Introduction and overview

We have prepared this privacy policy (version 20.03.2025-112967475) to explain to you, in accordance with the requirements of the General Data Protection Regulation (EU) 2016/679 and applicable national laws, which personal data (data for short) we as the controller – and the processors commissioned by us (e.g. providers) – process, will process in the future and what lawful options you have. The terms used are to be understood as gender-neutral.
In short: We provide you with comprehensive information about the data we process about you.

Data protection declarations usually sound very technical and use legal jargon. This privacy policy, on the other hand, is intended to describe the most important things to you as simply and transparently as possible. Where it is conducive to transparency, technical terms are explained in a reader-friendly way, links to further information are provided and graphics are used. We thus inform you in clear and simple language that we only process personal data as part of our business activities if there is a corresponding legal basis. This is certainly not possible by providing explanations that are as concise, unclear and legally technical as possible, as is often standard on the Internet when it comes to data protection. I hope you find the following explanations interesting and informative and perhaps there is one or two pieces of information that you did not yet know.
If you still have any questions, please contact the responsible body named below or in the legal notice, follow the links provided and look at further information on third-party websites. Our contact details can of course also be found in the legal notice.

Area of application

This privacy policy applies to all personal data processed by us in the company and to all personal data processed by companies commissioned by us (processors). By personal data, we mean information within the meaning of Art. 4 No. 1 GDPR, such as a person’s name, email address and postal address. The processing of personal data ensures that we can offer and bill our services and products, whether online or offline. The scope of this privacy policy includes

  • all online presences (websites, online stores) that we operate
  • Social media presences and email communication
  • Mobile apps for smartphones and other devices

In short, the privacy policy applies to all areas in which personal data is processed in the company in a structured manner via the channels mentioned. If we enter into legal relationships with you outside of these channels, we will inform you separately if necessary.

Legal basis

In the following privacy policy, we provide you with transparent information on the legal principles and regulations, i.e. the legal bases of the General Data Protection Regulation, which enable us to process personal data.
As far as EU law is concerned, we refer to REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016. You can of course read this EU General Data Protection Regulation online at EUR-Lex, the access point to EU law, at https://eur-lex.europa.eu/legal-content/DE/ALL/?uri=celex%3A32016R0679.

We only process your data if at least one of the following conditions applies:

  1. Consent (Article 6(1)(a) GDPR): You have given us your consent to process data for a specific purpose. An example would be the storage of the data you entered in a contact form.
  2. Contract (Article 6(1)(b) GDPR): In order to fulfill a contract or pre-contractual obligations with you, we process your data. For example, if we conclude a purchase contract with you, we need personal information in advance.
  3. Legal obligation (Article 6(1)(c) GDPR): If we are subject to a legal obligation, we process your data.
  4. Legitimate interests (Article 6(1)(f) GDPR): In the case of legitimate interests that do not restrict your fundamental rights, we reserve the right to process personal data. For example, we need to process certain data in order to operate our website securely and efficiently. This processing is therefore a legitimate interest.

Other conditions such as recording in the public interest, the exercise of official authority and the protection of vital interests do not generally apply to us. If such a legal basis is relevant, it will be indicated at the appropriate point.

In addition to the EU regulation, national laws also apply:

  • In Austria, this is the Federal Act on the Protection of Natural Persons with regard to the Processing of PersonalData (Data Protection Act), or DSG for short.
  • In Germany, the Federal Data Protection Act( BDSG) applies.

If other regional or national laws apply, we will inform you of this in the following sections.

Contact details of the controller

If you have any questions about data protection or the processing of personal data, you will find below the contact details of the controller in accordance with Article 4(7) of the EU General Data Protection Regulation (GDPR):

RHI GmbH – Glowing Point
HauseggerstraรŸe 56
8020 Graz
Austria


Authorized to represent: Robert Hiendler
E-Mail: info@glowingpoint.at
Phone: +43 664 22 05 355
Imprint: https://glowingpoint.at/impressum/

Storage duration

It is a general criterion for us that we only store personal data for as long as is absolutely necessary for the provision of our services and products. This means that we delete personal data as soon as the reason for the data processing no longer exists. In some cases, we are legally obliged to store certain data even after the original purpose has ceased to exist, for example for accounting purposes.

If you wish your data to be deleted or revoke your consent to data processing, the data will be deleted as quickly as possible and insofar as there is no obligation to store it.

We will inform you below about the specific duration of the respective data processing if we have further information on this.

