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Privacy Policy

We are very pleased about your interest in our company. Data protection is of particularly high importance to the management of maconda GmbH & Co. KG. Use of the maconda GmbH & Co. KG website is generally possible without providing any personal data. However, if a data subject wishes to use special services offered by our company via our website, processing of personal data may be required. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the data subject’s consent.

The processing of personal data, such as a data subject’s name, address, email address, or telephone number, is always carried out in accordance with the General Data Protection Regulation and in compliance with the country-specific data protection provisions applicable to maconda GmbH & Co. KG. With this Privacy Policy, our company would like to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, this Privacy Policy informs data subjects about the rights to which they are entitled.

As the controller responsible for processing, maconda GmbH & Co. KG has implemented numerous technical and organizational measures to ensure the most complete protection possible of personal data processed via this website. Nevertheless, internet-based data transmissions may generally have security gaps, so absolute protection cannot be guaranteed. For this reason, any data subject is free to transmit personal data to us via alternative means, for example by telephone.

1. Definitions
The Privacy Policy of maconda GmbH & Co. KG is based on the terminology used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our Privacy Policy is intended to be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.

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

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

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

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

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

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

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

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

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

Recipient
A recipient is a natural or legal person, public authority, agency, or other body to which personal data is disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union law or the law of the Member States shall not be regarded as recipients.

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

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

2. Name and address of the controller responsible for processing
The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union, and other provisions of a data protection nature is:

maconda GmbH & Co. KG
Friesenstr. 72-74
50670 Cologne
Germany

Tel.: +49 221 56964-0
Email: info@maconda.de
Website: www.maconda.de

3. Name and address of the Data Protection Officer
The Data Protection Officer of the controller responsible for processing is:

maconda GmbH & Co. KG
Friesenstr. 72-74
50670 Cologne
Germany

Tel.: +49 221 56964-0
Email: datenschutz@maconda.de
Website: www.maconda.de

Any data subject may contact our Data Protection Officer directly at any time with any questions or suggestions regarding data protection.

4. Cookies
The maconda GmbH & Co. KG website uses cookies. Cookies are text files that are stored and saved on a computer system via an internet browser.

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

By using cookies, maconda GmbH & Co. KG can provide users of this website with more user-friendly services that would not be possible without setting cookies.

By means of a cookie, the information and offers on our website can be optimized in the interests of the user. As already mentioned, cookies enable us to recognize users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, a user of a website that uses cookies does not have to re-enter their access data each time they visit the website, because this is handled by the website and the cookie stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop. The online shop remembers the items a customer has placed in the virtual shopping cart via a cookie.

The data subject can prevent the setting of cookies by our website at any time by means of an appropriate setting in the internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject disables the setting of cookies in the internet browser used, not all functions of our website may be fully usable.

To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool “Real Cookie Banner”. Details on how “Real Cookie Banner” works can be found at https://devowl.io/de/rcb/datenverarbeitung/.

The legal bases for the processing of personal data in this context are Art. 6(1)(c) GDPR and Art. 6(1)(f) GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.

Providing the personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we cannot manage your consents.

5. Collection of general data and information
With each access to the website by a data subject or an automated system, the maconda GmbH & Co. KG website collects a series of general data and information. This general data and information is stored in the server log files. The following may be recorded: (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the subpages accessed on our website via an accessing system, (5) the date and time of access to the website, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system, and (8) other similar data and information used for threat prevention in the event of attacks on our information technology systems.

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

6. Registration on our website
The data subject has the option to register on the website of the controller responsible for processing by providing personal data. Which personal data is transmitted to the controller responsible for processing is determined by the respective input form used for registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the controller responsible for processing and for its own purposes. The controller responsible for processing may arrange for the data to be passed on to one or more processors, for example a parcel service provider, which also uses the personal data exclusively for internal use attributable to the controller responsible for processing.

