Sleeptrust

privacy statement

sleeptrust

introductory remarks

With the following data protection declaration we would like to inform you which types of your personal data (hereinafter also referred to as “data”) we process for which purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both within the scope of providing our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).

  • Person in charge
  • Overview of processing operations
  • Contact data protection officer
  • Applicable legal bases
  • Safety precautions
  • Transmission and disclosure of personal data
  • Data processing in third countries
  • Use of cookies
  • Commercial and business services
  • Use of online marketplaces for e-commerce
  • Payment service provider
  • Registration and login
  • Blogs and publication media
  • Contact us
  • Communication via messenger
  • Online conferences, meetings and webinars
  • Surveys and surveys
  • Provision of online services and web hosting
  • Music & Podcasts
  • Cloud services
  • Newsletter and broad communication
  • Sweepstakes and competitions
  • Web analysis and optimization
  • Online marketing
  • Affiliate programs and affiliate links
  • Offer an affiliate program
  • Presence in social networks
  • Plugins and embedded functions and content
  • Deletion of data
  • Changes and updates to the privacy policy
  • Rights of data subjects
  • Definitions of terms

Person in charge

Michael, Hildebrandt / Sleeptrust UG
Kuchenheimer way 32

53913 Swisttal, Germany

Authorised representatives: Michael Hildebrandt

E-mail address: michael@sleeptrust.eu

Overview of processing operations

The following table summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

  • Inventory data (names, addresses, etc.).
  • Content data (text input, photographs, videos).
  • Contact details (e-mail, telephone numbers).
  • Meta/communication data (device information, IP addresses).
  • Usage data (websites visited, interest in content, access times).
  • Social data (data that is subject to social confidentiality (§ 35 SGB I) and is processed, for example, by social insurance institutions, social assistance institutions or pension authorities).
  • Location data.
  • Contract data (subject of contract, duration, customer category).
  • Payment data (bank details, invoices, payment history).

Special categories of data

Data revealing racial and ethnic origin.

Categories of data subjects

  • Employees (salaried employees, applicants, former employees).
  • Business partners and contractual partners.
  • Interested parties.
  • Communication partner.
  • Customers.
  • Users (website visitors, users of online services).
  • Participants in sweepstakes and competitions.

Purposes of processing

  • Affiliate tracking.
  • Provision of our online services and user friendliness.
  • Visit action evaluation.
  • Office and organisational procedures.
  • Clicktracking.
  • Cross-Device Tracking (cross-device processing of user data for marketing purposes).
  • Direct marketing (by e-mail or post).
  • Conducting sweepstakes and contests.
  • Feedback (collecting feedback, e.g. via a form).
  • Interest-based and behavioral marketing.
  • Contact requests and communication.
  • Conversion measurement (measurement of the effectiveness of marketing measures).
  • Profiling (creation of user profiles).
  • Remarketing.
  • Range measurement (access statistics, recognition of returning visitors).
  • Security measures.
  • Tracking (interest / behaviour related profiling, cookies).
  • Contractual services and service.
  • Management and answering of inquiries.
  • Target group formation (determination of relevant target groups for marketing purposes or other output of content).

Applicable legal bases

In the following we inform you about the legal basis of the Data Protection Ordinance (DSGVO), on the basis of which we process personal data. Please note that in addition to the provisions of the DSGVO, the national data protection regulations in your or our country of residence and domicile may apply.

  • Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO) – The data subject has given his/her consent to the processing of his/her personal data for one or more specific purposes.
  • Contract performance and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO) – Processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures at the request of the data subject.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c. DSGVO) – The processing is necessary to fulfil a legal obligation to which the controller is subject.
  • Protection of vital interests (Art. 6 para. 1 sentence 1 lit. d. DSGVO) – Processing is necessary in order to protect the vital interests of the data subject or another natural person.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO) – Processing is necessary to safeguard the legitimate interests of the data controller or of a third party, unless the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, prevail.

National data protection regulations in Germany: In addition to the data protection regulations of the Basic Data Protection Regulation, national regulations apply to data protection in Germany. In particular, this includes the Act on Protection against Misuse of Personal Data in Data Processing (Bundesdatenschutzgesetz – BDSG). In particular, the BDSG contains special provisions on the right of information, the right of deletion, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (§ 26 BDSG), in particular with regard to the establishment, execution or termination of employment relationships as well as the consent of employees. Furthermore, data protection laws of the individual federal states may be applied.

Safety precautions

We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, scope, 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, in order to ensure a level of protection appropriate to the risk.

 

Measures shall include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to, and access to, input, transmission, securing and separation of data. In addition, we have established procedures to ensure that data subjects’ rights are exercised, that data is deleted and that we react 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 through data protection-friendly default settings.

 

SSL encryption (https): To protect your data transmitted via our online service, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Transmission and disclosure of personal data

As part of our processing of personal data, it may happen that the data is transferred to other offices, companies, legally independent organisational units or persons or that it is disclosed to them. Recipients of this data may include, for example, payment institutions within the framework of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases we observe the legal requirements and in particular conclude corresponding contracts or agreements with the recipients of your data which serve to protect your data.

Data processing in third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third party services or disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements.

 

Subject to express consent or contractual or legally required transfer, we process or release the data only in third countries with a recognized level of data protection, which includes US processors certified under the “Privacy Shield” or on the basis of special guarantees, such as contractual obligations through so-called standard protection clauses of the EU Commission.