Rights under the General Data Protection Regulation

In accordance with Articles 13, 14 GDPR, we inform you of the following rights to which you are entitled in order to ensure fair and transparent processing of data:

  • According to Article 15 GDPR, you have a right to information as to whether we process your data. If this is the case, you have the right to receive a copy of the data and the following information:
    • the purpose for which we carry out the processing;
    • the categories, i.e. the types of data that are processed;
    • who receives this data and, if the data is transferred to third countries, how security can be guaranteed;
    • how long the data will be stored;
    • the existence of the right to rectification, erasure or restriction of processing and the right to object to processing;
    • that you can lodge a complaint with a supervisory authority (links to these authorities can be found below);
    • the origin of the data if we have not collected it from you;
    • whether profiling is carried out, i.e. whether data is automatically analyzed in order to create a personal profile of you.
  • According to Article 16 GDPR, you have a right to rectification of data, which means that we must correct data if you find errors.
  • According to Article 17 GDPR, you have the right to erasure (“right to be forgotten”), which specifically means that you may request the erasure of your data.
  • According to Article 18 GDPR, you have the right to restriction of processing, which means that we may only store the data but no longer use it.
  • According to Article 20 GDPR, you have the right to data portability, which means that we will provide you with your data in a commonly used format upon request.
  • According to Article 21 GDPR, you have the right to object, which will result in a change in the processing after enforcement.
    • If the processing of your data is based on Article 6(1)(e) (public interest, exercise of official authority) or Article 6(1)(f) (legitimate interest), you can object to the processing. We will then check as quickly as possible whether we can legally comply with this objection.
    • If data is used for direct marketing purposes, you can object to this type of data processing at any time. We may then no longer use your data for direct marketing.
    • If data is used for profiling, you can object to this type of data processing at any time. We may then no longer use your data for profiling.
  • Under Article 22 GDPR, you may have the right not to be subject to a decision based solely on automated processing (e.g. profiling).
  • According to Article 77 GDPR, you have the right to lodge a complaint. This means that you can lodge a complaint with the data protection authority at any time if you believe that the processing of personal data violates the GDPR.

In short: You have rights – do not hesitate to contact the responsible office listed above!

If you believe that the processing of your data violates data protection law or that your data protection rights have been violated in any other way, you can lodge a complaint with the supervisory authority. For Austria, this is the data protection authority, whose website can be found at https://www.dsb.gv.at/. In Germany, there is a data protection officer for each federal state. For more information, you can contact the Federal Commissioner for Data Protection and Freedom of Information (BfDI). The following local data protection authority is responsible for our company:

Austria Data Protection Authority

Head: Dr. Matthias Schmidl
Address:
Barichgasse 40-42, 1030 Vienna
Telephone number:
+43 1 52 152-0
E-mail address:
dsb@dsb.gv.at
Website:
https://www.dsb.gv.at/

Security of data processing

In order to protect personal data, we have implemented both technical and organizational measures. Where possible, we encrypt or pseudonymize personal data. In this way, we make it as difficult as possible for third parties to infer personal information from our data.

Art. 25 GDPR speaks here of “data protection by design and by default” and thus means that both software (e.g. forms) and hardware (e.g. access to the server room) should always be designed with security in mind and appropriate measures should be taken. If necessary, we will discuss specific measures below.

TLS encryption with https

TLS, encryption and https sound very technical – and they are. We use HTTPS (the Hypertext Transfer Protocol Secure stands for “secure hypertext transfer protocol”) to transmit data tap-proof on the Internet.
This means that the complete transmission of all data from your browser to our web server is secured – nobody can “eavesdrop”.

We have thus introduced an additional layer of security and comply with data protection by design(Article 25(1) GDPR). By using TLS (Transport Layer Security), an encryption protocol for secure data transmission on the Internet, we can ensure the protection of confidential data.
You can recognize the use of this data transmission security by the small lock symbol at the top left of the browser, to the left of the Internet address (e.g. For example, examplepage.com) and the use of the https scheme (instead of http) as part of our Internet address.
If you would like to know more about encryption, we recommend a Google search for “Hypertext Transfer Protocol Secure wiki” to obtain good links to further information.

Communication

Communication summary
๐Ÿ‘ฅ Data subjects: Anyone who communicates with us by telephone, email or online form
๐Ÿ““ Processed data: e.g. telephone number, name, email address, form data entered. You can find more details on this in the respective contact type used
๐Ÿค Purpose: Handling communication with customers, business partners, etc.
๐Ÿ“… Storage period: Duration of the business case and the statutory provisions
โš–๏ธ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. b GDPR (contract), Art. 6 para. 1 lit. f GDPR (legitimate interests)

If you contact us and communicate with us by telephone, e-mail or online form, personal data may be processed.

The data is processed for the handling and processing of your question and the associated business transaction. The data will be stored for as long as required by law.

Affected persons

All those who seek contact with us via the communication channels provided by us are affected by the aforementioned processes.

Telephone

When you call us, the call data is stored pseudonymously on the respective end device and with the telecommunications provider used. In addition, data such as name and telephone number may subsequently be sent by e-mail and stored for the purpose of responding to inquiries. The data will be deleted as soon as the business case has been completed and legal requirements permit.

e-mail

If you communicate with us by email, data may be stored on the respective end device (computer, laptop, smartphone, etc.) and data may be stored on the email server. The data will be deleted as soon as the business transaction has been completed and legal requirements permit.