By registering on the website of the controller responsible for processing, the IP address assigned by the data subject’s internet service provider (ISP), as well as the date and time of registration, are also stored. These data are stored because this is the only way to prevent misuse of our services and, if necessary, to enable the investigation of criminal offenses. In this respect, storing these data is necessary to safeguard the controller responsible for processing. These data are generally not passed on to third parties unless there is a legal obligation to do so or the disclosure serves criminal prosecution.

The registration of the data subject, with voluntary provision of personal data, serves the controller responsible for processing in offering the data subject content or services that, by their nature, can only be offered to registered users. Registered persons are free to change the personal data provided during registration at any time or to have it completely deleted from the data records of the controller responsible for processing.

The controller responsible for processing shall provide any data subject, at any time upon request, with information about which personal data relating to the data subject is stored. Furthermore, the controller responsible for processing shall rectify or erase personal data at the request or notice of the data subject, provided that no statutory retention obligations prevent this. All employees of the controller responsible for processing are available to the data subject as contact persons in this context.

7. Subscription to our newsletter
On the maconda GmbH & Co. KG website, users are given the opportunity to subscribe to our company’s newsletter. Which personal data is transmitted to the controller responsible for processing when ordering the newsletter is determined by the input form used for this purpose.

maconda GmbH & Co. KG informs its customers and business partners at regular intervals by means of a newsletter about the company’s offers. In principle, the data subject can only receive our newsletter if (1) the data subject has a valid email address and (2) the data subject has registered for newsletter delivery. For legal reasons, a confirmation email is sent to the email address entered for newsletter delivery for the first time using the double opt-in procedure. This confirmation email serves to verify whether the owner of the email address, as the data subject, has authorized receipt of the newsletter.

When registering for the newsletter, we also store the IP address assigned by the internet service provider (ISP) of the computer system used by the data subject at the time of registration, as well as the date and time of registration. The collection of these data is necessary in order to be able to trace the (possible) misuse of a data subject’s email address at a later point in time and therefore serves the legal protection of the controller responsible for processing.

The personal data collected as part of a newsletter registration is used exclusively for sending our newsletter. Furthermore, newsletter subscribers may be informed by email if this is necessary for the operation of the newsletter service or a related registration, such as in the event of changes to the newsletter offering or changes in technical conditions. No personal data collected as part of the newsletter service is passed on to third parties. The data subject may cancel the subscription to our newsletter at any time. Consent to the storage of personal data that the data subject has given us for newsletter delivery may be revoked at any time. For the purpose of revoking consent, each newsletter contains a corresponding link. Furthermore, it is also possible to unsubscribe from newsletter delivery at any time directly on the website of the controller responsible for processing or to inform the controller responsible for processing of this in another way.

8. Newsletter tracking
The newsletters of maconda GmbH & Co. KG contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in emails sent in HTML format to enable log file recording and log file analysis. This allows a statistical evaluation of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, maconda GmbH & Co. KG can determine whether and when an email was opened by a data subject and which links contained in the email were accessed by the data subject.

Such personal data collected via the tracking pixels contained in the newsletters is stored and evaluated by the controller responsible for processing in order to optimize newsletter delivery and to tailor the content of future newsletters even better to the interests of the data subject. This personal data is not passed on to third parties. Data subjects are entitled at any time to revoke the separate declaration of consent given via the double opt-in procedure. After a revocation, this personal data will be deleted by the controller responsible for processing. Unsubscribing from receiving the newsletter is automatically interpreted by maconda GmbH & Co. KG as a revocation.

9. Contact option via the website
Due to legal requirements, the maconda GmbH & Co. KG website contains information that enables quick electronic contact with our company and direct communication with us, which also includes a general address for so-called electronic mail (email address). If a data subject contacts the controller responsible for processing by email or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted voluntarily by a data subject to the controller responsible for processing is stored for the purpose of processing the request or contacting the data subject. This personal data is not passed on to third parties.

10. Subscription to comments in the blog on the website
Comments posted in the blog of maconda GmbH & Co. KG can generally be subscribed to by third parties. In particular, a commenter may subscribe to the comments that follow their comment on a specific blog post.

