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Privacy Policy

Privacy Policy

Introduction

With the following privacy policy, 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 privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offering”).

The terms used are not gender-specific.

Last updated: February 2025

Table of Contents

Controller

JKB – The Sailing Academy GmbH
Wasserfallweg 5
9520 Sattendorf
+43(0)676 8986 28304
office@in2theblue.com
www.in2theblue.com

Commercial Register Court: Klagenfurt Regional and Commercial Court
Commercial Register Number: FN 497218 d
VAT ID: ATU73547619

Contact Data Protection Officer

Markus Weisheitinger-Herrmann

JKB – The Sailing Academy GmbH
Wasserfallweg 5
9520 Sattendorf
+43(0)676 8986 28304
office@in2theblue.com
www.in2theblue.com

Overview of Processing

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

  • Inventory data (e.g. names, addresses).
  • Content data (e.g. entries in online forms).
  • Contact data (e.g. email, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Location data (information on the geographical position of a device or person).
  • Contract data (e.g. subject matter of contract, term, customer category).
  • Payment data (e.g. bank details, invoices, payment history).

Categories of Data Subjects

  • Business and contractual partners.
  • Prospective customers.
  • Communication partners.
  • Customers.
  • Users (e.g. website visitors, users of online services).

Purposes of Processing

  • Assessment of creditworthiness.
  • Provision of our online offering and user-friendliness.
  • Visitor action evaluation.
  • Office and organizational procedures.
  • Cross-device tracking (cross-device processing of user data for marketing purposes).
  • Direct marketing (e.g. by email or post).
  • Interest-based and behavioral marketing.
  • Contact requests and communication.
  • Conversion measurement (measuring the effectiveness of marketing measures).
  • Profiling (creating user profiles).
  • Remarketing.
  • Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures.
  • Tracking (e.g. interest/behavioral profiling, use of cookies).
  • Provision of contractual services and customer service.
  • Management and response to inquiries.
  • Audience building (determining target groups relevant for marketing purposes or other output of content).

Automated Individual Decisions

  • Credit information (decision based on a credit check).

Relevant Legal Bases

Below we share the legal bases of the General Data Protection Regulation (GDPR) on 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. Should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6(1)(a) GDPR) – The data subject has given consent to the processing of their personal data for one or more specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6(1)(c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6(1)(f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Security Measures

In accordance with legal requirements and taking into account the state of the art, the costs of implementation, and the nature, scope, context, and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of security appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access to, input, transmission, securing of availability, and separation of data. Furthermore, we have established procedures to ensure the exercise of data subject rights, deletion of data, and responses to data threats. In addition, we take the protection of personal data into account as early as the development or selection of hardware, software, and procedures 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 offering, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Transmission and Disclosure of Personal Data

In the course of our processing of personal data, it may occur that the data is transmitted to other entities, companies, legally independent organizational units, or persons, or that it is disclosed to them. Recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks, or providers of services and content that are integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

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 if the processing takes place in the context of the use of third-party services or disclosure or transmission of data to other persons, entities, or companies, this is only done in accordance with legal requirements.

Subject to explicit consent or contractually or legally required transmission, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligations through so-called standard contractual clauses of the EU Commission, in the presence of certifications, or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Within the framework of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the level of data protection for certain companies from the USA as secure within the framework of the adequacy decision of July 10, 2023. The list of certified companies as well as further information on the DPF can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/ (in English). We inform you in the data protection notices which service providers we use are certified under the Data Privacy Framework.

Use of Cookies

Cookies are small text files or other storage notes that store information on end devices and read information from the end devices. For example, to save the login status in a user account, a shopping cart content in an e-shop, the content accessed, or functions used in an online offering. Cookies can also be used for different purposes, e.g. for the purposes of functionality, security, and convenience of online offerings as well as the creation of analyses of visitor flows.

