This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offering and the associated websites, functions and content as well as external online presences, such as our social media profile. (hereinafter jointly referred to as “online offer”). With regard to the terms used, such as “processing” or “person responsible”, we refer to the definitions in Art. 4 of the Data Protection Basic Regulation (DSGVO).
50829 Cologne, Germany
+49 179 2765202
Types of data processed
- Inventory data (for example, names, addresses)
- Contact data (e.g., e-mail, telephone numbers)
- Content data (e.g., text input, photographs, videos)
- Contract data (for example, contract object, duration, customer category)
- Payment data (for example, bank details, payment history)
- usage data (e.g., websites visited, interest in content, access times)
- Meta/communication data (e.g., device information, IP addresses)
Processing of special categories of data (Art. 9 para. 1 DSGVO)
No special categories of data will be processed.
Categories of persons affected by the processing
- Visitors and users of the online offer.
In the following, we will refer to the data subjects collectively as “users”.
Purpose of the processing
- Provision of the online offer, its contents and shop functions.
- Provision of contractual services, service and customer care.
- Answering contact enquiries and communicating with users.
- Marketing, advertising and market research.
Date: October 2018
1. Terms used
1.1 “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more particular characteristics which express the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
1.2 “Processing” means any operation or set of operations carried out with or without the aid of automated processes relating to personal data. The term is broad and covers practically every handling of data.
1.3 A “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of the processing of personal data.
2. Applicable legal basis
In accordance with Art. 13 DSGVO, we inform you of the legal basis of our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 DSGVO, the legal basis for processing in order to fulfil our services and carry out contractual measures as well as answer inquiries is Art. 6 para. 1 lit. b DSGVO, the legal basis for processing in order to fulfil our legal obligations is Art. 6 para. 1 lit. c DSGVO, and the legal basis for processing in order to safeguard our legitimate interests is Art. 6 para. 1 lit. f DSGVO. Art. 6 para. 1 lit. d DSGVO serves as a legal basis in the event that vital interests of the data subject or another natural person necessitate the processing of personal data.
3. Changes and updates to the data protection declaration
We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as the changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
4. Security measures
4.1 We shall take appropriate technical and organisational measures in accordance with Art. 32 DSGVO, taking into account the state of the art, the implementation costs and the type, extent, circumstances and purposes of the processing as well as the different probability of occurrence and severity of the risk to the rights and freedoms of natural persons, to ensure a level of protection appropriate to the risk; these measures shall include in particular safeguarding the confidentiality, integrity and availability of data by controlling the physical access to the data as well as the access to, inputting, passing on, securing the availability and separation of the data concerning them. In addition, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data and the reaction to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and data protection-friendly default settings (Art. 25 DSGVO).
4.2 The security measures include in particular the encrypted transmission of data between your browser and our server.
5. Disclosure and transmission of data
5.1 If we disclose data to other persons and companies (contract processors or third parties) in the context of our processing, transfer them to them or otherwise grant them access to the data, this shall only take place on the basis of a legal permission (e.g. if a transfer of the data to third parties, such as payment service providers, pursuant to Art. 6 para. 1 lit. b DSGVO), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, hosting providers, tax, business and legal advisors, customer care, accounting, billing and similar services that allow us to efficiently and effectively fulfill our contractual obligations, administrative tasks and duties).
5.2 If we commission third parties with the processing of data on the basis of a so-called “order processing contract”, this is done on the basis of Art. 28 DSGVO.
6. Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of the use of third party services or disclosure or transfer of data to third parties, this will only occur if it is done to fulfil our (pre)contractual obligations, on the basis of your consent, a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special requirements of Art. 44 ff. of the German Data Protection Act are met. DSGVO process. This means that the processing takes place, for example, on the basis of special guarantees, such as the officially recognised determination of a data protection level corresponding to the EU (e.g. for the USA by the “Privacy Shield”) or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).
7. The rights of data subjects
7.1 You have the right to request confirmation as to whether the data in question will be processed and to obtain information about such data and further information and a copy of the data in accordance with Art. 15 DSGVO.
7.2 You have accordingly. Art. 16 DSGVO gives you the right to request the completion of data concerning you or the rectification of incorrect data concerning you.
7.3 Pursuant to Art. 17 DSGVO, you have the right to demand that the data concerned be deleted immediately or, alternatively, to demand a restriction on the processing of the data pursuant to Art. 18 DSGVO.
7.4 You have the right to demand that the data relating to you which you have provided to us be received in accordance with Art. 20 DSGVO and that it be transferred to other responsible parties.
7.5 Pursuant to Art. 77 DSGVO, you also have the right to file a complaint with the competent supervisory authority.
8. Right of revocation
They have the right to revoke consents granted pursuant to Art. 7 (3) DSGVO with effect for the future.
