Privacy Policy
1. An overview of data protection
1.1 General information
The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.
1.2 Data recording on this website
1.2.1 Who is the responsible party for the recording of data on this website (i.e., the "controler")?
The data on this website is processed by the operator of the website, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Policy.
1.2.2 How do we record your data?
We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form.
Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.
1.2.3 What are the purposes we use your data for?
A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns. If contracts can be concluded or initiated via the website, the transmitted data will also be processed for contract offers, orders or other order enquiries.
1.2.4 What rights do you have as far as your information is concerned?
You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.
Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.
1.2.5 Analysis tools and tools provided by third partis
There is a possibility that your browsing patterns will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer to as analysis programs.
For detailed information about these analysis programs please consult our Data Protection Declaration below.
2. Hosting and Contet Delivery Networks (CDN)
We are hosting the content of our website at the following providers:
2.1 Amazon Web Services (AWS)
The provider is the Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, 1855 Luxembourg (hereinafter referred to as “AWS”).
When you visit our website, your personal data will be processed on AWS servers. This may also result in the transfer of personal data to the parent company of AWS in the United States. The transfer of data to the US is based on the EU’s standard contractual clauses. For details please consult: https://aws.amazon.com/de/blogs/security/aws-gdpr-data-processing-addendum/
For more information, please see the AWS Data Privacy Policy: https://aws.amazon.com/de/privacy/?nc1=f_pr
AWS is used on the basis of Art. 6(1)(f) GDPR. We have a legitimate interest in a depiction of our website that is as reliable as possible. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5776
2.1.1 Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.
2.2 Cloudflare
We use the “Cloudflare” service provided by Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA. (hereinafter referred to as “Cloudflare”).
Cloudflare offers a content delivery network with DNS that is available worldwide. As a result, the information transfer that occurs between your browser and our website is technically routed via Cloudflare’s network. This enables Cloudflare to analyze data transactions between your browser and our website and to work as a filter between our servers and potentially malicious data traffic from the Internet. In this context, Cloudflare may also use cookies or other technologies deployed to recognize Internet users, which shall, however, only be used for the herein described purpose.
The use of Cloudflare is based on our legitimate interest in a provision of our website offerings that is as error free and secure as possible (Art. 6(1)(f) GDPR).
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details and further information on security and data protection at Cloudflare can be found here: https://www.cloudflare.com/privacypolicy/
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5666
3. General information and mandatory information
3.1 Data protection
The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.
Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.
We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.
3.2 Information about the responsible party (referred to as the "controller" in the GDPR)
The data processing controller on this website is:
Gustav Daiber GmbH
Vor dem Weißen Stein 25-31
D-72461 Albstadt
CEO: Kai Gminder, Christof Kunze
Phone: 07432-7016-0 I E-mail: [email protected]
The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).
3.3 Storage duration
Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.
3.4 General information on the legal basis for the data processing on this website
If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) DSGVO. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art. 49 (1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TDDDG. The consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art. 6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.
3.5 Designation of a data protection officer
We have appointed a data protection officer:
E-Mail: [email protected]
Phone: +49 151 730 44 032
3.6 Recipients of personal data
In the scope of our business activities, we cooperate with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only disclose personal data to external parties if this is required as part of the fulfillment of a contract, if we are legally obligated to do so (e.g., disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Art. 6 (1)(f) GDPR, or if another legal basis permits the disclosure of this data. When using processors, we only disclose personal data of our customers on the basis of a valid contract on data processing. In the case of joint processing, a joint processing agreement is concluded.
3.7 Revocation of your consent to the processing of data
A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.
3.8 Right to object to the collection of daata in special cases; right to object to direct advertising (Art. 21 GDPR)
IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21(1) GDPR).
IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).
3.9 Right to log a complaint with the competent supervisory agency
In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.
Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-Württemberg
Postfach 10 29 32
70025 Stuttgart
Phone: 0711/615541-0
Fax: 0711/615541-15
E-mail: [email protected]
3.10 Right to data portability
You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.
3.11 Information about, rectification and eradication of data
Within the scope of the applicable statutory provisions, you have the right to demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data at any time. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time.
3.12 Right to demand processing restrictions
You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:
- In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
- If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data instead of demanding the eradication of this data.
- If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
- If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.
If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.
3.13 SSL and/or TLS encryption
For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.
If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.
3.14 Rejection of unsolicited e-mails
We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in our Site Notice to send us promotional and information material that we have not expressly requested. The operators of this website and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.
4 Recording of data on this website
4.1 Cookies
Our websites and pages use what the industry refers to as “cookies.” Cookies are small data packages that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser.
Cookies can be issued by us (first-party cookies) or by third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services of third-party companies into websites (e.g., cookies for handling payment services).
Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of these cookies (e.g., the shopping cart function or the display of videos). Other cookies may be used to analyze user behavior or for promotional purposes.
Cookies, which are required for the performance of electronic communication transactions, for the provision of certain functions you want to use (e.g., for the shopping cart function) or those that are necessary for the optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of required cookies to ensure the technically error-free and optimized provision of the operator’s services. If your consent to the storage of the cookies and similar recognition technologies has been requested, the processing occurs exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR and § 25 (1) TDDDG); this consent may be revoked at any time.
You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete-function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.
Which cookies and services are used on this website can be found in this privacy policy.
4.2 CookieFirst
Our website uses CookieFirst to obtain your consent to the storage of certain cookies on your device or to use certain technologies and document them in a privacy-compliant manner. The provider of this technology is Digital Data Solutions B.V. (CookieFirst), Plantage Middenlaan 42A, 1018 DH Amsterdam, The Netherlands (hereinafter “CookieFirst”).