Online forms

If you communicate with us using an online form, data is stored on our web server and may be forwarded to one of our e-mail addresses. The data will be deleted as soon as the business transaction has been completed and legal requirements permit.

Legal basis

The processing of the data is based on the following legal bases:

  • Art. 6 para. 1 lit. a GDPR (consent): You give us your consent to store your data and to use it for purposes relating to the business transaction;
  • Art. 6 para. 1 lit. b GDPR (contract): It is necessary for the performance of a contract with you or a processor, such as the telephone provider, or we need to process the data for pre-contractual activities, such as the preparation of an offer;
  • Art. 6 para. 1 lit. f GDPR (legitimate interests): We want to handle customer inquiries and business communication in a professional manner. This requires certain technical facilities such as e-mail programs, exchange servers and mobile network operators in order to be able to operate communication efficiently.

Data processing agreement (DPA)

In this section, we would like to explain what a data processing agreement is and why it is needed. Because the word “data processing agreement” is a bit of a mouthful, we will often only use the acronym DPA in this text. Like most companies, we do not work alone, but also use the services of other companies or individuals. By involving various companies or service providers, we may pass on personal data for processing. These partners then act as processors with whom we conclude a contract, the so-called data processing agreement (DPA). The most important thing for you to know is that the processing of your personal data takes place exclusively in accordance with our instructions and must be regulated by the DPA.

Who are processors?

As a company and website owner, we are responsible for all data that we process from you. In addition to controllers, there may also be so-called processors. This includes any company or person who processes personal data on our behalf. More precisely and according to the GDPR definition: any natural or legal person, public authority, agency or other body which processes personal data on our behalf is considered a processor. Processors can therefore be service providers such as hosting or cloud providers, payment or newsletter providers or large companies such as Google or Microsoft.

To make the terminology easier to understand, here is an overview of the three roles in the GDPR:

Data subject (you as a customer or interested party) โ†’ Controller (we as a company and client) โ†’ Processor (service provider such as web host or cloud provider)

Content of an order processing contract

As mentioned above, we have concluded a DPA with our partners who act as processors. This states above all that the processor processes the data to be processed exclusively in accordance with the GDPR. The contract must be concluded in writing, although the electronic conclusion of the contract is also considered “written” in this context. The processing of personal data only takes place on the basis of the contract. The contract must contain the following:

  • Commitment to us as the controller
  • Obligations and rights of the controller
  • Categories of data subjects
  • Type of personal data
  • Type and purpose of data processing
  • Subject and duration of data processing
  • Place of data processing

Furthermore, the contract contains all obligations of the processor. The most important obligations are

  • to ensure data security measures
  • take possible technical and organizational measures to protect the rights of the data subject
  • to keep a data processing register
  • cooperate with the data protection supervisory authority at its request
  • carry out a risk analysis in relation to the personal data received
  • Sub-processors may only be commissioned with the written consent of the controller

You can find out what such an AVV looks like in concrete terms at https://www.wko.at/service/wirtschaftsrecht-gewerberecht/eu-dsgvo-mustervertrag-auftragsverarbeitung.html, for example. A sample contract is presented here.

Cookies

Cookies summary
๐Ÿ‘ฅ Affected parties: Visitors to the website
๐Ÿค Purpose: depending on the cookie. You can find more details on this below or from the manufacturer of the software that sets the cookie.
๐Ÿ““ Processed data: Depending on the cookie used. You can find more details on this below or from the manufacturer of the software that sets the cookie.
๐Ÿ“… Storage duration: depends on the cookie, can vary from hours to years
โš–๏ธ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit.f GDPR (legitimate interests)

What are cookies?

Our website uses HTTP cookies to store user-specific data.
Below we explain what cookies are and why they are used so that you can better understand the following privacy policy.

Whenever you surf the internet, you use a browser. Well-known browsers include Chrome, Safari, Firefox, Internet Explorer and Microsoft Edge. Most websites store small text files in your browser. These files are called cookies.

One thing cannot be denied: Cookies are really useful little helpers. Almost all websites use cookies. More precisely, they are HTTP cookies, as there are also other cookies for other areas of application. HTTP cookies are small files that are stored on your computer by our website. These cookie files are automatically stored in the cookie folder, the “brain” of your browser, so to speak. A cookie consists of a name and a value. When defining a cookie, one or more attributes must also be specified.

Cookies store certain user data about you, such as language or personal page settings. When you visit our site again, your browser transmits the “user-related” information back to our site. Thanks to cookies, our website knows who you are and offers you the settings you are used to. In some browsers, each cookie has its own file; in others, such as Firefox, all cookies are stored in a single file.

The following graphic shows a possible interaction between a web browser such as Chrome and the web server. The web browser requests a website and receives a cookie back from the server, which the browser uses again as soon as another page is requested.

HTTP cookie interaction between browser and web server

There are both first-party cookies and third-party cookies. First-party cookies are created directly by our website, third-party cookies are created by partner websites (e.g. Google Analytics). Each cookie must be evaluated individually, as each cookie stores different data. The expiry time of a cookie also varies from a few minutes to a few years. Cookies are not software programs and do not contain viruses, Trojans or other “malware”. Cookies also cannot access information on your PC.