Notes on consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, except when this is not required by law. Consent is not necessary in particular if the storage and reading of information, including cookies, is absolutely necessary in order to provide users with a telemedia service (i.e. our online offering) that they have expressly requested. The revocable consent is clearly communicated to users and contains information on the respective cookie use.

Notes on legal bases under data protection law: The legal basis under data protection law on which we process users’ personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their 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 offering and improvement of its usability) or, if this is done in the context of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We explain the purposes for which we process cookies in the course of this privacy policy or as part of our consent and processing procedures.

Storage duration: With regard to the storage duration, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user leaves an online offering and closes their end device (e.g. browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the data of users collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information on the type and storage duration of cookies (e.g. as part of obtaining consent), users should assume that cookies are permanent and the storage duration can be up to two years.

General notes 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 a given consent 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 the settings of your browser, e.g. by deactivating the use of cookies (whereby this may also restrict the functionality of our online offering). An objection to the use of cookies for online marketing purposes can 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 objection notices in the context of the information on the service providers and cookies used.

Processing of cookie data based on consent: We use a cookie consent management procedure in which users’ consent to the use of cookies, or the processing and providers mentioned in the cookie consent management procedure, is obtained and can be managed and revoked by users. The declaration of consent is stored so that the query 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 using 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 notes apply: The duration of storage of consent can be up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers), and the browser, system, and end device used.

Cookie settings/opt-out option:

Cookie-Richtlinie

Commercial and Business Services

We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships as well as associated measures and in the context of communication with contractual partners (or pre-contractually), e.g. to answer inquiries.

We process this data to fulfill our contractual obligations, to secure our rights, and for the purposes of the administrative tasks associated with this information as well as business organization. We only pass on the data of contractual partners to third parties within the framework of applicable law to the extent that this is necessary for the aforementioned purposes or to fulfill 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). Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the framework of this privacy policy.

We inform contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, through special marking (e.g. colors) or symbols (e.g. asterisks or similar), or personally.

We delete the data after expiry of statutory 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 reasons of archiving (e.g. for tax purposes, generally 10 years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications of the order, generally after the end of the order.

If 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 apply in the relationship between users and providers.

Customer account: Contractual partners can create an account within our online offering (e.g. customer or user account, in short “customer account”). If registration of a customer account is required, contractual partners will be informed of this as well as the information required for registration. Customer accounts are not public and cannot be indexed by search engines. As part of registration and subsequent logins and use of the customer account, we store the IP addresses of customers along with the access times in order to be able to prove registration and prevent any misuse of the customer account.

If customers have canceled their customer account, the data concerning the customer account will be deleted, provided that their retention is not required for legal reasons. It is the responsibility of customers to secure their data upon termination of the customer account.

Economic analyses and market research: For business reasons and in order to be able to recognize market trends, wishes of contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc., whereby the group of data subjects may include contractual partners, prospective customers, customers, visitors, and users of our online offering.

The analyses are carried out for the purpose of business evaluations, marketing, and market research (e.g. to determine customer groups with different characteristics). Where available, we can take into account the profiles of registered users together with their information, e.g. on services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with aggregated, i.e. anonymized values. Furthermore, we respect the privacy of users and process the data for analysis purposes as pseudonymously as possible and, where feasible, anonymously (e.g. as aggregated data).

Shop and e-commerce: We process the data of our customers to enable them to select, purchase, or order the selected products, goods, and related services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, freight forwarding, and shipping companies, to carry out the delivery or execution to our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is marked as such in the context of the order or comparable purchase process and includes the information required for delivery or provision and billing as well as contact information in order to be able to hold any consultation.

  • Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. email, telephone numbers), 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).
  • Data subjects: Prospective customers, business and contractual partners, customers.
  • Purposes of processing: Provision of contractual services and customer service, contact requests and communication, office and organizational procedures, management and response to inquiries, security measures, visitor action evaluation, interest-based and behavioral marketing, profiling (creating user profiles).
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legal obligation (Art. 6(1)(c) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Payment Service Providers

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 payment service providers in addition to banks and credit institutions (collectively “payment service providers”).