When you enter our website, a connection to CookieFirst's servers is established to obtain your consent and other statements regarding cookie use. CookieFirst then stores a cookie in your browser in order to be able to assign the consents granted to you or their revocation. In this process, the IP address (anonymized), the user agent of the browser and operating system, as well as the URL from which the consent was granted, are processed and integrated into CookieFirst. The data collected in this way is stored until you request us to delete it, delete the CookieFirst cookie yourself or the purpose for storing the data no longer applies. Mandatory statutory retention obligations remain unaffected.
CookieFirst transfers personal data to third-party providers. These include a CDN from Slovenia, IP geolocation from Romania, and hosting at OHV in Germany and France. CookieFirst has its corporate headquarters in Amsterdam, the Netherlands.
We use CookieFirst to obtain the consent required by law for the use of cookies from site visitors. The legal basis for this is Art. 6(1)(1)(c) GDPR.
4.2.1 Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.
4.3 Server log files
The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:
- The type and version of browser used
- The used operating system
- Referrer URL
- The hostname of the accessing computer
- The time of the server inquiry
- The IP address
This data is not merged with other data sources.
This data is recorded on the basis of Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded. Server log files are being stored for 7 days and then deleted.
4.4 Merchandise Management System
For order and contract processing, we use merchandise management systems from external service providers. Our service providers act on our behalf within the framework of a data processing agreement. If you have any questions about our service providers and the basis of our cooperation with them, please use the contact option described in this privacy policy.
4.4.1 plusserver GmbH
The provider is plusserver GmbH, Welserstraße 14, 51149 Cologne, Germany (hereinafter "plusserver"). When you visit our shop or place an order, plusserver collects and processes various log files, including your IP addresses, among other data. For details, please refer to plusserver's privacy policy: https://www.plusserver.com/datenschutzerklaerung/. In this context, plusserver hosts our ERP and merchandise management system, which is connected to our shop.
The use of plusserver is based on Art. 6 (1) (f) GDPR. We have a legitimate interest in ensuring our website is presented as reliably as possible and in the efficient processing of our orders. If the relevant consent has been requested, processing is carried out exclusively on the basis of Art. 6 (1) (a) GDPR and § 25 (1) TDDDG (German Telecommunications Telemedia Data Protection Act), insofar as the consent includes the storage of cookies or access to information on the user's terminal device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.
Data processing Agreement
We have concluded a data processing agreement (DPA) for the use of the aforementioned service. This is a contract mandated by data protection law, which ensures that this provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.
4.5 Contact form
If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.
The processing of these data is based on Art. 6(1)(b) GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or on your agreement (Art. 6(1)(a) GDPR) if this has been requested; the consent can be revoked at any time.
The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions, in particular retention periods.
4.6 General Inquiry Form
When you use our general inquiry form, we process the personal data you provide in it (mandatory fields: Company, Street, House Number, Postal Code, City, First Name, Last Name, Email; voluntary information: Remarks, Additional Information, Title, Telephone, Fax, Country, Contact Language) to receive, review, and respond to your inquiry. The processing is based on Art. 6(1)(b) GDPR, insofar as your inquiry is aimed at initiating a contractual relationship, or on Art. 6(1)(f) GDPR, whereby our legitimate interest lies in the proper processing of inquiries. The information on contact language is used to contact you in your preferred language. Your data will be used exclusively for processing your inquiry and will only be transmitted internally to the responsible departments. It will not be passed on to third parties without your express consent unless we are legally obligated to do so. The data will be deleted as soon as it is no longer required for the purpose for which it was collected, unless statutory retention obligations prevent this.
4.7 Inquiry Form to become a Dealer
If you submit an inquiry via our form and wish to apply for dealer access at the same time, we process the information you provide (mandatory fields: Company, Street, House Number, Postal Code, City, First Name, Last Name, Email, Password, VAT ID No., Register Court, Commercial Register Number; voluntary information: Remarks, Additional Information, Title, Telephone, Fax, Country, Contact Language, Checkbox for contact permission) to answer your inquiry and to check and prepare your registration as a dealer in our dealer portal. The legal basis for the processing is Art. 6(1)(b) GDPR (pre-contractual relationship) and—with regard to voluntary information—Art. 6(1)(a) GDPR (consent). By checking the box, you give your consent for us to actively contact you. Your password is processed exclusively for the creation of your user account; the password is stored in encrypted form. Your data will be used exclusively for processing your inquiry and will only be transmitted internally to the responsible departments. It will not be passed on to third parties without your express consent unless we are legally obligated to do so. The data will be deleted as soon as it is no longer required for carrying out the registration and any subsequent processes, unless statutory retention obligations exist.
4.8 Dealer Access Application Form
If you use our form exclusively to apply for access to the dealer portal, we process the personal data you provide (mandatory fields: Company, First Name, Last Name, Title, Telephone, Email, Password, VAT ID No., Register Court, Commercial Register Number; voluntary information: Country, Contact Language, Website, Checkbox for contact permission) to verify your identity, generate your access data, and grant you access to our dealer portal. The processing is based on Art. 6(1)(b) GDPR (for the performance of pre-contractual measures) and, in the case of voluntary information, on the basis of your consent in accordance with Art. 6(1)(a) GDPR. If you consent by checking the box, we may also actively contact you in connection with your request. Your password will be stored securely and in encrypted form. Your data will only be passed on to responsible internal departments; it will not be transmitted to third parties. The data will be deleted as soon as it is no longer required for the provision and administration of the access and no statutory retention obligations oppose this.
4.9 Data Transfer to Shipping Service Providers for the Purpose of Shipping Notification
If you have given us your express consent for this during or after your order, we will pass on your e-mail address and telephone number to the selected shipping service provider in accordance with Art. 6(1)(a) GDPR, so that they can contact you before delivery for the purpose of delivery notification or coordinatio1n.
