Privacy Policy

Privacy Policy

Preamble

With the following privacy policy we would like to inform you which types of your personal data (hereinafter also abbreviated as " data") we process for which purposes and in which scope. The privacy statement applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online services").

The terms used are not gender-specific.

Last Update: 19. April 2021

 

Table of contents

  • Preamble
  • Controller
  • Overview of processing operations
  • Contact information of the data protection officer
  • Legal Bases for the Processing
  • Security Precautions
  • Transmission and Disclosure of Personal Data
  • Data Processing in Third Countries
  • Use of Cookies
  • Provision of online services and web hosting
  • Blogs and publication media
  • Contacting us
  • Job Application Process
  • Newsletter and Electronic Communications
  • Web Analysis, Monitoring and Optimization
  • Onlinemarketing
  • Profiles in Social Networks (Social Media)
  • Plugins and embedded functions and content
  • Erasure of data
  • Changes and Updates to the Privacy Policy
  • Rights of Data Subjects
  • Terminology and Definitions

 

Controller

ELEMENT Insurance AG
Hardenbergstraße 32
10623 Berlin
Deutschland

Authorised Representatives: Dr. Christian Macht (Chairman of the Board), Eric Schuh

E-mail address: info@element.in

Contact information of the data protection officer

ELEMENT Insurance AG
Hardenbergstraße 32
10623 Berlin
Germany

datenschutz@element.in

 

Overview of processing operations

The following table summarises the types ofdata processed, the purposes for which they are processed and the concerneddata subjects.

Categories of Processed Data

  • Inventory data (e.g. names, addresses).
  • Job applicant details (e.g. Personal data, postal and contact addresses and the documents pertaining to the application and the     information contained therein, such as cover letter, curriculum vitae, certificates, etc., as well as other information on the person or qualifications of applicants provided with regard to a specific job or voluntarily by applicants).
  • Content data (e.g. text input, photographs, videos).
  • Contact data (e.g. e-mail, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Location data (Data that indicates the location of the end device of an end user).
       
       

Categories of Data Subjects

  • Job applicants.
  • Prospective customers.
  • Communication partner (Recipients of e-mails, letters, etc.).
  • Users (e.g. website visitors, users of online services).

 

Purposes of Processing

  • A/B Tests.
  • Provision of our online services and usability.
  • Conversion Tracking.
  • Job Application Process (Establishment and possible later execution as well as possible later termination of the employment relationship.).
  • Clicktracking.
  • Direct marketing  (e.g. by e-mail or postal).
  • Feedback (e.g. collecting feedback via online form).
  • Heatmaps ("Heatmaps" are mouse movements of the users, which are combined to an overall picture.).
  • Interest-based and behavioral marketing.
  • contact requests and communication.
  • Conversion tracking (Measurement of the effectiveness of marketing activities).
  • Profiling (Creating user profiles).
  • Remarketing.
  • Web Analytics (e.g. access statistics, recognition of returning visitors).
  • Security measures.
  • Targeting (e.g. profiling based on interests and behaviour, use of cookies).
  • Polls and Questionnaires (e.g. surveys with input options, multiple choice questions).
  • Contractual services and support.
  • Managing and responding to inquiries.

 

Legal Bases for the Processing

In the following we inform you about the legal basis of the General Data Protection Regulation (GDPR), on the basis of which we process personal data. Please note that, in addition to the regulations of the GDPR, the national data protection regulations may apply in your country or in our country of residence or domicile. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Article 6 (1) (a) GDPR) -  The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  • Performance of a contract and prior requests (Article 6 (1) (b)  GDPR) - Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legitimate Interests (Article 6 (1) (f) GDPR) - Processing is necessary for the purposes of the legitimate     interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
  • Article 9 (1)(b) GDPR (job application process as a     pre-contractual or contractual relationship) (If special categories of     personal data within the meaning of Article 9 (1) GDPR (e.g. health data,     such as severely handicapped status or ethnic origin) are requested from     applicants within the framework of the application procedure, so that the     responsible person or the person concerned can carry out the obligations     and exercising specific rights of the controller or of the data subject in     the field of employment and social security and social protection law,     their processing shall be carried out in accordance with Article 9 (2)(b)     GDPR , in the case of the protection of vital interests of applicants or     other persons on the basis of Article 9 (1)(c) GDPR  or for the purposes of preventive health     care or occupational medicine, for the assessment of the employee's     ability to work, for medical diagnostics, care or treatment in the health     or social sector or for the administration of systems and services in the     health or social sector in accordance with Article 9 (1)(d) GDPR. In the     case of a communication of special categories of data based on voluntary     consent, their processing is carried out on the basis of Article 9 (1)(a)     GDPR.) - .
       
       

National data protection regulations inGermany: In addition to the data protectionregulations of the General Data Protection Regulation, national regulationsapply to data protection in Germany. This includes in particular the Law onProtection against Misuse of Personal Data in Data Processing (Federal Data ProtectionAct - BDSG). In particular, the BDSG contains special provisions on the rightto access, the right to erase, the right to object, the processing of specialcategories of personal data, processing for other purposes and transmission aswell as automated individual decision-making, including profiling. Furthermore,it regulates data processing for the purposes of the employment relationship (§26 BDSG), in particular with regard to the establishment, execution ortermination of employment relationships as well as the consent of employees.Furthermore, data protection laws of the individual federal states may apply.