Use of cookies

Cookies” are small files that are stored on the user’s devices. Different data can be stored within the cookies. The information can include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was viewed. As a rule, cookies are also used if a user’s interests or behaviour (e.g. viewing certain content, use of functions, etc.) are stored in a user profile via individual websites. These profiles are used, for example, to display ads to users that correspond to their potential interests. This procedure is also referred to as “tracking”, i.e. tracking the potential interests of users. The term “cookies” also includes other technologies that perform the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also referred to as “user IDs”). If we use cookies or “tracking” technologies, we will inform you of this in our data protection declaration.

Notes on legal bases: The legal basis on which we process your personal data with the help of cookies depends on whether we ask you for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is your declared consent. Otherwise, the data processed with the aid of cookies will be processed on the basis of our legitimate interests (e.g., in a business operation of our online offer and its improvement) or if the use of cookies is necessary to fulfill our contractual obligations.

Revocation and objection (opt-out): Irrespective of whether processing is based on consent or legal permission, you have the possibility at any time to revoke a consent given or to object to the processing of your data using cookie technologies (collectively referred to as “opt-out”). You can initially explain your objection using the settings of your browser, e.g. by deactivating the use of cookies (which may also restrict the functionality of our online service). An objection to the use of cookies for online marketing purposes can be raised for a large number of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/ or generally on http://optout.aboutads.info

You will also find further information on possible objections within the scope of the information on the respective processing in this data protection declaration.

Processing of cookie data on the basis of consent: Before we process or have processed data within the framework of the use of cookies, we ask the user for consent that can be revoked at any time. Before the consent has not been given, we may use cookies that are necessary for the operation of our online offer. Their use is based on our interest and the user’s interest in the expected functionality of our online service.

 

  • Processed data types: Usage data (websites visited, interest in content, access times), meta/communication data (device information, IP addresses).
  • Affected persons: Users (website visitors, users of online services).
  • Legal basis: consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Commercial and business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) within the framework of contractual and comparable legal relationships as well as associated measures and communication with the contractual partners (or pre-contractual), e.g. to answer inquiries. We process this data in order to fulfil our contractual obligations, safeguard our rights and for the purposes of the administrative tasks associated with this data and the entrepreneurial organisation. In doing so, we only pass on the data of the contractual partners to third parties within the framework of the applicable law insofar as this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or is carried out with the consent of the contractual partners (e.g. telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities involved). The contractual partners will be informed about further processing, e.g. for marketing purposes, as part of this data protection declaration. Which data are necessary for the aforementioned purposes, we inform the contracting partners before or in the context of the data collection, e.g. in on-line forms by special marking (e.g. colors), and/or symbols (e.g. asterisks or the like), or personally. We delete the data after expiry of statutory warranty and comparable obligations, i.e. in principle after expiry of 4 years, unless the data is stored in a customer account e.g. as long as they must be stored for legal reasons of archiving (e.g., as a rule 10 years for tax purposes). In the case of data which has been disclosed to us by the contractual partner within the framework of an order, we delete the data in accordance with the specifications of the order, in principle after the end of the order. If we use third party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third party providers or platforms shall apply in the relationship between the users and the providers.

Customer account: Contracting parties can create an account within our online offer (e.g., customer or user account, in short “customer account”). If the registration of a customer account is required, the contractual partners will be informed of this as well as of the information required for registration. The customer accounts are not public and cannot be indexed by search engines. In the course of registration and subsequent logins and use of the customer account, we store the IP addresses of the customers along with the access times, in order to be able to prove registration and prevent any misuse of the customer account. If customers have terminated their customer account, their data will be deleted with regard to the customer account, subject to their retention is required for legal reasons. It is the responsibility of the customer to secure their data upon termination of the customer account.

Economic analyses and market research: For economic reasons and in order to be able to recognise market trends, wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., whereby the persons concerned may include contractual partners, interested parties, customers, visitors and users of our online services. The analyses are carried out for the purpose of business evaluations, marketing and market research (for example, to determine customer groups with different characteristics). If available, we can take into account the profiles of registered users with information, e.g. on the services they have used. The analyses serve us alone and are not disclosed externally unless they are anonymous analyses with summarised, i.e. anonymised values. Furthermore, we respect the privacy of the users and process the data for analysis purposes as pseudonymously as possible and if possible anonymously (e.g. as combined data).

Online shop and e-commerce: We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and related services, as well as their payment and delivery, or execution. The required details are identified as such within the framework of the ordering or comparable purchase process and include the details required for delivery or provision and invoicing as well as contact information in order to be able to hold any consultation.

Education and training services: We process the data of the participants of our education and training offers (uniformly referred to as “trainees”) in order to provide them with our training services. The data processed, the type, scope and purpose of the processing and the necessity of its processing are determined by the underlying contractual and training relationship. The processing also includes the performance evaluation and evaluation of our services and the teachers. As part of our activities, we may also process special categories of data, in particular information on the health of trainees and apprentices and data revealing ethnic origin, political opinions, religious or philosophical convictions. For this purpose we obtain, if necessary, the express consent of the trainees and trainees and process the special categories of data otherwise only if it is necessary for the provision of training services, for purposes of health care, social protection or the protection of vital interests of the trainees and trainees. Insofar as it is necessary for the fulfilment of our contract, for the protection of vital interests or by law, or with the consent of the trainees, we disclose or transfer the data of the trainees to third parties or agents, such as public authorities or in the field of IT, office or comparable services, in compliance with the provisions of professional law.

