Information in accordance with the duty to inform pursuant to §5 of the E-Commerce Act, §14 of the Austrian Commercial Code, §63 of the Industrial Code and the duty to disclose pursuant to §25 of the Media Act.
Schonger Wilhelm KG
Gries 16, Gries 16,
6631 Lermoos,
Österreich
Object of the company: Tourismusbetrieb, Hotel
VAT-Number: ATU39113703
Corporate register number: FN134139p
Corporate register court: GS Reutte
Company location: Gries 16, 6631 Lermoos
Phone: +43 56732 197
Email: info@laerchenhof-lermoos.at
Member of: WKO
Laws re. professions: Gewerbeordnung: www.ris.bka.gv.at
Supervisory/Trade authority: Bezirkshauptmannschaft Reutte
Job title: Tourismusbetrieb, Hotel
Awarding country: Österreich
Contact details of the data protection controller
If you have any question about data protection, please find the contact details of the body or person responsible for data protection below:
Christoph Schonger
Gries 16, 6631 Lermoos
E-Mail: info@laerchenhof-lermoos.at
Phone: +43 56732 197
Company details: https://www.laerchenhof-lermoos.at/impressum/
EU Dispute Resolution
We would like to inform you about the Online Dispute Resolution platform (ODR platform) in accordance with the regulation on Online Dispute Resolution in consumer matters (ODR Regulation).
Consumers have the option of submitting complaints to the European Commission’s Online Dispute Resolution platform at https://ec.europa.eu/consumers/odr/main/?event=main.home2.show. You will find the necessary contact details in our imprint above.
However, we would like to note, that we are not willing or obliged to participate in dispute settlement procedures before a consumer arbitration board.
Liability for the Contents of this Website
We are constantly developing the content of this website and strive to provide correct and up-to-date information. Unfortunately, we cannot accept liability for the accuracy of any content on this website. This especially includes content provided by third parties. As a service provider, we are neither obliged to monitor any information you transmit or store, nor to investigate any circumstances that indicate illegal activity.
Due to court- or official orders under the general law, our obligations to remove information or to block the use of information remain unaffected, even if we are not responsible.
If you notice any problematic or illegal content, please contact us immediately so we can remove the illegal content. You will find our contact details in the imprint.
Liability for Links on this Website
Our website contains links to other websites for which we are not responsible. We are not liable for any linked websites, since we have had no knowledge of illegal activities. If we ever become aware of any illegal activity, we will remove any links in question immediately.
If you notice illegal links on our website, please contact us. You will find our contact details in the imprint.
Copyright Notice
All contents of this website (pictures, images, photos, texts, videos) are subject to copyright. Please ask us before distributing, reproducing or using the contents of this website – such as republishing them on other websites. If necessary, we will prosecute the unauthorised use of our website’s content.
If you find content on this website that violates copyright, please contact us.
Picture Credits
The pictures, images and graphics on this website are protected by copyright.
The image rights are with:
Fotograf Claudia Lindner (kreatur.work)
All texts are copyrighted.
Privacy Policy
Privacy Policy Introduction and Overview
We have written this privacy policy (version 09.08.2023-122534183) in order to explain to you, in accordance with the provisions of the General Data Protection Regulation (EU) 2016/679 and applicable national laws, which personal data (data for short) we as the controller – and the processors commissioned by us (e.g. providers) – process, will process in the future and what legal options you have. The terms used are to be considered gender-neutral.
In short: We provide you with comprehensive information about any of your personal data we process.
Privacy policies usually sound very technical and use legal terminology. However, this privacy policy is intended to describe the most important things to you as simply and transparently as possible. So long as it aids transparency, technical terms are explained in a reader-friendly manner, links to further information are provided and graphics are used. We are thus informing in clear and simple language that we only process personal data in the context of our business activities if there is a legal basis for it. This is certainly not possible with brief, unclear and legal-technical statements, as is often standard on the internet when it comes to data protection. I hope you find the following explanations interesting and informative. Maybe you will also find some information that you have not been familiar with.
If you still have questions, we kindly ask you to contact the responsible body named below or in the imprint, follow the existing links and look at further information on third-party sites. You can of course also find our contact details in the imprint.
Scope
This privacy policy applies to all personal data processed by our company and to all personal data processed by companies commissioned by us (processors). With the term personal data, we refer to information within the meaning of Article 4 No. 1 GDPR, such as the name, email address and postal address of a person. The processing of personal data ensures that we can offer and invoice our services and products, be it online or offline. The scope of this privacy policy includes:
- all online presences (websites, online shops) that we operate
- Social media presences and email communication
- mobile apps for smartphones and other devices
In short: This privacy policy applies to all areas in which personal data is processed in a structured manner by the company via the channels mentioned. Should we enter into legal relations with you outside of these channels, we will inform you separately if necessary.
Legal bases
In the following privacy policy, we provide you with transparent information on the legal principles and regulations, i.e. the legal bases of the General Data Protection Regulation, which enable us to process personal data.
Whenever EU law is concerned, we refer to REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016. You can of course access the General Data Protection Regulation of the EU online at EUR-Lex, the gateway to EU law, at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679.
We only process your data if at least one of the following conditions applies:
- Consent (Article 6 Paragraph 1 lit. a GDPR): You have given us your consent to process data for a specific purpose. An example would be the storage of data you entered into a contact form.
- Contract (Article 6 Paragraph 1 lit. b GDPR): We process your data in order to fulfill a contract or pre-contractual obligations with you. For example, if we conclude a sales contract with you, we need personal information in advance.
- Legal obligation (Article 6 Paragraph 1 lit. c GDPR): If we are subject to a legal obligation, we will process your data. For example, we are legally required to keep invoices for our bookkeeping. These usually contain personal data.
- Legitimate interests (Article 6 Paragraph 1 lit. f GDPR): In the case of legitimate interests that do not restrict your basic rights, we reserve the right to process personal data. For example, we have to process certain data in order to be able to operate our website securely and economically. Therefore, the processing is a legitimate interest.
Other conditions such as making recordings in the interest of the public, the exercise of official authority as well as the protection of vital interests do not usually occur with us. Should such a legal basis be relevant, it will be disclosed in the appropriate place.
In addition to the EU regulation, national laws also apply:
- In Austria this is the Austrian Data Protection Act (Datenschutzgesetz), in short DSG.
- In Germany this is the Federal Data Protection Act (Bundesdatenschutzgesetz), in short BDSG.
Should other regional or national laws apply, we will inform you about them in the following sections.
Contact details of the data protection controller
If you have any questions about data protection, you will find the contact details of the responsible person or controller below:
Christoph Schonger
Gries 16, 6631 Lermoos
E-Mail: info@laerchenhof-lermoos.at
Phone: +43 56732 197
Company details: https://www.laerchenhof-lermoos.at/impressum/
Storage Period
It is a general criterion for us to store personal data only for as long as is absolutely necessary for the provision of our services and products. This means that we delete personal data as soon as any reason for the data processing no longer exists. In some cases, we are legally obliged to keep certain data stored even after the original purpose no longer exists, such as for accounting purposes.
If you want your data to be deleted or if you want to revoke your consent to data processing, the data will be deleted as soon as possible, provided there is no obligation to continue its storage.
We will inform you below about the specific duration of the respective data processing, provided we have further information.
Rights in accordance with the General Data Protection Regulation
In accordance with Articles 13, 14 of the GDPR, we inform you about the following rights you have to ensure fair and transparent processing of data:
- According to Article 15 DSGVO, you have the right to information about whether we are processing data about you. If this is the case, you have the right to receive a copy of the data and to know the following information:
- for what purpose we are processing;
- the categories, i.e. the types of data that are processed;
- who receives this data and if the data is transferred to third countries, how security can be guaranteed;
- how long the data will be stored;
- the existence of the right to rectification, erasure or restriction of processing and the right to object to processing;
- that you can lodge a complaint with a supervisory authority (links to these authorities can be found below);
- the origin of the data if we have not collected it from you;
- Whether profiling is carried out, i.e. whether data is automatically evaluated to arrive at a personal profile of you.
- You have a right to rectification of data according to Article 16 GDPR, which means that we must correct data if you find errors.
- You have the right to erasure (“right to be forgotten”) according to Article 17 GDPR, which specifically means that you may request the deletion of your data.
- According to Article 18 of the GDPR, you have the right to restriction of processing, which means that we may only store the data but not use it further.
- According to Article 20 of the GDPR, you have the right to data portability, which means that we will provide you with your data in a standard format upon request.
- According to Article 21 DSGVO, you have the right to object, which entails a change in processing after enforcement.
- If the processing of your data is based on Article 6(1)(e) (public interest, exercise of official authority) or Article 6(1)(f) (legitimate interest), you may object to the processing. We will then check as soon as possible whether we can legally comply with this objection.
- If data is used to conduct direct advertising, you may object to this type of data processing at any time. We may then no longer use your data for direct marketing.
- If data is used to conduct profiling, you may object to this type of data processing at any time. We may no longer use your data for profiling thereafter.
- According to Article 22 of the GDPR, you may have the right not to be subject to a decision based solely on automated processing (for example, profiling).
- You have the right to lodge a complaint under Article 77 of the GDPR. This means that you can complain to the data protection authority at any time if you believe that the data processing of personal data violates the GDPR.
In short: you have rights – do not hesitate to contact the responsible party listed above with us!
If you believe that the processing of your data violates data protection law or your data protection rights have been violated in any other way, you can complain to the supervisory authority. For Austria, this is the data protection authority, whose website can be found at https://www.dsb.gv.at/. In Germany, there is a data protection officer for each federal state. For more information, you can contact the Federal Commissioner for Data Protection and Freedom of Information (BfDI). The following local data protection authority is responsible for our company:
Cookies
Cookies Overview 👥 Affected parties: visitors to the website 🤝 Purpose: depending on the respective cookie. You can find out more details below or from the software manufacturer that sets the cookie. 📓 Processed data: depends on the cookie used. More details can be found below or from the manufacturer of the software that sets the cookie. 📅 Storage duration: can vary from hours to years, depending on the respective cookie ⚖️ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests) |
What are cookies?
Our website uses HTTP-cookies to store user-specific data.
In the following we explain what cookies are and why they are used, so that you can better understand the following privacy policy.
Whenever you surf the Internet, you are using a browser. Common browsers are for example, Chrome, Safari, Firefox, Internet Explorer and Microsoft Edge. Most websites store small text-files in your browser. These files are called cookies.
It is important to note that cookies are very useful little helpers. Almost every website uses cookies. More precisely, these are HTTP cookies, as there are also other cookies for other uses. HTTP cookies are small files that our website stores on your computer. These cookie files are automatically placed into the cookie-folder, which is the “brain” of your browser. A cookie consists of a name and a value. Moreover, to define a cookie, one or multiple attributes must be specified.
Cookies store certain user data about you, such as language or personal page settings. When you re-open our website to visit again, your browser submits these “user-related” information back to our site. Thanks to cookies, our website knows who you are and offers you the settings you are familiar to. In some browsers, each cookie has its own file, while in others, such as Firefox, all cookies are stored in one single file.
The following graphic shows a possible interaction between a web browser such as Chrome and the web server. The web browser requests a website and receives a cookie back from the server. The browser then uses this again as soon as another page is requested.
There are both first-party cookies and third-party cookies. First-party cookies are created directly by our site, while third-party cookies are created by partner-websites (e.g. Google Analytics). Each cookie must be evaluated individually, as each cookie stores different data. The expiry time of a cookie also varies from a few minutes to a few years. Cookies are not software programs and do not contain viruses, trojans or other malware. Cookies also cannot access your PC’s information.
This is an example of how cookie-files can look:
Name: _ga
Value: GA1.2.1326744211.152122534183-9
Purpose: Differentiation between website visitors
Expiry date: after 2 years
A browser should support these minimum sizes:
- At least 4096 bytes per cookie
- At least 50 cookies per domain
- At least 3000 cookies in total
Which types of cookies are there?
The exact cookies that we use, depend on the used services, which will be outlined in the following sections of this privacy policy. Firstly, we will briefly focus on the different types of HTTP-cookies.
There are 4 different types of cookies:
Essential cookies
These cookies are necessary to ensure the basic functions of a website. They are needed when a user for example puts a product into their shopping cart, then continues surfing on different websites and comes back later in order to proceed to the checkout. These cookies ensure the shopping cart does not get deleted, even if the user closes their browser window.
Purposive cookies
These cookies collect information about user behaviour and whether the user receives any error messages. Furthermore, these cookies record the website’s loading time as well as its behaviour in different browsers.
Target-orientated cookies
These cookies ensure better user-friendliness. Thus, information such as previously entered locations, fonts sizes or data in forms stay stored.
Advertising cookies
These cookies are also known as targeting cookies. They serve the purpose of delivering customised advertisements to the user. This can be very practical, but also rather annoying.
Upon your first visit to a website you are usually asked which of these cookie-types you want to accept. Furthermore, this decision will of course also be stored in a cookie.
If you want to learn more about cookies and do not mind technical documentation, we recommend https://tools.ietf.org/html/rfc6265, the Request for Comments of the Internet Engineering Task Force (IETF) called “HTTP State Management Mechanism”.
Purpose of processing via cookies
The purpose ultimately depends on the respective cookie. You can find out more details below or from the software manufacturer that sets the cookie.
Which data are processed?
Cookies are little helpers for a wide variety of tasks. Unfortunately, it is not possible to tell which data is generally stored in cookies, but in the privacy policy below we will inform you on what data is processed or stored.
Storage period of cookies
The storage period depends on the respective cookie and is further specified below. Some cookies are erased after less than an hour, while others can remain on a computer for several years.
You can also influence the storage duration yourself. You can manually erase all cookies at any time in your browser (also see “Right of objection” below). Furthermore, the latest instance cookies based on consent will be erased is after you withdraw your consent. The legality of storage will remain unaffected until then.
Right of objection – how can I erase cookies?