The data processed by payment service providers includes inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs, and checksums, as well as contract, sum, and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, but only information confirming or rejecting the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. This transmission is for the purpose of identity and credit checks. For this, we refer to the terms and conditions and data protection notices of the payment service providers.

The terms and conditions and data protection notices of the respective payment service providers apply to payment transactions, which can be accessed within the respective websites or transaction applications. We also refer to these for further information and the assertion of rights 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).
  • Data subjects: Customers, prospective customers.
  • Purposes of processing: Provision of contractual services and customer service.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Services and service providers used:

Provision of the Online Offering and Web Hosting

In order to provide our online offering securely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers managed by them) the online offering 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 as part of the provision of the hosting offering may include all information relating to users of our online offering that arises in the context of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the content of online offerings to browsers, and all entries made within our online offering or from websites.

Email dispatch and hosting: The web hosting services we use also include the dispatch, receipt, and storage of emails. For these purposes, the addresses of recipients and senders as well as further information concerning email dispatch (e.g. the providers involved) and the contents of the respective emails are processed. The aforementioned data may also be processed for the purposes of SPAM detection. Please note that emails on the internet are generally not sent encrypted. As a rule, emails 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. We can therefore accept no responsibility for the transmission path of emails between the sender and receipt 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, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), and as a rule IP addresses and the requesting provider.

The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the 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).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Contact

When contacting us (e.g. via contact form, email, telephone, or via social media), the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

The response to contact requests in the context of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to respond to (pre)contractual inquiries and otherwise on the basis of legitimate interests in responding to the inquiries.

  • Types of data processed: Inventory data (e.g., names, addresses), Contact data (e.g., email, phone numbers), Content data (e.g., entries in online forms), Usage data (e.g., visited websites, interest in content, access times), Meta/communication data (e.g., device information, IP addresses).
  • Data subjects: Communication partners, prospective customers.
  • Purposes of processing: Contact requests and communication, management and response to inquiries.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Services and service providers used:

  • Contact form: If users contact us via our contact form, email, or other communication channels, we process the data communicated to us in this context to process the communicated request. For this purpose, we process personal data in the context of pre-contractual and contractual business relationships to the extent necessary for their fulfillment and otherwise on the basis of our legitimate interests as well as the interests of communication partners in responding to the requests and our statutory retention obligations.
  • Help Scout: Management of contact requests and communication; Service provider: Help Scout Inc., 131 Tremont St, Boston, MA 02111-1338, USA; Website: https://www.helpscout.net; Privacy policy: https://www.helpscout.net/company/legal/privacy/; Basis for third country transfer: Standard contractual clauses (https://www.helpscout.com/company/legal/dpa/); Data processing agreement: https://www.helpscout.com/company/legal/dpa/.

Newsletter and Electronic Notifications

We send newsletters, emails, and other electronic notifications (hereinafter “newsletter”) only with the consent of the recipients or legal permission. If the contents of a newsletter are specifically described as part of registration for the newsletter, they are decisive for the consent of users. Otherwise, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient if you provide your email address. However, we may ask you to provide a name for personal address in the newsletter, or further information if this is necessary for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter generally takes place in a so-called double opt-in procedure. This means that after registration you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register with other people’s email addresses. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise, changes to your data stored with the dispatch service provider are logged.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a blacklist.

The logging of the registration procedure is based on our legitimate interests for the purpose of proving its proper course. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system.

Notes on legal bases: The dispatch of newsletters is based on the consent of recipients or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent this is permitted by law, e.g. in the case of existing customer advertising. If we commission a service provider to send emails, this is done on the basis of our legitimate interests. The registration procedure is recorded on the basis of our legitimate interests in order to prove that it was carried out in accordance with the law.

Contents: Information about us, our services, promotions, and offers.

Analysis and success measurement: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server, or, if we use a dispatch service provider, from their server when the newsletter is opened. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, is initially collected.