Cookie data can look like this, for example:

Name: _ga
Value: GA1.2.1326744211.152112967475-9
Purpose: Differentiation of website visitors
Expiry date: after 2 years

A browser should be able to support these minimum sizes:

  • At least 4096 bytes per cookie
  • At least 50 cookies per domain
  • At least 3000 cookies in total

What types of cookies are there?

The question of which cookies we use in particular depends on the services used and is clarified in the following sections of the privacy policy. At this point, we would like to briefly explain the different types of HTTP cookies.

A distinction can be made between 4 types of cookies:

Essential cookies
These cookies are necessary to ensure basic functions of the website. For example, these cookies are needed when a user places a product in the shopping cart, then continues surfing on other pages and only goes to the checkout later. These cookies ensure that the shopping cart is not deleted even if the user closes their browser window.

Purposeful cookies
These cookies collect information about user behavior and whether the user receives any error messages. These cookies are also used to measure the loading time and the behavior of the website with different browsers.

Targeted cookies
These cookies ensure better user-friendliness. For example, entered locations, font sizes or form data are saved.

Advertising cookies
These cookies are also known as targeting cookies. They are used to deliver customized advertising to the user. This can be very practical, but also very annoying.

When you visit a website for the first time, you are usually asked which of these cookie types you would like to allow. And of course this decision is also stored in a cookie.

If you would like to know more about cookies and are not afraid of technical documentation, we recommend https://datatracker.ietf.org/doc/html/rfc6265, the Request for Comments of the Internet Engineering Task Force (IETF) called “HTTP State Management Mechanism”.

Purpose of processing via cookies

The purpose ultimately depends on the cookie in question. You can find more details on this below or from the manufacturer of the software that sets the cookie.

What data is processed?

Cookies are little helpers for many different tasks. Unfortunately, it is not possible to generalize which data is stored in cookies, but we will inform you about the processed or stored data in the following privacy policy.

Storage duration of cookies

The storage period depends on the cookie in question and is specified below. Some cookies are deleted after less than an hour, others can remain stored on a computer for several years.

You can also influence the storage period yourself. You can delete all cookies manually at any time via your browser (see also “Right to object” below). Furthermore, cookies that are based on consent will be deleted at the latest after you withdraw your consent, whereby the legality of the storage until then remains unaffected.

Right to object – how can I delete cookies?

You decide how and whether you want to use cookies. Regardless of which service or website the cookies originate from, you always have the option of deleting, deactivating or only partially allowing cookies. For example, you can block third-party cookies but allow all other cookies.

If you want to find out which cookies have been stored in your browser, if you want to change or delete cookie settings, you can find this in your browser settings:

Chrome: Delete, activate and manage cookies in Chrome

Safari: Managing cookies and website data with Safari

Firefox: Delete cookies to remove data that websites have stored on your computer

Internet Explorer: Deleting and managing cookies

Microsoft Edge: Deleting and managing cookies

If you generally do not want to have cookies, you can set up your browser so that it always informs you when a cookie is to be set. You can then decide for each individual cookie whether or not to allow it. The procedure differs depending on the browser. It is best to search for the instructions in Google using the search term “delete cookies Chrome” or “deactivate cookies Chrome” in the case of a Chrome browser.

Legal basis

The so-called “Cookie Guidelines” have been in place since 2009. These state that the storage of cookies requires your consent (Article 6(1)(a) GDPR). However, there are still very different reactions to these directives within the EU countries. In Austria, however, this directive was implemented in Section 165 (3) of the Telecommunications Act (2021). In Germany, the cookie directives have not been implemented as national law. Instead, this directive was largely implemented in Section 15 (3) of the Telemedia Act (TMG), which has been replaced by the Digital Services Act (DDG) since May 2024.

For strictly necessary cookies, even if no consent has been given, there are legitimate interests (Article 6(1)(f) GDPR), which in most cases are of an economic nature. We want to provide visitors to the website with a pleasant user experience and certain cookies are often absolutely necessary for this.

If cookies that are not absolutely necessary are used, this will only take place with your consent. The legal basis in this respect is Art. 6 para. 1 lit. a GDPR.

In the following sections, you will be informed in more detail about the use of cookies if the software used uses cookies.

Social media introduction

Social media privacy policy summary
๐Ÿ‘ฅ Data subjects: Visitors to the website
๐Ÿค Purpose: Presentation and optimization of our services, contact with visitors, interested parties, etc., advertising
๐Ÿ““ Processed data: Data such as telephone numbers, email addresses, contact details, data on user behavior, information on your device and your IP address.
You can find more details on this in the respective social media tool used.
๐Ÿ“… Storage duration: depending on the social media platforms used
โš–๏ธ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is social media?