You can decide for yourself how and whether you want to use cookies. Regardless of which service or website the cookies originate from, you always have the option of erasing, deactivating or only partially accepting cookies. You can for example block third-party cookies but allow all other cookies.
If you want to find out which cookies have been stored in your browser, or if you want to change or erase cookie settings, you can find this option in your browser settings:
Chrome: Clear, enable and manage cookies in Chrome
Safari: Manage cookies and website data in Safari
Firefox: Clear cookies and site data in Firefox
Internet Explorer: Delete and manage cookies
Microsoft Edge: Delete cookies in Microsoft Edge
If you generally do not want cookies, you can set up your browser in a way to notify you whenever a cookie is about to be set. This gives you the opportunity to manually decide to either permit or deny the placement of every single cookie. This procedure varies depending on the browser. Therefore, it might be best for you to search for the instructions in Google. If you are using Chrome, you could for example put the search term “delete cookies Chrome” or “deactivate cookies Chrome” into Google.
Legal basis
The so-called “cookie directive” has existed since 2009. It states that the storage of cookies requires your consent (Article 6 Paragraph 1 lit. a GDPR). Within countries of the EU, however, the reactions to these guidelines still vary greatly. In Austria, however, this directive was implemented in Section 96 (3) of the Telecommunications Act (TKG). In Germany, the cookie guidelines have not been implemented as national law. Instead, this guideline was largely implemented in Section 15 (3) of the Telemedia Act (TMG).
For absolutely necessary cookies, even if no consent has been given, there are legitimate interests (Article 6 (1) (f) GDPR), which in most cases are of an economic nature. We want to offer our visitors a pleasant user experience on our website. For this, certain cookies often are absolutely necessary.
This is exclusively done with your consent, unless absolutely necessary cookies are used. The legal basis for this is Article 6 (1) (a) of the GDPR.
In the following sections you will find more detail on the use of cookies, provided the used software does use cookies.
Web hosting
Web hosting Overview 👥 Affected parties: visitors to the website 📓 Purpose: professional hosting of the website and security of operations 🤝 Processed data: IP address, time of website visit, browser used and other data. You can find more details on this below or at the respective web hosting provider. 📅 Storage period: dependent on the respective provider, but usually 2 weeks ⚖️ Legal basis: Art. 6 para. 1 lit. f GDPR (legitimate interests) |
What is web hosting?
Every time you visit a website nowadays, certain information – including personal data – is automatically created and stored, including on this website. This data should be processed as sparingly as possible, and only with good reason. By website, we mean the entirety of all websites on your domain, i.e. everything from the homepage to the very last subpage (like this one here). By domain we mean example.uk or examplepage.com.
When you want to view a website on a screen, you use a program called a web browser. You probably know the names of some web browsers: Google Chrome, Microsoft Edge, Mozilla Firefox, and Apple Safari.
The web browser has to connect to another computer which stores the website’s code: the web server. Operating a web server is complicated and time-consuming, which is why this is usually done by professional providers. They offer web hosting and thus ensure the reliable and flawless storage of website data.
Whenever the browser on your computer establishes a connection (desktop, laptop, smartphone) and whenever data is being transferred to and from the web server, personal data may be processed. After all, your computer stores data, and the web server also has to retain the data for a period of time in order to ensure it can operate properly.
Illustration:
Why do we process personal data?
The purposes of data processing are:
- Professional hosting of the website and operational security
- To maintain the operational as well as IT security
- Anonymous evaluation of access patterns to improve our offer, and if necessary, for prosecution or the pursuit of claims.li>
Which data are processed?
Even while you are visiting our website, our web server, that is the computer on which this website is saved, usually automatically saves data such as
- the full address (URL) of the accessed website (e. g. https://www.examplepage.uk/examplesubpage.html?tid=122534183)
- browser and browser version (e.g. Chrome 87)
- the operating system used (e.g. Windows 10)
- the address (URL) of the previously visited page (referrer URL) (e. g. https://www.examplepage.uk/icamefromhere.html/)
- the host name and the IP address of the device from the website is being accessed from (e.g. COMPUTERNAME and 194.23.43.121)
- date and time
- in so-called web server log files
How long is the data stored?
Generally, the data mentioned above are stored for two weeks and are then automatically deleted. We do not pass these data on to others, but we cannot rule out the possibility that this data may be viewed by the authorities in the event of illegal conduct.
In short: Your visit is logged by our provider (company that runs our website on special computers (servers)), but we do not pass on your data without your consent!
Legal basis
The lawfulness of processing personal data in the context of web hosting is justified in Art. 6 para. 1 lit. f GDPR (safeguarding of legitimate interests), as the use of professional hosting with a provider is necessary to present the company in a safe and user-friendly manner on the internet, as well as to have the ability to track any attacks and claims, if necessary.
Web Analytics
Web Analytics Privacy Policy Overview 👥 Affected parties: visitors to the website 🤝 Purpose: Evaluation of visitor information to optimise the website. 📓 Processed data: Access statistics that contain data such as access location, device data, access duration and time, navigation behaviour, click behaviour and IP addresses. You can find more details on this from the respective web analytics tool directly. 📅 Storage period: depending on the respective web analytics tool used ⚖️ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests) |
What is Web Analytics?
We use software on our website, which is known as web analytics, in order to evaluate website visitor behaviour. Thus, data is collected, which the analytic tool provider (also called tracking tool) stores, manages and processes. Analyses of user behaviour on our website are created with this data, which we as the website operator receive. Most tools also offer various testing options. These enable us, to for example test which offers or content our visitors prefer. For this, we may show you two different offers for a limited period of time. After the test (a so-called A/B test) we know which product or content our website visitors find more interesting. For such testing as well as for various other analyses, user profiles are created and the respective data is stored in cookies.
Why do we run Web Analytics?
We have a clear goal in mind when it comes to our website: we want to offer our industry’s best website on the market. Therefore, we want to give you both, the best and most interesting offer as well as comfort when you visit our website. With web analysis tools, we can observe the behaviour of our website visitors, and then improve our website accordingly for you and for us. For example, we can see the average age of our visitors, where they come from, the times our website gets visited the most, and which content or products are particularly popular. All this information helps us to optimise our website and adapt it to your needs, interests and wishes.
Which data are processed?
The exact data that is stored depends on the analysis tools that are being used. But generally, data such as the content you view on our website are stored, as well as e. g. which buttons or links you click, when you open a page, which browser you use, which device (PC, tablet, smartphone, etc.) you visit the website with, or which computer system you use. If you have agreed that location data may also be collected, this data may also be processed by the provider of the web analysis tool.
Moreover, your IP address is also stored. According to the General Data Protection Regulation (GDPR), IP addresses are personal data. However, your IP address is usually stored in a pseudonymised form (i.e. in an unrecognisable and abbreviated form). No directly linkable data such as your name, age, address or email address are stored for testing purposes, web analyses and web optimisations. If this data is collected, it is retained in a pseudonymised form. Therefore, it cannot be used to identify you as a person.
The following example shows Google Analytics’ functionality as an example for client-based web tracking with JavaScript code.
The storage period of the respective data always depends on the provider. Some cookies only retain data for a few minutes or until you leave the website, while other cookies can store data for several years.
Duration of data processing
If we have any further information on the duration of data processing, you will find it below. We generally only process personal data for as long as is absolutely necessary to provide products and services. The storage period may be extended if it is required by law, such as for accounting purposes for example for accounting.
Right to object
You also have the option and the right to revoke your consent to the use of cookies or third-party providers at any time. This works either via our cookie management tool or via other opt-out functions. For example, you can also prevent data processing by cookies by managing, deactivating or erasing cookies in your browser.
Legal basis
The use of Web Analytics requires your consent, which we obtained with our cookie popup. According to Art. 6 para. 1 lit. a of the GDPR (consent), this consent represents the legal basis for the processing of personal data, such as by collection through Web Analytics tools.
In addition to consent, we have a legitimate interest in analysing the behaviour of website visitors, which enables us to technically and economically improve our offer. With Web Analytics, we can recognise website errors, identify attacks and improve profitability. The legal basis for this is Art. 6 para. 1 lit. f of the GDPR (legitimate interests). Nevertheless, we only use these tools if you have given your consent.
Since Web Analytics tools use cookies, we recommend you to read our privacy policy on cookies. If you want to find out which of your data are stored and processed, you should read the privacy policies of the respective tools.
If available, information on special Web Analytics tools can be found in the following sections.
Google Tag Manager Privacy Policy
Google Tag Manager Privacy Policy Overview 👥 Affected parties: website visitors 🤝 Purpose: Organisation of individual tracking tools 📓 Processed data: Google Tag Manager itself does not store any data. The data record tags of the web analytics tools used. 📅 Storage period: depending on the web analytics tool used ⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests) |
What is Google Tag Manager?
We use Google Tag Manager by the company Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA) for our website.
This Tag Manager is one of Google’s many helpful marketing products. With it, we can centrally integrate and manage code sections of various tracking tools, that we use on our website.
In this privacy statement we will explain in more detail, what Google Tag Manager does, why we use it and to what extent your data is processed.
Google Tag Manager is an organising tool with which we can integrate and manage website tags centrally and via a user interface. Tags are little code sections which e.g. track your activities on our website. For this, segments of JavaScript code are integrated to our site’s source text. The tags often come from Google’s intern products, such as Google Ads or Google Analytics, but tags from other companies can also be integrated and managed via the manager. Since the tags have different tasks, they can collect browser data, feed marketing tools with data, embed buttons, set cookies and track users across several websites.
Why do we use Google Tag Manager for our website?
Everybody knows: Being organised is important! Of course, this also applies to maintenance of our website. In order to organise and design our website as well as possible for you and anyone who is interested in our products and services, we rely on various tracking tools, such as Google Analytics.
The collected data shows us what interests you most, which of our services we should improve, and which other persons we should also display our services to. Furthermore, for this tracking to work, we must implement relevant JavaScript Codes to our website. While we could theoretically integrate every code section of every tracking tool separately into our source text, this would take too much time and we would lose overview. This is the reason why we use Google Tag Manager. We can easily integrate the necessary scripts and manage them from one place. Additionally, Google Tag Manager’s user interface is easy to operate, and requires no programming skills. Therefore, we can easily keep order in our jungle of tags.
What data is stored by Google Tag Manager?
Tag Manager itself is a domain that neither uses cookies nor stores data. It merely functions as an “administrator“ of implemented tags. Data is collected by the individual tags of the different web analysis tools. Therefore, in Google Tag Manager the data is sent to the individual tracking tools and does not get saved.
However, with the integrated tags of different web analysis tools such as Google Analytics, this is quite different. Depending on the analysis tool used, various data on your internet behaviour is collected, stored and processed with the help of cookies. Please read our texts on data protection for more information on the articular analysis and tracking tools we use on our website.
We allowed Google via the account settings for the Tag Manager to receive anonymised data from us. However, this exclusively refers to the use of our Tag Manager and not to your data, which are saved via code sections. We allow Google and others, to receive selected data in anonymous form. Therefore, we agree to the anonymised transfer of our website data. However, even after extensive research we could not find out what summarised and anonymous data it is exactly that gets transmitted. What we do know is that Google deleted any info that could identify our website. Google combines the data with hundreds of other anonymous website data and creates user trends as part of benchmarking measures. Benchmarking is a process of comparing a company’s results with the ones of competitors. As a result, processes can be optimised based on the collected information.
How long and where is the data stored?
When Google stores data, this is done on Google’s own servers. These servers are located all over the world, with most of them being in America. At https://www.google.com/about/datacenters/inside/locations/?hl=en you can read in detail where Google’s servers are.
In our individual data protection texts on the different tools you can find out how long the respective tracking tools store your data.
How can I delete my data or prevent data retention?
Google Tag Manager itself does not set any cookies but manages different tracking websites’ tags. In our data protection texts on the different tracking tools you can find detailed information on how you can delete or manage your data.
Please note that when using this tool, your data may also be stored and processed outside the EU. Most third countries (including the USA) are not considered secure under current European data protection law. Data must not be transferred, stored and processed to insecure third countries, unless there are suitable guarantees (such as EU standard contractual clauses) between us and the non-European service provider.
Legal basis
The use of the Google Tag Manager requires your consent, which we obtained via our cookie popup. According to Art. 6 para. 1 lit. a GDPR (consent), this consent is the legal basis for personal data processing, such as when it is collected by web analytics tools.
In addition to consent, we have a legitimate interest in analysing the behaviour of website visitors and thus technically and economically improving our offer. With the help of Google Tag Managers we can also improve profitability. The legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests). We only use Google Tag Manager if you have given us your consent.
Google also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.
Google uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Google to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847
The Google Ads Data Processing Terms, which reference the standard contractual clauses, can be found at https://business.safety.google/intl/en/adsprocessorterms/
If you want to learn more about Google Tag Manager, we recommend their FAQs at https://support.google.com/tagmanager/?hl=en#topic=3441530.
Jetpack Privacy Policy
Jetpack Privacy Policy Overview 👥 Affected parties: visitors to the website 🤝 Purpose: Evaluation of visitor information to optimise the website. 📓 Processed data: Access statistics that contain data such as the access location , device data, access duration and time, navigation behaviour, click behaviour and IP addresses. 📅 Storage period: until the data is no longer required for the services ⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests) |
What is Jetpack?
We use the WordPress plug-in Jetpack on our website. Jetpack is a software that provides us with an array of services such as web analyses. Jetpack is operated by Automattic (Inc. 132 Hawthorne Street San Francisco, CA 94107, USA), which uses Quantcast (Inc., 201 3rd St, Floor 2, San Francisco, CA 94103-3153, USA). The integrated tracking tool also collects, stores and processes your personal data. In this privacy policy, we will show you exactly which data are involved, why we use Jetpack and how you can prevent this data storage.
Jetpack is a plug-in for WordPress websites and has many different functions and modules. All these tools help us not only to design our website more beautifully, but also to make it safer and to welcome more visitors. Jetpack for example allows to display related posts and to share content. On top of that it can also improve our website’s loading speed. All functions are hosted and provided by WordPress.