This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened, and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our aim nor, if used, that of the dispatch service provider to observe individual users. The evaluations serve us rather to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The evaluation of the newsletter and the success measurement are carried out, subject to express consent of users, on the basis of our legitimate interests for the purposes of using a user-friendly and secure newsletter system, which serves both our business interests and meets the expectations of users.

A separate revocation of the success measurement is unfortunately not possible; in this case, the entire newsletter subscription must be canceled or objected to.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g. by email or post).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
  • Opt-out option: You can cancel receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options stated above, preferably email, for this purpose.

Services and service providers used:

Web Analysis, Monitoring and Optimization

Web analysis (also referred to as “reach measurement”) serves to evaluate the visitor flows of our online offering and can include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can recognize, for example, at what time our online offering or its functions or content are most frequently used or invite reuse. Likewise, we can understand which areas require optimization.

In addition to web analysis, we can also use test procedures to test and optimize different versions of our online offering or its components.

For these purposes, so-called user profiles can be created and stored in a file (so-called “cookie”) or similar procedures with the same purpose can be used. This information may include, for example, content viewed, websites visited and elements used there, 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, these may also be processed depending on the provider.

The IP addresses of users are also collected. However, we use an IP masking procedure (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored in the context of web analysis, A/B testing, and optimization, but pseudonyms. This means that we as well as the providers of the software used do not know the actual identity of users, but only the information stored in their profiles for the purposes of the respective procedures.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behavioral profiling, use of cookies), visitor action evaluation, profiling (creating user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services and service providers used:

  • etracker: Web analysis/reach measurement; Service provider: etracker GmbH, Erste Brunnenstraße 1 20459 Hamburg, Germany; Website: https://www.etracker.com; Privacy policy: https://www.etracker.com/datenschutz/; Data processing agreement: https://www.etracker.com/av-vertrag/.
  • Google Analytics: We use Google Analytics to measure and analyze the use of our online offering based on a pseudonymous user identification number. This identification number does not contain unique data such as names or email addresses. It serves to assign analysis information to an end device to recognize which content users have accessed within one or various usage processes, which search terms they have used, have re-accessed them, or have interacted with our online offering. Likewise, the time and duration of use are stored, as well as the sources of users who refer to our online offering and technical aspects of their end devices and browsers. Pseudonymous user profiles are created with information from the use of various devices, whereby cookies may be used. In Analytics, data on geographical location is provided at a higher level by collecting the following metadata based on IP lookup: “City” (and the derived latitude and longitude of the city), “Continent,” “Country,” “Region,” “Subcontinent” (and the ID-based equivalents). To ensure the protection of user data in the EU, Google receives and processes all user data via domains and servers within the EU. User IP addresses are not logged and are truncated by default by the last two digits. IP address truncation takes place on EU servers for EU users. In addition, all sensitive data collected from users in the EU is deleted before it is collected via EU domains and servers; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfer: Data Privacy Framework, Standard Contractual Clauses (https://business.safety.google/adsprocessorterms); Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for ad display: https://adssettings.google.com/authenticated; Further information: https://privacy.google.com/businesses/adsservices (types of processing and data processed).
  • Google Tag Manager: Google Tag Manager is a solution that allows us to manage so-called website tags via an interface and thus integrate other services into our online offering (for this, please refer to further information in this privacy policy). The Tag Manager itself (which implements the tags) does not create user profiles or store cookies, for example. Google only learns the user’s IP address, which is necessary to run Google Tag Manager; 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; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement:
    https://business.safety.google/adsprocessorterms; Basis for third-country transfer: Data Privacy Framework, Standard Contractual Clauses (https://business.safety.google/adsprocessorterms); Further information: https://privacy.google.com/businesses/adsservices (types of processing and data processed).
  • Matomo (without cookies): Matomo is a privacy-friendly web analytics software that is used without cookies and where the recognition of returning users is done with the help of a so-called “digital fingerprint,” which is stored anonymously and changed every 24 hours; The “digital fingerprint” records user movements within our online offering with the help of pseudonymized IP addresses in combination with user-side browser settings in such a way that conclusions about the identity of individual users are not possible. The user data collected within the scope of Matomo’s use is processed only by us and not shared with third parties; Website: https://matomo.org/.
  • Matomo: Matomo is a software used for web analysis and reach measurement. When using Matomo, cookies are generated and stored on the users’ end devices. The user data collected within the scope of Matomo’s use is processed only by us and not shared with third parties. Cookies are stored for a maximum period of 13 months: https://matomo.org/faq/general/faq_146/; Data deletion: Cookies have a maximum storage period of 13 months.