If a data subject chooses to subscribe to comments, the controller responsible for processing sends an automatic confirmation email in order to verify, using the double opt-in procedure, that the owner of the specified email address has indeed chosen this option. The option to subscribe to comments can be ended at any time.

11. Routine erasure and blocking of personal data
The controller responsible for processing processes and stores the personal data of the data subject only for the period necessary to achieve the purpose of storage, or insofar as this has been provided for by the European legislator or another legislator in laws or regulations to which the controller responsible for processing is subject.

If the purpose of storage no longer applies or a storage period prescribed by the European legislator or another competent legislator expires, the personal data will be routinely blocked or erased in accordance with statutory provisions.

12. Rights of the data subject

  • Right to confirmation
    Each data subject has the right granted by the European legislator to obtain from the controller responsible for processing confirmation as to whether personal data concerning them is being processed. If a data subject wishes to exercise this right to confirmation, they may contact an employee of the controller responsible for processing at any time.
  • Right of access
    Each data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller responsible for processing, at any time and free of charge, information about the personal data stored about them and a copy of this information. Furthermore, the European legislator has granted the data subject access to the following information:
    • the purposes of the processing
    • the categories of personal data being processed
    • the recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organizations
    • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
    • the existence of the right to rectification or erasure of personal data concerning them, or restriction of processing by the controller, or the right to object to such processing
    • the existence of the right to lodge a complaint with a supervisory authority
    • where the personal data is not collected from the data subject: any available information as to its source
    • the existence of automated decision-making, including profiling, pursuant to Art. 22(1) and (4) GDPR and—at least in those cases—meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject

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

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

  • Right to rectification
    Each data subject affected by the processing of personal data has the right granted by the European legislator to obtain without undue delay the rectification of inaccurate personal data concerning them. Furthermore, the data subject has the right, taking into account the purposes of the processing, to have incomplete personal data completed—including by means of providing a supplementary statement.

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

  • Right to erasure (right to be forgotten)
    Each data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller the erasure of personal data concerning them without undue delay, where one of the following grounds applies and insofar as the processing is not necessary:
    • The personal data has been collected or otherwise processed for purposes for which it is no longer necessary.
    • The data subject revokes their consent on which the processing was based pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, and there is no other legal basis for the processing.
    • The data subject objects to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21(2) GDPR.
    • The personal data has been processed unlawfully.
    • The erasure of the personal data is necessary for compliance with a legal obligation under Union law or the law of the Member States to which the controller is subject.
    • The personal data has been collected in relation to the offer of information society services pursuant to Art. 8(1) GDPR.

If one of the above reasons applies and a data subject wishes to request the erasure of personal data stored by maconda GmbH & Co. KG, they may contact an employee of the controller responsible for processing at any time. The employee of maconda GmbH & Co. KG will ensure that the erasure request is complied with without undue delay.

If maconda GmbH & Co. KG has made the personal data public and our company, as the controller, is obliged pursuant to Art. 17(1) GDPR to erase the personal data, maconda GmbH & Co. KG shall, taking account of available technology and the cost of implementation, take reasonable measures, including technical measures, to inform other controllers processing the published personal data that the data subject has requested from those other controllers the erasure of all links to, or copies or replications of, that personal data, insofar as processing is not required. The employee of maconda GmbH & Co. KG will arrange what is necessary in each individual case.