Why do we use Jetpack?
It is crucial for us that you feel comfortable on our website and find what you are looking for. We can only be successful if you are satisfied with our services. And for us to know how and where we can improve our website, we need information. With Jetpack we can for example see how often and for how long you are on a single site or which buttons you tend to click. With the help of this information, we can improve our website and adapt it to your wishes and preferences.
Which data are stored by Jetpack?
Your personal data will be identified, stored and processed, which is done especially through the built-in tracking tool WordPress.com-statistics. In order for Jetpack to work, Jetpack will set a cookie in your browser when you open a website with built-in components of the tool. The collected data will be synchronised with Automattic and stored there.
In addition to your IP address (which is anonymised before storage), the retained data includes data on your user behaviour, which is for example your browser type, unique device identifier, preferred language, the date and time of page entry, your operating system and information about your mobile network. Jetpack uses this information to improve its own services and offers and to get better insights on the use of its services. The following data may also be synchronised and stored:
- For Google Ads customers, email address and physical address of the account will be synchronised
- Successful and unsuccessful login attempts. Your IP address and the user agent will also be stored for this purpose
- User IDs, usernames, email addresses, roles, and skills of the registered users. However, no passwords will be retained
- The user ID of users who make changes to the website
- Twitter username, if it has been configured with Jetpack
Jetpack also uses cookies to store data. In the following we will show you a few exemplary cookies that Jetpack may use:
Name: eucookielaw
Value: 1613651061376122534183-6
Purpose: Stores the status of the user’s consent to the use of cookies.
Expiry date: after 180 days
Name: tk_ai
Value: 0
Purpose: This cookie stores a randomly generated anonymous ID. It is only used within the admin area to keep track of general analyses.
Expiry date: after end of the session
Name: tk_tc
Value: E3%2BgJ1Pw6iYKk%2Fvj122534183-3
Purpose: This is a so-called referral cookie. With it, the connection between WooCommerce and a website with a Jetpack plugin is analysed.
Expiry date: after end of the session
Note: Jetpack uses many different cookies. Which cookies are actually used depends on what Jetpack functions are used and on what your actions are on the websites that have an integrated Jetpack plug-in. At https://jetpack.com/support/cookies/ you will see a list of possible cookies used by Jetpack.
How long and where are the data stored?
Automattic retains the collected data until it is no longer used for its own services. Beyond this period, your data will only stay stored if the company is obliged to keep it for legal reasons. Certain data are deleted after about 30 days. These include web server logs such as your IP address, browser type and operating system. The data are stored on the company’s American servers.
How can I erase my data or prevent data retention?
As mentioned above, Jetpack uses cookies to retain data. If you do not want Jetpack to collect your data in the future, you can request an “Opt-Out” cookie at https://www.quantcast.com/opt-out/. Quantcast will then place this cookie and none of your visitor data will be stored. This will be the case until you delete this cookie again.
Alternatively, you can easily manage, deactivate or delete cookies yourself in your browser if you want to. Cookie management works a little differently depending on the browser type you are using. In the following, you will find instructions to do this in the most common browsers.
Chrome: Clear, enable and manage cookies in Chrome
Safari: Manage cookies and website data in Safari
Firefox: Clear cookies and site data in Firefox
Internet Explorer: Delete and manage cookies
Microsoft Edge: Delete cookies in Microsoft Edge
Legal basis
The use of Jetpack requires your consent, which we obtained via our cookie popup. According to Art. 6 para. 1 lit. a GDPR (consent) , this consent represents the legal basis for the personal data processing, such as when it is collected by web analytics tools.
In addition to consent, we have legitimate interest in analysing the behaviour of website visitors and thus technically and economically improving our offer. With the help of Jetpack we can recognise website errors, identify attacks and improve profitability. The legal basis for this is Art. 6 para. 1 lit.f GDPR (legitimate interests). Nevertheless, we only use Jetpack if you have given your consent.
Jetpack also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.
Jetpack uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Jetpack to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=en
If you want to find out more about the privacy guidelines and data processing by Jetpack or Automattic, we recommend you to read the privacy policy at https://automattic.com/privacy/, the cookie guidelines at https://automattic.com/cookies/ and also the information page at https://jetpack.com/support/what-data-does-jetpack-sync/. We hope we could provide you with a good overview on Jetpack’s data processing.
Push Messages
Push Messages Overview 👥 Affected parties: subscribers to push messages 🤝 Purpose: to notify you about interesting events that are relevant to the system 📓 Processed data: data that was entered during registration, usually also location data. You can find more details on this at the respective push notification tool. 📅 Storage period: data are usually stored for as long as is necessary for the service provision. ⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. b GDPR (contract) |
What are push notifications?
We use so-called push notification services on our website, which help us to keep our users up to date. Thus, if you have agreed to the use of such push notifications, we can send you short news using a software tool. Push messages are text messages that appear on your smartphone or on other devices such as tablets or PCs, provided you have registered for them. You can also receive these messages if you are not on our website at this point in time, or are not actively using our offer. Moreover, data about your location and your user behaviour may also be collected and stored.
Why do we use push notifications?
On the one hand, we use push notifications to be able to fully provide the services we have contractually agreed to with you. On the other hand, they are helpful to our online marketing. This is because we can show you our services or products better with them. Thus, we can inform you immediately if there is e.g. any news in our company. We also want to get to know our users’ preferences and habits as well as possible, in order to continuously improve our offer.
Which data are processed?
For you to receive push notifications, you must confirm that you want to receive them. Any data accumulated during the process of confirming your consent is stored, managed and processed. This is necessary to recognise and proof users’ consent to receiving push notifications. Hence, a so-called device token or push token is stored in your browser. Along with this, your location data or the location of your device are usually also retained.
We also statistically evaluate how you handle our messages, so we can always send you push messages that are important and interesting. Thus, we can e.g. see when you open a message. With this knowledge we can adapt our communication strategy to your wishes and interests. Although this stored data could be assigned to you, we do not want to screen you as an individual. Rather, we are interested in the collected data from all our users so we can optimise further. In the privacy policies of the respective service providers, you can find out which data is stored exactly.
Duration of data processing
The duration of data processing and retention depends primarily on the tool we use. Below you can find out more about data processing of the individual tools. The providers’ privacy policies usually state exactly which data is stored and processed and for how long. Generally, personal data is only processed for as long as is necessary for the provision of our services. If data is stored in cookies, the storage duration can vary greatly. On the one hand, this data may be deleted immediately after leaving a website, and on the other hand it may get stored for several years. Therefore, if you want to know more about data storage, you should look at each individual cookie in detail. In most cases, you will also find informative information on individual cookies in the privacy policies of the respective providers.
Legal basis
It may be possible, that push messages may be necessary for us to be able to fulfill certain obligations in a contract. An example would be us notifying you about technical or organisational news. In this case, the legal basis is Art. 6 paragraph 1 lit. b of the GDPR.
Should this not be the case, push notifications will only be sent on the basis of your consent. Our push messages may particularly include advertising content. Furthermore, push notifications may also be sent depending on your location displayed on your device. The above-mentioned analytical evaluations are also based on your consent to their receipt. The legal basis for this is Article 6 (1) (a) of the GDPR. Of course, you can either revoke your consent at any time in the settings, or change various settings.
Messenger & Communication Introduction
Messenger & Communication Privacy Statement Overview 👥 Affected parties: website visitors 🤝 Purpose: for contact requests and general communications between yourself and us 📓 Processed data: Data such as name, address, email address, telephone number, general content data, plus IP address if applicable You can find more details on this under the respective tools used. 📅 Storage duration: depends on the messenger & communication functions ⚖️ Legal bases: Article 6 paragraph 1 letter a GDPR (consent), Article 6 paragraph 1 letter f GDPR (legitimate interests), Article 6 paragraph 1 sentence 1 letter b. GDPR (contractual or pre-contractual obligations) |
What are Messenger & Communication functions?
We offer you various options on our website to communicate with us (e.g. messenger and chat functions, online or contact forms, email, telephone). With the use of these functions, your data will be processed and stored insofar as it is necessary to answer your inquiry and conduct any of our subsequent measures.
In addition to classic means of communication such as email, contact forms or telephone, we also use chats or messengers. The most commonly used messenger function at the moment is WhatsApp, but of course, there are many different providers who offer messenger functions for websites. If content is end-to-end encrypted, it will be indicated in our individual privacy policies or in the privacy policy of the respective provider. End-to-end encryption means that the content of a message is not visible to the provider themselves. However, information about your device, location settings and other technical data can still be processed and stored.
Why do we use Messenger & Communication functions?
The ability to communicate with you is very important to us. After all, we want to keep the conversation with you going and answer any questions you may have about our service as best we can. Needless to say, smooth communication is an important part of our service. With our practical messenger & communication functions, you always have the option to choose the ones you prefer most. In exceptional cases, however, we may not be able to answer certain questions via chat or messenger. This may be the case for internal contractual matters, for example. For matters like these, we recommend you to use other communication options such as email or telephone.
We generally assume our responsibility under data protection law, even if we use the services of any social media platform. However, the European Court of Justice has decided that in certain cases the operator of the social media platform be jointly responsible alongside us in the scope of Art. 26 GDPR. Should this be the case, we will point it out separately and work on the basis of a relevant agreement. You will find the essence of the agreement for the respective platforms below.
Please note that when using our integrated elements, your data may also be processed outside the European Union, since many providers, such as Facebook Messenger or WhatsApp, are American companies. As a result, you may not be able to claim or enforce your rights in relation to your personal data as easily.
Which data is processed?
Exactly which data is retained and processed depends on the respective messenger & communication function provider. In general, it is data such as your name, address, telephone number, email address and content data such as any information you enter into a contact form. In most cases, information about your device and IP address are also stored. Moreover, data that are transmitted via a messenger & communication function are also stored on the providers’ servers.
If you want to know exactly which data is stored and processed by the respective providers and how you can object to the data processing, you please carefully read the respective privacy policy of the company in question.
How long is data stored?
How long data is processed and stored depends primarily on the tools we use. Below you can find out more about the data processing of individual tools. The providers’ privacy policies usually state exactly which data is stored and processed and for how long. In general, we only process personal data for as long as necessary to provide our services. When data is stored in cookies, the storage period varies greatly. Data may e.g. be deleted immediately after leaving a website, or they may be stored for several years. Therefore, you should study each individual cookie in detail if you want to know more about data storage. In most cases, you will also find helpful information about individual cookies in the privacy policies of the individual providers.
Right to object
You also have the right and the option to revoke your consent to the use of cookies or third-party providers at any time. This can be done either via our cookie management tool or via other opt-out functions. For example, you can also prevent data collection by cookies by managing, deactivating or deleting the cookies in your browser. For more information, we recommend you to read the Consent section.
Since cookies may be in use with messenger & communication functions, we recommend you to read our general privacy policy on cookies. To find out exactly which of your data is stored and processed, please read the privacy policies of the respective tools.
Legal Basis
If you have consented to the data processing and storage by integrated messenger & communication functions, this consent is the legal basis for data processing (Art. 6 Para. 1 lit. a GDPR). We process your request and manage your data within the framework of contractual or pre-contractual relationships in order to fulfill our pre-contractual and contractual obligations or to answer inquiries. The basis for this is Art. 6 Para. 1 section 1 lit. b GDPR. In general, if you have given your consent, your data will also be stored and processed on the basis of our legitimate interest (Art. 6 Para. 1 lit. f GDPR) in quick and smooth communication with you or other customers and business partners.
Social Media
Social Media Privacy Policy Overview 👥 Affected parties: website visitors 🤝 Purpose: Service presentation and optimisation, staying in contact with visitors, interested parties, etc. as well as advertising 📓 Processed data: data such as telephone numbers, email addresses, contact data, data on user behaviour, information about your device and your IP address. You can find more details on this directly at the respective social media tool used. 📅 Storage period: depending on the social media platforms used ⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests) |
What is Social Media?
In addition to our website, we are also active on various social media platforms. For us to be able to target interested users via social networks, user data may be processed. Additionally, elements of social media platforms may be embedded directly in our website. This is e.g. the case if you click a so-called social button on our website and are forwarded directly to our social media presence. So-called social media are websites and apps on which registered members can produce and exchange content with other members, be it openly or in certain groups and networks.
Why do we use Social Media?
For years, social media platforms have been the place where people communicate and get into contact online. With our social media presence, we can familiarise interested people better with our products and services. The social media elements integrated on our website help you switch to our social media content quickly and hassle free.
The data that is retained and processed when you use a social media channel is primarily used to conduct web analyses. The aim of these analyses is to be able to develop more precise and personal marketing and advertising strategies. The evaluated data on your behaviour on any social media platform can help to draw appropriate conclusions about your interests. Moreover, so-called user profiles can be created. Thus, the platforms may also to present you with customised advertisements. For this, cookies are usually placed in your browser, which store data on your user behaviour.
We generally assume that we will continue to be responsible under Data Protection Law, even when using the services of a social media platform. However, the European Court of Justice has ruled that, within the meaning of Art. 26 GDPR, in certain cases the operator of the social media platform can be jointly responsible with us. Should this be the case, we will point it out separately and work on the basis of a related agreement. You will then find the essence of the agreement for the concerned platform below.
Please note that when you use social media platforms or our built-in elements, your data may also be processed outside the European Union, as many social media channels, such as Facebook or Twitter, are American companies. As a result, you may no longer be able to easily claim or enforce your rights regarding your personal data.
Which data are processed?
Exactly which data are stored and processed depends on the respective provider of the social media platform. But usually it is data such as telephone numbers, email addresses, data you enter in contact forms, user data such as which buttons you click, what you like or who you follow, when you visited which pages, as well as information about your device and IP address. Most of this data is stored in cookies. Should you have a profile on the social media channel you are visiting and are logged in, data may be linked to your profile.
All data that are collected via social media platforms are also stored on the providers’ servers. This means that only the providers have access to the data and can provide you with appropriate information or make changes for you.