 

Security Precautions

We take appropriate technical and organisational measures in accordance with the legal requirements, taking intoaccount the  state of the art, the costsof implementation and the nature, scope, context and purposes of processing aswell as the risk of varying likelihood and severity for the rights and freedomsof natural persons, in order to ensure a level of security appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data bycontrolling physical and electronic access to the data as well as access to,input, transmission, securing and separation of the data. In addition, we haveestablished procedures to ensure that data subjects' rights are respected, thatdata is erased, and that we are prepared to respond to data threats rapidly.Furthermore, we take the protection of personal data into account as early asthe development or selection of hardware, software and service providers, inaccordance with the principle of privacy by design and privacy by default.


SSL encryption (https)
: In order to protect yourdata transmitted via our online services in the best possible way, we use SSLencryption. You can recognize such encrypted connections by the prefix https://in the address bar of your browser.

To secure the personal information youprovide on our website, we use Transport Layer Security (TLS), which encryptsthe information you provide.

Transmission and Disclosure of Personal Data

In the context of our processing ofpersonal data, it may happen that the data is transferred to other places,companies or persons or that it is disclosed to them. Recipients of this datamay include, for example, payment institutions within the context of paymenttransactions, service providers commissioned with IT tasks or providers ofservices and content that are embedded in a website. In such a case, the legalrequirements will be respected and in particular corresponding contracts oragreements, which serve the protection of your data, will be concluded with therecipients of your data.

Data Processing in Third Countries

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

Subject to express consent or transferrequired by contract or law, we process or have processed the data only inthird countries with a recognised level of data protection, on the basis ofspecial guarantees, such as a contractual obligation through so-called standardprotection clauses of the EU Commission or if certifications or bindinginternal data protection regulations justify the processing (Article 44 to 49GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).

Use of Cookies

Cookies are text files that contain datafrom visited websites or domains and are stored by a browser on the user'scomputer. A cookie is primarily used to store information about a user duringor after his visit within an online service. The information stored caninclude, for example, the language settings on a website, the login status, ashopping basket or the location where a video was viewed. The term"cookies" also includes other technologies that fulfil the samefunctions as cookies (e.g. if user information is stored using pseudonymousonline identifiers, also referred to as "user IDs").

The following types and functions ofcookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has     left an online service and closed his browser.
  • Permanent cookies: Permanent     cookies remain stored even after closing the browser. For example, the     login status can be saved or preferred content can be displayed directly     when the user visits a website again. The interests of users who are used     for range measurement or marketing purposes can also be stored in such a     cookie.
  • First-Party-Cookies:     First-Party-Cookies are set by ourselves.
  • Third party cookies: Third party     cookies are mainly used by advertisers (so-called third parties) to     process user information.
  • Necessary (also: essential) cookies: Cookies can be necessary for the operation of a website (e.g.     to save logins or other user inputs or for security reasons).
  • Statistics, marketing and personalisation cookies: Cookies are also generally used to measure a website's reach     and when a user's interests or behaviour (e.g. viewing certain content,     using functions, etc.) are stored on individual websites in a user     profile. Such profiles are used, for example, to display content to users     that corresponds to their potential interests. This procedure is also     referred to as "tracking", i.e. tracking the potential interests     of users. . If we use cookies or "tracking" technologies, we     will inform you separately in our privacy policy or in the context of     obtaining consent.

 

Information on legal basis: The legal basis on which we process your personal data with thehelp of cookies depends on whether we ask you for your consent. If this appliesand you consent to the use of cookies, the legal basis for processing your datais your declared consent. Otherwise, the data processed with the help ofcookies will be processed on the basis of our legitimate interests (e.g. in abusiness operation of our online service and its improvement) or, if the use ofcookies is necessary to fulfill our contractual obligations.

Retention period: Unless we provide you with explicit information on the retentionperiod of permanent cookies (e.g. within the scope of a so-called cookieopt-in), please assume that the retention period can be as long as two years.

General information on Withdrawal ofconsent and objection (Opt-Out): Respective ofwhether processing is based on consent or legal permission, you have the optionat any time to object to the processing of your data using cookie technologiesor to revoke consent (collectively referred to as "opt-out"). You caninitially explain your objection using the settings of your browser, e.g. bydeactivating the use of cookies (which may also restrict the functionality ofour online services). An objection to the use of cookies for online marketingpurposes can be raised for a large number of services, especially in the caseof tracking, via the websites https://www.aboutads.info/choices/and https://www.youronlinechoices.com.In addition, you can receive further information on objections in the contextof the information on the used service providers and cookies.

Processing Cookie Data on the Basis ofConsent: Before we process or have processed datawithin the context of the usage of cookies, we ask the users for their consent,which can be revoked at any time. Before the consent has not been given, we mayuse cookies that are necessary for the operation of our online services.

 

Cookie Settings/ Opt-Out:

  • Processed data types: Usage data     (e.g. websites visited, interest in content, access times),     Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website     visitors, users of online services).
  • Legal Basis: Consent (Article 6 (1)     (a) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Services and service providers beingused:

·      Usercentrics: ConsentManagement; Service provider: Usercentrics GmbH, Rosental 4, 80331 München;Website: https://usercentrics.com/de/; Privacy policy:https://usercentrics.com/de/datenschutzerklaerung/

 

This website uses Usercentrics that sets atechnically necessary cookie (usercentrics cookie) to store your cookieconsent.

Usercentrics does not process any personaldata.