Online Marketing

We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the display of advertising and other content (collectively referred to as “content”) based on the potential interests of users, as well as the measurement of their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (a “cookie”) or similar procedures are used, by means of which information relevant for the display of the aforementioned content is stored about the user. This information may include, for example, viewed content, visited websites, used online networks, 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 may also be processed.

User IP addresses are also collected. However, we use available IP masking procedures (i.e., pseudonymization by truncating the IP address) to protect users. In general, no clear data of users (such as email addresses or names) are stored within the online marketing process, but pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in cookies or by similar procedures. These cookies can generally also be read out later on other websites that use the same online marketing procedure and analyzed for the purpose of displaying content, as well as supplemented with further data and stored on the server of the online marketing procedure provider.

In exceptional cases, clear data can be assigned to the profiles. This is the case, for example, if users are members of a social network whose online marketing procedure we use and the network links the user profiles with the aforementioned information. Please note that users may make additional agreements with the providers, e.g., by giving consent during registration.

We generally only receive access to aggregated information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. Conversion measurement is used solely to analyze the success of our marketing measures.

Unless otherwise stated, please assume that used cookies are stored for a period of two years.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g., visited websites, interest in content, access times), Meta/communication data (e.g., device information, IP addresses), Location data (information on the geographical position of a device or person).
  • Affected persons: Users (e.g., website visitors, users of online services), Prospects.
  • Purposes of processing: Tracking (e.g., interest/behavior-based profiling, use of cookies), Remarketing, Visit action evaluation, Interest-based and behavior-based marketing, Profiling (creation of user profiles), Conversion measurement (measurement of the effectiveness of marketing measures), Reach measurement (e.g., access statistics, recognition of recurring visitors), Target group formation (determination of target groups relevant for marketing purposes or other output of content), Cross-device tracking (cross-device processing of user data for marketing purposes).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
  • Right to object (Opt-Out): We refer to the privacy policies of the respective providers and the opt-out options provided for the providers. If no explicit opt-out option has been specified, there is the possibility that you can disable cookies in your browser settings. However, this may restrict functions of our online offering. We therefore also recommend the following opt-out options, which are offered collectively for the respective areas:a) Europe: https://www.youronlinechoices.eu.
    b) Canada: https://www.youradchoices.ca/choices.
    c) USA: https://www.aboutads.info/choices.
    d) Cross-regional: https://optout.aboutads.info.

Services and service providers used:

  • Facebook Pixel and Audience Creation (Custom Audiences): With the help of the Facebook Pixel (or comparable functions for transmitting event data or contact information via interfaces in apps), Facebook can determine the visitors to our online offering as a target group for displaying ads (so-called “Facebook Ads”). Accordingly, we use the Facebook Pixel to display the Facebook Ads placed by us only to those users on Facebook and within the services of Facebook’s cooperating partners (so-called “Audience Network” https://www.facebook.com/audiencenetwork/) who have shown an interest in our online offering or who exhibit certain characteristics (e.g., interest in certain topics or products, which can be seen from the visited websites) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook Pixel, we also want to ensure that our Facebook Ads correspond to the potential interests of users and do not appear annoying. With the help of the Facebook Pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion measurement”); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Basis for third-country transfer: Data Privacy Framework, Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum) in the case of data processing by Facebook as the basis for processing event data of EU citizens in the USA and the inclusion in the “Facebook Platform Terms” (https://developers.facebook.com/terms) with regard to Facebook’s own processing of event data for ad delivery; Further information: The “Data Processing Terms” (https://www.facebook.com/legal/terms/dataprocessing/update) apply with regard to event data that Facebook processes on our behalf to provide reports and analyses to companies; Furthermore, the “Controller Addendum” applies as an agreement on joint responsibility (Art. 26 para. 1 sentence 3 GDPR), which is decisive in the case of Facebook’s own processing of event data for targeting purposes and the improvement and security of Facebook products.
  • Google Ad Manager: We use the “Google Marketing Platform” (and services such as “Google Ad Manager”) to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.). The Google Marketing Platform is characterized by displaying ads in real time based on presumed user interests. This allows us to display ads more targeted for and within our online offering, to present users only with ads that potentially match their interests. If a user, for example, is shown ads for products they were interested in on other online offerings, this is referred to as “Remarketing”; 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; Privacy Policy: https://policies.google.com/privacy; Further information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices; Data processing terms for Google advertising products: Information on the services Data processing terms between controllers: https://business.safety.google/adscontrollerterms; if Google acts as a processor, data processing terms for Google advertising products and standard contractual clauses for third-country data transfers: https://business.safety.google/adsprocessorterms; Basis for third-country transfer: Data Privacy Framework, Standard Contractual Clauses (https://business.safety.google/adsprocessorterms).
  • Google Ads and Conversion Measurement: We use the online marketing procedure “Google Ads” to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads (so-called “conversion”). Furthermore, we measure the conversion of the ads. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page with a so-called “conversion tracking tag.” We ourselves do not receive any information that allows users to be identified; 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; Privacy Policy: https://policies.google.com/privacy; Further information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices; Data processing terms for Google advertising products: Information on the services Data processing terms between controllers: https://business.safety.google/adscontrollerterms; Basis for third-country transfer: Data Privacy Framework, Standard Contractual Clauses (https://business.safety.google/adsprocessorterms).

Presences on Social Networks (Social Media)

We maintain online presences within social networks and process user data in this context to communicate with active users there or to offer information about us.

We point out that user data may be processed outside the European Union. This may result in risks for users, for example, because the enforcement of user rights could be made more difficult.

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behavior and resulting interests. These user profiles can then be used, for example, to place advertisements within and outside the networks that presumably correspond to the users’ interests. For these purposes, cookies are generally stored on the users’ computers, in which user behavior and interests are stored. Furthermore, data independent of the devices used by the users can also be stored in the user profiles (especially if the users are members of the respective platforms and are logged in there).

For a detailed description of the respective processing forms and the possibilities of objection (opt-out), we refer to the privacy policies and information of the operators of the respective networks.

Even in the case of information requests 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 user data and can directly take appropriate measures and provide information. Should you still need help, you can contact us.

  • Types of data processed: Inventory data (e.g., names, addresses), Contact data (e.g., email, phone numbers), Content data (e.g., entries in online forms), Usage data (e.g., visited websites, interest in content, access times), Meta/communication data (e.g., device information, IP addresses).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Contact inquiries and communication, Tracking (e.g., interest/behavior-based profiling, use of cookies), Remarketing, Reach measurement (e.g., access statistics, recognition of recurring visitors).
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services and service providers used:

Plugins and Embedded Functions and Content

We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may include, for example, graphics, videos, or social media buttons and posts (hereinafter uniformly referred to as “content”).