If you want to know exactly which data is stored and processed by social media providers and how you can object to the data processing, we recommend you to carefully read the privacy policy of the respective company. We also recommend you to contact the provider directly if you have any questions about data storage and data processing or if you want to assert any corresponding rights.
Duration of data processing
Provided we have any further information on this, we will inform you about the duration of the data processing below. The social media platform Facebook example stores data until they are no longer needed for the company’s own purposes. However, customer data that is synchronised with your own user data is erased within two days. Generally, we only process personal data for as long as is absolutely necessary for the provision of our services and products. This storage period can also be exceeded however, if it is required by law, such as e.g. in the case of accounting.
Right to object
You also retain the right and the option to revoke your consent to the use of cookies or third-party providers such as embedded social media elements at any time. This can be done either via our cookie management tool or via other opt-out functions. You can e.g. also prevent data collection via cookies by managing, deactivating or erasing cookies in your browser.
Since cookies may be used with social media tools, we also recommend you to read our privacy policy on cookies. If you want to find out which of your data is stored and processed, we advise you to read the privacy policies of the respective tools.
Legal basis
If you have consented to the processing and storage of your data by integrated social media elements, this consent serves as the legal basis for data processing (Art. 6 para. 1 lit. a GDPR). Generally, provided you have given your consent, your data will also be stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f GDPR) in maintaining fast and good communication with you and other customers and business partners. Nevertheless, we only use the tools if you have consented. Most social media platforms also set cookies on your browser to store data. We therefore recommend you to read our privacy policy on cookies carefully and to take a look at the privacy policy or cookie policy of the respective service provider.
in the following section you can find information on special social media platforms – provided this information is available.
Facebook Privacy Policy
Facebook Privacy Policy Overview 👥 Affected parties: website visitors 🤝 Purpose: service optimisation 📓 Processed data: data such as customer data, data on user behaviour, device information and IP address. You can find more details in the Privacy Policy below. 📅 Storage period: until the data no longer serves Facebook’s purposes ⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests) |
What are Facebook tools?
We use selected Facebook tools on our website. Facebook is a social media network of the company Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland. With the aid of this tool we can provide the best possible offers to you and anyone interested in our products and services.
If your data is collected and forwarded via our embedded Facebook elements or via our Facebook page (fanpage), both we and Facebook Ireland Ltd. are responsible for this. However, should any further processing occur, then Facebook is solely responsible for this data. Our joint commitments were also set out in a publicly available agreement at https://www.facebook. com / legal / controller_addendum . It e.g. states that we must clearly inform you about the use of Facebook tools on our website. We are also responsible for ensuring that the tools are securely integrated into our website and are in accordance with the applicable privacy laws. Facebook, on the other hand, is e.g. responsible for the data security of Facebook’s products. If you have any questions about Facebook’s data collection and processing, you can contact the company directly. Should you direct the question to us, we are obliged to forward it to Facebook.
In the following we will give you an overview on the different Facebook tools, as well as on what data is sent to Facebook and how you can erase this data.
Along with many other products, Facebook also offers so called “Facebook Business Tools”. This is Facebook’s official name for its tools, but it is not very common. Therefore, we decided to merely call them “Facebook tools”. They include the following:
- Facebook-Pixel
- Social Plugins (e.g. the “Like” or “Share“ button)
- Facebook Login
- Account Kit
- APIs (application programming interface)
- SDKs (Softwart developmept kits)
- Plattform-integrations
- Plugins
- Codes
- Specifications
- Documentations
- Technologies and Services
With these tools Facebook can extend its services and is able to receive information on user activities outside of Facebook.
Why do we use Facebook tools on our website?
We only want to show our services and products to people who are genuinely interested in them. With the help of advertisements (Facebook Ads) we can reach exactly these people. However, to be able to show suitable adverts to users, Facebook requires additional information on people’s needs and wishes. Therefore, information on the user behaviour (and contact details) on our website, are provided to Facebook. Consequently, Facebook can collect better user data and is able to display suitable adverts for our products or services. Thanks to the tools it is possible to create targeted, customised ad campaigns of Facebook.
Facebook calls data about your behaviour on our website “event data” and uses them for analytics services. That way, Facebook can create “campaign reports” about our ad campaigns’ effectiveness on our behalf. Moreover, by analyses we can get a better insight in how you use our services, our website or our products. Therefore, some of these tools help us optimise your user experience on our website. With the social plugins for instance, you can share our site’s contents directly on Facebook.
What data is stored by Facebook tools?
With the use of Facebook tools, personal data (customer data) may be sent to Facebook. Depending on the tools used, customer data such as name, address, telephone number and IP address may be transmitted.
Facebook uses this information to match the data with the data it has on you (if you are a Facebook member). However, before the customer data is transferred to Facebook, a so called “Hashing” takes place. This means, that a data record of any size is transformed into a string of characters, which also has the purpose of encrypting data.
Moreover, not only contact data, but also “event data“ is transferred. These data are the information we receive about you on our website. To give an example, it allows us to see what subpages you visit or what products you buy from us. Facebook does not disclose the obtained information to third parties (such as advertisers), unless the company has an explicit permission or is legally obliged to do so. Also, “event data“ can be linked to contact information, which helps Facebook to offer improved, customised adverts. Finally, after the previously mentioned matching process, Facebook deletes the contact data.
To deliver optimised advertisements, Facebook only uses event data, if they have been combined with other data (that have been collected by Facebook in other ways). Facebook also uses event data for the purposes of security, protection, development and research. Many of these data are transmitted to Facebook via cookies. Cookies are little text files, that are used for storing data or information in browsers. Depending on the tools used, and on whether you are a Facebook member, a different number of cookies are placed in your browser. In the descriptions of the individual Facebook tools we will go into more detail on Facebook cookies. You can also find general information about the use of Facebook cookies at https://www.facebook.com/policies/cookies.
How long and where are the data stored?
Facebook fundamentally stores data, until they are no longer of use for their own services and products. Facebook has servers for storing their data all around the world. However, customer data is cleared within 48 hours after they have been matched with their own user data.
How can I erase my data or prevent data retention?
In accordance with the General Data Protection Regulation (GDPR) you have the right of information, rectification, transfer and deletion of your data.
The collected data is only fully deleted, when you delete your entire Facebook account. Deleting your Facebook account works as follows:
1) Click on settings in the top right side in Facebook.
2) Then, click “Your Facebook information“ in the left column.
3) Now click on “Deactivation and deletion”.
4) Choose “Permanently delete account“ and then click on “Continue to account deletion“.
5) Enter your password, click on “continue“ and then on “Delete account“.
The retention of data Facebook receives via our site is done via cookies (e.g. with social plugins), among others. You can deactivate, clear or manage both all and individual cookies in your browser. How this can be done differs depending on the browser you use. The following instructions show, how to manage cookies in your browser:
Chrome: Clear, enable and manage cookies in Chrome
Safari: Manage cookies and website data in Safari
Firefox: Clear cookies and site data in Firefox
Internet Explorer: Delete and manage cookies
Microsoft Edge: Delete cookies in Microsoft Edge
If you generally do not want to allow any cookies at all, you can set up your browser to notify you whenever a cookie is about to be set. This gives you the opportunity to decide upon the permission or deletion of every single cookie.
Legal basis
If you have consented to your data being processed and stored by integrated Facebook tools, this consent is the legal basis for data processing (Art. 6 para. 1 lit. a GDPR). Generally, your data is also stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f GDPR) to maintain fast and good communication with you or other customers and business partners. Nevertheless, we only use these tools if you have given your consent. Most social media platforms also set cookies on your browser to store data. We therefore recommend you to read our privacy policy about cookies carefully and to take a look at the privacy policy or Facebook’s cookie policy.
Facebook also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.
Facebook uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Facebook to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847
We hope we could give you an understanding of the most important information about the use of Facebook tools and data processing. If you want to find out more on how Facebook use your data, we recommend reading the data policies at https://www.facebook.com/about/privacy/update.
Facebook Login Privacy Policy
We integrated the convenient Facebook Login to our website. With it, you can easily log into our site with your Facebook account, without having to create a new user account. If you decide to register via the Facebook Login, you will be redirected to the social media network Facebook. There, you can log in with your Facebook user data. By using this method to log in, data on you and your user behaviour is stored and transmitted to Facebook.
To save the data, Facebook uses various cookies. In the following we will show you the most significant cookies that are placed in your browser or that already exist when you log into our site via the Facebook Login:
Name: fr
Value: 0jieyh4c2GnlufEJ9..Bde09j…1.0.Bde09j
Purpose: This cookie is used to make the social plugin function optimally on our website.
Expiry date: after 3 months
Name: datr
Value: 4Jh7XUA2122534183SEmPsSfzCOO4JFFl
Purpose: Facebook sets the “datr” cookie, when a web browser accesses facebook.com. The cookie helps to identify login activities and protect users.
Expiry date: after 2 years
Name: _js_datr
Value: deleted
Purpose: Facebook sets this session cookie for tracking purposes, even if you do not have a Facebook account or are logged out.
Expiry date: after the end of the session
Note: The cookies we stated are only a small range of the cookies which are available to Facebook. Other cookies include for example _ fbp, sb or wd. It is not possible to disclose an exhaustive list, since Facebook have a multitude of cookies at their disposal which they use in variation.
On the one hand, Facebook Login enables a fast and easy registration process. On the other hand, it gives us the opportunity to share data with Facebook. In turn, we can customise our offer and advertising campaigns better to your needs and interests. The data we receive from Facebook by this means, is public data such as
- your Facebook name
- your profile picture
- your stored email address
- friends lists
- button clicks (e.g. “Like“ button)
- date of birth
- language
- place of residence
In return, we provide Facebook with information about your activities on our website. These include information on the terminal device you used, which of our subpages you visit, or what products you have bought from us.
By using Facebook Login, you agree to the data processing. You can terminate this agreement anytime. If you want to learn more about Facebook’s data processing, we recommend you to read Facebook’s Data Policy at https://www.facebook.com/policy.php.
If you are registered with Facebook, you can change your advertisement settings anytime at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.
Facebook Social Plugins Privacy Policy
We installed so-called social plugins from Facebook Inc. to our website. You can recognise these buttons by the classic Facebook logo, the “Like” button (hand with raised thumb) or by a “Facebook plugin” label. A social plugin is a small part of Facebook that is integrated into our page. Each plugin has its own function. The most used functions are the well-known “Like” and “Share” buttons.
Facebook offers the following social plugins:
- “Save” button
- “Like” button, Share, Send and Quote
- Page plugin
- Comments
- Messenger plugin
- Embedded posts and video player
- Group Plugin
At https://developers.facebook.com/docs/plugins you will find more information on how the individual plugins are used. On the one hand, we use the social plug-ins to offer you a better user experience on our site, and on the other hand because Facebook can optimise our advertisements with it.
If you have a Facebook account or have already visited facebook.com, Facebook has already placed at least one cookie in your browser. In this case, your browser sends information to Facebook via this cookie as soon as you visit our website or interact with social plugins (e.g. the “Like” button).
The received information will be deleted or anonymised within 90 days. According to Facebook, this data includes your IP address, the websites you have visited, the date, time and other information relating to your browser.
In order to prevent Facebook from collecting much data and matching it with your Facebook data during your visit to our website, you must log out of Facebook while you visit our website.
If you are not logged in to Facebook or do not have a Facebook account, your browser sends less information to Facebook because you have fewer Facebook cookies. Nevertheless, data such as your IP address or which website you are visiting can be transmitted to Facebook. We would like to explicitly point out that we do not know what exact data is collected. However, based on our current knowledge, we want to try informing you as best we can about data processing. You can also read about how Facebook uses the data in the company’s data policy at https://www.facebook.com/about/privacy/update.
At least the following cookies are set in your browser when you visit a website with social plugins from Facebook:
Name: dpr
Value: no information
Purpose:This cookie is used to make the social plugins work on our website.
Expiry date: after end of session
Name: fr
Value: 0jieyh4122534183c2GnlufEJ9..Bde09j…1.0.Bde09j
Purpose:The cookie is also necessary for the plugins to function properly
Expiry date: after 3 months
Note: These cookies were set after our test and may be placed even if you are not a Facebook member.
If you are registered with Facebook, you can change your settings for advertisements yourself at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. If you are not a Facebook user, you can go to https://www.youronlinechoices.com/uk/your-ad-choices/ and manage your usage-based online advertising. There you have the option to deactivate or activate providers.
If you want to learn more about Facebook’s data protection, we recommend the company’s own data policies at https://www.facebook.com/policy.php.
Instagram Privacy Policy
Instagram Privacy Policy Overview 👥 Affected parties: website visitors 🤝 Purpose: optimising our service 📓 Processed data: includes data on user behaviour, information about your device and IP address. More details can be found in the privacy policy below. 📅 Storage period: until Instagram no longer needs the data for its purposes ⚖️ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests) |
What is Instagram?
We have integrated functions of Instagram to our website. Instagram is a social media platform of the company Instagram LLC, 1601 Willow Rd, Menlo Park CA 94025, USA. Since 2012, Instagram is a subsidiary company of Facebook Inc. and is a part of Facebook’s products. The inclusion of Instagram’s contents on our website is called embedding. With this, we can show you Instagram contents such as buttons, photos or videos directly on our website. If you open websites of our online presence, that have an integrated Instagram function, data gets transmitted to, as well as stored and processed by Instagram. Instagram uses the same systems and technologies as Facebook. Therefore, your data will be processed across all Facebook firms.
In the following, we want to give you a more detailed insight on why Instagram collects data, what data these are and how you can control data processing. As Instagram belongs to Facebook Inc., we have, on the one hand received this information from the Instagram guidelines, and on the other hand from Facebook’s Data Policy.
Instagram is one of the most famous social media networks worldwide. Instagram combines the benefits of a blog with the benefits of audio-visual platforms such as YouTube or Vimeo. To “Insta“ (how the platform is casually called by many users) you can upload photos and short videos, edit them with different filters and also share them to other social networks. Also, if you do not want to be active on Instagram yourself, you can just follow other interesting users.