In addition to our website, we are also active on various social media platforms. User data may be processed so that we can target users who are interested in us via the social networks. In addition, elements of a social media platform may also be embedded directly in our website. This is the case, for example, if you click on a social button on our website and are forwarded directly to our social media presence. Social media refers to websites and apps that registered members can use to produce content, share content openly or in specific groups and network with other members.

Why do we use social media?

For years, social media platforms have been the place where people communicate and get in touch online. Our social media presence allows us to bring our products and services closer to interested parties. The social media elements integrated on our website help you to switch to our social media content quickly and without complications.

The data that is stored and processed through your use of a social media channel is primarily for the purpose of carrying out web analyses. The aim of these analyses is to be able to develop more precise and personalized marketing and advertising strategies. Depending on your behavior on a social media platform, the evaluated data can be used to draw conclusions about your interests and create user profiles. This also enables the platforms to present you with customized advertisements. Cookies are usually set in your browser for this purpose, which store data on your usage behavior.

As a rule, we assume that we remain responsible under data protection law, even if we use the services of a social media platform. However, the European Court of Justice has ruled that in certain cases the operator of the social media platform may be jointly responsible with us within the meaning of Art. 26 GDPR. If this is the case, we will point this out separately and work on the basis of an agreement to this effect. The essence of the agreement is then reproduced below for the platform concerned.

Please note that when using the social media platforms or our built-in elements, your data may also be processed outside the European Union, as many social media channels, such as Facebook or Twitter, are American companies. As a result, you may not be able to claim or enforce your rights in relation to your personal data as easily.

What data is processed?

Exactly which data is stored and processed depends on the respective provider of the social media platform. However, it usually involves data such as telephone numbers, email addresses, data that you enter in a contact form, user data such as which buttons you click, who you like or follow, when you visited which pages, information about your device and your IP address. Most of this data is stored in cookies. Data can be linked to your profile, especially if you have a profile on the social media channel you are visiting and are logged in.

All data that is collected via a social media platform is also stored on the provider’s servers. This means that only the providers have access to the data and can provide you with the appropriate information or make changes.

If you want to know exactly what data is stored and processed by social media providers and how you can object to data processing, you should carefully read the company’s privacy policy. We also recommend that you contact the provider directly if you have any questions about data storage and data processing or wish to assert corresponding rights.

Duration of data processing

We will inform you about the duration of data processing below if we have further information on this. For example, the social media platform Facebook stores data until it is no longer required for its own purposes. However, customer data that is compared with our own user data is deleted within two days. In general, we only process personal data for as long as is absolutely necessary for the provision of our services and products. If required by law, for example in the case of accounting, this storage period may be exceeded.

Right of objection

You also have the right and the option to withdraw your consent to the use of cookies or third-party providers such as embedded social media elements at any time. This works either via our cookie management tool or via other opt-out functions. For example, you can also prevent data collection by cookies by managing, deactivating or deleting cookies in your browser.

As social media tools may use cookies, we also recommend that you read our general privacy policy on cookies. To find out exactly which of your data is stored and processed, you should read the privacy policies of the respective tools.

Legal basis

If you have consented to your data being processed and stored by integrated social media elements, this consent is the legal basis for data processing (Art. 6 para. 1 lit. a GDPR). In principle, your data will also be stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f GDPR) in fast and good communication with you or other customers and business partners if you have given your consent. Nevertheless, we only use the tools if you have given your consent. Most social media platforms also set cookies in your browser to store data. We therefore recommend that you read our data protection text on cookies carefully and consult the privacy policy or cookie guidelines of the respective service provider.

Information on specific social media platforms – if available – can be found in the following sections.

Facebook privacy policy

Facebook privacy policy summary
๐Ÿ‘ฅ Data subject: Visitors to the website
๐Ÿค Purpose: Optimization of our service performance
๐Ÿ““ Processed data: Data such as customer data, user behavior data, information about your device and your IP address.
More details can be found below in the privacy policy.
๐Ÿ“… Storage period: until the data is no longer useful for Facebook’s purposes
โš–๏ธ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What are Facebook tools?

We use selected tools from Facebook on our website. Facebook is a social media network of the company Meta Platforms Inc. or, for the European region, Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. With the help of these tools, we can offer you and people who are interested in our products and services the best possible offer.

If data is collected and forwarded from you via our embedded Facebook elements or via our Facebook page (fan page), both we and Facebook Ireland Ltd. are responsible for this. Facebook is solely responsible for the further processing of this data. Our joint obligations are also set out in a publicly accessible agreement at https://www.facebook.com/legal/controller_addendum. This states, for example, that we must clearly inform you about the use of Facebook tools on our site. Furthermore, we are also responsible for ensuring that the tools are securely integrated into our website in accordance with data protection law. Facebook, on the other hand, is responsible for the data security of Facebook products, for example. If you have any questions about data collection and data processing by Facebook, you can contact the company directly. If you address the question to us, we are obliged to forward it to Facebook.

Below we provide an overview of the various Facebook tools, what data is sent to Facebook and how you can delete this data.