This consent can be revoked at any time by sending a message to the contact option described in this privacy policy or directly to the shipping service provider at the contact address listed below. After revocation, we will delete 2the data you provided for this purpose, unless you have expressly consented to further use of your data or we reserve the right to use data beyond this scope, which is permitted by law and about which we inform you in this statement.
United Parcel Service Deutschland S.à r.l. & Co. OHG
Görlitzer Straße 1
41460 Neuss
Germany
DHL Paket GmbH
Sträßchensweg 10
53113 Bonn
Germany
Other freight forwarders commissioned by us for shipping in individual cases.
4.10 Request by e-mail, post, telephone, or fax
If you contact us by e-mail, post, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.
These data are processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained; the consent can be revoked at any time.
The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.
4.11 Jotform
We have integrated Jotform into this website. The provider is Jotform Inc., 111 Pine St. Suite, 1815 San Francisco, California 94111, USA (hereinafter referred to as “Jotform”).
Jotform enables us to generate online forms to record messages, inquiries and other entries entered by visitors to our website. All entries you make will be processed on Jotform’s servers.
We use Jotform on the basis of our legitimate interest in determining your needs as effectively as possible (Art. 6(1)(f) GDPR). If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.
The data you enter into the form will remain in our possession until you ask us to delete them, revoke your consent to the archiving of your data or until the purpose of archiving the data no longer exists (e.g., upon completion of the processing of your inquiry). This does not affect mandatory statutory provisions – in particular those governing retention periods.
The transfer of the data to the United States is safeguarded by EU Standard Contract Clauses we have executed with Jotform. For details, please follow this link: https://www.jotform.com/gdpr-compliance/dpa/
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/6788
4.11.1 Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.
4.12 Registration on this website
You have the option to register on this website to be able to use additional website functions. We shall use the data you enter only for the purpose of using the respective offer or service you have registered for. The required information we request at the time of registration must be entered in full. Otherwise, we shall reject the registration.
To notify you of any important changes to the scope of our portfolio or in the event of technical modifications, we shall use the e-mail address provided during the registration process.
The data entered during registration is processed for the purpose of implementing the user relationship established by the registration and, if necessary, for the initiation of further contracts (Art. 6 (1)(b) GDPR).
The data recorded during the registration process shall be stored by us as long as you are registered on this website. Subsequently, such data shall be deleted. This shall be without prejudice to mandatory statutory retention obligations.
5. Analysis tools and advertising
5.1 Google Tag Manager
We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via it. However, the Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States.
The Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the quick and uncomplicated integration and administration of various tools on his website. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780
5.2 Cloudflare Turnstile
We use Cloudflare Turnstile (hereinafter "Turnstile") on this website. The provider is Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA (hereinafter "Cloudflare").
Turnstile is intended to verify whether the data entry on this website (e.g., in a contact form) is made by a human or by an automated program. To do this, Turnstile analyzes the behavior of the website visitor based on various characteristics.
This analysis begins automatically as soon as the website visitor enters a website with Turnstile enabled. For the analysis, Turnstile evaluates various pieces of information (e.g., IP address, the visitor's duration of stay on the website, or mouse movements made by the user). The data collected during the analysis is forwarded to Cloudflare.
The storage and analysis of the data are based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in protecting their web offerings from abusive automated spying and from SPAM. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG (German Telecommunications Telemedia Data Protection Act), insofar as the consent includes the storage of cookies or access to information on the user's terminal device (e.g., device fingerprinting) within the meaning of the TDDDG. The consent can be revoked at any time.
The data processing is based on Standard Contractual Clauses, which you can find here: https://www.cloudflare.com/cloudflare-customer-scc/
Further information about Cloudflare Turnstile can be found in the data processing agreement here: https://www.cloudflare.com/cloudflare-customer-dpa/
The company is certified under the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF commits to upholding these data protection standards. You can obtain more information on this from the provider at the following link: https://www.dataprivacyframework.gov/participant/5666
5.3 Hotjar
This website utilizes Hotjar. The provider is Hotjar Ltd., Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta, Europe (website: https://www.hotjar.com).
Hotjar is a tool used to analyze your user patterns on this website. Hotjar allows us to for instance record your mouse and scroll movements as well as your click. During this process, Hotjar also has the capability to determine how long your cursor remained in a certain position. Based on this information, Hotjar compiles so-called Heatmaps, that make possible to determine which parts of the website the website visitor reviews with preference.
We are also able to determine how long you have stayed on a page of this website and when you left. We can also determine at which point you suspended making entries into a contact form (so-called conversion funnels).
Furthermore, Hotjar can be deployed to obtain direct feedback from website visitors. This function aims at the improvement of the website offerings of the website operator.
Hotjar uses technologies that make it possible to recognize the user for the purpose of analyzing the user patterns (e.g., cookies or the deployment of device fingerprinting).
If your approval (consent) has been obtained the use of the abovementioned service shall occur on the basis of Art. 6(1)(a) GDPR and § 25 TDDDG (German Telecommunications Act). Such consent may be revoked at any time. If your consent was not obtained, the use of the service will occur on the basis of Art. 6(1)(f) GDPR; the website operator has a legitimate interest in the analysis of user patterns to optimize both, the web presentation and the operator’s advertising activities.
5.3.1 Deactivation of Hotjar
If you would like to deactivate the recording of data by Hotjar, please click on the link below and follow the instructions provided under the link: https://www.hotjar.com/policies/do-not-track/
Please keep in mind that you will have to separately deactivate Hotjar for every browser and every device.
For more detailed information about Hotjar and the data to be recorded, please consult the Data Privacy Declaration of Hotjar under the following link: https://www.hotjar.com/privacy
5.3.2 Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.
5.4 Matomo
This website uses the open-source web analysis service Matomo.