Why do we use Instagram on our website?
Instagram is a social media platform whose success has skyrocketed within recent years. Naturally, we have also reacted to this boom. We want you to feel as comfortable as possible on our website. Therefore, we attach great importance to diversified contents. With the embedded Instagram features we can enrich our content with helpful, funny or exciting Instagram contents. Since Instagram is a subsidiary company of Facebook, the collected data can also serve us for customised advertising on Facebook. Hence, only persons who are genuinely interested in our products or services can see our ads.
Instagram also uses the collected data for tracking and analysis purposes. We receive summarised statistics and therefore more insight to your wishes and interests. It is important to mention that these reports do not identify you personally.
What data is stored by Instagram?
Whenever you land on one of our sites, which have Instagram functions (i.e. Instagram photos or plugins) integrated to them, your browser automatically connects with Instagram’s servers. Thereby, data is sent to, as well as saved and processed by Instagram. This always happens, whether you have an Instagram account or not. Moreover, it includes information on our website, your computer, your purchases, the advertisements you see and on how you use our offer. The date and time of your interaction is also stored. If you have an Instagram account or are logged in, Instagram saves significantly more data on you.
Facebook distinguishes between customer data and event data. We assume this is also the case for Instagram. Customer data are for example names, addresses, phone numbers and IP addresses. These data are only transmitted to Instagram, if they have been “hashed” first. Thereby, a set of data is transformed into a string of characters, which encrypts any contact data. Moreover, the aforementioned “event data“ (data on your user behaviour) is transmitted as well. It is also possible, that contact data may get combined with event data. The collected data data is matched with any data Instagram already has on you.
Furthermore, the gathered data are transferred to Facebook via little text files (cookies) which usually get set in your browser. Depending on the Instagram function used, and whether you have an Instagram account yourself, the amount of data that gets stored varies.
We assume data processing on Instagram works the same way as on Facebook. Therefore, if you have an account on Instagram or have visited www.instagram.com, Instagram has set at least one cookie. If this is the case, your browser uses the cookie to send information to Instagram, as soon as you come across an Instagram function. No later than 90 days (after matching) the data is deleted or anonymised. Even though we have studied Instagram’s data processing in-depth, we cannot tell for sure what exact data Instagram collects and retains.
In the following we will show you a list of the least cookies placed in your browser when click on an Instagram function (e.g. button or an Insta picture). In our test we assume you do not have an Instagram account, since if you would be logged in to your Instagram account, your browser would place significantly more cookies.
The following cookies were used in our test:
Name: csrftoken
Value: “”
Purpose: This cookie is most likely set for security reasons to prevent falsifications of requests. We could not find out more information on it.
Expiry date: after one year
Name: mid
Value: “”
Purpose: Instagram places this cookie to optimise its own offers and services in- and outside of Instagram. The cookie allocates a unique user ID.
Expiry date: after end of session
Name: fbsr_122534183124024
Value: no information
Purpose: This cookie stores the login request of Instagram app users.
Expiry date: after end of session
Name: rur
Value: ATN
Purpose: This is an Instagram cookie which guarantees functionality on Instagram.
Expiry date: after end of session
Name: urlgen
Value: “{”194.96.75.33”: 1901}:1iEtYv:Y833k2_UjKvXgYe122534183”
Purpose: This cookie serves Instagram’s marketing purposes.
Expiry date: after end of session
Note: We do not claim this list to be exhaustive. The cookies that are placed in each individual case, depend on the functions embedded as well as on your use of Instagram.
How long and where are these data stored?
Instagram shares the information obtained within the Facebook businesses with external partners and persons you are globally connected with. Data processing is done according to Facebook’s internal data policy. Your data is distributed to Facebook’s servers across the world, partially for security reasons. Most of these servers are in the USA.
How can I erase my data or prevent data retention?
Thanks to the General Data Protection Regulation (GDPR), you have the right of information, rectification, transfer and deletion of your data. Furthermore, you can manage your data in Instagram’s settings. If you want to delete your data on Instagram completely, you will have to delete your Instagram account permanently.
And this is how an Instagram account can be deleted:
First, open the Instagram app. Then, navigate to your profile page, select the three bars in the top right, choose “Settings” and then click “Help”. Now, you will be redirected to the company’s website, where you must click on “Managing Your Account” and then “Delete Your Account”.
When you delete your account completely, Instagram deletes posts such as your photos and status updates. Any information other people shared about you are not a part of your account and do therefore not get deleted.
As mentioned before, Instagram primarily stores your data via cookies. You can manage, deactivate or delete these cookies in your browser. Depending on your browser, managing them varies a bit. We will show you the instructions of the most relevant browsers here.
Chrome: Clear, enable and manage cookies in Chrome
Safari: Manage cookies and website data in Safari
Firefox: Clear cookies and site data in Firefox
Internet Explorer: Delete and manage cookies
Microsoft Edge: Delete cookies in Microsoft Edge
Generally, you can set your browser to notify you whenever a cookie is about to be set. Then you can individually decide upon the permission of every cookie.
Legal basis
If you have consented to the processing and storage of your data by integrated social media elements, this consent is the legal basis for data processing (Art. 6 para. 1 lit. a GDPR) . Generally, your data is also stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f GDPR) to maintain fast and good communication with you or other customers and business partners. We only use the integrated social media elements if you have given your consent. Most social media platforms also place cookies in your browser to store data. We therefore recommend you to read our privacy policy about cookies carefully and to take a look at the privacy policy or the cookie policy of the respective service provider.
Instagram and Facebook also process data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfer to the USA. This can be associated with various risks to the legality and security of data processing.
As a basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfers there, Facebook uses standard contractual clauses approved by the EU Commission (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Facebook to comply with the EU’s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=en
We have tried to give you the most important information about data processing by Instagram. On https://help.instagram.com/519522125107875
you can take a closer look at Instagram’s data guidelines.
Online Marketing
Online Marketing Privacy Policy Overview 👥 Affected parties: visitors to the website 🤝 Purpose: Evaluation of visitor information for website optimisation 📓 Processed data: Access statistics containing data such as access location, device data, access duration and time, navigation behaviour, click behaviour and IP addresses. Personal data such as name or email address may also be processed. You can find more details on this from the respective Online Marketing tool. 📅 Storage period: depending on the Online Marketing tools used ⚖️ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests) |
What is Online Marketing?
Online Marketing refers to all measures that are carried out online to achieve marketing goals, such as increasing brand awareness or doing business transactions. Furthermore, our Online Marketing measures aim to draw people’s attention to our website. In order to be able to show our offer to many interested people, we do Online Marketing. It mostly is about online advertising, content marketing or search engine optimisation. For this, personal data is also stored and processed, to enable us to use Online Marketing efficiently and targeted. On the one hand, the data help us to only show our content to people who are interested in it. On the other hand, it helps us to measure the advertising success of our Online Marketing measures.
Why do we use Online Marketing tools?
We want to show our website to everyone who is interested in our offer. We are aware that this is not possible without conscious measures being taken. That is why we do Online Marketing. There are various tools that make working on our Online Marketing measures easier for us. These also provide suggestions for improvement via data. Thus, we can target our campaigns more precisely to our target group. The ultimate purpose of these Online Marketing tools is to optimise our offer.
Which data are processed?
For our Online Marketing to work and to measure its success, user profiles are created and data are e.g. stored in cookies (small text files). With the help of this data, we can not only advertise in the traditional way, but also present our content directly on our website in the way you prefer. There are various third-party tools that offer these functions and thus collect and store your data accordingly. The aforementioned cookies e.g. store the pages you visit on our website, how long you view these pages, which links or buttons you click or which website you came from. What is more, technical information may also be stored. This may include e.g. your IP address, the browser and device you use to visit our website or the time you accessed our website as well as the time you left. If you have agreed for us to determine your location, we can also store and process it.
Your IP address is stored in pseudonymised form (i.e. shortened). What is more, distinct data that directly identify you as a person, such as your name, address or email address, are only stored in pseudonymised for advertising and Online Marketing purposes. With this data we cannot identify you as a person and only retain the pseudonymised information that is stored in your user profile.
Under certain circumstances, cookies may also be utilised, analysed and used for advertising purposes on other websites that use the same advertising tools. Thus, your data may then also be stored on the servers of the respective provider of the advertising tool.
In rare exceptions, unique data (name, email address, etc.) may also be stored in the user profiles. This can happen, if you are for example a member of a social media channel that we use for our Online Marketing measures and if the network connects previously received data with the user profile.
We only ever receive summarised information from the advertising tools we use that do store data on their servers. We never receive data that can be used to identify you as an individual. What is more, the data only shows how well-placed advertising measures have worked. For example, we can see what measures have caused you or other users to visit our website and purchase a service or product. Based on these analyses we can improve our advertising offer in the future and adapt it more precisely to the needs and wishes of people who are interested.
Duration of data processing
Below we will inform you on the duration of data processing, provided we have this information. In general, we only process personal data for as long as is absolutely necessary to provide our services and products. Data stored in cookies are retained for different lengths of time. Some cookies are deleted after you leave a website, while others may be stored in your browser for a number of years. However, in the respective privacy policies of the respective provider, you will usually find detailed information on the individual cookies this provider uses.
Right of withdrawal
You also retain the right and the option to revoke your consent to the use of cookies or third-party providers at any time. This can be done either via our cookie management tool or via other opt-out functions. You can for example also prevent data collection by cookies if you manage, deactivate or erase cookies in your browser. The legality of the processing remains unaffected to the point of revocation.
Since Online Marketing tools usually use cookies, we also recommend you to read our privacy policy on cookies. If you want to find out which of your data is stored and processed, you should read the privacy policies of the respective tools.
Legal basis
If you have consented to the use of third-party providers, then this consent is the legal basis for the corresponding data processing. According to Art. 6 para. 1 lit. a GDPR (consent) , this consent is the legal basis for personal data processing, as may be done when data is collected by online marketing tools.
Moreover, we have a legitimate interest in measuring our online marketing activities in anonymised form, in order to use this data for optimising our offer and our Marketing. The corresponding legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests) . Nevertheless, we only use these tools if you have given your consent.
Information on special online marketing tools can be found in the following sections, provided this information is available.
Cookie Consent Management Platform
Cookie Consent Management Platform Overview 👥 Affected parties: Website visitors 🤝 Purpose: Obtaining and managing consent to certain cookies and thus the use of certain tools 📓 Processed data: data for managing cookie settings such as IP address, time of consent, type of consent and individual consent. You can find more details on this directly with the tool that is being used. 📅 Storage period: depends on the tool used, periods of several years can be assumed ⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests) |
What is a cookie consent management platform?
We use a Consent Management Platform (CMP) software on our website that makes it easier for us and you to handle the scripts and cookies used correctly and securely. The software automatically creates a cookie pop-up, scans and controls all scripts and cookies, provides you with the cookie consent required under data protection law and helps you and us to keep track of all cookies. Most cookie consent management tools identify and categorize all existing cookies. As a website visitor, you then decide for yourself whether and which scripts and cookies you allow or not. The following graphic shows the relationship between browser, web server and CMP.
Why do we use a cookie management tool?
Our goal is to offer you the best possible transparency in the area of data protection. We are also legally obliged to do so. We want to inform you as well as possible about all tools and all cookies that can save and process your data. It is also your right to decide for yourself which cookies you accept and which you do not. In order to grant you this right, we first need to know exactly which cookies actually landed on our website. Thanks to a cookie management tool, which regularly scans the website for all cookies present, we know about all cookies and can provide you with GDPR-compliant information. You can then use the consent system to accept or reject cookies.
Which data are processed?
As part of our cookie management tool, you can manage each individual cookie yourself and have complete control over the storage and processing of your data. The declaration of your consent is stored so that we do not have to ask you every time you visit our website and we can also prove your consent if required by law. This is saved either in an opt-in cookie or on a server. The storage time of your cookie consent varies depending on the provider of the cookie management tool. Usually this data (e.g. pseudonymous user ID, time of consent, detailed information on the cookie categories or tools, browser, device information) is stored for up to two years.
Duration of data processing
We will inform you below about the duration of the data processing if we have further information. In general, we only process personal data for as long as is absolutely necessary for the provision of our services and products. Data stored in cookies are stored for different lengths of time. Some cookies are deleted after you leave the website, others may be stored in your browser for a few years. The exact duration of the data processing depends on the tool used, in most cases you should be prepared for a storage period of several years. In the respective data protection declarations of the individual providers, you will usually receive precise information about the duration of the data processing.
Right of objection
You also have the right and the option to revoke your consent to the use of cookies at any time. This works either via our cookie management tool or via other opt-out functions. For example, you can also prevent data collection by cookies by managing, deactivating or deleting cookies in your browser.
Information on special cookie management tools can be found – if available – in the following sections.
Legal basis
If you agree to cookies, your personal data will be processed and stored via these cookies. If we are allowed to use cookies with your consent (Article 6 paragraph 1 lit. a GDPR), this consent is also the legal basis for the use of cookies and the processing of your data. In order to be able to manage the consent to cookies and to enable you to give your consent, a cookie consent management platform software is used. The use of this software enables us to operate the website in an efficient and legally compliant manner, which is a legitimate interest (Article 6 paragraph 1 lit. f GDPR).
Security & Anti-spam
Security & Anti-Spam Privacy Policy Overview 👥 Affected parties: website visitors 🤝 Purpose: for cyber security 📓 Processed data: Data such as your IP address, name or technical data such as browser version More details can be found below and in the individual privacy policies. 📅 Duration of storage: In most cases, data is stored until it is no longer required in order to provide the service ⚖️ Legal bases: Article 6 paragraph 1 lit. a GDPR (consent), Article 6 paragraph 1 lit. f GDPR (legitimate interests) |
What is Security & Anti-spam software?