9. Right of objection
You may object at any time to the future processing of the data concerning you in accordance with Art. 21 DSGVO. In particular, you may object to the processing of your data for the purposes of direct marketing.
10. Cookies and right to object to direct advertising
10.1 “Cookies” are small files that are stored on the user’s computer. Different data can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after the user’s visit to an online service. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. The content of a shopping basket in an online shop or a login status, for example, can be stored in such a cookie. Cookies are referred to as “permanent” or “persistent” and remain stored even after the browser has been closed. For example, the login status can be saved if users visit it after several days. The interests of the users can also be stored in such a cookie, which are used for range measurement or marketing purposes. Third party cookies” are cookies from providers other than the person responsible for operating the online service (otherwise, if they are only cookies of this person, they are referred to as “first party cookies”).
10.2 We use temporary and permanent cookies and explain this in the context of our data protection declaration.
If users do not wish cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies may lead to functional limitations of this online service.
11. Deletion of data
11.1 The data processed by us shall be deleted or their processing restricted in accordance with Art. 17 and 18 DSGVO. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and there are no legal obligations to retain them. If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons.
11.2. Germany: According to legal requirements, data is stored in particular for 6 years in accordance with § 257 para. 1 HGB (German Commercial Code) (commercial books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting records, etc.) and for 10 years in accordance with § 147 para. 1 AO (German Tax Code) (books, records, management reports, accounting records, commercial and business letters, documents relevant for taxation, etc.).
12. Order processing in the online shop and customer account
12.1 We process the data of our customers within the framework of the order processes in our online shop, in order to enable them to select and order the selected products and services, as well as their payment and delivery, or execution.
12.2 The processed data includes inventory data, communication data, contract data, payment data and the persons concerned, our customers, interested parties and other business partners. Processing is carried out for the purpose of providing contractual services within the framework of operating an online shop, billing, delivery and customer services. We use session cookies to store the contents of the shopping basket and permanent cookies to store the login status.
12.3 Processing takes place on the basis of Art. 6 Para. 1 lit. b (execution of order processes) and c (legally required archiving) DSGVO. The information marked as necessary is required to substantiate and fulfil the contract. We disclose the data to third parties only within the scope of delivery, payment or within the scope of the statutory permits and obligations to legal advisors and authorities. The data will only be processed in third countries if this is necessary for the fulfilment of the contract (e.g. at the customer’s request upon delivery or payment).
12.4 Users may optionally create a user account, in particular by viewing their orders. Within the scope of registration, the required mandatory information will be communicated to the users. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, subject to its retention for commercial or tax reasons in accordance with Art. 6 para. 1 lit. c DSGVO is necessary. Data in the customer account shall remain in force until it is deleted with subsequent archiving in the event of a legal obligation. It is the responsibility of the users to back up their data before the end of the contract if they terminate the contract.
12.5 Within the scope of registration and renewed registrations as well as use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user’s protection against misuse and other unauthorized use. These data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation pursuant to Art. 6 para. 1 lit. c DSGVO.
12.6 The deletion takes place after expiry of legal warranty and comparable obligations, the necessity of data storage is reviewed every three years; in the case of legal archiving obligations, the deletion takes place after their expiry (end of commercial (6 years) and tax (10 years) retention obligation); information in the customer account remain until its deletion.
13. Business analyses and market research
13.1 In order to operate our business economically, to identify market trends, customer and user wishes, we analyse the data available to us on business transactions, contracts, enquiries, etc., in order to identify the most suitable and appropriate means of communication. We process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. of the German Data Protection Act (DSGVO). DSGVO, whereby the persons concerned include customers, interested parties, business partners, visitors and users of the online offer. The analyses are carried out for the purpose of economic evaluations, marketing and market research. We can consider the profiles of the registered users with information, e.g. on their purchase transactions. The analyses serve us to increase the user friendliness, the optimization of our offer and the business economy. The analyses serve us alone and are not disclosed externally unless they are anonymous analyses with summarized values.
14. Establishing contact and customer service
14.1 When contacting us (via contact form or e-mail), the user’s details will be processed in order to process the contact request and its processing in accordance with Art. 6 Para. 1 lit. b) DSGVO.
14.2 The data of the users can be stored in our Customer Relationship Management System (“CRM System”) or comparable inquiry organization.
14.3 We delete the enquiries if they are no longer necessary. We check the necessity every two years; inquiries from customers who have a customer account are stored permanently and refer to the customer account details for deletion. Furthermore, the statutory archiving obligations apply.