Usercentrics stores the consent you gavewhen you entered the website. If you wish to revoke these consents, simplydelete the cookie in your browser. When you enter/reload the website, you willbe asked again for your cookie consent.

If you want to change the settings you madepreviously, you can do so at any time. To do this, open the selection menu viathe fingerprint symbol displayed in the lower left corner of your screen.

 

Provision of online services and web hosting

In order to provide our online servicessecurely and efficiently, we use the services of one or more web hostingproviders from whose servers (or servers they manage) the online services canbe accessed. For these purposes, we may use infrastructure and platformservices, computing capacity, storage space and database services, as well assecurity and technical maintenance services.

The data processed within the framework of theprovision of the hosting services may include all information relating to theusers of our online services that is collected in the course of use andcommunication. This regularly includes the IP address, which is necessary to beable to deliver the contents of online services to browsers, and all entriesmade within our online services or from websites.

 

Collection of Access Data and Log Files: We, ourselves or our web hosting provider, collect data on thebasis of each access to the server (so-called server log files). Server logfiles may include the address and name of the web pages and files accessed, thedate and time of access, data volumes transferred, notification of successfulaccess, browser type and version, the user's operating system, referrer URL(the previously visited page) and, as a general rule, IP addresses and therequesting provider.

The server log files can be used forsecurity purposes, e.g. to avoid overloading the servers (especially in thecase of abusive attacks, so-called DDoS attacks) and to ensure the stabilityand optimal load balancing of the servers.

  • Processed data types: Content data     (e.g. text input, photographs, videos), Usage data (e.g. websites visited,     interest in content, access times), Meta/communication data (e.g. device     information, IP addresses).
  • Data subjects: Users (e.g. website     visitors, users of online services).
  • Legal Basis: Legitimate Interests     (Article 6 (1) (f) GDPR).

 

Services and service providers beingused:

  • Amazon Web Services (AWS): Web     hosting and infrastructural services; Service provider: Amazon Web     Services, Inc., 410 Terry Avenue North, Seattle WA 98109, USA; Website: https://aws.amazon.com/; Privacy     Policy: https://aws.amazon.com/de/privacy/?nc1=f_pr.
  • Webflow: Webhosting und     infrastrukturelle Dienstleistungen; Service provider: Webflow, Inc., 398     11th Street, 2nd Floor, San Francisco, CA 94103, USA; Website:     https://webflow.com; Privacy policy: https://webflow.com/privacy.

 

Blogs and publication media

We use blogos or comparable means of onlinecommunication and publication (hereinafter "publication medium").Readers' data will only be processed for the purposes of the publication mediumto the extent necessary for its presentation and communication between authorsand readers or for security reasons. For the rest, we refer to the informationon the processing of visitors to our publication medium within the scope ofthis privacy policy.

  • Processed data types: Inventory     data (e.g. names, addresses), Contact data (e.g. e-mail, telephone     numbers), Content data (e.g. text input, photographs, videos), Usage data     (e.g. websites visited, interest in content, access times),     Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website     visitors, users of online services).
  • Purposes of Processing: Contractual     services and support, Feedback (e.g. collecting feedback via online form).
  • Legal Basis: Performance of a     contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests     (Article 6 (1) (f) GDPR).

Services and service providers beingused:

Contacting us

When contacting us (e.g. by contact form,e-mail, telephone or via social media), the data of the inquiring persons areprocessed insofar as this is necessary to answer the contact enquiries and anyrequested activities.

The response to contact enquiries withinthe framework of contractual or pre-contractual relationships is made in orderto fulfil our contractual obligations or to respond to (pre)contractualenquiries and otherwise on the basis of the legitimate interests in respondingto the enquiries.

  • Processed data types: Inventory     data (e.g. names, addresses), Contact data (e.g. e-mail, telephone     numbers), Content data (e.g. text input, photographs, videos), Usage data     (e.g. websites visited, interest in content, access times), Meta/communication     data (e.g. device information, IP addresses).
  • Data subjects: Communication     partner (Recipients of e-mails, letters, etc.).
  • Purposes of Processing: contact     requests and communication.
  • Legal Basis: Performance of a     contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests     (Article 6 (1) (f) GDPR).
       
       

Services and service providers beingused:

·       Salesforce: CRM-System, Management von Kontaktanfragen und Kommunikation;Dienstanbieter: salesforce.com Germany GmbH, Erika-Mann-Str. 31, 80636 München;Mutterunternehmen: Salesforce.com, inc. Salesforce Tower, 415 Mission Street,3rd Floor, San Francisco, CA 94105, USA; Website:https://www.salesforce.com/de/; Datenschutzerklärung: https://www.salesforce.com/de/company/privacy/.

 

Job Application Process

The application process requires applicantsto provide us with the data necessary for their assessment and selection. Theinformation required can be found in the job description or, in the case ofonline forms, in the information contained therein.

In principle, the required informationincludes personal information such as name, address, a contact option and proofof the qualifications required for a particular employment. Upon request, we willbe happy to provide you with additional information.

If made available, applicants can submittheir applications via an online form. The data will be transmitted to usencrypted according to the state of the art. Applicants can also send us theirapplications by e-mail. Please note, however, that e-mails on the Internet aregenerally not sent in encrypted form. As a rule, e-mails are encrypted duringtransport, but not on the servers from which they are sent and received. We cantherefore accept no responsibility for the transmission path of the applicationbetween the sender and the reception on our server. For the purposes ofsearching for applicants, submitting applications and selecting applicants, wemay make use of the applicant management and recruitment software, platformsand services of third-party providers in compliance with legal requirements.Applicants are welcome to contact us about how to submit their application orsend it to us by regular mail.