  • Right to restriction of processing
    Each data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
    The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
    The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of its use instead. The controller no longer needs the personal data for the purposes of the processing, but the data subject requires it for the establishment, exercise, or defense of legal claims. The data subject has objected to processing pursuant to Art. 21(1) GDPR and it has not yet been determined whether the legitimate grounds of the controller override those of the data subject. If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored by maconda GmbH & Co. KG, they may contact an employee of the controller responsible for processing at any time. The employee of maconda GmbH & Co. KG will arrange the restriction of processing.
  • Right to data portability
    Each data subject affected by the processing of personal data has the right granted by the European legislator to receive the personal data concerning them, which was provided by the data subject to a controller, in a structured, commonly used, and machine-readable format. They also have the right to transmit those data to another controller without hindrance from the controller to which the personal data has been provided, where the processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. Furthermore, in exercising their right to data portability pursuant to Art. 20(1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others. To assert the right to data portability, the data subject may contact an employee of maconda GmbH & Co. KG at any time.
  • Right to object
    Each data subject affected by the processing of personal data has the right granted by the European legislator to object, on grounds relating to their particular situation, at any time to the processing of personal data concerning them which is based on Art. 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions. maconda GmbH & Co. KG will no longer process the personal data in the event of an objection unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or the processing serves the establishment, exercise, or defense of legal claims. If maconda GmbH & Co. KG processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data for such marketing. This also applies to profiling insofar as it is related to such direct marketing. If the data subject objects to maconda GmbH & Co. KG to the processing for direct marketing purposes, maconda GmbH & Co. KG will no longer process the personal data for these purposes. In addition, the data subject has the right, on grounds relating to their particular situation, to object to processing of personal data concerning them by maconda GmbH & Co. KG for scientific or historical research purposes or for statistical purposes pursuant to Art. 89(1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest. To exercise the right to object, the data subject may contact any employee of maconda GmbH & Co. KG directly or another employee. The data subject is also free to exercise their right to object, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, by automated means using technical specifications.
  • Automated individual decision-making, including profiling
    Each data subject affected by the processing of personal data has the right granted by the European legislator not to be subject to a decision based solely on automated processing—including profiling—which produces legal effects concerning them or similarly significantly affects them, provided that the decision (1) is not necessary for entering into, or performance of, a contract between the data subject and the controller, or (2) is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is based on the data subject’s explicit consent.
  • If the decision (1) is necessary for entering into, or performance of, a contract between the data subject and the controller, or (2) is based on the data subject’s explicit consent, maconda GmbH & Co. KG shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, including at least the right to obtain human intervention on the part of the controller, to express their point of view, and to contest the decision.
  • If the data subject wishes to assert rights relating to automated decisions, they may contact an employee of the controller responsible for processing at any time.
  • Right to withdraw a data protection consent
    Each data subject affected by the processing of personal data has the right granted by the European legislator to withdraw consent to the processing of personal data at any time.
  • If the data subject wishes to exercise their right to withdraw consent, they may contact an employee of the controller responsible for processing at any time.

13. Data protection for applications and in the application procedure
The controller responsible for processing collects and processes the personal data of applicants for the purpose of handling the application procedure. Processing may also be carried out electronically. This is particularly the case if an applicant submits relevant application documents to the controller responsible for processing electronically, for example by email or via a web form on the website. If the controller responsible for processing concludes an employment contract with an applicant, the transmitted data will be stored for the purpose of handling the employment relationship in compliance with statutory provisions. If the controller responsible for processing does not conclude an employment contract with the applicant, the application documents will be automatically deleted two months after notification of the rejection decision, provided that no other legitimate interests of the controller responsible for processing prevent deletion. Such other legitimate interest may be, for example, an obligation to provide evidence in proceedings under the General Equal Treatment Act (AGG).

14. Data protection provisions on the use of AddThis
The controller responsible for processing has integrated components of the company AddThis on this website. AddThis is a so-called bookmarking provider. The service enables simplified bookmarking of websites via buttons. By hovering the mouse over the AddThis component or clicking it, a list of bookmarking and sharing services is displayed. AddThis is used on more than 15 million websites, and according to the operating company, the buttons are displayed more than 20 billion times per year.

The operating company of AddThis is Oracle Corporation, 10 Van de Graaff Drive, Burlington, MA 01803, USA.