Publishing activities: We process the data of our contact partners, interview partners and other persons who are the subject of our publishing, editorial, journalistic and related activities. Here we refer to the validity of protection regulations of freedom of opinion and freedom of the press according to Art. 85 DSGVO in connection with the respective national laws. The processing serves us the fulfilment of order activities and finds otherwise in particular on the basis of the interest of the general public in information and media offers.

 

  • Processed data types: inventory data (names, addresses, etc.), payment data (bank details, invoices, payment history), contact data (e-mail, telephone numbers), contract data (subject of contract, duration, customer category), usage data (websites visited, interest in content, access times), meta/communication data (device information, IP addresses).
  • Special categories of data: Health data (Art. 9 para. 1 DGSVO), data on sex life or sexual orientation (Art. 9 para. 1 DGSVO), religious or ideological beliefs (Art. 9 para. 1 DGSVO), data revealing racial and ethnic origin.
  • Affected persons: Interested parties, business and contractual partners, customers.
  • Purposes of processing: contractual services, contact enquiries and communication, office and organisational procedures, administration and response to enquiries, security measures, evaluation of visits, marketing based on interests and behaviour, profiling (creation of user profiles).
  • Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), legal obligation (Art. 6 para. 1 sentence 1 lit. c. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Use of online marketplaces for e-commerce

We offer our services on online platforms operated by other service providers. In addition to our data protection notices, the data protection notices of the respective platforms apply. This is particularly true with regard to the methods used on the platforms for measuring range and interest-related marketing.

 

  • Processed data types: inventory data (names, addresses, etc.), payment data (bank details, invoices, payment history), contact data (e-mail, telephone numbers), contract data (subject of contract, duration, customer category), usage data (websites visited, interest in content, access times), meta/communication data (device information, IP addresses).
  • Affected persons: Customers.
  • Purposes of processing: Contractual services and service.
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Payment service provider

Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the persons concerned efficient and secure payment options and use other payment service providers in addition to banks and credit institutions (together referred to as “payment service providers”).

The data processed by the payment service providers includes inventory data such as name and address, bank data such as account or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient details. The information is required to complete the transactions. However, the data entered will only be processed and stored by the payment service providers. This means that we do not receive any account- or credit card-related information, but only information with confirmation or negative information about the payment. The data may be transmitted by payment service providers to credit reference agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard we refer to the General Terms and Conditions and data protection notices of the payment service providers.

Payment transactions are subject to the terms and conditions and data protection notices of the respective payment service providers, which can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and assertion of revocation, information and other rights affected.

 

  • Processed data types: inventory data (names, addresses, etc.), payment data (bank details, invoices, payment history), contract data (subject of contract, duration, customer category), usage data (websites visited, interest in content, access times), meta/communication data (device information, IP addresses).
  • Affected persons: Customers, interested parties.
  • Purposes of processing: contractual services and service, contact requests and communication, affiliate tracking.
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Services and service providers used:

Registration and Login

Users can create a user account. Within the scope of registration, the required mandatory information is communicated to the users and processed for the purposes of providing the user account on the basis of contractual fulfilment of obligations. The processed data includes in particular the login information (name, password and an e-mail address). The data entered during registration will be used for the purposes of using the user account and its purpose.

Users may be informed by e-mail of information relevant to their user account, such as technical changes. If users have terminated their user account, their data will be deleted with regard to the user account, subject to a statutory retention obligation. It is the responsibility of the users to secure their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract.

Within the scope of using our registration and login functions as well as the use of the user account, 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. This data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.

 

  • Processed data types: inventory data (names, addresses, etc.), contact data (e-mail, telephone numbers), content data (text input, photographs, videos), meta/communication data (device information, IP addresses).
  • Affected persons: Users (website visitors, users of online services).
  • Purposes of processing: contractual services and service, security measures, management and response to inquiries.
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f DSGVO).

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data will only be processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the framework of this data protection notice.

Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests. This is done for our safety, if someone leaves illegal contents (insults, forbidden political propaganda, etc.) in comments and contributions. In this case, we ourselves can be prosecuted for the comment or contribution and are therefore interested in the author’s identity. Furthermore, we reserve the right to process user data for the purpose of spam detection on the basis of our legitimate interests.

On the same legal basis, in the case of surveys, we reserve the right to store the IP addresses of users for the duration of the surveys and to use cookies in order to avoid multiple votes. The personal information provided in the course of comments and contributions, any contact and website information as well as the content information will be stored permanently by us until the user objects.

Retrieval of WordPress emojis and smilies: Within our WordPress blog, graphic emojis (or smilies), i.e. small graphic files expressing feelings, obtained from external servers, are used for the efficient integration of content elements. Here the providers of the servers collect the IP addresses of the users. This is necessary so that the emoji files can be transmitted to the browsers of the users.

 

  • Processed data types: inventory data (names, addresses, etc.), contact data (e-mail, telephone numbers), content data (text input, photographs, videos), usage data (visited websites, interest in content, access times), meta/communication data (device information, IP addresses), contract data (subject of contract, term, customer category).
  • Affected persons: Users (website visitors, users of online services).
  • Purposes of processing: contractual services, feedback (collection of feedback, e.g. via forms), security measures, administration and response to inquiries.
  • Legal basis: fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO), consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), protection of vital interests (Art. 6 para. 1 sentence 1 lit. d. DSGVO).