 

Processing of special categories of data: If special categories of personal data within the meaning ofArticle 9 (1) GDPR (e.g. health data, such as severely handicapped status orethnic origin) are requested from applicants within the framework of theapplication procedure, so that the responsible person or the person concernedcan exercise his/her rights arising from labour law and social security andsocial protection law and fulfil his/her duties in this regard, theirprocessing shall be carried out in accordance with Article 9 (1)(b) GDPR, inthe case of the protection of vital interests of applicants or other personspursuant to Article 9 (1)(c) GDPR or for the purposes of preventive health careor occupational medicine, for the assessment of the employee's ability to work,for medical diagnostics, care or treatment in the health or social sector orfor the administration of systems and services in the health or social sectorin accordance with Article 9 (1)(h) GDPR. In the case of a communication ofspecial categories of data based on voluntary consent, their processing iscarried out on the basis of Article 9 (1)(a) GDPR.

 

Ereasure of data: In the event of a successful application, the data provided by theapplicants may be further processed by us for the purposes of the employmentrelationship. Otherwise, if the application for a job offer is not successful,the applicant's data will be deleted. Applicants' data will also be deleted ifan application is withdrawn, to which applicants are entitled at any time.Subject to a justified revocation by the applicant, the deletion will takeplace at the latest after the expiry of a period of six months, so that we cananswer any follow-up questions regarding the application and comply with ourduty of proof under the regulations on equal treatment of applicants. Invoicesfor any reimbursement of travel expenses are archived in accordance with taxregulations.

 

Admission to a talent pool - Admission to an talent pool, if offered, is based on consent.Applicants are informed that their consent to be included in the talent pool isvoluntary, has no influence on the current application process and that theycan revoke their consent at any time for the future.

  • Processed data types: Job applicant     details (e.g. Personal data, postal and contact addresses and the     documents pertaining to the application and the information contained     therein, such as cover letter, curriculum vitae, certificates, etc., as     well as other information on the person or qualifications of applicants     provided with regard to a specific job or voluntarily by applicants).
  • Data subjects: Job applicants.
  • Purposes of Processing: Job     Application Process (Establishment and possible later execution as well as     possible later termination of the employment relationship.).
  • Legal Basis: Article 9 (1)(b) GDPR     (job application process as a pre-contractual or contractual relationship)     (If special categories of personal data within the meaning of Article 9     (1) GDPR (e.g. health data, such as severely handicapped status or ethnic     origin) are requested from applicants within the framework of the     application procedure, so that the responsible person or the person     concerned can carry out the obligations and exercising specific rights of the     controller or of the data subject in the field of employment and social     security and social protection law, their processing shall be carried out     in accordance with Article 9 (2)(b) GDPR , in the case of the protection     of vital interests of applicants or other persons on the basis of Article     9 (1)(c) GDPR  or for the purposes     of preventive health care or occupational medicine, for the assessment of     the employee's ability to work, for medical diagnostics, care or treatment     in the health or social sector or for the administration of systems and     services in the health or social sector in accordance with Article 9     (1)(d) GDPR. In the case of a communication of special categories of data     based on voluntary consent, their processing is carried out on the basis     of Article 9 (1)(a) GDPR.).

 

Services and service providers beingused:

 

Newsletter and Electronic Communications

We send newsletters, e-mails and otherelectronic communications (hereinafter referred to as "newsletters")only with the consent of the recipient or a legal permission. Insofar as thecontents of the newsletter are specifically described within the framework ofregistration, they are decisive for the consent of the user. Otherwise, ournewsletters contain information about our services and us.

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

 

Double opt-in procedure: The registration to our newsletter takes place in general in aso-called Double-Opt-In procedure. This means that you will receive an e-mail afterregistration asking you to confirm your registration. This confirmation isnecessary so that no one can register with external e-mail addresses.
The registrations for the newsletter are logged in order to be able to provethe registration process according to the legal requirements. This includesstoring the login and confirmation times as well as the IP address. Likewise,the changes of your data stored with the dispatch service provider are logged.

Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three yearsbased on our legitimate interests before deleting them to provide evidence ofprior consent. The processing of these data is limited to the purpose of apossible defense against claims. An individual deletion request is possible atany time, provided that the former existence of a consent is confirmed at thesame time. In the case of an obligation to permanently observe an objection, wereserve the right to store the e-mail address solely for this purpose in ablacklist.

Information on legal bases: The sending of the newsletter is based on the consent of therecipients or, if consent is not required, on the basis of our legitimateinterests in direct marketing. Insofar as we engage a service provider forsending e-mails, this is done on the basis of our legitimate interests. Theregistration procedure is recorded on the basis of our legitimate interests forthe purpose of demonstrating that it has been conducted in accordance with thelaw.

 

Contents: Information aboutELEMENT, our services, products, promotions and offers as well as generalinformation from the insurance industry.

 

Analysis and performance measurement: The newsletters contain a so-called "web-beacon", i.e. apixel-sized file, which is retrieved from our server when the newsletter isopened or, if we use a mailing service provider, from its server. Within thescope of this retrieval, technical information such as information about thebrowser and your system, as well as your IP address and time of retrieval arefirst collected.