So-called security & Anti-spam software can protect you and us from various spam or phishing emails and other potential cyber-attacks. Spam includes advertising emails from mass mailings that you did not sign up for yourself. Such emails are also called data garbage and can also cause costs. Other spam such as phishing emails, on the other hand, are messages that aim to gain trust via fake messages or websites in order to obtain personal information. Anti-spam software usually protects against unwanted spam messages or malicious emails that could inject viruses into our system. We also use general firewall and security systems that protect our devices from unwanted network attacks.
Why do we use Security & Anti-spam software?
We put great importance on our website’s security. After all, this is not just about our safety, but also about your safety. Unfortunately, cyber threats are now part of everyday life in the world of IT and the internet. Hackers e. g. often try to steal personal data from IT systems with the help of cyber attacks. And therefore a good defence system is absolutely necessary. A security system monitors all incoming and outgoing connections to our network or computer. In order to achieve even greater security against cyber attacks, we also use other external security services on our devices in addition to standardised security systems. Unauthorised data transmissions are thus better prevented and this is how we protect ourselves from cybercrime.
Which data are processed by Security & Anti-spam software?
The data that is collected and stored of course depends on the respective service. However, we always try to only use programs that collect data very sparingly or only store data that is necessary for the fulfilment of the offered service. In general, the service may store data such as name, address, IP address, email address and technical data such as browser type or browser version. Any performance and log data may also be collected in order to identify possible incoming threats in good time. This data will be processed as part of the provided services and in compliance with applicable laws. This also includes the GDPR for US providers (via the Standard Contractual Clauses). In some cases, security services also work with third parties who may store and/or process data under instructions and in accordance with privacy policies and other security measures. Data is usually stored using cookies.
Duration of data processing
We will inform you below about the duration of data processing, provided we have further information on this. For example, security programs store data until you or we revoke data storage. In general, personal data is only stored for as long as is absolutely necessary for the provision of the services. Unfortunately, in many cases, we do not have precise information from the providers about their data storage periods.
Right to object
You also have the right and the option to revoke your consent to the use of cookies or third-party security software at any time. This can be done either via our cookie management tool or via other opt-out functions. For example, you can also prevent data collection through cookies by managing, deactivating or erasing the cookies in your browser.
Since cookies may also be used with security services, we recommend you read our privacy policy on cookies. To find out exactly which of your data is stored and processed, you should read the privacy policies of the respective tools.
Legal Basis
We use security services mainly on the basis of our legitimate interests (Art. 6 Para. 1 lit. f GDPR) in a good security system and protection against various cyber attacks.
Certain data processing requires your consent – in particular, the use of cookies and security functions. If you have agreed to the processing and storage of your data by integrated security services, your consent is the legal basis for data processing (Article 6 (1) (a) GDPR). Most of the services we use set cookies on your browser to store data. We, therefore, recommend you read our privacy policy on cookies carefully and consult the privacy policy or cookie policy of the relevant service provider.
Information on special tools – if available – can be found in the following sections.
Google reCAPTCHA Privacy Policy
Google reCAPTCHA Privacy Policy Overview 👥 Affected parties: website visitors 🤝 Purpose: Service optimisation and protection against cyber attacks 📓 Processed data: data such as IP address, browser information, operating system, limited location and usage data You can find more details on this in the Privacy Policy below. 📅 Storage duration: depending on the retained data ⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests) |
What is reCAPTCHA?
Our primary goal is to provide you an experience on our website that is as secure and protected as possible. To do this, we use Google reCAPTCHA from Google Inc. (1600 Amphitheater Parkway Mountain View, CA 94043, USA). With reCAPTCHA we can determine whether you are a real person from flesh and bones, and not a robot or a spam software. By spam we mean any electronically undesirable information we receive involuntarily. Classic CAPTCHAS usually needed you to solve text or picture puzzles to check. But thanks to Google’s reCAPTCHA you usually do have to do such puzzles. Most of the times it is enough to simply tick a box and confirm you are not a bot. With the new Invisible reCAPTCHA version you don’t even have to tick a box. In this privacy policy you will find out how exactly this works, and what data is used for it.
reCAPTCHA is a free captcha service from Google that protects websites from spam software and misuse by non-human visitors. This service is used the most when you fill out forms on the Internet. A captcha service is a type of automatic Turing-test that is designed to ensure specific actions on the Internet are done by human beings and not bots. During the classic Turing-test (named after computer scientist Alan Turing), a person differentiates between bot and human. With Captchas, a computer or software program does the same. Classic captchas function with small tasks that are easy to solve for humans but provide considerable difficulties to machines. With reCAPTCHA, you no longer must actively solve puzzles. The tool uses modern risk techniques to distinguish people from bots. The only thing you must do there, is to tick the text field “I am not a robot”. However, with Invisible reCAPTCHA even that is no longer necessary. reCAPTCHA, integrates a JavaScript element into the source text, after which the tool then runs in the background and analyses your user behaviour. The software calculates a so-called captcha score from your user actions. Google uses this score to calculate the likelihood of you being a human, before entering the captcha. reCAPTCHA and Captchas in general are used every time bots could manipulate or misuse certain actions (such as registrations, surveys, etc.).
Why do we use reCAPTCHA on our website?
We only want to welcome people from flesh and bones on our side and want bots or spam software of all kinds to stay away. Therefore, we are doing everything we can to stay protected and to offer you the highest possible user friendliness. For this reason, we use Google reCAPTCHA from Google. Thus, we can be pretty sure that we will remain a “bot-free” website. Using reCAPTCHA, data is transmitted to Google to determine whether you genuinely are human. reCAPTCHA thus ensures our website’s and subsequently your security. Without reCAPTCHA it could e.g. happen that a bot would register as many email addresses as possible when registering, in order to subsequently “spam” forums or blogs with unwanted advertising content. With reCAPTCHA we can avoid such bot attacks.
What data is stored by reCAPTCHA?
reCAPTCHA collects personal user data to determine whether the actions on our website are made by people. Thus, IP addresses and other data Google needs for its reCAPTCHA service, may be sent to Google. Within member states of the European Economic Area, IP addresses are almost always compressed before the data makes its way to a server in the USA. Moreover, your IP address will not be combined with any other of Google’s data, unless you are logged into your Google account while using reCAPTCHA. Firstly, the reCAPTCHA algorithm checks whether Google cookies from other Google services (YouTube, Gmail, etc.) have already been placed in your browser. Then reCAPTCHA sets an additional cookie in your browser and takes a snapshot of your browser window.
The following list of collected browser and user data is not exhaustive. Rather, it provides examples of data, which to our knowledge, is processed by Google.
- Referrer URL (the address of the page the visitor has come from)
- IP-address (z.B. 256.123.123.1)
- Information on the operating system (the software that enables the operation of your computers. Popular operating systems are Windows, Mac OS X or Linux)
- Cookies (small text files that save data in your browser)
- Mouse and keyboard behaviour (every action you take with your mouse or keyboard is stored)
- Date and language settings (the language and date you have set on your PC is saved)
- All Javascript objects (JavaScript is a programming language that allows websites to adapt to the user. JavaScript objects can collect all kinds of data under one name)
- Screen resolution (shows how many pixels the image display consists of)
Google may use and analyse this data even before you click on the “I am not a robot” checkmark. In the Invisible reCAPTCHA version, there is no need to even tick at all, as the entire recognition process runs in the background. Moreover, Google have not given details on what information and how much data they retain.
The following cookies are used by reCAPTCHA: With the following list we are referring to Google’s reCAPTCHA demo version at https://www.google.com/recaptcha/api2/demo.
For tracking purposes, all these cookies require a unique identifier. Here is a list of cookies that Google reCAPTCHA has set in the demo version:
Name: IDE
Value: WqTUmlnmv_qXyi_DGNPLESKnRNrpgXoy1K-pAZtAkMbHI-122534183-8
Purpose: This cookie is set by DoubleClick (which is owned by Google) to register and report a user’s interactions with advertisements. With it, ad effectiveness can be measured, and appropriate optimisation measures can be taken. IDE is stored in browsers under the domain doubleclick.net.
Expiry date: after one year
Name: 1P_JAR
Value: 2019-5-14-12
Purpose: This cookie collects website usage statistics and measures conversions. A conversion e.g. takes place, when a user becomes a buyer. The cookie is also used to display relevant adverts to users. Furthermore, the cookie can prevent a user from seeing the same ad more than once.
Expiry date: after one month
Name: ANID
Value: U7j1v3dZa1225341830xgZFmiqWppRWKOr
Purpose: We could not find out much about this cookie. In Google’s privacy statement, the cookie is mentioned in connection with “advertising cookies” such as “DSID”, “FLC”, “AID” and “TAID”. ANID is stored under the domain google.com.
Expiry date: after 9 months
Name: CONSENT
Value: YES+AT.de+20150628-20-0
Purpose: This cookie stores the status of a user’s consent to the use of various Google services. CONSENT also serves to prevent fraudulent logins and to protect user data from unauthorised attacks.
Expiry date: after 19 years
Name: NID
Value: 0WmuWqy122534183zILzqV_nmt3sDXwPeM5Q
Purpose: Google uses NID to customise advertisements to your Google searches. With the help of cookies, Google “remembers” your most frequently entered search queries or your previous ad interactions. Thus, you always receive advertisements tailored to you. The cookie contains a unique ID to collect users’ personal settings for advertising purposes.
Expiry date: after 6 months
Name: DV
Value: gEAABBCjJMXcI0dSAAAANbqc122534183-4
Purpose: This cookie is set when you tick the “I am not a robot” checkmark. Google Analytics uses the cookie personalised advertising. DV collects anonymous information and is also used to distinct between users.
Expiry date: after 10 minutes
Note: We do not claim for this list to be extensive, as Google often change the choice of their cookies.
How long and where are the data stored?
Due to the integration of reCAPTCHA, your data will be transferred to the Google server. Google have not disclosed where exactly this data is stored, despite repeated inquiries. But even without confirmation from Google, it can be assumed that data such as mouse interaction, length of stay on a website or language settings are stored on the European or American Google servers. The IP address that your browser transmits to Google does generally not get merged with other Google data from the company’s other services.
However, the data will be merged if you are logged in to your Google account while using the reCAPTCHA plug-in. Google’s diverging privacy policy applies for this.
How can I erase my data or prevent data retention?
If you want to prevent any data about you and your behaviour to be transmitted to Google, you must fully log out of Google and delete all Google cookies before visiting our website or use the reCAPTCHA software. Generally, the data is automatically sent to Google as soon as you visit our website. To delete this data, you must contact Google Support at https://support.google.com/?hl=en-GB&tid=122534183.
If you use our website, you agree that Google LLC and its representatives automatically collect, edit and use data.
Please note that when using this tool, your data can also be stored and processed outside the EU. Most third countries (including the USA) are not considered secure under current European data protection law. Data to insecure third countries must not simply be transferred to, stored and processed there unless there are suitable guarantees (such as EU’s Standard Contractual Clauses) between us and the non-European service provider.
Legal basis
If you have consented to the use of Google reCAPTCHA, your consent is the legal basis for the corresponding data processing. According to Art. 6 Paragraph 1 lit. a GDPR (consent) your consent is the legal basis for the processing of personal data, as can occur when processed by Google reCAPTCHA.
We also have a legitimate interest in using Google reCAPTCHA to optimise our online service and make it more secure. The corresponding legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests). Nevertheless, we only use Google reCAPTCHA if you have given your consent to it.
Google also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.
Google uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Google to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.
The Google Ads Data Processing Terms, which reference the standard contractual clauses, can be found at https://business.safety.google/intl/en/adsprocessorterms/.
You can find out a little more about reCAPTCHA on Google’s web developer page at https://developers.google.com/recaptcha/. Google goes into the technical development of the reCAPTCHA in more detail here, but you will look in vain for detailed information about data storage and data protection issues. A good overview of the basic use of data by Google can be found in the in-house data protection declaration at https://policies.google.com/privacy?hl=en-GB.
Web Design Introduction
Web Design Privacy Policy Overview 👥 Affected parties: website visitors 🤝 Purpose: improvement of user experience 📓 Processed data: depends heavily on the services used. Usually, data such as IP address, technical data, language settings, browser version, screen resolution and browser name are processed. You can find more details directly with the respective web design tools. 📅 Storage duration: depends on the tools used ⚖️ Legal bases: Article 6 paragraph 1 lit. a GDPR (consent), Article 6 paragraph 1 lit. f GDPR (legitimate interests) |
What is web design?
We use various tools on our website for the purpose of our web design. Contrary to common belief, web design is not just about making our website look nice, but rather also about functionality and performance. But of course, a good-looking website is also a major goal of professional web design. Web design is a part of media design and deals with the visual as well as the structural and functional design of a website. Our aim with our web design is to improve your experience on our site. In web design jargon, this is called User Experience (UX) and usability. User Experience entails all impressions and experiences that website visitors come across on a website. What is more, usability is part of the User Experience, as it determines how user-friendly a website is. This includes the clear structuring of content, subpages or products, along with how quickly and easily the website enables you to find what you are looking for. In order to offer you the best possible experience on our website, we also use so-called third-party web design tools. Therefore, all tools and services that help improve our website’s design are classified under the category “web design”. This may, for example, include fonts, various plugins or other integrated web design functions.
Why do we use web design tools?
The way you absorb information on a website depends very much on its structure, functionality and visual perception. Therefore, good and professional web design has become increasingly important for us. We are constantly working on improving our site as a way of further extending our services for you as a website visitor. Furthermore, a beautiful and functioning website also has economic advantages for us. Needless to say, you will only visit it and take advantage of our offers if you feel completely at ease.
What data is stored by web design tools?
When you visit our website, any web design elements integrated into our pages may process your data. The exact data that is processed depends on the tools used. Below you can see exactly which tools we use for our website. For more information about data processing, we recommend you also read the respective privacy policy of the respective tools. There you can usually find out which data is processed, whether cookies are used and how long the data is stored. Moreover, fonts such as Google Fonts, for example, also automatically transmit information such as your language settings, IP address, browser version, browser screen resolution and browser name to Google’s servers.