Through Matomo, we are able to collect and analyze data on the use of our website-by-website visitors. This enables us to find out, for instance, when which page views occurred and from which region they came. In addition, we collect various log files (e.g. IP address, referrer, browser, and operating system used) and can measure whether our website visitors perform certain actions (e.g. clicks, purchases, etc.).
The use of this analysis tool is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the analysis of user patterns, in order to optimize the operator’s web offerings and advertising. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.
5.4.1 IP anonymization
For analysis with Matomo we use IP anonymization. Your IP address is shortened before the analysis, so that it is no longer clearly assignable to you.
5.4.2 Hosting
We host Matomo exclusively on our own servers so that all analysis data remains with us and is not passed on.
5.5 Micro-Conversions
To continuously improve our platform and user experience, we collect certain interactions of logged-in users, such as clicks on control elements, the use of filter functions, or scrolling behavior. This information helps us, among other things, to optimize our services and to address our users in the most individual and personalized way possible, for example, via email. You can object to receiving emails in this context at any time with future effect in every notification email. No information is stored on your terminal device, nor is any such information accessed.
Data processed in connection with Micro-Conversions:
- Clerk/Agent ID: If the user is logged in, their unique ID is recorded; otherwise, dummy values are used.
- IP Address: The logged-in user's IP address is stored to technically assign the interactions.
- Session ID: A unique identifier for the current session to recognize related actions.
- Context of the Micro-Conversion: Information about the context in which the micro-conversion occurs.
- Event Name: The designation of the specific event being recorded.
- Event Date: The exact time at which the event occurred.
- User Agent: Technical information about the device and browser used by the user.
- Payload Field: Additional information relevant to the specific micro-conversion event.
This data is processed on the basis of our legitimate interest in accordance with Art. 6(1)(f) GDPR to improve the usability of our platform, to detect and analyze errors, and to offer our users the most suitable functions, products, and finishing options. You can find more information on our data protection practices in our privacy policy.
6. Plugins and Tool
6.1 Personalisazion of Products via Embroidery Pattern Configurator
We offer you the option to personalize selected products by embroidering an individual logo or image. For this purpose, we provide a tool in the "Configure, order with logo" section, which is only accessible to registered and logged-in users.
6.2 Purpose, Scope, and Legal Basis of Data Processing
When you use this tool, we process the image or logo file you upload exclusively for the purpose of creating an embroidery pattern that is readable by our embroidery machines and for calculating a price. This includes the technical conversion of the file format and the analysis of the file to determine the scope of the embroidery (e.g., the number of stitches required) in order to provide you with a quote and to produce your order. Only the image or logo file you upload in the configurator is processed. This file may contain personal data if, for example, it shows images of people, names, or other identifying features.
The processing of this data is necessary for carrying out pre-contractual measures (quote creation) and for the subsequent fulfillment of the contract for the production of a personalized product. The legal basis for the processing is therefore Art. 6(1)(b) GDPR.
6.3 Recipients of the Data and Data Processing
To technically enable the creation of the embroidery pattern, we work with specialized service providers who act as our data processors and process your data strictly according to our instructions. We have concluded data processing agreements (DPAs) with both service providers in accordance with Art. 28 GDPR, which ensure that your data is protected and used only for the defined purposes.
6.3.1 File Format Conversion by Cloudconvert
To convert your file into a format compatible with our embroidery machines, we use the following service provider, to whom the file you upload is transmitted: Lunaweb GmbH, Nördliche Münchner Straße 47, 82031 Grünwald, Germany. Lunaweb GmbH stores your file only temporarily for the duration of the conversion process. After the conversion is complete, but no later than 24 hours, your file will be automatically and irrevocably deleted from the servers of Lunaweb GmbH.
6.3.2 Analysis of Embroidery Scope by Tajima PulseID Toolkit
After conversion, the file is forwarded to the following service provider to analyze the necessary scope for the embroidery (e.g., the stitch count): Tajima Software Solutions Inc., Suite 402, 7125 Mississauga Rd., Mississauga, Ontario L5N 0C2, Canada.
The headquarters of Tajima Software Solutions Inc. is in Canada, a country outside the European Union (a third country). The transfer of your data to Canada is permissible under Art. 45 GDPR, as the EU Commission has determined in an adequacy decision that Canada ensures an adequate level of data protection for commercial organizations subject to the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA). Your data therefore enjoys a level of protection in Canada that is essentially equivalent to that in the EU.
In accordance with the contractual agreements made with Tajima Software Solutions Inc., your file will also be stored by this service provider only temporarily for the duration of the technical analysis and will be deleted immediately thereafter.
7. Newsletter
7.1 Newsletter data
If you would like to receive the newsletter offered on the website, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the newsletter. Further data is not collected or only on a voluntary basis. For the handling of the newsletter, we use newsletter service providers, which are described below.
7.2 CleverReach
This website uses CleverReach for the sending of newsletters. The provider is the CleverReach GmbH & Co. KG, Schafjückenweg 2, 26180 Rastede, Germany (hereinafter “CleverReach”). CleverReach is a service that can be used to organize and analyze the sending of newsletters. The data you have entered for the purpose of subscribing to our newsletter (e.g., e-mail address) are stored on servers of CleverReach in Germany or in Ireland.
Newsletters we send out via CleverReach allow us to analyze the user patterns of our newsletter recipients. Among other things, in conjunction with this, it is possible how many recipients actually opened the newsletter e-mail and how often which link inside the newsletter has been clicked. With the assistance of a tool called Conversion Tracking, we can also determine whether an action that has been predefined in the newsletter actually occurred after the link was clicked (e.g., purchase of a product on this website). For more information on the data analysis services by CleverReach newsletters, please go to: https://www.cleverreach.com/en/features/reporting-tracking/
The data is processed based on your consent (Art. 6(1)(a) GDPR). You may revoke any consent you have given at any time by unsubscribing from the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place prior to your revocation.