 

This information is used for the technicalimprovement of our newsletter on the basis of technical data or target groupsand their reading behaviour on the basis of their retrieval points (which canbe determined with the help of the IP address) or access times. This analysisalso includes determining whether newsletters are opened, when they are openedand which links are clicked. For technical reasons, this information can beassigned to the individual newsletter recipients. It is, however, neither our endeavornor, if used, that of the shipping service provider to observe individualusers. The evaluations serve us much more to recognize the reading habits ofour users and to adapt our content to them or to send different contentaccording to the interests of our users.

 

The evaluation of the newsletter and themeasurement of success is carried out, subject to the express consent of theuser, on the basis of our legitimate interests for the purposes of using a user-friendlyand secure newsletter system which serves both our business interests and theexpectations of the user.

 

A separate objection to the performancemeasurement is unfortunately not possible, in this case the entire newslettersubscription must be cancelled or objected to.

  • Processed data types: Inventory     data (e.g. names, addresses), Contact data (e.g. e-mail, telephone     numbers), Meta/communication data (e.g. device information, IP addresses),     Usage data (e.g. websites visited, interest in content, access times).
  • Data subjects: Communication     partner (Recipients of e-mails, letters, etc.).
  • Purposes of Processing: Direct     marketing  (e.g. by e-mail or     postal).
  • Legal Basis: Consent (Article 6 (1)     (a) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Opt-Out: You can cancel the receipt     of our newsletter at any time, i.e. revoke your consent or object to     further receipt. You will find a link to cancel the newsletter either at     the end of each newsletter or you can otherwise use one of the contact     options listed above, preferably e-mail.

 

Services and service providers beingused:

Web Analysis, Monitoring and Optimization

Web analysis is used to evaluate thevisitor traffic on our website and may include the behaviour, interests ordemographic information of users, such as age or gender, as pseudonymousvalues. With the help of web analysis we can e.g. recognize, at which time ouronline services or their functions or contents are most frequently used orrequested for repeatedly, as well as which areas require optimization.

In addition to web analysis, we can alsouse test procedures, e.g. to test and optimize different versions of our onlineservices or their components.

For these purposes, so-called user profilescan be created and stored in a file (so-called "cookie") or similarprocedures in which the relevant user information for the aforementionedanalyses is stored. This information may include, for example, content viewed,web pages visited and elements and technical data used there, such as thebrowser used, computer system used and information on times of use. If usershave consented to the collection of their location data, these may also beprocessed, depending on the provider.

The IP addresses of the users are alsostored. However, we use any existing IP masking procedure (i.e.pseudonymisation by shortening the IP address) to protect the user. In general,within the framework of web analysis, A/B testing and optimisation, no userdata (such as e-mail addresses or names) is stored, but pseudonyms. This meansthat we, as well as the providers of the software used, do not know the actualidentity of the users, but only the information stored in their profiles forthe purposes of the respective processes.

 

Information on legal basis: If we ask the users for their consent to the use of third partyproviders, the legal basis of the processing is consent. Furthermore, theprocessing can be a component of our (pre)contractual services, provided thatthe use of the third party was agreed within this context. Otherwise, user datawill be processed on the basis of our legitimate interests (i.e. interest inefficient, economic and recipient friendly services). In this context, we wouldalso like to refer you to the information on the use of cookies in this privacypolicy.

  • Processed data types: Usage data     (e.g. websites visited, interest in content, access times),     Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website     visitors, users of online services).
  • Purposes of Processing: Web     Analytics (e.g. access statistics, recognition of returning visitors),     Targeting (e.g. profiling based on interests and behaviour, use of     cookies), Conversion Tracking, Profiling (Creating user profiles),     Clicktracking, A/B Tests, Feedback (e.g. collecting feedback via online     form), Heatmaps ("Heatmaps" are mouse movements of the users,     which are combined to an overall picture.), Polls and Questionnaires (e.g.     surveys with input options, multiple choice questions).
  • Security measures: IP Masking     (Pseudonymization of the IP address).
  • Legal Basis: Consent (Article 6 (1)     (a) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

 

Services and service providers beingused:

 

Onlinemarketing

We process personal data for the purposesof online marketing, which may include in particular the marketing ofadvertising space or the display of advertising and other content (collectivelyreferred to as "Content") based on the potential interests of usersand the measurement of their effectiveness.

For these purposes, so-called user profilesare created and stored in a file (so-called "cookie") or similarprocedure in which the relevant user information for the display of theaforementioned content is stored. This information may include, for example,content viewed, websites visited, online networks used, communication partnersand technical information such as the browser used, computer system used andinformation on usage times. If users have consented to the collection of theirsideline data, these can also be processed.

The IP addresses of the users are alsostored. However, we use provided IP masking procedures (i.e. pseudonymisationby shortening the IP address) to ensure the protection of the user's by using apseudonym. In general, within the framework of the online marketing process, noclear user data (such as e-mail addresses or names) is secured, but pseudonyms.This means that we, as well as the providers of online marketing procedures, donot know the actual identity of the users, but only the information stored intheir profiles.

The information in the profiles is usuallystored in the cookies or similar memorizing procedures. These cookies canlater, generally also on other websites that use the same online marketingtechnology, be read and analyzed for purposes of content display, as well assupplemented with other data and stored on the server of the online marketingtechnology provider.

Exceptionally, clear data can be assignedto the profiles. This is the case, for example, if the users are members of asocial network whose online marketing technology we use and the network linksthe profiles of the users in the aforementioned data. Please note that usersmay enter into additional agreements with the social network providers or otherservice providers, e.g. by consenting as part of a registration process.