In addition to many other products, Facebook also offers the so-called “Facebook Business Tools”. This is the official term used by Facebook. However, as the term is hardly known, we have decided to simply call them Facebook tools. These include, among others:

  • Facebook pixel
  • Social plug-ins (such as the “Like” or “Share” button)
  • Facebook login
  • account kit
  • APIs (programming interface)
  • SDKs (collection of programming tools)
  • Platform integrations
  • plugins
  • codes
  • specifications
  • Documentation
  • Technologies and services

Through these tools, Facebook expands services and has the ability to obtain information about user activity outside of Facebook.

Why do we use Facebook tools on our website?

We only want to show our services and products to people who are really interested in them. With the help of advertisements (Facebook ads), we can reach precisely these people. However, Facebook needs information about people’s wishes and needs in order to show users suitable advertising. The company is therefore provided with information about user behavior (and contact details) on our website. As a result, Facebook collects better user data and can show interested people suitable advertising about our products or services. The tools thus enable customized advertising campaigns on Facebook.

Facebook calls data about your behavior on our website “event data”. This is also used for measurement and analysis services. Facebook can thus create “campaign reports” on our behalf about the impact of our advertising campaigns. Furthermore, analytics give us a better insight into how you use our services, website or products. This allows us to optimize your user experience on our website with some of these tools. For example, you can use the social plug-ins to share content on our site directly on Facebook.

What data is stored by Facebook tools?

By using individual Facebook tools, personal data (customer data) can be sent to Facebook. Depending on the tools used, customer data such as name, address, telephone number and IP address may be sent.

Facebook uses this information to match the data with the data it has about you (if you are a Facebook member). Before customer data is transmitted to Facebook, it is hashed. This means that a data set of any size is transformed into a character string. This is also used to encrypt data.

In addition to the contact data, “event data” is also transmitted. “Event data” refers to the information that we receive about you on our website. For example, which subpages you visit or which products you buy from us. Facebook does not share the information it receives with third parties (such as advertisers) unless the company has explicit permission or is legally obliged to do so. “Event data” can also be linked to contact details. This allows Facebook to offer better personalized advertising. After the aforementioned matching process, Facebook deletes the contact data again.

In order to deliver optimized ads, Facebook only uses the event data if it has been combined with other data (collected by Facebook in other ways). Facebook also uses this event data for security, protection, development and research purposes. Much of this data is transferred to Facebook via cookies. Cookies are small text files that are used to store data or information in browsers. Depending on the tools used and whether you are a Facebook member, different numbers of cookies are stored in your browser. We go into more detail about individual Facebook cookies in the descriptions of the individual Facebook tools. You can also find general information about the use of Facebook cookies at https://www.facebook.com/policies/cookies.

How long and where is the data stored?

In principle, Facebook stores data until it is no longer needed for its own services and Facebook products. Facebook has servers all over the world where its data is stored. However, customer data is deleted within 48 hours after it has been compared with the company’s own user data.

How can I delete my data or prevent data storage?

In accordance with the General Data Protection Regulation, you have the right to information, correction, transferability and deletion of your data.

The data will only be completely deleted if you delete your Facebook account completely. And this is how deleting your Facebook account works:

1) Click on Settings on the right-hand side of Facebook.

2) Then click on “Your Facebook information” in the left-hand column.

3) Now click on “Deactivation and deletion”.

4) Now select “Delete account” and then click on “Continue and delete account”

5) Now enter your password, click on “Next” and then on “Delete account”

The data that Facebook receives via our site is stored using cookies (e.g. for social plugins). You can deactivate, delete or manage individual or all cookies in your browser. Depending on which browser you use, this works in different ways. In the “Cookies” section, you will find the relevant links to the instructions for the most popular browsers.

If you generally do not want to have cookies, you can set up your browser so that it always informs you when a cookie is to be set. This allows you to decide for each individual cookie whether you want to allow it or not.

Legal basis

If you have consented to your data being processed and stored by integrated Facebook tools, this consent is the legal basis for data processing (Art. 6 para. 1 lit. a GDPR). In principle, your data is also stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f GDPR) in fast and good communication with you or other customers and business partners. Nevertheless, we only use the tools if you have given your consent. Most social media platforms also set cookies in your browser to store data. We therefore recommend that you read our privacy policy about cookies carefully and take a look at Facebook’s privacy policy or cookie guidelines.

Facebook also processes your data in the USA, among other places. Facebook or Meta Platforms is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA. You can find more information on this at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

In addition, Facebook uses so-called standard contractual clauses (= Art. 46 (2) and (3) GDPR). Standard Contractual Clauses (SCCs) are templates provided by the EU Commission and are intended to ensure that your data complies with European data protection standards even if it is transferred to third countries (such as the USA) and stored there. Through the EU-US Data Privacy Framework and the standard contractual clauses, Facebook undertakes to comply with the European level of data protection when processing your relevant data, even if the data is stored, processed and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding standard contractual clauses here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de

The Facebook data processing conditions, which refer to the standard contractual clauses, can be found at https://www.facebook.com/legal/terms/dataprocessing.