If you do not want to permit an analysis by CleverReach, you must unsubscribe from the newsletter. We provide a link for you to do this in every newsletter message.
The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected.
After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist, if such action is necessary to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.
For more details, please consult the Data Protection Provisions of CleverReach at: https://www.cleverreach.com/en/privacy-policy/
7.2.1 Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.
7.3 Newsletter mailing to existing customers
If you order goods or services from us and enter your e-mail address, this e-mail address may subsequently be used by us to send you newsletters, provided we inform you of this in advance. In such a case, only direct advertising for our own similar goods or services will be sent via the newsletter. You can unsubscribe from this newsletter at any time. There is a corresponding link in every newsletter for this purpose. In this case, the legal basis for sending the newsletter is Art. 6 (1)(f) GDPR in conjunction with Section 7 (3) UWG.
After you unsubscribe from the newsletter distribution list, we may store your email address in a blacklist to prevent future mailings to you. The data from the blacklist will only be used for this purpose and will not be merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 (1)(f) GDPR). Storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.
8. Social Media
8.1 Facebook
This website integrates icons (image of the social media platform's logo with a link to our social media presence there) of the social network Facebook. Clicking on the icon will redirect you to the Facebook page. This is not a "Like" or "Share" button. The provider of the service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. However, according to Facebook, the data collected when visiting the Facebook page is also transferred to the USA and other third countries.
When you click on the Facebook icon provided on this website, a direct connection is established between your browser and the Facebook server. Facebook thereby receives the information that you have visited this website with your IP address. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by Facebook. For more information, please see Facebook's privacy policy at: https://de-de.facebook.com/privacy/explanation
If you do not want Facebook to be able to associate your visit to our Facebook page with your Facebook user account, please log out of your Facebook user account beforehand.
The use of the Facebook icon with a link to our Facebook page is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in achieving the widest possible visibility on social media.
Insofar as you click on the icon and are redirected to our Facebook page, personal data is collected on our website and forwarded to Facebook. In this respect, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 GDPR).
The joint responsibility is limited exclusively to the collection of the data and its transfer to Facebook. The processing by Facebook that takes place after the transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. You can find the text of the agreement at: https://www.facebook.com/legal/controller_addendum
According to this agreement, we are responsible for providing the data protection information when using the Facebook tool or icon link and for the data protection-compliant implementation of the tool or link on our website. Facebook is responsible for the data security of Facebook products. You can assert data subject rights (e.g., requests for information) regarding the data processed by Facebook directly with Facebook. If you assert your data subject rights with us, we are obliged to forward them to Facebook.
The data transfer to the USA is based on the Standard Contractual Clauses of the EU Commission.
Details can be found here:
https://www.facebook.com/legal/EU_data_transfer_addendum,
https://de-de.facebook.com/help/566994660333381 and
https://www.facebook.com/policy.php.
The company is certified under the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF commits to upholding these data protection standards. You can obtain more information on this from the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt0000000GnywAAC&status=Active
8.2 Instagram
This website integrates icons (image of the social media platform's logo with a link to our social media presence there) of the social network Instagram. Clicking on the icon will redirect you to the Instagram page. This is not a "Like" or "Share" button. The provider of the Instagram website is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. However, according to Facebook or Instagram, the data collected when visiting the Instagram page is also transferred to the USA and other third countries.
When you click on the Instagram icon provided on this website, a direct connection is established between your browser and the Instagram server. Instagram thereby receives the information that you have visited this website with your IP address. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by Instagram.
Insofar as you click on the icon and are redirected to our Instagram page, personal data is collected on our website and forwarded to Facebook or Instagram. In this respect, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 GDPR).
The joint responsibility is limited exclusively to the collection of the data and its transfer to Facebook or Instagram. The processing by Facebook or Instagram that takes place after the transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. You can find the text of the agreement at: https://www.facebook.com/legal/controller_addendum
According to this agreement, we are responsible for providing the data protection information when using the Facebook or Instagram tool or icon link and for the data protection-compliant implementation of the tool or link on our website. Facebook is responsible for the data security of Facebook or Instagram products. You can assert data subject rights (e.g., requests for information) regarding the data processed by Facebook or Instagram directly with Facebook. If you assert your data subject rights with us, we are obliged to forward them to Facebook.
If you do not want Instagram to be able to associate your visit to our Instagram website with your Instagram user account, please log out of your Instagram user account beforehand.
The data transfer to the USA is based on the Standard Contractual Clauses of the EU Commission.
Details can be found here:
https://www.facebook.com/legal/EU_data_transfer_addendum,
https://privacycenter.instagram.com/policy/ and
https://de-de.facebook.com/help/566994660333381.
For more information, please see Instagram's privacy policy: https://privacycenter.instagram.com/policy/
The company is certified under the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF commits to upholding these data protection standards. You can obtain more information on this from the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt0000000GnywAAC&status=Active
8.3 YouTube with Enhanced Privacy
This website embeds videos from the YouTube website. The operator of the website is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.
When you visit one of our pages on which YouTube is embedded, a connection to the YouTube servers is established. This tells the YouTube server which of our pages you have visited. If you are logged into your YouTube account, you enable YouTube to assign your surfing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account.
We use YouTube in enhanced privacy mode. According to YouTube, videos played in enhanced privacy mode are not used to personalize browsing on YouTube. Ads displayed in enhanced privacy mode are also not personalized. No cookies are set in enhanced privacy mode. Instead, however, so-called local storage elements are stored in the user's browser, which, similar to cookies, contain personal data and can be used for recognition. Details on the enhanced privacy mode can be found here: https://support.google.com/youtube/answer/171780
It is possible that further data processing operations may be triggered after activating a YouTube video, over which we have no influence.