Duration of data processing
Data processing times are very individual and depend on the web design elements used. For example, when cookies are used, the retention period can be as little as a minute, but it may also be a few years. Please make yourself familiar with this topic. You may for example read our general section on cookies as well as the Privacy Policies of the tools used. There you can likely find out exactly which cookies are used and what information is stored there. For example, Google Font files are stored for one year, in order to improve the loading speed of a website. In principle, data is only kept for as long as is necessary to provide the service. But legal requirements may require data to be stored for longer.
Right to object
You also retain the right and the option to revoke your consent to the use of cookies or third-party providers at any time. You can do this either via our cookie management tool or via other opt-out functions. You can also prevent cookies from collecting your data by managing, deactivating or deleting the cookies in your browser. However, among web design elements (typically fonts) there is also data that cannot be erased easily. This is the case whenever data is automatically collected as soon as a page is accessed and then directly transmitted to a third party (e.g. Google). In these cases, please contact the support of the respective provider. In the case of Google, you can reach support at https://support.google.com/?hl=de.
Legal Basis
If you have consented to the use of web design tools, this consent serves as the legal basis for the relevant data processing. According to Article 6 (1) (a) GDPR (consent), your consent represents the legal basis for the processing of personal data, as it may occur when it is collected by web design tools. We also have a legitimate interest in web design to improve on our website. After all, only then can we provide you with a beautiful and professional web offer. The corresponding legal basis for this is Article 6 (1) (f) GDPR (legitimate interests). However, we strongly want to emphasise once more that we only use web design tools if you have given your consent.
You can find information on different web design tools – if available – in the following sections.
Google Fonts Privacy Policy
Google Fonts Privacy Policy Overview 👥 Affected parties: website visitors 🤝 Purpose: service optimisation 📓 Processed data: data such as IP address, CSS and font requests You can find more details on this in the Privacy Policy below. 📅 Storage period: Google stores font files for one year ⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests) |
What are Google Fonts?
On our website we use Google Fonts, by the company Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA).
To use Google Fonts, you must log in and set up a password. Furthermore, no cookies will be saved in your browser. The data (CSS, Fonts) will be requested via the Google domains fonts.googleapis.com and fonts.gstatic.com. According to Google, all requests for CSS and fonts are fully separated from any other Google services. If you have a Google account, you do not need to worry that your Google account details are transmitted to Google while you use Google Fonts. Google records the use of CSS (Cascading Style Sheets) as well as the utilised fonts and stores these data securely. We will have a detailed look at how exactly the data storage works.
Google Fonts (previously Google Web Fonts) is a directory with over 800 fonts that Google provides its users free of charge.
Many of these fonts have been published under the SIL Open Font License license, while others have been published under the Apache license. Both are free software licenses.
Why do we use Google Fonts on our website?
With Google Fonts we can use different fonts on our website and do not have to upload them to our own server. Google Fonts is an important element which helps to keep the quality of our website high. All Google fonts are automatically optimised for the web, which saves data volume and is an advantage especially for the use of mobile terminal devices. When you use our website, the low data size provides fast loading times. Moreover, Google Fonts are secure Web Fonts. Various image synthesis systems (rendering) can lead to errors in different browsers, operating systems and mobile terminal devices. These errors could optically distort parts of texts or entire websites. Due to the fast Content Delivery Network (CDN) there are no cross-platform issues with Google Fonts. All common browsers (Google Chrome, Mozilla Firefox, Apple Safari, Opera) are supported by Google Fonts, and it reliably operates on most modern mobile operating systems, including Android 2.2+ and iOS 4.2+ (iPhone, iPad, iPod). We also use Google Fonts for presenting our entire online service as pleasantly and as uniformly as possible.
Which data is stored by Google?
Whenever you visit our website, the fonts are reloaded by a Google server. Through this external cue, data gets transferred to Google’s servers. Therefore, this makes Google recognise that you (or your IP-address) is visiting our website. The Google Fonts API was developed to reduce the usage, storage and gathering of end user data to the minimum needed for the proper depiction of fonts. What is more, API stands for „Application Programming Interface“ and works as a software data intermediary.
Google Fonts stores CSS and font requests safely with Google, and therefore it is protected. Using its collected usage figures, Google can determine how popular the individual fonts are. Google publishes the results on internal analysis pages, such as Google Analytics. Moreover, Google also utilises data of ist own web crawler, in order to determine which websites are using Google fonts. This data is published in Google Fonts’ BigQuery database. Enterpreneurs and developers use Google’s webservice BigQuery to be able to inspect and move big volumes of data.
One more thing that should be considered, is that every request for Google Fonts automatically transmits information such as language preferences, IP address, browser version, as well as the browser’s screen resolution and name to Google’s servers. It cannot be clearly identified if this data is saved, as Google has not directly declared it.
How long and where is the data stored?
Google saves requests for CSS assets for one day in a tag on their servers, which are primarily located outside of the EU. This makes it possible for us to use the fonts by means of a Google stylesheet. With the help of a stylesheet, e.g. designs or fonts of a website can get changed swiftly and easily.
Any font related data is stored with Google for one year. This is because Google’s aim is to fundamentally boost websites’ loading times. With millions of websites referring to the same fonts, they are buffered after the first visit and instantly reappear on any other websites that are visited thereafter. Sometimes Google updates font files to either reduce the data sizes, increase the language coverage or to improve the design.
How can I erase my data or prevent it being stored?
The data Google stores for either a day or a year cannot be deleted easily. Upon opening the page this data is automatically transmitted to Google. In order to clear the data ahead of time, you have to contact Google’s support at https://support.google.com/?hl=en-GB&tid=122534183. The only way for you to prevent the retention of your data is by not visiting our website.
Unlike other web fonts, Google offers us unrestricted access to all its fonts. Thus, we have a vast sea of font types at our disposal, which helps us to get the most out of our website. You can find out more answers and information on Google Fonts at https://developers.google.com/fonts/faq?tid=122534183. While Google does address relevant elements on data protection at this link, it does not contain any detailed information on data retention.
It proofs rather difficult to receive any precise information on stored data by Google.
Legal basis
If you have consented to the use of Google Fonts, your consent is the legal basis for the corresponding data processing. According to Art. 6 Paragraph 1 lit. a GDPR (Consent) your consent is the legal basis for the processing of personal data, as can occur when it is processed by Google Fonts.
We also have a legitimate interest in using Google Font to optimise our online service. The corresponding legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests). Nevertheless, we only use Google Font if you have given your consent to it.
Google also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.
Google uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Google to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847
You can find more information on which data is generally retained by Google and what this data is used at https://policies.google.com/privacy?hl=en-GB.
Online Map Services Introduction
Online Map Services Privacy Policy Overview 👥 Affected parties: website visitors 🤝 Purpose: Improvement of user experience 📓 Processed data: the data that is processed depends heavily on the services used. Usually, it is your IP address, location data, search queries and/or technical data. You can find more details on this under the respective tools used. 📅 Storage duration: depends on the tools used ⚖️ Legal bases: Article 6 paragraph 1 lit. a GDPR (consent), Article 6 paragraph 1 lit. f GDPR (legitimate interests) |
What are Online Map Services?
We also use online map services for our website as an extended service. Google Maps is probably the service you are most familiar with. But there are also other providers out there that specialise in creating digital maps. These services allow the display of locations, route maps or other geographical information directly via our website. Thanks to an integrated map service, you no longer have to leave our website to e. g. view the route to a location. In order to ensure that the online map can run on our website, we have integrated map sections within our HTML code. This way the services can display street maps, the earth’s surface, or aerial or satellite imagery. If you use the built-in map service, your data will be transferred to the tool used, where it will be retained. This may also include your personal data.
Why do we use Online Map Services on our website?
Generally speaking, it is imperative for us to offer you a pleasant time on our website. Of course, we know that you will most likely only enjoy your time here if you can easily find your way around and find all the information you need quickly and easily. Therefore, we decided that an online map system may be a significant optimisation of our website’s service. After all, you can use the map system to easily view route descriptions, locations or any other points of interest – without leaving our site. Needless to say, it is certainly also very practical that you can easily see where our company headquarters are so that you can find us quickly and safely. As you can see, there are just a lot of advantages – and we clearly consider online map services on our website to be part of our customer service.
What data is stored by Online Map Services?
If you open a page on our website with an online map function installed, your personal data may be transmitted to the relevant service, where it may be stored. This usually includes your IP address, which may also be used to determine your approximate location. In addition to your IP address, data such as the search terms you entered, as well as your longitude and latitude coordinates will be stored. If you e. g. enter an address for route planning, this data will also be stored. This data is not stored by us but instead on the servers of the integrated tools. You can think of it like this: You may be on our website, but when you interact with a mapping service, that interaction is actually happening on their website. Moreover, in order for the service to function properly, at least one cookie is usually set in your browser. As an example, Google Maps also uses cookies to record user behaviour, with which it can optimise its own service and offer personalised advertising. You can find out more about cookies in our “Cookies” section.
How long and where is the data stored?
Every online map service processes different user data. Provided we have further information, we will inform you about the duration of data processing in the corresponding sections on the individual tools below. Generally, personal data is only retained for as long as is necessary to provide the service. Google Maps e. g. stores certain data for a specified period of time, but you must erase other data yourself. At Mapbox, for example, your IP address is stored for 30 days after which it is deleted. As you can see, each tool stores data for different lengths of time. We thus recommend you take a closer look at the privacy policies of the tools used.
The providers may use cookies to store data on your user behaviour in relation to their map services. You can find more information about cookies in our “Cookies” section, but in the individual providers’ privacy policies you can most probably also find out which cookies may be used. In most cases, however, this is only an indicative list and is not exhaustive.
Right to object
You always have the possibility and the right to access your personal data and to object to its use and processing. You can also revoke the consent you gave to us at any time. This is usually easiest through the cookie consent tool. However, there are other opt-out tools that you can use. You can also manage, erase or deactivate any cookies set by the used providers yourself with just a few mouse clicks. However, this may lead to some service functions stopping to work as usual. It also depends on your browser how you can manage cookies there. In our “Cookies” section you will find links to instructions of the most popular browsers.
Legal Basis
If you have agreed to the use of an online map service, the legal basis for the corresponding data processing is this consent. According to Article 6 Paragraph 1 lit. (consent) this consent is the legal basis for the processing of personal data as may occur when collected by an online map service.
We also have a legitimate interest in using an online map service to optimise our service on our website. The corresponding legal basis for this is Article 6 (1) (f) GDPR (legitimate interests). However, we only use an online map service if you have given your consent. We definitely wanted to stress this point once again.
You can find information on specific online map services – if available – in the following sections.
Google Maps Privacy Policy
Google Maps Privacy Policy Overview 👥 Affected parties: website visitors 🤝 Purpose: service optimisation 📓 Processed data: data such as entered search terms, IP address as well as latitude and longitude coordinates. You can find more details on this in the Privacy Policy below. 📅 Storage duration: depending on the retained data ⚖️ Legal bases: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests) |
What is Google Maps?
On our website we use Google Maps of the company Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). With the use of Google Maps, we can show you locations in a better way and can therefore adjust our service to your needs. Due to the utilisation of Google Maps, data gets transferred to Google and is saved on Google’s servers. In the following, we want to explain in detail what Google Maps is, why we use this Google service, what data is stored and how you can prevent this.
Google Maps is an internet maps service of the company Google Inc. With Google Maps you can search for exact locations of cities, sights, accommodations or businesses online via a PC, a tablet or an app. If businesses are represented on Google My Business, the respective location as well as other information about the company are shown there. In order to show route directions, a location’s map sections can be integrated in a website through a HTML-code. Google Maps depicts the earth’s surface as either a road map or as air and satellite images. Due to the street view and high-quality satellite images, it is possible for exact representations to be made.
Why do we use Google Maps on our website?
The efforts we make on this page have the goal of giving you a useful and meaningful experience on our website. Through the integration of Google Maps, we can offer you essential information on various locations. Therefore, you can spot our office address with one glance. Furthermore, the route directions always show you the best and fastest way to us. You can retrieve the route directions for traveling either by car, by public transport, on foot or by bike. The integration of Google Maps is a part of our customer service.
What data is stored by Google Maps?
For Google Maps to offer its full services, the company must collect and store your data. This includes your entered search terms, your IP-address as well as your longitude and latitude coordinates. When you use the route-planner function, the entered start address is stored also. However, this data retention happens on Google Maps‘ websites. We can only inform you about it but cannot influence it in any way. Since we have included Google Maps on our website, Google will set at least one cookie (Name: NID) into your browser. This cookie saves data on your user behaviour. Google primarily uses this data to optimise ist own services and to provide you with individual, personalised advertisements.
The following cookies are set in your browser due to the integration of Google Maps:
Name: NID
Value: 188=h26c1Ktha7fCQTx8rXgLyATyITJ122534183-5
Purpose: Google uses NID in order to adjust advertisments to your Google searches. With the cookie’s help Google “remembers“ your most frequently entered search queries or your previous interaction with ads. That way you always receive customised adertisments. The cookie contains a unique ID, wich Google uses to collect your personal settings for advertising porposes.
Expiration date: after 6 months
Note: We cannot guarantee completeness of the information on saved data. This is, because especially concerning the use of cookies, changes can happen anytime. To identify the cookie NID, a test page was created, to which Google Maps was included.
How long and where is the data stored?
There are Google servers in data centres across the entire planet. However, most servers are in America. For this reason, your data is widely stored in the USA. Here you can read in detail about where the Google servers are located: https://www.google.com/about/datacenters/locations/?hl=en
Google distributes data to various data carriers. This makes it possible to retrieve the data faster and to better protect it from possible attempted manipulations. Every server has emergency programs. Thus, should for example a problem with Google’s hardware occur or should a natural disaster impact the servers, any data will quite certainly stay protected.
Moreover, Google saves some data for a specified period. With some other data on the other hand, Google only offers the opportunity for deleting it manually. Furthermore, the company anonymises information (e.g. advertising data) in server logs, by deleting a part of the IP-address and cookie information after 9 to 18 months.