We hope we have provided you with the most important information about the use and data processing by the Facebook tools. If you would like to find out more about how Facebook uses your data, we recommend that you read the data policy at https://www.facebook.com/privacy/policy/.

Instagram privacy policy

Instagram privacy policy summary
๐Ÿ‘ฅ Data subject: Visitors to the website
๐Ÿค Purpose: Optimization of our service performance
๐Ÿ““ Processed data: Data such as user behavior data, information about your device and your IP address.
More details can be found below in the privacy policy.
๐Ÿ“… Storage period: until Instagram no longer needs the data for its purposes
โš–๏ธ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is Instagram?

We have integrated Instagram functions on our website. Instagram is a social media platform of the company Instagram LLC, 1601 Willow Rd, Menlo Park CA 94025, USA. Instagram has been a subsidiary of Meta Platforms Inc. since 2012 and is a Facebook product. Embedding Instagram content on our website is called embedding. This allows us to show you content such as buttons, photos or videos from Instagram directly on our website. When you visit web pages on our website that have an Instagram function integrated, data is transmitted to Instagram, stored and processed. Instagram uses the same systems and technologies as Facebook. Your data is therefore processed across all Facebook companies.

In the following, we want to give you a more detailed insight into why Instagram collects data, what data is involved and how you can largely control data processing. As Instagram belongs to Meta Platforms Inc., we obtain our information from the Instagram guidelines on the one hand, but also from the Meta privacy policy itself on the other.

Instagram is one of the best-known social media networks in the world. Instagram combines the advantages of a blog with the benefits of audiovisual platforms such as YouTube or Vimeo. You can upload photos and short videos to “Insta” (as many users casually call the platform), edit them with various filters and also share them on other social networks. And if you don’t want to be active yourself, you can also just follow other interesting users.

Why do we use Instagram on our website?

Instagram is the social media platform that has really gone through the roof in recent years. And of course we have also responded to this boom. We want you to feel as comfortable as possible on our website. That’s why a varied presentation of our content is a matter of course for us. The embedded Instagram functions allow us to enrich our content with helpful, funny or exciting content from the Instagram world. As Instagram is a subsidiary of Facebook, the data collected can also be useful to us for personalized advertising on Facebook. This means that only people who are genuinely interested in our products or services receive our advertisements.

Instagram also uses the collected data for measurement and analysis purposes. We receive summarized statistics and thus more insight into your wishes and interests. It is important to note that these reports do not identify you personally.

What data is stored by Instagram?

When you visit one of our pages that has Instagram functions (such as Instagram images or plug-ins), your browser automatically connects to Instagram’s servers. In the process, data is sent to Instagram, stored and processed. This happens regardless of whether you have an Instagram account or not. This includes information about our website, your computer, purchases made, advertisements you see and how you use our services. The date and time of your interaction with Instagram are also stored. If you have an Instagram account or are logged in, Instagram stores significantly more data about you.

Facebook distinguishes between customer data and event data. We assume that this is exactly the case with Instagram. Customer data includes, for example, name, address, telephone number and IP address. This customer data is only transmitted to Instagram once it has been hashed. Hashing means that a data record is converted into a character string. This allows the contact data to be encrypted. The “event data” mentioned above is also transmitted. By “event data”, Facebook – and consequently Instagram – means data about your user behavior. Contact data may also be combined with event data. The contact data collected is compared with the data that Instagram already has about you.

The collected data is transmitted to Facebook via small text files (cookies), which are usually set in your browser. Depending on the Instagram functions used and whether you have an Instagram account yourself, different amounts of data are stored.

We assume that Instagram processes data in the same way as Facebook. This means that if you have an Instagram account or have visited www.instagram.com, Instagram has at least set a cookie. If this is the case, your browser sends information to Instagram via the cookie as soon as you come into contact with an Instagram function. This data is deleted or anonymized after 90 days at the latest (after reconciliation). Although we have looked closely at Instagram’s data processing, we cannot say exactly what data Instagram collects and stores.

Below we will show you the minimum cookies that are set in your browser when you click on an Instagram function (such as a button or an Insta image). In our test, we assume that you do not have an Instagram account. If you are logged in to Instagram, significantly more cookies will of course be set in your browser.

These cookies were used in our test:

Name: csrftoken
Value: “”
Purpose: This cookie is most likely set for security reasons to prevent falsification of requests. However, we were unable to find out more about this.
Expiration date: after one year

Name: mid
Value: “”
Purpose: Instagram sets this cookie to optimize its own services and offers in and outside of Instagram. The cookie defines a unique user ID.
Expiration date: after the end of the session

Name: fbsr_112967475124024
Value: not specified
Purpose: This cookie stores the log-in request for users of the Instagram app.
Expiration date: after the end of the session

Name: rur
Value: ATN
Purpose: This is an Instagram cookie that ensures functionality on Instagram.
Expiry date: after the end of the session

Name: urlgen
Value: “{“194.96.75.33”: 1901}:1iEtYv:Y833k2_UjKvXgYe112967475
Purpose: This cookie is used for Instagram’s marketing purposes.
Expiry date: at the end of the session

Note: We cannot claim completeness here. Which cookies are set in individual cases depends on the embedded functions and your use of Instagram.