Each time one of the individual pages of this website is accessed, which is operated by the controller responsible for processing and on which an AddThis component has been integrated, the internet browser on the data subject’s information technology system is automatically prompted by the respective AddThis component to download data from the website www.addthis.com. As part of this technical procedure, AddThis obtains knowledge of the visit and which specific individual page of this website is used by the information technology system used by the data subject. Furthermore, AddThis obtains knowledge of the IP address assigned by the internet service provider (ISP) of the computer system used by the data subject, the browser type, the browser language, the website accessed before our website, the date, and the time of the visit to our website. AddThis uses these data to create anonymized user profiles. The data and information transmitted to AddThis in this way enable AddThis itself, as well as companies affiliated with AddThis or its partner companies, to target visitors to the controller’s websites with personalized, interest-based advertising.

AddThis displays personalized, interest-based advertising based on a cookie set by the company. This cookie analyzes the individual browsing behavior of the computer system used by the data subject. The cookie stores visits to websites originating from the computer system.

The data subject can prevent the setting of cookies by our website at any time, as described above, by means of an appropriate setting in the internet browser used and thus permanently object to the setting of cookies. Such a setting in the internet browser used would also prevent AddThis from setting a cookie on the data subject’s information technology system. In addition, cookies already set by AddThis can be deleted at any time via an internet browser or other software programs.

The data subject also has the option to permanently object to the processing of personal data by AddThis. To do so, the data subject must press the opt-out button at the link http://www.addthis.com/privacy/opt-out, which sets an opt-out cookie. The opt-out cookie set with the objection is stored on the information technology system used by the data subject. If the cookies on the data subject’s system are deleted after an objection, the data subject must access the link again and set a new opt-out cookie.

However, by setting the opt-out cookie, it is possible that the controller’s website may no longer be fully usable for the data subject.

The applicable data protection provisions of AddThis can be accessed at http://www.addthis.com/privacy/privacy-policy.

15. Data protection provisions on the use of Google Analytics (with anonymization function)
The controller responsible for processing has integrated the Google Analytics component (with anonymization function) on this website. Google Analytics is a web analytics service. Web analytics is the collection, gathering, and evaluation of data about the behavior of visitors to websites. A web analytics service collects, among other things, data about which website a data subject came from to a website (so-called referrer), which subpages of the website were accessed, or how often and for how long a subpage was viewed. Web analytics is predominantly used to optimize a website and for cost-benefit analysis of internet advertising.

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

The controller uses the “_gat._anonymizeIp” extension for web analysis via Google Analytics. This extension shortens and anonymises the IP address of the data subject’s internet connection by Google if access to our website is from a Member State of the European Union or from another contracting state to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyse visitor traffic on our website. Among other things, Google uses the data and information obtained to evaluate the use of our website, to compile online reports for us showing the activities on our website, and to provide other services related to the use of our website.

Google Analytics places a cookie on the data subject’s information technology system. What cookies are has already been explained above. By setting the cookie, Google is enabled to analyse the use of our website. Each time one of the individual pages of this website is accessed, which is operated by the controller and on which a Google Analytics component has been integrated, the internet browser on the data subject’s information technology system is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical process, Google obtains knowledge of personal data, such as the data subject’s IP address, which serves Google, among other things, to trace the origin of visitors and clicks and subsequently to enable commission settlements.

By means of the cookie, personal information is stored, for example the access time, the location from which access originated, and the frequency of visits to our website by the data subject. Each time our website is visited, this personal data, including the IP address of the internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may disclose this personal data collected via the technical process to third parties.

The data subject can prevent the setting of cookies by our website at any time, as described above, by means of an appropriate setting in the internet browser used and thus permanently object to the setting of cookies. Such a setting in the internet browser used would also prevent Google from setting a cookie on the data subject’s information technology system. In addition, a cookie already set by Google Analytics can be deleted at any time via the internet browser or other software programs.