15. Collection of access data and log files
15.1 On the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. we collect data on each access to the server on which this service is located (so-called server log files). DSGVO Data on each access to the server on which this service is located (so-called server log files). Access data includes the name of the website accessed, the file, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
15.2 Log file information is stored for a maximum period of seven days for security reasons (e.g. to clarify misuse or fraud) and then deleted. Data, the further storage of which is necessary for evidence purposes, shall be excluded from deletion until the respective incident has been finally clarified.
16. Online presences in social media
16.1 We maintain online presences within social networks and platforms on the basis of our legitimate interests as defined in Art. 6 para. 1 lit. f. DSGVO online presences within social networks and platforms in order to communicate with customers, interested parties and users active there and to inform them about our services. When calling up the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators shall apply.
16.2 Unless otherwise stated in our data protection declaration, we process user data insofar as they communicate with us within the social networks and platforms, e.g. compose articles on our online presences or send us messages.
17. Google Analytics
17.2 Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
17.3 Google will use this information on our behalf in order to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services associated with the use of this online offer and the use of the Internet. Pseudonymous user profiles of the users can be created from the processed data. 17.4.
17.4 We use Google Analytics only with activated IP anonymisation. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. 17.5.
17.6 Further information on the use of data by Google, setting and objection options can be found on the websites of Google: https://www.google.com/intl/de/policies/privacy/partners (“Use of data by Google for your use of websites or apps of our partners”), https://policies.google.com/technologies/ads (“Use of data for advertising purposes”), https://adssettings.google.com/authenticated (“Manage information that Google uses to show you advertising”).
18. Google-Re/Marketing Services
18.1 We use the marketing and remarketing services (in short “Google Marketing Services”) of Google LLC, 160000, 160000, 160000, 160000, 160000, 160000, 160000, 160000, 160000, 16000000, 16000000, on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online services within the meaning of Art. 6 para. 1 lit. f. of the German Data Protection Act). DSGVO) the marketing and remarketing services (“Google Marketing Services”) of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).
18.2 Google is certified under the Privacy Shield Agreement, thereby providing a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
18.3 Google Marketing Services allow us to display advertisements for and on our website in a more targeted manner to show users only ads that potentially match their interests. For example, if a user sees ads for products that interest him or her on other websites, this is referred to as “remarketing. For these purposes, when you visit our and other websites on which Google marketing services are active, Google executes a code directly from Google and (re)marketing tags (invisible graphics or code, also known as “web beacons”) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). Cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com and googleadservices.com. In this file it is noted which websites the user visits, which contents he is interested in and which offers he has clicked, furthermore technical information about the browser and operating system, referring websites, visiting time as well as further information about the use of the online offer. The IP address of the user is also recorded, whereby we inform within the scope of Google Analytics that the IP address within member states of the European Union or in other contracting states of the Agreement on the European Economic Area is shortened and only in exceptional cases completely transferred to a Google server in the USA and shortened there. The IP address is not merged with user data within other Google services. Google may also combine the above information with such information from other sources. If the user subsequently visits other websites, advertisements tailored to the user’s interests may be displayed. 18.4.
18.4 The user’s data is processed pseudonymously within the framework of Google Marketing Services. I.e. Google does not store and process, for example, the name or e-mail address of the user, but processes the relevant data cookie-related within pseudonymous user profiles. This means that, from Google’s point of view, the ads are not administered and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymisation. The information Google Marketing Services collects about users is transmitted to Google and stored on Google’s servers in the United States.
18.5 The Google marketing services we use include the online advertising program “Google AdWords”. In the case of Google AdWords, each AdWords customer receives a different “conversion cookie”. Cookies can therefore not be tracked via the websites of AdWords customers. The information collected through the cookie is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers will know the total number of users who clicked on their ad and were directed to a page tagged with a conversion tracking tag. However, you will not receive any information that personally identifies users.
18.8 We may also use the “Google Optimizer” service. Google Optimizer allows us to track the effects of various changes to a website (e.g. changes to input fields, design, etc.) within the framework of so-called “A/B-Testings”. For these test purposes, cookies are stored on the user’s devices. Only pseudonymous data of the users will be processed.
18.9 We may also use the “Google Tag Manager” to integrate and manage the Google analysis and marketing services on our website.
19. Jetpack (WordPress Stats)
19.1 On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer in the sense of Art. 6 para. 1 lit. f. of the German Data Protection Act) we use the plugin jetpack (here the sub-function “WordPress Stats”). DSGVO) the plugin Jetpack (here the sub-function “WordPress Stats”), which includes a tool for statistical evaluation of visitor access and from Automattic, Inc. 132 Hawthorne Street San Francisco, CA 94107, USA. Jetpack uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site.