Services and service providers used:

 

  • Retrieval of WordPress emojis and smilies: Retrieval of WordPress emojis and smilies; service provider: Automattic Inc. 60 29th Street #343, San Francisco, CA 94110, USA; Website: https://automattic.com; Privacy Policy: https://automattic.com/privacy.

Contact us

When contacting us (e.g. via contact form, e-mail, telephone or via social media), the data of the inquiring persons are processed insofar as this is necessary to answer the contact enquiries and any requested measures. The response to contact enquiries within the framework of contractual or pre-contractual relationships is made in order to fulfil our contractual obligations or to respond to (pre)contractual enquiries and otherwise on the basis of the legitimate interests in responding to the enquiries.

 

  • Processed data types: inventory data (names, addresses, etc.), contact data (e-mail, telephone numbers), content data (text input, photographs, videos), usage data (visited websites, interest in content, access times), meta/communication data (device information, IP addresses).
  • Affected persons: Communication partner.
  • Purposes of processing: contact requests and communication, management and response to requests.
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Services and service providers used:

Zoho Desk: Service provider: Zoho Corporatioplaceholder placeholder placeholder placeholder; website: https://www.zoho.complaceholder placeholder placeholder; privacy policy: https://www.zoho.complaceholder placeholder placeholder; standard contractual clauses (guarantee data protection level for processing in third countries): Upon request to the placeholder placeholder placeholder.

Communication via Messenger

We use Messenger services for communication purposes and therefore ask you to observe the following information regarding the functionality of the Messenger, encryption, use of the metadata of the communication and your objection options. You can also contact us by alternative means, e.g. telephone or e-mail. Please use the contact options provided to you or use the contact options provided within our online offer.

In the case of end-to-end encryption of content (i.e. the content of your message and attachments) we point out that the communication content (i.e. the content of the message and attachments) is encrypted end-to-end. This means that the content of the messages is not visible, not even by the messenger providers themselves. You should always use a current version of Messenger with encryption enabled to ensure that message content is encrypted.

However, we would like to draw the attention of our communication partners to the fact that although messenger providers do not see the content, they can find out that and when communication partners communicate with us and process technical information on the communication partner’s device used and, depending on the settings of their device, also location information (so-called metadata).

Information on legal bases: If we ask communication partners for permission before communicating with them via Messenger, the legal basis of our processing of their data is their consent. Otherwise, if we do not request consent and you contact us, for example, voluntarily, we use Messenger in our dealings with our contractual partners and as part of the contract initiation process as a contractual measure and in the case of other interested parties and communication partners on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners for communication via Messengers. We would also like to point out that we do not transmit the contact data provided to us to the messengers for the first time without your consent.

Revocation, objection and deletion: You can revoke your consent at any time or object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete the messages in accordance with our general deletion policy (i.e. as described above after the end of contractual relationships, archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information provided by the communication partners, if no reference to a previous conversation is to be expected and there are no legal obligations to store the messages to prevent deletion.

Reservation of reference to other communication channels: Finally, we would like to point out that we reserve the right, for reasons of your safety, not to answer enquiries via Messenger. This is the case if, for example, internal contractual matters require special secrecy or if an answer via Messenger does not meet the formal requirements. In such cases we refer you to more appropriate communication channels. Skype: end-to-end encryption of Skype requires its activation (unless it is activated by default).

 

  • Processed data types: contact data (e-mail, telephone numbers), usage data (visited websites, interest in content, access times), meta/communication data (device information, IP addresses), content data (text input, photographs, videos).
  • Affected persons: Communication partner.
  • Purposes of processing: contact requests and communication, direct marketing (by e-mail or postal mail).
  • Legal basis: consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Services and service providers used:

 

Online conferences, meetings and webinars

We use third-party platforms and applications (hereinafter referred to as “Third Party Providers”) for the purposes of conducting video and audio conferences, webinars and other types of video and audio meetings. When selecting third-party providers and their services, we observe the legal requirements.

In this context data of the communication participants are processed and stored on the servers of the third party providers, as far as these are part of communication processes with us. This data may include, but is not limited to, login and contact information, visual and voice contributions, chats and shared screen content.

If, in the course of communication, business or other relationships with us, users refer to the third party providers or their software, the third party provider shall be liable for any damages resulting from the use of this software.

 

  • Processed data types: inventory data (names, addresses, etc.), contact data (e-mail, telephone numbers), content data (text input, photographs, videos), usage data (visited websites, interest in content, access times), meta/communication data (device information, IP addresses).
  • Affected persons: Communication partners, users (website visitors, users of online services).
  • Purposes of processing: contractual services, contact requests and communication, office and organisational procedures.
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f DSGVO).

Services and service providers used:

 

Surveys and surveys

The surveys and surveys we conduct (hereinafter referred to as “surveys”) are evaluated anonymously. Personal data is only processed insofar as this is necessary for the provision and technical execution of the survey (e.g. processing the IP address to display the survey in the user’s browser or to enable a resumption of the survey with the aid of a temporary cookie (session cookie)) or users have consented.

Information on legal bases: If we ask the participants for their consent to the processing of their data, this is the legal basis for the processing, otherwise the processing of the participants’ data takes place on the basis of our legitimate interests in carrying out an objective survey.

 

  • Processed data types: contact data (e-mail, telephone numbers), content data (text input, photographs, videos), usage data (websites visited, interest in content, access times), meta/communication data (device information, IP addresses).
  • Affected persons: Communication partners, users (website visitors, users of online services).
  • Purposes of processing: contact enquiries and communication, direct marketing (by e-mail or post), tracking (interest and behaviour profiling, cookies), feedback (collecting feedback, e.g. via forms).
  • Legal basis: consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Services and service providers used:

Provision of online services and web hosting

In order to provide our online services securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers they manage) the online services can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security and technical maintenance services.