The integration always requires that the third-party providers of this content process the users’ IP address, as they would not be able to send the content to their browser without the IP address. The IP address is therefore necessary for the display of this content or functions. We strive to use only content whose respective providers use the IP address solely 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. Through the “pixel tags,” information such as visitor traffic on the pages of this website can be evaluated. The pseudonymous information can also be stored in cookies on the users’ device and may contain, among other things, technical information about the browser and operating system, referring websites, visit time, and other information about the use of our online offering, as well as be linked with such information from other sources.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g., visited websites, interest in content, access times), Meta/communication data (e.g., device information, IP addresses), Location data (information on the geographical position of a device or person), Content data (e.g., entries in online forms), Inventory data (e.g., names, addresses), Contact data (e.g., email, phone numbers).
  • Affected persons: Users (e.g., website visitors, users of online services), Communication partners.
  • Purposes of processing: Provision of our online offering and user-friendliness, Provision of contractual services and customer service, Contact inquiries and communication, Tracking (e.g., interest/behavior-based profiling, use of cookies), Interest-based and behavior-based marketing, Profiling (creation of user profiles), Security measures, Management and response to inquiries.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR), Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR).

Services and service providers used:

  • 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 the Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/ – Together with Meta Platforms Ireland Limited, we are jointly responsible for the collection or receipt, within the scope of a transmission (but not the further processing), of “event data” that Facebook collects via the Facebook Social Plugins (and content embedding functions) executed on our online offering or receives within the scope of a transmission for the following purposes: a) Display of content and advertising information that corresponds to the presumed interests of users; b) Delivery of commercial and transaction-related messages (e.g., addressing users via Facebook Messenger); c) Improvement of ad delivery and personalization of functions and content (e.g., improving the recognition of which content or advertising information presumably corresponds to the interests of users). We have concluded a special agreement with Facebook (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum), which specifically regulates which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the rights of data subjects (i.e., users can, for example, address information or deletion requests directly to Facebook). Note: If Facebook provides us with metrics, analyses and reports (which are aggregated, i.e., do not contain information about individual users and are anonymous to us), this processing does not take place within the framework of joint responsibility, but on the basis of a data processing agreement (“Data Processing Terms”, https://www.facebook.com/legal/terms/dataprocessing), the “Data Security Terms” (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of 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; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy.
  • Google Fonts: We integrate the fonts (“Google Fonts”) from the provider Google, whereby user data is used solely for the purpose of displaying the fonts in the users’ browser. The integration is based on our legitimate interests in a technically secure, maintenance-free, and efficient use of fonts, their uniform display, and taking into account possible licensing restrictions for their integration; 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://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy.
  • Google Maps: We integrate the maps of the “Google Maps” service from the provider Google. The processed data may include, in particular, IP addresses and location data of users, which are not collected without their consent (usually given in the settings of their mobile devices); 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/maps-platform; Privacy Policy: https://policies.google.com/privacy; Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for ad display: https://adssettings.google.com/authenticated.
  • reCAPTCHA: We integrate the “reCAPTCHA” function to recognize whether entries (e.g., in online forms) are made by humans and not by automatically acting machines (so-called “bots”). The processed data may include IP addresses, information about operating systems, devices or browsers used, language settings, location, mouse movements, keyboard strokes, time spent on websites, previously visited websites, interactions with reCAPTCHA on other websites, possibly cookies, and results of manual recognition processes (e.g., answering questions or selecting objects in images); 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.google.com/recaptcha/; Privacy Policy: https://policies.google.com/privacy; Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for ad display: https://adssettings.google.com/authenticated.
  • 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 option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for ad display: https://adssettings.google.com/authenticated.

Deletion of Data

The data processed by us will be deleted in accordance with legal requirements as soon as the consents permitting their processing are revoked or other permissions cease to apply (e.g., if the purpose of processing this data has ceased or it is no longer required for the purpose).

If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person.

Further information on the deletion of personal data can also be found in the individual privacy notices of this privacy policy.

Amendment 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 changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require an action on your part (e.g., consent) or any other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that addresses may change over time and we ask you to check the information before contacting them.