How can I erase my data, or prevent data retention?
Due to the automatic delete function for location and activity data, which was introduced in 2019, information that is used for determining your location and web or app activity is saved for either 3 or 18 months, depending on your preferred decision, and is deleted thereafter. Furthermore, it is possible to delete this data manually from your browser history via your Google account anytime. If you want to prevent the determination of your location altogether, you must pause the category “Web and app activity” in your Google account. Click on “Data and personalisation” and then choose the option “Activity controls”. Here you can switch the activities on or off.
Moreover, in your browser you can deactivate, delete or manage individual cookies. This function can differ a little, depending on what browser you are using. The following instructions will show you how to manage cookies in your browser:
Chrome: Clear, enable and manage cookies in Chrome
Safari: Manage cookies and website data in Safari
Firefox: Clear cookies and site data in Firefox
Internet Explorer: Delete and manage cookies
Microsoft Edge: Delete cookies in Microsoft Edge
If you generally do not want to permit any cookies, you can set up your browser in a way that ensures you get informed whenever a cookie is about to be placed. That way you can decide to either permit or refuse every single cookie.
Please note, that when using this tool, your data may also be stored and processed outside the EU. Most third countries (including the USA) are not considered secure under current European data protection law. Data to insecure third countries must not simply be transferred to, stored and processed there unless there are suitable guarantees (such as EU Standard Contractual Clauses) between us and the non-European service provider.
Legal basis
If you have consented to the use of Google Maps, your consent is the legal basis for the corresponding data processing. According to Art. 6 paragraph 1 lit. a GDPR (consent) this consent is the legal basis for the processing of personal data, as can occur when processed by Google Maps.
We also have a legitimate interest in using Google Maps to optimise our online service. The corresponding legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests). Nevertheless, we only use Google Maps if you have given your consent to it.
Google also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.
Google uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Google to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847
The Google Ads Data Processing Terms, which reference the standard contractual clauses, can be found at https://business.safety.google/intl/en/adsprocessorterms/.
If you want to find out more about Google’s data processing, we recommend you to read the company’s own Privacy Policy at https://policies.google.com/privacy?hl=en-GB.
Online Booking Systems Introduction
Online Booking Systems Privacy Policy Overview 👥 Affected parties: website visitors 🤝 Purpose: improvement of user experience and organisation 📓 Processed data: depends heavily on the services used. Usually, data such as IP address, contact and payment details and/or technical data is processed. You can get more details on this directly from the respective tools used. 📅 Storage duration: depends on the tools used ⚖️ Legal bases: Article 6 paragraph 1 lit. a GDPR (consent), Article 6 paragraph 1 lit. f GDPR (legitimate interests) |
What is an online booking system?
We use one or more booking systems which enable you to make bookings via our website. That way e.g. appointments can easily be created online. A booking system is a software application integrated into our website that displays available resources (such as available appointments) and allows you to book – and usually, also pay – directly online. You’ve probably already come across many such booking systems from the restaurant or hotel industry. However, such systems are actually used in a wide variety of industries. Depending on the tool and settings, booking systems can be used both by us internally, as well as by customers like yourself. In most cases, your personal data is also collected and stored.
Bookings usually work as follows: You will find a booking system on our website, through which you can book an appointment directly with one click. Then you will enter your data and usually also be able to pay immediately. You may also have the option to enter various information about yourself into a form. Please be aware that any information you enter may be stored and managed in a database.
Why do we use an online booking system?
In a way, we also consider our website a free service for you. We want you to receive helpful information on our site and feel comfortable on there. This also includes an online service that makes it as easy as possible for you to book appointments or services. Gone are the days when you had to wait days for booking confirmations via phone or email. With an online booking system, you can get everything done after just a few clicks and get on with your day. The system also makes it easier for us to manage all bookings and appointments. Therefore, we consider a booking system absolutely sensible for both you and ourselves.
Which data is processed?
In this general introduction about booking systems, we naturally cannot tell you exactly what data is processed for which system. It always depends on the tool used, as well as the functions and possibilities it contains. What is more, in addition to the conventional booking function, many booking systems also offer a range of other features. For example, many systems also have an external online payment system (e.g. Stripe, Klarna or Paypal) and an integrated calendar synchronisation function. Accordingly, different data and different amounts of data can be processed, depending on the included functions. Usually, data such as your IP address, name and contact details, technical device information and the time of your booking are processed. If you also make a payment via the system, your bank details such as your account number, credit card number, passwords, TANs etc. will also be stored and passed on to the respective payment provider. We recommend you carefully read the respective privacy policy of the tool used, so that you know which of your data is processed specifically.
Duration of data processing
Each booking system stores data for different lengths of time. Therefore, we cannot yet give any specific information about the duration of data processing in this instance. In general, however, personal data is only stored for as long as is absolutely necessary to provide the services. Booking systems usually also use cookies, which store information for different lengths of time. While some cookies are erased immediately after leaving the site, others can be stored for a number of years. You can find out more about this in our “Cookies” section. Please also take a look at the respective privacy policies of the providers. There you should find answers on how long your data will be stored specifically.
Right to object
If you have consented to data processing by a booking system, you always retain the option and the right to revoke this consent. So please, always be aware that you have rights in relation to your personal data and that you can exercise these rights at any time. Thus, if you do not agree to the processing of your personal data, then none of your personal data may be processed. It is that simple. The easiest way to revoke data processing is via a cookie consent tool or via other available opt-out functions. You can, for example, manage data retention by cookies directly in your browser. Until you withdraw your consent, the lawfulness of data processing remains unaffected.
Legal Basis
If you have agreed that booking systems may be used, this consent is the legal basis for the corresponding data processing. According to Article 6 (1) (a) GDPR (consent), your consent represents the legal basis for the processing of personal data, as it may occur through the use of booking systems.
Furthermore, we also have a legitimate interest in using booking systems because we use them to extend our customer service and to optimise our internal booking organisation. The corresponding legal basis for this is Article 6 (1) (f) GDPR (legitimate interests). However, we strongly want to emphasise once more that we only use these tools if you have given your consent.
You can find information on different booking systems – if available – in the following sections.
Explanation of the terminology used
We always strive to make our privacy policy as clear and comprehensible as possible. However, this is not always easy, especially when it comes to technical and legal matters. It is often sensible to use legal terms (such as ‘personal data)’ or certain technical terms (such as ‘cookies’ or ‘IP address’). But we don’t want to use such terms without any explanation. This is why you will find an alphabetical list of important terms used below. These are terms we may not yet have sufficiently explained in the privacy policy. In case we have adopted any of these terms from the GDPR which are definitions, we will also list the GDPR texts here and add our own further explanations if necessary.
Processor
Definition according to Article 4 of the GDPR
For the purposes of this Regulation, the term means:
“processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
Explanation: As a company and a website owner, we are responsible for all your data we process (i. e. the ‘controller’). In addition to the controller, there may also be so-called processors. This includes any company or person who processes personal data on our behalf. In addition to service providers such as tax consultants, processors can also be hosting or cloud providers, payment or newsletter providers or large companies such as Google or Microsoft.
Consent
Definition according to Article 4 of the GDPR
For the purposes of this Regulation, the term means:
“consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
Explanation: With websites, such consent is usually given via a cookie consent tool. You’ve most certainly come across these. Whenever you visit a website for the first time, you will usually be asked via a banner whether you agree or consent to the data processing. You can usually also make individual settings and thus decide for yourself which level of data processing you want to allow. If you do not give your consent, no personal data may be processed. Consent can of course also be given in writing, i.e. not via a tool.
Personal Data
Definition according to Article 4 of the GDPR
For the purposes of this Regulation, the term means:
“personenal data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
Explanation: Personal data is all data that can identify you as a person. This is usually data such as:
- name
- address
- email address
- postal address
- phone number
- birthday
- identification numbers such as social security number, tax identification number, ID card number or matriculation number
- banking data such as account number, credit information, account balances and more.
According to the European Court of Justice (ECJ), your IP address is also personal data. IT experts can use your IP address to determine at least the approximate location of your device and subsequently your location as the connection owner. Therefore, storing an IP address also requires a legal basis within the scope of the GDPR. There are also so-called “special categories” of personal data, which are particularly worthy of protection. These include:
- racial and ethnic origin
- political opinions
- religious or ideological beliefs
- Union membership
- genetic data such as data obtained from blood or saliva samples
- biometric data (this is information about psychological, physical or behavioural characteristics that can identify an individual).
health Data - Data relating to sexual orientation or sex life
Profiling
Definition according to Article 4 of the GDPR
For the purposes of this Regulation, the term means:
“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;
Explanation: Profiling collects various personal data about an individual in order to learn more about that individual. On the internet, profiling is often used for advertising purposes or for credit checks. Web and advertising analysis programs e. g. collect data about your behaviour and interests on a website. This results in a special user profile that can be used to target advertising to specific target groups.
Controller
Definition according to Article 4 of the GDPR
For the purposes of this Regulation, the term means:
“controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
Explanation: In our example, we are responsible for the processing of your personal data and are therefore the “controller”. If we pass on collected data to other service providers for processing, they are considered “contract processors”. For this, a “Data Processing Agreement (DPA)” must be concluded.
Processing
Definition according to Article 4 of the GDPR
For the purposes of this Regulation, the term means:
“processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
Note: When we talk about processing in our Privacy Policy, we talk about any type of data processing. As mentioned above in the original GDPR declaration, this includes not only the collection but also the storage and processing of data.
Closing Remarks
Congratulations! If you are reading these lines, you have most likely familiarised yourself with our entire Privacy Policy – or at least scrolled down here. As you can see from the scope of our Privacy Policy, we do not take the protection of your personal data lightly.
We find it important to inform you about the processing of your personal data to the best of our abilities. In doing so, we not only want to tell you which data is processed but also explain to you why we use various software programs. In general, Privacy Policies have very technical and legal jargon. However, since most of you are not web developers or solicitors, we wanted to take a different approach and explain the facts in simple and clear language. Of course, this is not always possible due to the subject matter. Therefore, you can also find a more detailed explanation of the most important terms at the end of the Privacy Policy.
If you have any questions about data protection on our website, please do not hesitate to contact us or the responsible body. We wish you all the best and hope to soon welcome you to our website again.
All texts are copyrighted.
Additional Information about ADDITIVE
ADDITIVE+ LANDINGPAGE – Online Marketing and Landing Pages
Beside our website we do also operate optimized landing pages for means of hotel online marketing. To process your request, reservation, order, activation, registration or the transmission of other contact forms on our website as well as to save and store your data we use cloud services, CRM systems and software provided by ADDITIVE Srl, 39011 Lana (BZ), Italy (“ADDITIVE”), our partner in the field of hotel digital marketing. The adequate level of data protection is based on data processing agreements with the respective company.
Our landing pages use Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics enables website operators to analyse the user behavior of the visitors. The information about the user behavior is transmitted to and stored by Google on its servers.
Your IP address is collected but immediately anonymised (for example by deleting the last 8 bits). As a result the geolocation data is less accurate.
You can prevent the data collection connected to your use of our online services through cookies and the processing of this data by Google, by installing the browser-plugin available at the following link:
https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh
ADDITIVE has an insight into data gathered through Google Analytics. This data will be used only to analyse the use of our websites and to evaluate our marketing and distribution strategies.
Our website and landing pages also use functions provided by ADDITIVE for the multi-channel monitoring of the use of our websites as well as marketing and distribution strategies like landing pages, newsletter and social media presence. Information about your visits and submitted forms on our websites are also transmitted to ADDITIVE in order to evaluate and optimize our marketing and sales measures.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit f (legitimate interests) of the GDPR.
Our objective in accordance with the GDPR (legitimate interests) is the improvement of our products and services and our web presence through the analysis of the use of our website as well as marketing and distribution strategies.
Our website and our landing pages also use remarketing functions provided by Google Inc. (“Google”) and by Meta Platforms Inc. (“Meta”). Therefore, Meta and Google will know that you have visited our website. This way visitors of our website and of our landing pages will find ads adapted to their interests on Google’s advertising platforms and on the social media platforms Facebook and Instagram.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit a (consent) of the GDPR.
When you visit our landing pages a banner will inform you about the use of cookies for remarketing functions. If you continue using the website or click on the respective button you consent to the use of cookies. You can deny your consent anytime, by visiting the page containing the cookie information and denying the use in the banner that will be displayed.
ADDITIVE+ MARKETING AUTOMATION – Direct Marketing
In order to increase customer loyalty and to sell our services and additional services we use hotel online marketing software provided by ADDITIVE Srl, 39011 Lana (BZ), Italy (“ADDITIVE”) within the field of hotel marketing automation.
Therefore your data, which we gather and process in connection with your request, reservation, order, activation, registration or the transmission of other contact forms on our website, will be analysed and used to provide you with automatically generated offers for our services and additional services. Through the use of these services and systems your data will be processed and stored, at least in part, also outside of the EU or the EEC. The adequate level of data protection is based on data processing agreements.
You can deny the use of your data for this purpose anytime by clicking on the “unsubscribe” link in the respective message.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit f (legitimate interests) of the GDPR.
Our objective in accordance with the GDPR (legitimate interests) is the prevention of competitive disadvantages, the increase in brand awareness and the maximisation of our economic success through an optimal use of the acquired contacts.
ADDITIVE+ VOUCHERS
On our website you have the possibility to buy vouchers by using the integrated voucher software. To process your purchase and to save and store your data we use software provided by ADDITIVE Srl, 39011 Lana (BZ), Italy (“ADDITIVE”) in the context of voucher marketing. Through the use of these services and systems your data will be processed and stored in the EU.
The data you provide is required to fulfil the contract or to carry out pre-contractual measures. Without this data we cannot conclude a contract with you. The data will not be transferred to an outside third party, except for your credit card data which will be transferred to the payment provider and to our tax accountant to fulfil our tax obligations.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit a (consent) and/or lit b (processing necessary for the performance of a contract) of the GDPR.