The data processed within the framework of the provision of the hosting offer may include all information relating to the users of our online offer that is collected within the scope of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders, as well as further information regarding the sending of e-mails (e.g. the providers involved) and the contents of the respective e-mails are processed. The above data may also be processed for SPAM detection purposes. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted during transport, but not on the servers from which they are sent and received (unless a so-called end-to-end encryption method is used). We can therefore accept no responsibility for the transmission path of e-mails between the sender and reception on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data about each access to the server (so-called server log files). Server log files may include the address and name of the web pages and files accessed, the date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the utilization of the servers and optimization of their stability.

 

  • Processed data types: Content data (text input, photographs, videos), usage data (websites visited, interest in content, access times), meta/communication data (device information, IP addresses).
  • Affected persons: Users (website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Music & Podcasts

We use the hosting and analysis services of the following service providers to offer our audio content for listening or downloading and to obtain statistical information on the retrieval of the audio content.

 

  • Processed data types: Usage data (websites visited, interest in content, access times), meta/communication data (device information, IP addresses).
  • Affected persons: Users (website visitors, users of online services).
  • Purposes of processing: measurement of reach (access statistics, recognition of returning visitors), evaluation of visitor actions, profiling (creation of user profiles).

Services and service providers used:

 

Cloud services

We use software services (“Cloud Services”, also referred to as “Software as a Service”) that are accessible over the Internet and run on the servers of its providers for the following purposes: storing and managing documents, managing calendars, sending e-mail, spreadsheets and presentations, exchanging documents, content and information with specific recipients or publishing websites, forms or other content and information, and chatting and participating in audio and video conferences.

Within this framework, personal data may be processed and stored on the provider’s servers insofar as these are part of communication processes with us or are otherwise processed by us as set out in this data protection declaration. This data may include in particular master data and contact data of users, data on processes, contracts, other processes and their contents. Cloud service providers also process usage data and metadata that they use for security and service optimization purposes.

If we use cloud services to provide documents and content to other users or publicly accessible websites, forms or the like, providers may store cookies on users’ devices for web analysis purposes or to remember users’ settings (e.g. in the case of media control).

Information on legal bases: If we ask for consent to the use of cloud services, the legal basis for processing data for the purposes of online marketing is consent. Furthermore, their use can be a component of our (pre)contractual services, provided that the use of cloud services has been agreed in this context. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in efficient and secure administrative and collaboration processes).

 

  • Processed data types: inventory data (names, addresses, etc.), contact data (e-mail, telephone numbers), content data (text input, photographs, videos), usage data (visited websites, interest in content, access times), meta/communication data (device information, IP addresses).
  • Affected persons: Customers, employees (salaried employees, applicants, former employees), interested parties, communication partners.
  • Purposes of processing: office and organisational procedures.

Newsletter and broad communication

We send newsletters, e-mails and other electronic notifications (hereinafter referred to as “newsletters”) only with the consent of the recipient or a legal permission. Insofar as the contents of the newsletter are specifically described within the framework of registration, they are decisive for the consent of the user. In addition, our newsletters contain information about our services and us.

In order to subscribe to our newsletters, it is sufficient to enter your e-mail address. We may, however, ask you to provide a name for the purpose of contacting us personally in the newsletter or to provide further information if this is required for the purposes of the newsletter.

Double opt-in process: The registration to our newsletter takes place in principle in a so-called Double-Opt-In procedure. This means that you will receive an e-mail after registration asking you to confirm your registration. This confirmation is necessary so that no one 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 storing the login and confirmation times as well as the IP address. Likewise the changes of your data stored with the dispatch service provider are logged.

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

The logging of the registration procedure is carried out on the basis of our legitimate interests for the purpose of proving its proper course. If we hire a service provider to send e-mails, we do so on the basis of our legitimate interests in an efficient and secure delivery system.

Information on legal bases: The newsletter is sent on the basis of the recipient’s consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, provided and to the extent that this is permitted by law, e.g. in the case of existing customer advertising. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to demonstrate that it has been conducted in accordance with the law.

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

Success measurement: 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 from the server of a dispatch service provider if we use one. Within the scope 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 our newsletter on the basis of technical data or target groups and their reading behaviour on the basis of their retrieval points (which can be determined with the help of the IP address) or access times. This analysis also includes 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 shipping service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The evaluation of the newsletter and the measurement of success is carried out, subject to the express consent of the user, on the basis of our legitimate interests for the purposes of using a user-friendly and secure newsletter system which serves both our business interests and the expectations of the user. A separate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled or contradicted

Prerequisite for the use of free services: Consent to the sending of mailings can be made dependent on the use of free services (e.g. access to certain content or participation in certain campaigns) as a prerequisite. If the users wish to make use of the free service without registering for the newsletter, please contact us.

 

  • Processed data types: inventory data (names, addresses, etc.), contact data (e-mail, telephone numbers), meta/communication data (device information, IP addresses), usage data (websites visited, interest in content, access times).
  • Affected persons: Communication partners, users (website visitors, users of online services).
  • Purposes of processing: direct marketing (by e-mail or post), contractual services and service.
  • Legal basis: consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
  • Opt-out: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options listed above, preferably e-mail.