As a matter of principle, we only gainaccess to summarised information about the performance of our advertisements.However, within the framework of so-called conversion measurement, we can checkwhich of our online marketing processes have led to a so-called conversion,i.e. to the conclusion of a contract with us. The conversion measurement isused alone for the performance analysis of our marketing activities.

Unless otherwise stated, we kindly ask youto consider that cookies used will be stored for a period of two years.

 

Information on legal basis: If we ask users for their consent (e.g. in the context of aso-called "cookie banner consent"), the legal basis for processingdata for online marketing purposes is this consent. Otherwise, user data will beprocessed on the basis of our legitimate interests (i.e. interest in theanalysis, optimisation and economic operation of our online services. In thiscontext, we would also like to refer you to the information on the use ofcookies in this privacy policy.

  • Processed data types: Usage data     (e.g. websites visited, interest in content, access times),     Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website     visitors, users of online services), Prospective customers.
  • Purposes of Processing: Targeting     (e.g. profiling based on interests and behaviour, use of cookies),     Remarketing, Conversion Tracking, Interest-based and behavioral marketing,     Profiling (Creating user profiles), Conversion tracking (Measurement of     the effectiveness of marketing activities), Web Analytics (e.g. access     statistics, recognition of returning visitors).
  • Security measures: IP Masking     (Pseudonymization of the IP address).
  • Legal Basis: Consent (Article 6 (1)     (a) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Opt-Out: We refer to the privacy     policies of the respective service providers and the possibilities for     objection (so-called "opt-out"). If no explicit opt-out option     has been specified, it is possible to deactivate cookies in the settings     of your browser. However, this may restrict the functions of our online     offer. We therefore recommend the following additional opt-out options,     which are offered collectively for each area:a) Europe: https://www.youronlinechoices.eu.     b) Canada: https://www.youradchoices.ca/choices.     c) USA: https://www.aboutads.info/choices.     d) Cross-regional: https://optout.aboutads.info.

 

Services and service providers beingused:

  • Google Tag Manager: Google Tag     Manager is a solution with which we can manage so-called website tags via     an interface and thus integrate other services into our online services.     The Tag Manager itself (which implements the tags) does not process any     personal user data. With regard to the processing of users' personal data,     reference is made to the information below regarding Google services.     Service provider: Google Ireland Limited, Gordon House, Barrow Street,     Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway,     Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com;     Privacy Policy: https://policies.google.com/privacy.
  • Google Analytics: Online marketing     and web analytics; Service provider: Google Ireland Limited, Gordon House,     Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600     Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/en/about/analytics/;     Privacy Policy: https://policies.google.com/privacy;     Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en,     Settings for the Display of Advertisements: https://adssettings.google.com/authenticated.
  • Google Ads and Conversion Tracking:     We use the Google "Ads" online marketing method to place ads on     the Google advertising network (e.g., in search results, videos, websites,     etc.) so that they are displayed to users who have an alleged interest in     the ads. We also measure the conversion of the ads. However, we only know     the anonymous total number of users who clicked on our ad and were     redirected to a page tagged with a conversion tracking tag. However, we     ourselves do not receive any information that can be used to identify     users. Service provider: Google Ireland Limited, Gordon House, Barrow     Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre     Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com;     Privacy Policy: https://policies.google.com/privacy.
  • LinkedIn: e.g. Insights Tag /     Conversion tracking; Service provider: LinkedIn Corporation, 2029 Stierlin     Court, Mountain View, CA 94043, USA; Website: https://www.linkedin.com; Security     measures:  IP Masking     (Pseudonymization of the IP address); Privacy Policy: https://www.linkedin.com/legal/privacy-policy,     cookie policy: https://www.linkedin.com/legal/cookie_policy;     Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • HubSpot: Email marketing platform;     Service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge,     Massachusetts 02141, USA; Website: https://www.hubspot.com;     Privacy Policy: https://legal.hubspot.com/privacy-policy.

 

Profiles in Social Networks (Social Media)

We maintain online presences within socialnetworks and process user data in this context in order to communicate with theusers active there or to offer information about us.

We would like to point out that user datamay be processed outside the European Union. This may entail risks for users,e.g. by making it more difficult to enforce users' rights.

In addition, user data is usually processedwithin social networks for market research and advertising purposes. Forexample, user profiles can be created on the basis of user behaviour and theassociated interests of users. The user profiles can then be used, for example,to place advertisements within and outside the networks which are presumed tocorrespond to the interests of the users. For these purposes, cookies areusually stored on the user's computer, in which the user's usage behaviour andinterests are stored. Furthermore, data can be stored in the user profilesindependently of the devices used by the users (especially if the users aremembers of the respective networs or will become members later on).

For a detailed description of therespective processing operations and the opt-out options, please refer to therespective data protection declarations and information provided by theproviders of the respective networks.

Also in the case of requests forinformation and the exercise of rights of data subjects, we point out thatthese can be most effectively pursued with the providers. Only the providershave access to the data of the users and can directly take appropriate measuresand provide information. If you still need help, please do not hesitate tocontact us.

  • Processed data types: Inventory     data (e.g. names, addresses), Contact data (e.g. e-mail, telephone     numbers), Content data (e.g. text input, photographs, videos), Usage data     (e.g. websites visited, interest in content, access times),     Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website     visitors, users of online services).
  • Purposes of Processing: contact     requests and communication, Targeting (e.g. profiling based on interests     and behaviour, use of cookies), Remarketing.
  • Legal Basis: Legitimate Interests     (Article 6 (1) (f) GDPR).