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

Google Tag Manager

We use the service called Google Tag Manager from Google. “Google” is a group of companies and consists of Google Ireland Ltd. (service provider), Gordon House, Barrow Street, Dublin 4, Ireland, as well as Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, and other affiliated companies of Google LLC. We have concluded a data processing agreement with Google. Google Tag Manager is an auxiliary service and processes personal data itself only for technically necessary purposes. Google Tag Manager ensures the loading of other components, which in turn may collect data. Google Tag Manager does not access this data. Further information and Google’s applicable privacy policy can be accessed at https://www.google.de/intl/de/policies/privacy/ and at http://www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail at https://www.google.com/intl/de_de/analytics/. Please note that US authorities, such as intelligence services, may gain access to personal data due to US laws such as the Cloud Act, which may inevitably be exchanged with Google when integrating this service due to the Internet Protocol (TCP).

16. Privacy policy on the use of Google AdWords
The controller has integrated Google AdWords on this website. Google AdWords is an online advertising service that allows advertisers to place ads both in Google’s search engine results and in the Google advertising network. Google AdWords enables an advertiser to define specific keywords in advance, by means of which an ad is displayed in Google’s search engine results only when the user retrieves a keyword-relevant search result using the search engine. In the Google advertising network, the ads are distributed on topic-relevant websites by means of an automated algorithm and in accordance with the previously defined keywords.

The operating company of the Google AdWords services is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The purpose of Google AdWords is to promote our website by displaying interest-based advertising on the websites of third-party companies and in the search engine results of the Google search engine, and by displaying third-party advertising on our website.

If a data subject reaches our website via a Google ad, a so-called conversion cookie is stored by Google on the data subject’s information technology system. What cookies are has already been explained above. A conversion cookie expires after thirty days and is not used to identify the data subject. Via the conversion cookie, provided the cookie has not yet expired, it is possible to track whether certain subpages, for example the shopping cart of an online shop system, were accessed on our website. The conversion cookie enables both us and Google to track whether a data subject who reached our website via an AdWords ad generated revenue, i.e., completed or cancelled a purchase.

The data and information collected through the use of the conversion cookie are used by Google to create visit statistics for our website. We in turn use these visit statistics to determine the total number of users who were referred to us via AdWords ads, i.e., to determine the success or failure of the respective AdWords ad and to optimise our AdWords ads for the future. Neither our company nor other Google AdWords advertising customers receive information from Google that could be used to identify the data subject.

By means of the conversion cookie, personal information is stored, for example the websites visited by the data subject. Each time our website is visited, personal data, including the IP address of the internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may disclose this personal data collected via the technical process to third parties.

The data subject can prevent the setting of cookies by our website at any time, as described above, by means of an appropriate setting in the internet browser used and thus permanently object to the setting of cookies. Such a setting in the internet browser used would also prevent Google from setting a conversion cookie on the data subject’s information technology system. In addition, a cookie already set by Google AdWords can be deleted at any time via the internet browser or other software programs.

Furthermore, the data subject has the option to object to interest-based advertising by Google. To do so, the data subject must access the link www.google.de/settings/ads from each internet browser they use and make the desired settings there.

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

17. Privacy policy on the use of Jetpack for WordPress
The controller has integrated Jetpack on this website. Jetpack is a WordPress plug-in that provides the operator of a WordPress-based website with additional functions. Among other things, Jetpack allows the website operator to view an overview of the site’s visitors. Displaying related posts and publications or enabling content sharing on the site can also increase visitor numbers. In addition, Jetpack includes security features so that a Jetpack-using website is better protected against brute-force attacks. Jetpack also optimises and accelerates the loading of images integrated on the website.

The operating company of the Jetpack plug-in for WordPress is Aut O’Mattic A8C Ireland Ltd., Business Centre, No.1 Lower Mayor Street, International Financial Services Centre, Dublin 1, Ireland.

Jetpack places a cookie on the data subject’s information technology system. What cookies are has already been explained above. Each time one of the individual pages of this website is accessed, which is operated by the controller and on which a Jetpack component has been integrated, the internet browser on the data subject’s information technology system is automatically prompted by the respective Jetpack component to transmit data to Automattic for analysis purposes. As part of this technical process, Automattic obtains knowledge of data that is subsequently used to create an overview of website visits. The data thus obtained is used to analyse the behaviour of the data subject who accessed the controller’s website and is evaluated with the aim of optimising the website. The data collected via the Jetpack component is not used to identify the data subject without first obtaining separate, explicit consent from the data subject. The data is also made known to Quantcast. Quantcast uses the data for the same purposes as Automattic.