Services and service providers used:

Sweepstakes and competitions

We process the personal data of participants in sweepstakes and competitions only in compliance with the relevant data protection regulations if the processing is contractually necessary for the provision, execution and handling of the sweepstake, if the participants have consented to the processing or if the processing serves our legitimate interests (e.g. in the security of the sweepstake or the protection of our interests against misuse by possible recording of IP addresses when submitting sweepstake entries).

In the event that entries from participants are published as part of the sweepstakes (e.g. as part of a vote or presentation of entries to the sweepstakes or the winner or reporting on the sweepstakes), we would like to point out that the names of participants may also be published in this context. The participants can object to this at any time.

If the competition takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as “online platform”), the usage and data protection provisions of the respective platforms also apply. In these cases we would like to point out that we are responsible for the information provided by the participants in the context of the competition and that we must be contacted with regard to the competition.

The data of the participants will be deleted as soon as the competition has ended and the data is no longer required to inform the winners or because queries regarding the competition are to be expected. In principle, the data of the participants will be deleted at the latest 6 months after the end of the competition. Winners’ data can be retained for a longer period of time, e.g. in order to answer questions about the prizes or to fulfil the prizes; in this case, the retention period depends on the type of prize and is up to three years for items or services, e.g. in order to be able to process warranty claims. Furthermore, the participants’ data may be stored for longer, e.g. in the form of reports on the competition in online and offline media.

Insofar as data was collected for other purposes as part of the competition, its processing and storage period shall be governed by the data protection information for this use (e.g., in the case of registration for a newsletter as part of a competition).

 

  • Processed data types: inventory data (names, addresses, etc.), content data (text entries, photographs, videos).
  • Affected persons: Participants in sweepstakes and competitions.
  • Purposes of processing: Conducting sweepstakes and contests.
  • Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO).

Web Analysis and Optimization

Web analysis (also referred to as “range measurement”) is used to evaluate the flow of visitors to our website and may include their behaviour, interests or demographic information, such as age or gender, as pseudonymous values. With the help of the range analysis we can recognize, for example, at which time our online offer or its functions or contents are most frequently used or invite for reuse, as well as which areas require optimization.

In addition to web analysis, we can also use test procedures, e.g. to test and optimize different versions of our online offering or its components. For these purposes, so-called user profiles can be created and stored in a file (so-called “cookie”) or similar procedures in which the relevant user information for the aforementioned analyses is stored. This information may include, for example, content viewed, web pages visited and elements and technical data used there, such as the browser used, computer system used and information on times of use. If users have consented to the collection of their location data, these may also be processed, depending on the provider.

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

Information on legal bases: If we ask the users for their consent (e.g. in the context of a so-called “Cookie Banner Agreement”), the legal basis of the processing of data for the purposes of online marketing is consent. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online service). We refer you to the note on the use of cookies in this data protection declaration.

 

  • Affected persons: Users (website visitors, users of online services).
  • Purposes of processing: measurement of reach (access statistics, recognition of returning visitors), tracking (interest and behaviour-related profiling, cookies), evaluation of visit campaigns, profiling (creation of user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Online marketing

We process personal data for the purposes of online marketing, which includes in particular the presentation of advertising and other content (collectively referred to as “Content”) based on the potential interests of users and the measurement of their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedure in which the relevant user information for the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on times of use. If users have consented to the collection of their location data, these can also be processed.

The IP addresses of the users are also stored. However, we use existing IP masking methods (i.e. pseudonymisation by shortening the IP address) to protect users. In general, within the framework of the online marketing procedure, no plain data of the users (such as e-mail addresses or names) is stored, but pseudonyms. This means that we, as well as the providers of online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles.

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

Exceptionally, plain data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing procedures we use and the network links the profiles of the users in the aforementioned data. Please note that users may enter into additional agreements with the providers, e.g. by consenting to the registration process.

As a matter of principle, we only gain access to summarised information about the success of our advertisements. However, within the framework of so-called conversion measurement, we can check which of our online marketing procedures have led to a so-called conversion, i.e. to the conclusion of a contract with us, for example. The conversion measurement is used alone for the success analysis of our marketing measures.

Information on legal bases: If we ask the users for their consent (e.g. in the context of a so-called “Cookie Banner Agreement”), the legal basis of the processing of data for the purposes of online marketing is consent. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online service). We refer you to the note on the use of cookies in this data protection declaration.

Facebook pixels: With the help of Facebook pixels, Facebook is able on the one hand to determine the visitors of our online offering as the target group for the display of ads (so-called “Facebook ads”). Accordingly, we use Facebook pixels to display Facebook ads placed by us only to Facebook users who have shown an interest in our online offering or who have certain features (e.g., interests in certain topics or products that are determined on the basis of the websites visited) that we transmit to Facebook (so-called “custom audiences”). With the help of Facebook pixels, we also want to ensure that our Facebook ads correspond to the potential interest of users and do not appear annoying. The Facebook pixel also enables us to track the effectiveness of Facebook ads for statistical and market research purposes by showing whether users were referred to our website after clicking on a Facebook ad (known as “conversion measurement”).  
  • Processed data types: Usage data (websites visited, interest in content, access times), meta/communication data (device information, IP addresses), location data, social data (data subject to social secrecy (§ 35 SGB I) and processed by social insurance institutions, social welfare institutions or pension authorities, for example).
  • Affected persons: Users (website visitors, users of online services), interested parties, customers, employees (employees, applicants, former employees), communication partners.
  • Purposes of processing: Tracking (interest / behaviour related profiling, cookies), remarketing, visitor action evaluation, interest based and behaviour related marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), range measurement (access statistics, recognition of returning visitors), cross-device tracking (cross-device processing of user data for marketing purposes), target group formation (determination of relevant target groups for marketing purposes or other output of content), click tracking.
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
  • Opt-Out: We refer to the data protection information of the respective providers and the possibilities of objection given to the providers (so-called \”Opt-Out\”). If no explicit opt-out option has been specified, it is possible to deactivate cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for each area: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-area: http://optout.aboutads.info.
Services and service providers used:    