 

Services and service providers beingused:

Plugins and embedded functions and content

Within our online services, we integratefunctional and content elements that are obtained from the servers of theirrespective providers (hereinafter referred to as "third-partyproviders"). These may, for example, be graphics, videos or social mediabuttons as well as contributions (hereinafter uniformly referred to as"Content").

The integration always presupposes that thethird-party providers of this content process the IP address of the user, sincethey could not send the content to their browser without the IP address. The IPaddress is therefore required for the presentation of these contents orfunctions. We strive to use only those contents, whose respective offerers usethe IP address only for the distribution of the contents. Third parties mayalso use so-called pixel tags (invisible graphics, also known as "webbeacons") for statistical or marketing purposes. The "pixeltags" can be used to evaluate information such as visitor traffic on thepages of this website. The pseudonymous information may also be stored incookies on the user's device and may include technical information about thebrowser and operating system, referring websites, visit times and otherinformation about the use of our website, as well as may be linked to suchinformation from other sources.

 

Information on legal basis: If we ask users for their consent (e.g. in the context of aso-called "cookie banner consent"), the legal basis for processing isthis consent. Otherwise, user data will be processed on the basis of ourlegitimate interests (i.e. interest in the analysis, optimisation and economicoperation of our online services. We refer you to the note on the use ofcookies in this privacy policy.

  • Processed data types: Usage data     (e.g. websites visited, interest in content, access times),     Meta/communication data (e.g. device information, IP addresses), Location     data (Data that indicates the location of the end device of an end user),     Inventory data (e.g. names, addresses), Contact data (e.g. e-mail,     telephone numbers), Content data (e.g. text input, photographs, videos).
  • Data subjects: Users (e.g. website     visitors, users of online services).
  • Purposes of Processing: Provision     of our online services and usability, Contractual services and support,     Security measures, Managing and responding to inquiries.
  • Legal Basis: Legitimate Interests     (Article 6 (1) (f) GDPR), Consent (Article 6 (1) (a) GDPR), Performance of     a contract and prior requests (Article 6 (1) (b) GDPR).

 

Services and service providers beingused:

  • Google Fonts: We integrate the     fonts ("Google Fonts") of the provider Google, whereby the data     of the users are used solely for purposes of the representation of the     fonts in the browser of the users. The integration takes place on the     basis of our legitimate interests in a technically secure, maintenance-free     and efficient use of fonts, their uniform presentation and consideration     of possible licensing restrictions for their integration. Service     provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4,     Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain     View, CA 94043, USA; Website: https://fonts.google.com/;     Privacy Policy: https://policies.google.com/privacy.
  • Google Maps: We integrate the maps     of the service "Google Maps" from the provider Google. The data     processed may include, in particular, IP addresses and location data of     users, which are not collected without their consent (usually within the     framework of the settings of their mobile devices); Service provider:     Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland,     parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA     94043, USA; Website: https://cloud.google.com/maps-platform;     Privacy Policy: https://policies.google.com/privacy;     Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en,  Settings for the Display of     Advertisements: https://adssettings.google.com/authenticated.
  • YouTube videos: Video contents;     Service provider: Google Ireland Limited, Gordon House, Barrow Street,     Dublin 4, Ireland, , parent company: Google LLC, 1600 Amphitheatre     Parkway, Mountain View, CA 94043, USA; Website: https://www.youtube.com; Privacy     Policy: https://policies.google.com/privacy;     Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en,  Settings for the Display of     Advertisements: https://adssettings.google.com/authenticated.

 

Erasure of data

The data processed by us will be erased inaccordance with the statutory provisions as soon as their processing is revokedor other permissions no longer apply (e.g. if the purpose of processing thisdata no longer applies or they are not required for the purpose).

If the data is not deleted because they arerequired for other and legally permissible purposes, their processing islimited to these purposes. This means that the data will be restricted and notprocessed for other purposes. This applies, for example, to data that must bestored for commercial or tax reasons or for which storage is necessary toassert, exercise or defend legal claims or to protect the rights of anothernatural or legal person.

Further information on the erasure ofpersonal data can also be found in the individual data protection notices ofthis privacy policy.

 

Changes and Updates to the Privacy Policy

We kindly ask you to inform yourselfregularly about the contents of our data protection declaration. We will adjustthe privacy policy as changes in our data processing practices make thisnecessary. We will inform you as soon as the changes require your cooperation(e.g. consent) or other individual notification.

If we provide addresses and contactinformation of companies and organizations in this privacy policy, we ask youto note that addresses may change over time and to verify the informationbefore contacting us.