The data subject can prevent the setting of cookies by our website at any time, as described above, by means of an appropriate setting in the internet browser used and thus permanently object to the setting of cookies. Such a setting in the internet browser used would also prevent Automattic/Quantcast from setting a cookie on the data subject’s information technology system. In addition, cookies already set by Automattic can be deleted at any time via the internet browser or other software programs.

Furthermore, the data subject has the option to object to the collection of data generated by the Jetpack cookie relating to the use of this website and to the processing of this data by Automattic/Quantcast, and to prevent such collection and processing. To do so, the data subject must press the opt-out button at https://www.quantcast.com/opt-out/, which sets an opt-out cookie. The opt-out cookie set with the objection is stored on the information technology system used by the data subject. If the cookies on the data subject’s system are deleted after an objection, the data subject must access the link again and set a new opt-out cookie.

However, by setting the opt-out cookie, it is possible that the controller’s website may no longer be fully usable for the data subject.

Automattic’s applicable privacy policy can be accessed at https://automattic.com/privacy/. Quantcast’s applicable privacy policy can be accessed at https://www.quantcast.com/privacy/.

18. Privacy policy on the use of LinkedIn
The controller has integrated components of LinkedIn Corporation on this website. LinkedIn is an internet-based social network that enables users to connect with existing business contacts and to establish new business contacts. Over 400 million registered people use LinkedIn in more than 200 countries. LinkedIn is currently the largest platform for business contacts and one of the most visited websites in the world.

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

Each time our website is accessed, which is equipped with a LinkedIn component (LinkedIn plug-in), this component causes the browser used by the data subject to download a corresponding display of the LinkedIn component. Further information on the LinkedIn plug-ins can be accessed at https://developer.linkedin.com/plugins. As part of this technical process, LinkedIn obtains knowledge of which specific subpage of our website is visited by the data subject.

If the data subject is simultaneously logged in to LinkedIn, LinkedIn recognises with each access to our website by the data subject and for the entire duration of the respective stay on our website which specific subpage of our website the data subject visits. This information is collected by the LinkedIn component and assigned by LinkedIn to the data subject’s respective LinkedIn account. If the data subject clicks a LinkedIn button integrated on our website, LinkedIn assigns this information to the data subject’s personal LinkedIn user account and stores this personal data.

LinkedIn always receives information via the LinkedIn component that the data subject has visited our website if the data subject is simultaneously logged in to LinkedIn at the time our website is accessed; this occurs regardless of whether the data subject clicks the LinkedIn component or not. If the data subject does not want such information to be transmitted to LinkedIn, they can prevent the transmission by logging out of their LinkedIn account before accessing our website.

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

19. Privacy policy on the use of Shariff
The controller has integrated the Shariff component on this website. The Shariff component provides social media buttons that comply with data protection requirements. Shariff was developed for the German computer magazine c’t and is published via GitHub, Inc.

The developer of the component is GitHub, Inc., 88 Colin P. Kelly Junior Street, San Francisco, CA 94107, USA.

Typically, the button solutions provided by social networks transmit personal data to the respective social network as soon as a user visits a website into which a social media button has been integrated. By using the Shariff component, personal data is only transmitted to social networks when the visitor to a website actively clicks one of the social media buttons. Further information on the Shariff component is provided by the computer magazine c’t at http://www.heise.de/newsticker/meldung/Datenschutz-und-Social-Media-Der-c-t-Shariff-ist-im-Einsatz-2470103.html. The use of the Shariff component serves the purpose of protecting the personal data of visitors to our website while at the same time enabling us to integrate a button solution for social networks on this website.

Further information and GitHub’s applicable privacy policy can be accessed at https://help.github.com/articles/github-privacy-policy/.