Affiliate Programs and Affiliate Links

Within our online offering, we include so-called affiliate links or other references (which may include discount codes, for example) to the offers and services of third parties (collectively, “affiliate links”). When users follow affiliate links or subsequently take advantage of offers, we may receive commission or other benefits (collectively referred to as “commission”) from these third parties.

In order to be able to track whether the users have noticed the offers of an affiliate link used by us, it is necessary for the respective third party provider to know that the users have followed an affiliate link used within our online offer. The assignment of affiliate links to the respective business transactions or other actions (e.g., purchases) serves the sole purpose of commission settlement and is cancelled as soon as it is no longer required for the purpose.

For the purposes of the aforementioned affiliate link assignment, the affiliate links may be supplemented by certain values that may be a component of the link or otherwise stored, for example, in a cookie. The values may include in particular the source website (referrer), time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer and an online identifier of the user.

Information on legal bases: If we ask the users for their consent (e.g. in the context of a so-called “Cookie Banner Agreement”), the legal basis for the processing of data for the purposes of affiliate marketing is consent. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in analysis, optimisation and profitability). We refer you to the note on the use of cookies in this data protection declaration.

 

  • Processed data types: contract data (subject of contract, duration, customer category), usage data (visited websites, interest in content, access times), meta/communication data (device information, IP addresses).
  • Affected persons: Users (website visitors, users of online services).
  • Purposes of processing: Affiliate tracking.
  • Legal basis: consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Offer an Affiliate Program

We offer an affiliate program, i.e. we offer commissions or other benefits (collectively referred to as “Commission”) to users (collectively referred to as “Affiliates”) who refer to our offers and services. The reference is made through a link associated with the Affiliate or other methods (e.g., discount codes) that allow us to recognize that the use of our services was based on the reference (collectively referred to as “Affiliate Links”). In order to track whether users have perceived our services based on affiliate links used by affiliates, it is necessary for us to know that users have followed an affiliate link. The assignment of the affiliate links to the respective business transactions or

Presence in social networks

We maintain online presences within social networks in order to communicate with the users active there or to offer information about us there. We would like to point out that user data may be processed outside the European Union. This may entail risks for users, e.g. by making it more difficult to enforce users’ rights. With regard to US providers certified under the Privacy Shield or offering comparable guarantees of a secure level of data protection, we would like to point out that they thereby commit themselves to comply with EU data protection standards.

In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the resulting interests of users. The user profiles can in turn be used, for example, to place advertisements within and outside the networks which are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer, in which the user’s usage behaviour and interests are stored. Furthermore, data can be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).

For a detailed description of the respective processing operations and the opt-out options, please refer to the respective data protection declarations and information provided by the operators of the respective networks. Also in the case of requests for information and the assertion of rights of data subjects, we point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, please do not hesitate to contact us.

 

  • Processed data types: inventory data (names, addresses, etc.), contact data (e-mail, telephone numbers), content data (text input, photographs, videos), usage data (visited websites, interest in content, access times), meta/communication data (device information, IP addresses).
  • Affected persons: Users (website visitors, users of online services).
  • Purposes of processing: contact enquiries and communication, tracking (interest / behaviour related profiling, cookies), remarketing, range measurement (access statistics, recognition of returning visitors).
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Services and service providers used:

 

Plugins and embedded functions and content

Within our online offer, we integrate functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may, for example, be graphics, videos or social media buttons as well as contributions (hereinafter uniformly referred to as “Content”).

The integration always presupposes that the third party providers of this content process the IP address of the user, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents or functions. We strive to use only those contents, whose respective offerers use the IP address only for the distribution of the contents. Third parties may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring websites, visit times and other information about the use of our website, as well as may be linked to such information from other sources.

Information on legal bases: If we ask the users for their consent (e.g. in the context of a so-called “Cookie Banner Agreement”), the legal basis of the processing of data for the purposes of online marketing is consent. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online service). We refer you to the note on the use of cookies in this data protection declaration.

 

  • Processed data types: Usage data (visited websites, interest in content, access times), meta/communication data (device information, IP addresses), contact data (e-mail, telephone numbers), content data (text input, photographs, videos), inventory data (names, addresses, etc.).
  • Affected persons: Users (website visitors, users of online services), communication partners.
  • Purposes of processing: provision of our online services and user-friendliness, contractual services and support, contact enquiries and communication, direct marketing (by e-mail or post), tracking (interest / behaviour profiling, cookies), interest based and behaviour based marketing, profiling (creation of user profiles), range measurement (access statistics, recognition of returning visitors), security measures, administration and response to enquiries.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO), consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO).

Services and service providers used:

 

Deletion of data

The data processed by us will be deleted in accordance with the statutory provisions as soon as their consent permitted for processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or it is not necessary for the purpose).