 

Rights of Data Subjects

As data subject, you are entitled tovarious rights under the GDPR, which arise in particular from Articles 15 to 21of the GDPR:

  • Right to Object: You have the right, on grounds arising from     your particular situation, to object at any time to the processing of your     personal data which is based on letter (e) or (f) of Article 6(1) GDPR ,     including profiling based on those provisions.Where personal data are     processed for direct marketing purposes, you have the right to object at     any time to the processing of the personal data concerning you for the     purpose of such marketing, which includes profiling to the extent that it     is related to such direct marketing.
  • Right of withdrawal for consents:     You have the right to revoke consents at any time.
  • Right of access: You have the right     to request confirmation as to whether the data in question will be     processed and to be informed of this data and to receive further     information and a copy of the data in accordance with the provisions of     the law.
  • Right to rectification: You have     the right, in accordance with the law, to request the completion of the     data concerning you or the rectification of the incorrect data concerning     you.
  • Right to Erasure and Right to Restriction of Processing: In accordance with the statutory provisions, you have the     right to demand that the relevant data be erased immediately or,     alternatively, to demand that the processing of the data be restricted in     accordance with the statutory provisions.
  • Right to data portability: You have     the right to receive data concerning you which you have provided to us in     a structured, common and machine-readable format in accordance with the     legal requirements, or to request its transmission to another controller.
  • Complaint to the supervisory authority: You also have the right, under the conditions laid down by     law, to lodge a complaint with a supervisory authority, in particular in     the Member State of your habitual residence, place of work or place of the     alleged infringement if you consider that the processing of personal data     relating to you infringes the GDPR.

Supervisory authority competent for us:

Berliner Beauftragte fürDatenschutz und Informationsfreiheit, Friedrichstr. 219,10969 Berlin

 

Terminology and Definitions

This section provides an overview of theterms used in this privacy policy. Many of the terms are drawn from the law anddefined mainly in Article 4 GDPR. The legal definitions are binding. Thefollowing explanations, on the other hand, are intended above all for thepurpose of comprehension. The terms are sorted alphabetically.

  • A/B Tests: A/B tests are designed     to improve the usability and performance of online services. For example,     users are presented with different versions of a website or its elements,     such as input forms, on which the placement of the contents or labels of     the navigation elements can differ. The behaviour of users, e.g. prolonged     visits to the site or more frequent interaction with the elements, can     then be used to determine which of these sites or elements are more     responsive to users' needs.
  • Clicktracking: Clicktracking allows     users to keep track of their movements within an entire website. Since the     results of these tests are more accurate if the interaction of the users     can be followed over a certain period of time (e.g. if a user likes to     return), cookies are usually stored on the computers of the users for     these test purposes.
  • Controller: "Controller"     means the natural or legal person, public authority, agency or other body     which, alone or jointly with others, determines the purposes and means of     the processing of personal data.
  • Conversion Tracking:     "Conversion Tracking" refers to a procedure by which the     effectiveness of marketing measures can be determined. As a rule, a cookie     is stored on the devices of the users within the websites on which the     marketing measures are carried out and then called up again on the target     website (e.g. this enables us to track whether the ads we placed on other     websites were successful).
  • Conversion tracking: Conversion     tracking is a method used to evaluate the effectiveness of marketing     measures. For this purpose, a cookie is usually stored on the devices of     the users within the websites on which the marketing measures take place     and then called up again on the target website (e.g. we can thus trace     whether the advertisements placed by us on other websites were     successful).
  • Heatmaps: "Heatmaps" are     mouse movements of the users, which are combined to an overall picture,     with the help of which it can be recognized, for example, which web page     elements are preferred and which web page elements users prefer less.
  • IP Masking: IP masking is a method     by which the last octet, i.e. the last two numbers of an IP address, are     deleted so that the IP address alone can no longer be used to uniquely     identify a person. IP masking is therefore a means of pseudonymising     processing methods, particularly in online marketing.
  • Interest-based and behavioral marketing: Interest-related and/or behaviour-related marketing is the     term used when potential user interest in advertisements and other content     is predicted if possible. This is done on the basis of information on the     previous behaviour of users (e.g. visiting and staying on certain     websites, purchasing behaviour or interaction with other users), which is     stored in a so-called profile. For these purposes cookies are usually     used.
  • Personal Data: "personal     data" means any information relating to an identified or identifiable     natural person ("data subject"); an identifiable natural person     is one who can be identified, directly or indirectly, in particular by     reference to an identifier such as a name, an identification number,     location data, an online identifier or to one or more factors specific to     the physical, physiological, genetic, mental, economic, cultural or social     identity of that natural person.
  • Processing: The term     "processing" covers a wide range and practically every handling     of data, be it collection, evaluation, storage, transmission or erasure.
  • Profiling: "Profiling"     means any automated processing of personal data consisting in the use of     such personal data to analyse, evaluate or predict certain personal     aspects relating to a natural person (depending on the type of profiling,     this includes information regarding age, gender, location and movement     data, interaction with websites and their contents, shopping behaviour,     social interactions with other people) (e.g. interests in certain contents     or products, click behaviour on a website or the location). Cookies and     web beacons are often used for profiling purposes.
  • Remarketing: Remarketing" or     "retargeting" is the term used, for example, to indicate for     advertising purposes which products a user is interested in on a website     in order to remind the user of these products on other websites, e.g. in     advertisements.  
  • Targeting: Tracking" is the     term used when the behaviour of users can be traced across several     websites. As a rule, behavior and interest information with regard to the     websites used is stored in cookies or on the servers of the tracking     technology providers (so-called profiling). This information can then be     used, for example, to display advertisements to users presumably     corresponding to their interests.
  • Web Analytics: Web Analytics serves     the evaluation of visitor traffic of online services and can determine     their behavior or interests in certain information, such as content of     websites. With the help of web analytics, website owners, for example, can     recognize at what time visitors visit their website and what content they     are interested in. This allows them, for example, to optimize the content     of the website to better meet the needs of their visitors. For purposes of     web analytics, pseudonymous cookies and web beacons are frequently used in     order to recognise returning visitors and thus obtain more precise     analyses of the use of an online service.