data exchanged with Sofortüberweisung includes first name, last name, address, email address, IP address, telephone number, mobile phone number, or other data necessary for payment processing. The purpose of transmitting this data is to process payments and prevent fraud. The data controller will also transfer other personal data to Sofortüberweisung if there is a legitimate interest in doing so. The personal data exchanged between Sofortüberweisung and the data controller may be transferred by Sofortüberweisung to credit bureaus. This transfer is intended for identity and creditworthiness verification.

Sofortüberweisung may disclose personal data to affiliated companies, service providers, or subcontractors to the extent necessary to fulfill contractual obligations or where the data is to be processed on their behalf.

The data subject has the right to withdraw their consent to the processing of personal data at any time by notifying Sofortüberweisung. Such a withdrawal does not affect personal data that must be processed, used, or transmitted for the purpose of (contractual) payment processing.

Sofortüberweisung’s current privacy policy is available at https://www.klarna.com/sofort/datenschutz/.

20. Legal Basis for Processing

Article 6(1)(a) of the GDPR serves as the legal basis for our company’s processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party—as is the case, for example, with processing operations required for the delivery of goods or the provision of other services or consideration—the processing is based on Article 6(1)(b) of the GDPR. The same applies to processing operations necessary for the implementation of pre-contractual measures, such as in cases of inquiries regarding our products or services. If our company is subject to a legal obligation that requires the processing of personal data, such as to fulfill tax obligations, the processing is based on Article 6(1)(c) of the GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were to be injured on our premises and their name, age, health insurance information, or other vital information subsequently had to be disclosed to a doctor, a hospital, or other third parties. In such a case, the processing would be based on Article 6(1)(d) of the GDPR. Finally, processing operations may be based on Article 6(1)(f) of the GDPR. This legal basis applies to processing operations not covered by any of the aforementioned legal bases, provided that the processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights, and fundamental freedoms of the data subject do not take precedence. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this regard, the legislator took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47, Sentence 2 of the GDPR).

21. Legitimate interests in processing pursued by the controller or a third party

If the processing of personal data is based on Article 6(1)(f) of the GDPR, our legitimate interest is the conduct of our business activities for the benefit of all our employees and shareholders.

22. Period for which personal data is stored

The criterion for the duration of storage of personal data is the applicable statutory retention period. Upon expiration of this period, the relevant data is routinely deleted, provided it is no longer required for the performance of a contract or for entering into a contract.

23. Legal or contractual requirements regarding the provision of personal data; necessity for the conclusion of the contract; the data subject’s obligation to provide personal data; possible consequences of failure to provide such data

We would like to inform you that the provision of personal data is in some cases required by law (e.g., tax regulations) or may also arise from contractual provisions (e.g., information about the contracting party). In some cases, it may be necessary for a data subject to provide us with personal data in order to conclude a contract, which we must then process. For example, the data subject is obligated to provide us with personal data when our company enters into a contract with them. Failure to provide the personal data would result in the contract with the data subject not being able to be concluded. Before providing personal data, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of personal data is required by law or contract, or is necessary for the conclusion of the contract; whether there is an obligation to provide the personal data; and what consequences failure to provide the personal data would have.

24. Use of Automated Decision-Making

As a responsible company, we do not use automated decision-making or profiling.

Developed by the LegalTech specialists at Willing & Able, who also developed the system for GDPR processing activity registers. The texts of the Privacy Policy Generator were created and published by Prof. Dr. h.c. Heiko Jonny Maniero and attorney Christian Solmecke.