The use of YouTube is in the interest of an appealing presentation of our online offers. This constitutes a legitimate interest within the meaning of Art. 6(1)(f) GDPR. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user's terminal device (e.g., device fingerprinting) within the meaning of the TDDDG. The consent can be revoked at any time.
Further information about data protection at YouTube can be found in their privacy policy at: https://policies.google.com/privacy?hl=de
The company is certified under the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF commits to upholding these data protection standards. You can obtain more information on this from the provider at the following link: https://www.dataprivacyframework.gov/participant/5780
8.4 LinkedIn
This website integrates icons (image of the social media platform's logo with a link to our social media presence there) of the social network LinkedIn. Clicking on the icon will redirect you to the LinkedIn page. This is not a "Recommend" or "Share" button. The provider of the LinkedIn website is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
When you click on the LinkedIn icon provided on this website, a direct connection is established between your browser and the LinkedIn server. LinkedIn thereby receives the information that you have visited this website with your IP address. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by LinkedIn. For more information, please see LinkedIn's privacy policy at: https://www.linkedin.com/legal/privacy-policy
If you do not want LinkedIn to be able to associate your visit to our LinkedIn website with your LinkedIn user account, please log out of your LinkedIn user account.
The use of the LinkedIn icon with a link to our LinkedIn page is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in achieving the widest possible visibility on social media.
The data transfer to the USA is based on the Standard Contractual Clauses of the EU Commission.
Details can be found here: https://www.linkedin.com/help/linkedin/answer/62538/datenubertragung-aus-der-eu-dem-ewr-und-der-schweiz?lang=de
For more information, please see LinkedIn's privacy policy at: https://www.linkedin.com/legal/privacy-policy
8.5 XING
This website integrates icons (image of the social media platform's logo with a link to our social media presence there) of the social network Xing. Clicking on the icon will redirect you to the Xing page. This is not a "Like" or "Share" button. The provider of the Xing website is New Work SE, Am Strandkai 1, 20457 Hamburg, Germany.
When you click on the Xing icon provided on this website, a direct connection is established between your browser and the Xing server. Xing thereby receives the information that you have visited this website with your IP address. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by Xing. For more information, please see Xing's privacy policy (https://privacy.xing.com/de/datenschutzerklaerung).
If you do not want Xing to be able to associate your visit to our Xing website with your Xing user account, please log out of your Xing user account.
The use of the Xing icon with a link to our Xing page is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in achieving the widest possible visibility on social media.
Xing is responsible for the data security of Xing products. You can assert data subject rights (e.g., requests for information) regarding the data processed by Xing directly with Xing.
9. Our Social Media Presences
This privacy policy applies to the following social media presences:
https://www.facebook.com/gustavdaibergmbh/?locale=de_DE
https://www.instagram.com/gustav_daiber_gmbh/
https://www.xing.com/pages/gustavdaibergmbh
https://www.linkedin.com/company/gustav-daiber-gmbh/?originalSubdomain=de
https://www.youtube.com/channel/UC5wMWjXploDwFyNpsvteBkA
https://www.kununu.com/de/gustav-daiber
9.1 Data processing by social networks
We maintain publicly accessible profiles on social networks. The specific social networks we use are listed below.
Social networks such as Facebook, LinkedIn, etc., can generally analyze your user behavior comprehensively when you visit their website or a website with integrated social media content (e.g., "Like" buttons or advertising banners). Visiting our social media presences triggers numerous data protection-relevant processing operations. In detail:
If you are logged into your social media account and visit our social media presence, the operator of the social media portal can assign this visit to your user account. However, your personal data may also be collected under certain circumstances if you are not logged in or do not have an account with the respective social media portal. In this case, this data collection occurs, for example, via cookies that are stored on your terminal device or by recording your IP address.
With the help of the data collected in this way, the operators of the social media portals can create user profiles in which your preferences and interests are stored. In this way, interest-based advertising can be displayed to you both inside and outside the respective social media presence. If you have an account with the respective social network, the interest-based advertising can be displayed on all devices on which you are or were logged in.
Please also note that we cannot trace all processing operations on the social media portals. Depending on the provider, further processing operations may therefore be carried out by the operators of the social media portals. For details, please refer to the terms of use and data protection provisions of the respective social media portals.
9.2 Legal basis
Our social media presences are intended to ensure the most comprehensive presence possible on the internet. This constitutes a legitimate interest within the meaning of Art. 6(1)(f) GDPR. The analysis processes initiated by the social networks may be based on different legal bases, which must be specified by the operators of the social networks (e.g., consent within the meaning of Art. 6(1)(a) GDPR).
9.3 Controller and assertion of rights
When you visit one of our social media presences (e.g., Facebook), we are jointly responsible with the operator of the social media platform for the data processing operations triggered during this visit. In principle, you can assert your rights (information, correction, deletion, restriction of processing, data portability, and complaint) against both us and the operator of the respective social media portal (e.g., against Facebook).
Please note that despite the joint responsibility with the social media portal operators, we do not have full influence on the data processing operations of the social media portals. Our options are largely determined by the corporate policy of the respective provider.
9.4 Storage period
When you visit one of our social media presences (e.g., Facebook), we are jointly responsible with the operator of the social media platform for the data processing operations triggered during this visit. In principle, you can assert your rights (information, correction, deletion, restriction of processing, data portability, and complaint) against both us and the operator of the respective social media portal (e.g., against Facebook).
Please note that despite the joint responsibility with the social media portal operators, we do not have full influence on the data processing operations of the social media portals. Our options are largely determined by the corporate policy of the respective provider.
9.5 Your rights
You have the right at any time to receive information free of charge about the origin, recipient, and purpose of your stored personal data. You also have a right to object, to data portability, and a right to lodge a complaint with the competent supervisory authority. Furthermore, you can request the correction, blocking, deletion, and, under certain circumstances, the restriction of the processing of your personal data.