If the data are not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person. Further information on the deletion of personal data can also be found in the individual data protection notices of this data protection declaration.

Changes and Updates to the Privacy Policy

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 changes in the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

Rights of data subjects

 

  • Right of objection: You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you on the basis of Art. 6 para. 1 lit. e or f DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct advertising, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such advertising; this also applies to profiling to the extent that it is connected with such direct advertising.
  • Right of withdrawal for consents: You have the right to revoke your consent at any time.
  • Right of access: You have the right to obtain confirmation as to whether the data in question will be processed and to obtain access to such data, as well as further information and a copy of the data in accordance with the provisions of the law.
  • Right of rectification: You have the right, in accordance with the law, to request the completion of data concerning you or the rectification of incorrect data concerning you.
  • Right to deletion and limitation of processing: You have the right, in accordance with the statutory provisions, to demand that the relevant data be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
  • Right to data transfer: You have the right to receive data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to demand that it be transferred to another responsible party.
  • Complaints to the supervisory authority: You also have the right to submit a complaint to the competent supervisory authority in accordance with the statutory provisions.

Definitions of terms

This section provides an overview of the terms used in this privacy statement. Many of the terms are taken from the law and defined above all in Art. 4 DSGVO. The legal definitions are binding. The following explanations, on the other hand, are intended above all for the sake of understanding. The terms are sorted alphabetically.

 

  • Affiliate tracking: Affiliate tracking logs links that the linking websites use to refer users to websites with product or other offers. The operators of the respective linked websites can receive a commission if users follow these so-called affiliate links and subsequently take advantage of the offers (e.g. buy goods or use services). To this end, it is necessary for providers to be able to track whether users who are interested in certain offers subsequently perceive them at the instigation of the affiliate links. It is therefore necessary for the functionality of affiliate links that they are supplemented by certain values that become part of the link or are otherwise stored, e.g. in a cookie. The values include in particular the source website (referrer), time, an online identification of the operator of the website on which the affiliate link was located, an online identification of the respective offer, an online identification of the user, as well as tracking specific values such as advertising media ID, partner ID and categorizations.
  • Conversion Tracking: The term “Conversion Tracking” refers to a process by which the effectiveness of marketing measures can be determined. As a rule, a cookie is stored on the devices of the users within the websites on which the marketing measures are carried out and then called up again on the target website (e.g. this enables us to track whether the ads we placed on other websites were successful).
  • Clicktracking: Clicktracking allows users to keep track of their movements within an entire online offering. Since the results of these tests are more accurate if the user interaction can be tracked over a period of time (e.g. to see if a user would like to return), cookies are usually stored on the user’s computer for these test purposes.
  • Cross-Device Tracking: Cross-Device Tracking is a form of tracking in which behavior and interest information of the user is recorded across all devices in so-called profiles by assigning an online identifier to the user. This means that user information can usually be analysed for marketing purposes regardless of the browser or device used (e.g. mobile phone or desktop computer). With most providers, the online identifier is not linked to plain data such as names, postal addresses or e-mail addresses.
  • IP masking: IP masking is a method by which the last octet, i.e. the last two numbers of an IP address, are deleted so that the IP address can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymising processing methods, particularly in online marketing.
  • Interest-based and behavioral marketing: Interest-based and/or behavioral marketing is the term used when potential user interest in ads and other content is determined as precisely as possible. This is done on the basis of information on their previous behaviour (e.g. visiting and staying on certain websites, purchasing behaviour or interaction with other users), which is stored in a so-called profile. Cookies are generally used for these purposes.
  • Conversion measurement: Conversion measurement is a method by which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the devices of the users within the websites on which the marketing measures take place and then called up again on the target website (e.g. we can thus trace whether the advertisements placed by us on other websites were successful).
  • Profiling: “Profiling” means any automated processing of personal data consisting of the use of such personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (including, depending on the type of profiling, information relating to age, gender, location and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people) (e.g. interest in certain content or products, click behaviour on a website or location). Cookies and web beacons are frequently used for profiling purposes.
  • Range measurement : Range measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and may include the behaviour or interests of visitors in specific information, such as the content of websites. With the help of reach analysis, website owners can, for example, recognize at what time visitors visit their website and what content they are interested in. This allows them, for example, to optimize the content of the website to better meet the needs of their visitors. For purposes of range analysis, pseudonymous cookies and web beacons are frequently used in order to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Remarketing: “Remarketing” or “retargeting” is the term used, for example, to indicate for advertising purposes which products a user is interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Location data: Data that indicates the location of the end device of an end user.
  • Tracking: The term “tracking” is used when the behaviour of users can be traced across several online offers. As a rule, behavioural and interest information relating to the online offers used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users that are believed to be of interest to them.
  • Processing: ‘processing’ means any operation or set of operations which is carried out with or without the aid of automated processes and which involves personal data. The term reaches far and covers practically every handling of data, be it collection, evaluation, storage, transmission or deletion.
  • Target group formation: Target group formation (or “custom audiences”) is the term used when target groups are determined for advertising purposes, e.g. insertion of advertisements. For example, a user’s interest in certain products or topics on the Internet may be used to infer that that user is interested in advertisements for similar products or the online store in which they viewed the products. Lookalike Audiences” (or similar target groups) is the term used to describe content that is viewed as suitable by users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used to create custom audiences and lookalike audiences. Target groups can be created by processing visitors to an online offer or can be uploaded to the provider of an online marketing process by uploading (which is usually done pseudonymised).

Sleeptrust

Contact Us