20. Privacy policy on the use of Xing
The controller has integrated components of Xing on this website. Xing is an internet-based social network that enables users to connect with existing business contacts and to establish new business contacts. Individual users can create a personal profile on Xing. Companies can, for example, create company profiles or publish job postings on Xing.

The operating company of Xing is XING SE, Dammtorstraße 30, 20354 Hamburg, Germany.

Each time one of the individual pages of this website is accessed, which is operated by the controller and on which a Xing component (Xing plug-in) has been integrated, the internet browser on the data subject’s information technology system is automatically prompted by the respective Xing component to download a display of the corresponding Xing component from Xing. Further information on the Xing plug-ins can be accessed at https://dev.xing.com/plugins. As part of this technical process, Xing obtains knowledge of which specific subpage of our website is visited by the data subject.

If the data subject is simultaneously logged in to Xing, Xing recognises with each access to our website by the data subject and for the entire duration of the respective stay on our website which specific subpage of our website the data subject visits. This information is collected by the Xing component and assigned by Xing to the data subject’s respective Xing account. If the data subject clicks one of the Xing buttons integrated on our website, for example the “Share” button, Xing assigns this information to the data subject’s personal Xing user account and stores this personal data.

Xing always receives information via the Xing component that the data subject has visited our website if the data subject is simultaneously logged in to Xing at the time our website is accessed; this occurs regardless of whether the data subject clicks the Xing component or not. If the data subject does not want such information to be transmitted to Xing, they can prevent the transmission by logging out of their Xing account before accessing our website.

The privacy policy published by Xing, which can be accessed at https://www.xing.com/privacy, provides information about the collection, processing and use of personal data by Xing. In addition, Xing has published data protection information for the XING Share button at https://www.xing.com/app/share?op=data_protection.

21. Legal basis for processing
Art. 6(1)(a) GDPR serves our company as the legal basis for processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, with processing operations necessary for the delivery of goods or the provision of another service or consideration, the processing is based on Art. 6(1)(b) GDPR. The same applies to such processing operations that are necessary to carry out pre-contractual measures, for example in cases of enquiries about our products or services. If our company is subject to a legal obligation that requires the processing of personal data, for example to fulfil tax obligations, the processing is based on Art. 6(1)(c) GDPR. In rare cases, the processing of personal data may be necessary to protect vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured on our premises and their name, age, health insurance data or other vital information had to be passed on to a doctor, a hospital or other third parties. In that case, the processing would be based on Art. 6(1)(d) GDPR. Ultimately, processing operations may be based on Art. 6(1)(f) GDPR. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to safeguard a legitimate interest of our company or of a third party, provided that the interests, fundamental rights and freedoms of the data subject do not override them. Such processing operations are permitted to us in particular because they were specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 sentence 2 GDPR).

22. Legitimate interests in processing pursued by the controller or a third party
If the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is the conduct of our business activities for the benefit of the well-being of all our employees and our shareholders.

23. Duration for which personal data is stored
The criterion for the duration of the storage of personal data is the respective statutory retention period. After expiry of the period, the corresponding data is routinely deleted, provided it is no longer required for contract performance or contract initiation.

24. Statutory or contractual provisions on the provision of personal data; necessity for concluding a contract; obligation of the data subject to provide the personal data; possible consequences of failure to provide
We inform you that the provision of personal data is partly required by law (e.g., tax regulations) or may also result from contractual provisions (e.g., information on the contracting party). In some cases, it may be necessary for the conclusion of a contract that a data subject provides us with personal data that must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before providing personal data, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and what the consequences of failure to provide the personal data would be.

25. Existence of automated decision-making
As a responsible company, we refrain from automated decision-making or profiling.

This model privacy policy was created by the privacy policy generator of DGD Deutsche Gesellschaft für Datenschutz GmbH, which carries out data protection audits, in cooperation with the media law firm WILDE BEUGER SOLMECKE.

Further sources: Klaus Meffert, Dr. GDPR Blog
Privacy Policy