Rights of Data Subjects

As a data subject, you have various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions. If personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for the purpose of such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw given consents at any time.
  • Right of access: You have the right to request confirmation as to whether data concerning you is being processed and to information about this data, as well as further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: You have the right, in accordance with legal requirements, to request the completion of incomplete data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: You have the right, in accordance with legal requirements, to request that data concerning you be deleted without undue delay, or alternatively, in accordance with legal requirements, to request a restriction of the processing of the data.
  • Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with legal requirements, or to request its transmission to another controller.
  • Right to lodge a complaint with a supervisory authority: You also have the right, in accordance with legal requirements, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Definitions

In this section, you will find an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined primarily in Art. 4 GDPR. The legal definitions are binding. The following explanations, however, are primarily intended to aid understanding. The terms are sorted alphabetically.

  • Visit Action Evaluation: “Visit action evaluation” (English “Conversion Tracking”) refers to a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users’ devices within the websites where the marketing measures take place and then retrieved again on the target website. For example, we can thus track whether the ads we placed on other websites were successful).
  • Creditworthiness information: Automated decisions are based on automatic data processing without human intervention (e.g., in the case of an automatic rejection of a purchase on account, an online credit application or an online application process without any human intervention. Such automated decisions are only permissible under Art. 22 GDPR if data subjects consent, if they are necessary for the performance of a contract or if national laws permit these decisions.
  • Cross-Device Tracking: Cross-device tracking is a form of tracking in which user behavior and interest information is collected across devices in so-called profiles by assigning an online identifier to users. This allows user information to be analyzed for marketing purposes, regardless of the browsers or devices used (e.g., mobile phones or desktop computers). The online identifier is not linked to clear data, such as names, postal addresses or email addresses, for most providers.
  • IP Masking: “IP masking” refers to a method in which the last octet, i.e., the last two numbers of an IP address, is deleted so that the IP address can no longer serve to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing procedures, especially in online marketing.
  • Interest-based and behavior-based marketing: Interest- and/or behavior-based marketing refers to the most accurate possible pre-determination of potential user interests in advertisements and other content. This is done based on information about their past behavior (e.g., visiting certain websites and staying on them, purchasing behavior or interaction with other users), which is stored in a so-called profile. For these purposes, cookies are usually used.
  • Conversion tracking: Conversion tracking is a method used to measure the effectiveness of marketing activities. Usually, a cookie is stored on users’ devices on the websites where the marketing takes place and is then accessed again on the target website. For example, this helps us understand if the ads we placed on other websites were successful.
  • 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.
  • Profiling: “Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person (depending on the type of profiling, this includes information concerning age, gender, location data and movement data, interaction with websites and their content, purchasing behavior, social interactions with other people) to analyze, assess or predict them (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.
  • Reach Measurement: Reach measurement (also known as web analytics) serves to evaluate the visitor flows of an online offering and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, website owners can, for example, recognize at what time visitors visit their website and what content they are interested in. This allows them, for example, to better adapt the content of the website to the needs of their visitors. For the purpose of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more accurate analyses of the use of an online offering.
  • Remarketing: “Remarketing” or “retargeting” refers to the practice of noting, for example, which products a user was interested in on a website for advertising purposes, in order to remind the user of these products on other websites, e.g., in advertisements.
  • Location Data: Location data is generated when a mobile device (or another device with the technical prerequisites for location determination) connects to a radio cell, Wi-Fi, or similar technical means and location determination functions. Location data serves to indicate the geographically determinable position on Earth where the respective device is located. Location data can, for example, be used to display map functions or other location-dependent information.
  • Tracking: “Tracking” refers to the ability to trace user behavior across multiple online offerings. Typically, behavioral and interest information regarding the online offerings used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
  • 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” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it collection, evaluation, storage, transmission or deletion.
  • Audience building: Audience building (or “Custom Audiences”) refers to defining target groups for advertising purposes, e.g. displaying ads. For example, a user’s interest in certain products or topics online can be used to infer that this user is interested in ads for similar products or for the online shop where they viewed the products. “Lookalike Audiences” (or similar audiences), in turn, refers to showing content deemed suitable to users whose profiles or interests are presumed to match those of the users for whom the profiles were created. Cookies and web beacons are generally used to create Custom Audiences and Lookalike Audiences.