9.6 Social networks in detail
9.6.1 Facebook
We have a profile on Facebook. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (hereinafter Meta). According to Meta, the collected data is also transferred to the USA and other third countries.
We have concluded a joint processing agreement (Controller Addendum) with Meta. This agreement specifies which data processing operations we or Meta are responsible for when you visit our Facebook page. You can view this agreement at the following link: https://www.facebook.com/legal/terms/page_controller_addendum
You can adjust your advertising settings independently in your user account. To do so, click on the following link and log in: https://www.facebook.com/settings?tab=ads
The data transfer to the USA is based on the Standard Contractual Clauses of the EU Commission.
Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum and https://de-de.facebook.com/help/566994660333381
Details can be found in Facebook's privacy policy: https://www.facebook.com/about/privacy/
The company is certified under the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF commits to upholding these data protection standards. You can obtain more information on this from the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt0000000GnywAAC&status=Active
9.6.2 Instagram
We have a profile on Instagram. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
The data transfer to the USA is based on the Standard Contractual Clauses of the EU Commission.
Details can be found here:
https://www.facebook.com/legal/EU_data_transfer_addendum,
https://privacycenter.instagram.com/policy/ and
https://de-de.facebook.com/help/566994660333381.
For details on how they handle your personal data, please see Instagram's privacy policy: https://privacycenter.instagram.com/policy/
The company is certified under the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF commits to upholding these data protection standards. You can obtain more information on this from the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt0000000GnywAAC&status=Active
9.6.3 XING
We have a profile on XING. The provider is New Work SE, Am Strandkai 1, 20457 Hamburg, Germany. For details on how they handle your personal data, please see XING's privacy policy: https://privacy.xing.com/de/datenschutzerklaerung
9.6.4 LinkedIn
We have a profile on LinkedIn. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. LinkedIn uses advertising cookies.
If you wish to deactivate LinkedIn advertising cookies, please use the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
The data transfer to the USA is based on the Standard Contractual Clauses of the EU Commission.
Details can be found here: https://www.linkedin.com/legal/l/dpa and https://www.linkedin.com/legal/l/eu-sccs
For details on how they handle your personal data, please see LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy
9.6.5 YouTube
We have a profile on YouTube. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. For details on how they handle your personal data, please see YouTube's privacy policy: https://policies.google.com/privacy?hl=de
The company is certified under the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF commits to upholding these data protection standards. You can obtain more information on this from the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt000000001L5AAI&status=Active
9.6.6 Kununu
We have a profile on Kununu. The provider of this service is the platform Kununu as a service of New Work SE, Am Strandkai 1, 20457 Hamburg. For details on how they handle your personal data, please see the Kununu privacy policy at: https://privacy.xing.com/de/datenschutzerklaerung
You can reach Kununu's data protection officer at datenschutzbeauftragter(at)xing.com.
10. eCommerce and payment service providers
10.1 Processing of Customer and Contract Data
We collect, process, and use personal customer and contract data for the establishment, content arrangement and modification of our contractual relationships. Data with personal references to the use of this website (usage data) will be collected, processed, and used only if this is necessary to enable the user to use our services or required for billing purposes. The legal basis for these processes is Art. 6(1)(b) GDPR.
The collected customer data shall be deleted upon completion of the order or termination of the business relationship and upon expiration of any existing statutory archiving periods. This shall be without prejudice to any statutory archiving periods.
10.2 Data transfer upon closing of contracts for online stores, retailers, and the shipment of merchandise
Whenever you order merchandise from us, we will share your personal data with the transportation company entrusted with the delivery as well as the payment service commissioned to handle the payment transactions. Only the data these respective service providers require to meet their obligations will be shared. The legal basis for this sharing is Art. 6 (1)(b) GDPR, which permits the processing of data for the fulfillment of contractual or pre-contractual obligations. If you give us your respective consent pursuant to Art. 6 (1)(a) GDPR, we will share your email address with the transportation company entrusted with the delivery so that this company can notify you on the shipping status for your order via email. You have the option to revoke your consent at any time.
10.3 Credit checks
For a purchase on account or any other payment method where we provide goods or services in advance, we may conduct a credit check (scoring). To do this, we transmit the data you have provided (e.g., name, address, age, or bank details) to a credit agency (Creditreform Boniversum GmbH, Hellersbergstr. 11, 41460 Neuss). The probability of a payment default is determined on the basis of this data. If there is an excessive risk of payment default, we may refuse the payment method in question.
Creditreform Boniversum GmbH processes the received data and also uses it for the purpose of profiling (scoring) to provide its contractual partners in the European Economic Area, Switzerland, and where applicable, other third countries (provided an adequacy decision from the European Commission exists for them) with information, including for the assessment of creditworthiness. Further information on the activities of Creditreform Boniversum GmbH can be found in the Creditreform Boniversum GmbH information sheet or online at https://www.experian.de/legal/partnership.
The credit check is carried out on the basis of the performance of a contract (Art. 6(1)(b) GDPR) and for the prevention of payment defaults (legitimate interest pursuant to Art. 6(1)(f) GDPR). If consent has been obtained, the credit check is based on this consent (Art. 6(1)(a) GDPR); consent can be revoked at any time.
11. Online-based Audio and Video Conferences (Conference tools)
11.1 Data processing
We use online conference tools, among other things, for communication with our customers. The tools we use are listed in detail below. If you communicate with us by video or audio conference using the Internet, your personal data will be collected and processed by the provider of the respective conference tool and by us. The conferencing tools collect all information that you provide/access to use the tools (email address and/or your phone number). Furthermore, the conference tools process the duration of the conference, start and end (time) of participation in the conference, number of participants and other “context information” related to the communication process (metadata).