19.2 Automattic is certified under the Privacy Shield Agreement and thereby provides a guarantee of compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt0000000CbqcAAC&status=Active).
20. Communication by post, e-mail, fax or telephone
20.1 We use means of distance communication such as mail, telephone or e-mail for business transactions and marketing purposes. We process inventory data, address and contact data as well as contract data of customers, participants, interested parties and communication partners.
20.2 Processing takes place on the basis of Art. 6 para. 1 lit. a, Art. 7 DSGVO, Art. 6 para. 1 lit. f DSGVO in conjunction with legal requirements for advertising communications. Contact will only be established with the consent of the contact partners or within the scope of the legal permissions, and the processed data will be deleted as soon as they are not required and otherwise with objection/ revocation or omission of the authorization bases or legal archiving obligations.
21.1 With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures and your rights of objection. By subscribing to our newsletter, you declare your agreement with the receipt and the described procedures.
21.2 Content of the newsletter: We send newsletters, e-mails and other electronic notifications containing advertising information (hereinafter “newsletter”) only with the consent of the recipient or a legal permission. If the contents of the newsletter are specifically described within the scope of registration, they are decisive for the consent of the user. In addition, our newsletters contain information on our products, offers, promotions and our company.
21.3 Double opt-in and logging: The registration to our newsletter takes place in a so-called double opt-in procedure. I.e. after registration you will receive an e-mail in which you will be asked to confirm your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address. Likewise the changes of your data stored with the dispatch service provider are logged.
21.4 Dispatch service provider: The dispatch of the newsletter takes place by means of CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede, hereinafter referred to as “dispatch service provider”. You can view the data protection regulations of the shipping service provider here: https://www.cleverreach.com/de/datenschutz/. 21.5.
21.5 If we use a dispatch service provider, the dispatch service provider may, according to its own information, use this data in pseudonymous form, i.e. without allocation to a user, to optimise or improve its own services, e.g. for the technical optimisation of dispatch and the presentation of the newsletter or for statistical purposes in order to determine from which countries the recipients come. However, the shipping service provider does not use the data of our newsletter recipients to write to them itself or pass them on to third parties.
21.6 Registration data: To subscribe to the newsletter, it is sufficient for you to enter your e-mail address. Optionally, we ask you to enter a name in the newsletter in order to address you personally.
21.7 Measurement of success – The newsletters contain a so-called “web beacon”, i.e. a file the size of a pixel, which is retrieved from our server when the newsletter is opened or, if we use a dispatch service provider, from whose server. In the course of this retrieval, technical information such as information about the browser and your system, as well as your IP address and time of retrieval are first collected. This information is used for the technical improvement of the services on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. Statistical surveys also include determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. It is, however, neither our endeavour nor, if used, that of the mail-order service provider to observe individual users. The evaluations serve us much more to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
21.8 The dispatch of the newsletter and the performance measurement are based on the consent of the recipients according to Art. 6 Para. 1 lit. a, Art. 7 DSGVO in conjunction with § 7 Para. 2 No. 3 UWG or on the legal permission according to § 7 Para. 3 UWG.
21.10. The registration procedure is recorded on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f DSGVO and serves as proof of consent to receive the newsletter.
21.11. Recipients of newsletters can cancel the receipt of our newsletter at any time, i.e. revoke their consent. You will find a link to cancel the newsletter at the end of each newsletter. At the same time their consent to the performance measurement expires. A separate revocation of the performance measurement is unfortunately not possible, in which case the entire newsletter subscription must be cancelled. With the cancellation of the newsletter, the personal data are deleted, unless their storage is legally required or justified, whereby their processing is limited in this case only to these exceptional purposes. In particular, we may store the deleted e-mail addresses for up to three years on the basis of our legitimate interests before we delete them for the purpose of sending the newsletter in order to be able to prove that we have previously given our consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of a consent is confirmed at the same time.
22. Integration of services and contents of third parties
22.1 Within our online offer, we use content or service offers of third parties on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. of the German Data Protection Act). DSGVO) content or service offers from third parties in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”). This always presupposes that the third-party providers of this content perceive the IP address of the user, since they would not be able to send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We make every effort to use only those contents whose respective providers only use the IP address to deliver the contents. Third party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring web pages, visit times and other information about the use of our online services, as well as may be linked to such information from other sources.
22.2 The following presentation provides an overview of third party providers and their content, together with links to their data protection declarations, which contain further information on the processing of data and, in some cases already mentioned here, possibilities for objection (so-called opt-out).
- If our customers use the payment services of third parties (e.g. PayPal or Sofortüberweisung), the terms and conditions and privacy notices of the respective third party providers, which are available within the respective websites or transaction applications, apply.