Furthermore, the provider of the tool processes all the technical data required for the processing of the online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or loudspeaker and the type of connection.
Should content be exchanged, uploaded, or otherwise made available within the tool, it is also stored on the servers of the tool provider. Such content includes, but is not limited to, cloud recordings, chat/ instant messages, voicemail uploaded photos and videos, files, whiteboards, and other information shared while using the service.
Please note that we do not have complete influence on the data processing procedures of the tools used. Our possibilities are largely determined by the corporate policy of the respective provider. Further information on data processing by the conference tools can be found in the data protection declarations of the tools used, and which we have listed below this text.
11.2 Purpose and legal bases
The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6(1)(b) GDPR). Furthermore, the use of the tools serves to generally simplify and accelerate communication with us or our company (legitimate interest in the meaning of Art. 6(1)(f) GDPR). Insofar as consent has been requested, the tools in question will be used on the basis of this consent; the consent may be revoked at any time with effect from that date.
11.3 Duration of storage
Data collected directly by us via the video and conference tools will be deleted from our systems immediately after you request us to delete it, revoke your consent to storage, or the reason for storing the data no longer applies. Stored cookies remain on your end device until you delete them. Mandatory legal retention periods remain unaffected.
We have no influence on the duration of storage of your data that is stored by the operators of the conference tools for their own purposes. For details, please directly contact the operators of the conference tools.
11.4 Conference tools used
We employ the following conference tools:
11.4.1 TeamViewer
We use TeamViewer. The provider is TeamViewer Germany GmbH, Jahnstr. 30, 73037 Göppingen. Details about data processing can be found in the TeamViewer privacy policy: https://www.teamviewer.com/en/privacy-policy/
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.
11.4.2 Microsoft Teams
We use Microsoft Teams. The provider is the Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. For details on data processing, please refer to the Microsoft Teams privacy policy: https://privacy.microsoft.com/en-us/privacystatement
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/6474
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.
12. Custom Services
12.1 Handling applicant data
We offer website visitors the opportunity to submit job applications to us (e.g., via e-mail, via postal services on by submitting the online job application form). Below, we will brief you on the scope, purpose and use of the personal data collected from you in conjunction with the application process. We assure you that the collection, processing, and use of your data will occur in compliance with the applicable data privacy rights and all other statutory provisions and that your data will always be treated as strictly confidential.
12.2 Scope and purpose of the collection of data
If you submit a job application to us, we will process any affiliated personal data (e.g., contact and communications data, application documents, notes taken during job interviews, etc.), if they are required to make a decision concerning the establishment or an employment relationship. The legal grounds for the aforementioned are § 26 BDSG according to German Law (Negotiation of an Employment Relationship), Art. 6(1)(b) GDPR (General Contract Negotiations) and – provided you have given us your consent – Art. 6(1)(a) GDPR. You may revoke any consent given at any time. Within our company, your personal data will only be shared with individuals who are involved in the processing of your job application.
If your job application should result in your recruitment, the data you have submitted will be archived on the grounds of § 26 BDSG and Art. 6(1)(b) GDPR for the purpose of implementing the employment relationship in our data processing system.
12.3 Data Archiving Period
If we are unable to make you a job offer or you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted on the basis of our legitimate interests (Art. 6(1)(f) GDPR) for up to 6 months from the end of the application procedure (rejection or withdrawal of the application). Afterwards the data will be deleted, and the physical application documents will be destroyed. The storage serves in particular as evidence in the event of a legal dispute. If it is evident that the data will be required after the expiry of the 6-month period (e.g., due to an impending or pending legal dispute), deletion will only take place when the purpose for further storage no longer applies.
Longer storage may also take place if you have given your agreement (Article 6(1)(a) GDPR) or if statutory data retention requirements preclude the deletion.
12.4 Admission to the applicant pool
If we do not make you a job offer, you may be able to join our applicant pool. In case of admission, all documents and information from the application will be transferred to the applicant pool in order to contact you in case of suitable vacancies.
Admission to the applicant pool is based exclusively on your express agreement (Art. 6(1)(a) GDPR). The submission agreement is voluntary and has no relation to the ongoing application procedure. The affected person can revoke his agreement at any time. In this case, the data from the applicant pool will be irrevocably deleted, provided there are no legal reasons for storage.
The data from the applicant pool will be irrevocably deleted no later than two years after consent has been granted.
12.5 Applicant Portal
Users have the option to apply for job vacancies advertised by the operator via the website.
The operator collects a range of personal data through an application form. Specifically, the following information is requested:
- Master data: First name, Last name, Street, Postal code, City, Telephone, Mobile phone, Email, Date of birth
- General data: Other voluntary information (notes/information about the application)
- School, Education, Profession: Cover letter, CV/Resume, Certificates, Application documents
All data provided to the operator within the applicant portal is transmitted via a secure, i.e., encrypted, connection. The lawfulness of this processing is governed by § 26 BDSG (German Federal Data Protection Act - Application Procedure). Providing your data is necessary to participate in the application process and to conclude a contract with the operator. If you provide no or incomplete information, the operator will not consider you for the application process.
Application documents received by the operator will be stored for up to 6 months after a rejection, unless the applicant has given consent for a longer retention period. You can find further information in the privacy policy on our careers page.
13. Handling of Business Cards
When we exchange business cards, we gain access to the personal data you provide on your business card. We use the information on your business card for the purposes of communication and following up on the initial contact. If you requested during our conversation (when exchanging business cards) that we send you information about our products and services, we will send the information about our company to the contact details on your card.
If no further exchange takes place, or if you do not respond to our contact and follow-up attempts, we will delete your data (business card) within 1 year. You have the right to request the deletion of your data at any time – for this, please feel free to send us an informal email.