How long and where is the data stored?

Instagram shares the information received between the Facebook companies with external partners and with people you connect with worldwide. Data processing is carried out in compliance with its own data policy. For security reasons, among others, your data is distributed on Facebook servers around the world. Most of these servers are located in the USA.

How can I delete my data or prevent data storage?

Thanks to the General Data Protection Regulation, you have the right to access, portability, rectification and erasure of your data. You can manage your data in the Instagram settings. If you want to completely delete your data on Instagram, you must permanently delete your Instagram account.

And this is how deleting your Instagram account works:

First open the Instagram app. Go to the bottom of your profile page and click on “Help section”. You will now be taken to the company’s website. On the website, click on “Manage your account” and then on “Delete your account”.

If you delete your account completely, Instagram will delete posts such as your photos and status updates. Information that other people have shared about you does not belong to your account and is therefore not deleted.

As mentioned above, Instagram stores your data primarily via cookies. You can manage, deactivate or delete these cookies in your browser. Depending on your browser, the management always works a little differently. In the “Cookies” section, you will find the relevant links to the instructions for the most popular browsers.

You can also set up your browser so that you are always informed when a cookie is to be set. Then you can always decide individually whether you want to allow the cookie or not.

Legal basis

If you have consented to your data being processed and stored by integrated social media elements, this consent is the legal basis for data processing (Art. 6 para. 1 lit. a GDPR). In principle, your data is also stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f GDPR) in fast and good communication with you or other customers and business partners. Nevertheless, we only use the integrated social media elements if you have given your consent. Most social media platforms also set cookies in your browser to store data. We therefore recommend that you read our data protection text on cookies carefully and consult the privacy policy or cookie guidelines of the respective service provider.

Instagram also processes your data in the USA, among other places. Instagram or Meta Platforms is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data of EU citizens to the USA. You can find more information on this at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Instagram also uses so-called standard contractual clauses (= Art. 46 (2) and (3) GDPR). Standard Contractual Clauses (SCCs) are templates provided by the EU Commission and are intended to ensure that your data complies with European data protection standards even if it is transferred to third countries (such as the USA) and stored there. Through the EU-US Data Privacy Framework and the Standard Contractual Clauses, Instagram undertakes to comply with the European level of data protection when processing your relevant data, even if the data is stored, processed and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding standard contractual clauses here, among others: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de

We have tried to provide you with the most important information about data processing by Instagram. You can find out more about Instagram’s data policy at https://privacycenter.instagram.com/policy/.

Security & Anti-Spam

Security & Anti-Spam Privacy Policy Summary
๐Ÿ‘ฅ Data subjects: Visitors to the website
๐Ÿค Purpose: Cybersecurity
๐Ÿ““ Processed data: Data such as your IP address, name or technical data such as browser version
More details can be found below and in the individual data protection texts.
๐Ÿ“… Storage period: Most of the data is stored until it is no longer required to provide the service
โš–๏ธ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is security & anti-spam software?

With so-called security and anti-spam software, you and we can protect ourselves from various spam or phishing emails and possible other cyberattacks. Spam refers to advertising emails from a mass mailing that you did not request yourself. Such emails are also known as data junk and can also cause costs. Phishing emails, on the other hand, are messages that aim to build trust via fake messages or websites in order to obtain personal data. Anti-spam software generally protects against unwanted spam messages or malicious emails that could introduce viruses into our system. We also use general firewall and security systems to protect our computers from unwanted network attacks.

Why do we use security & anti-spam software?

We attach great importance to security on our website. After all, it’s not just about our security, but above all about yours. Unfortunately, cyber threats have become part of everyday life in the world of IT and the Internet. Hackers often try to steal personal data from an IT system with the help of a cyber attack. And that is why a good defense system is absolutely essential. A security system monitors all incoming and outgoing connections to our network or computer. To achieve even greater security against cyber attacks, we also use other external security services in addition to the standardized security systems on our computer. This prevents unauthorized data traffic and protects us from cybercrime.

What data is processed by security & anti-spam software?

Exactly which data is collected and stored depends of course on the respective service. However, we always strive to use only programs that collect data very sparingly or only store data that is necessary for the performance of the service offered. In principle, the service may store data such as name, address, IP address, e-mail address and technical data such as browser type or browser version. Any performance and log data may also be collected in order to detect possible incoming threats in good time. This data is processed as part of the services and in compliance with the applicable laws. This also includes the GDPR for US providers (via the standard contractual clauses). In some cases, these security services also work with third-party providers who may store and/or process data under instructions and in accordance with the data protection guidelines and other security measures. Data is usually stored via cookies.

Duration of data processing

We will inform you about the duration of data processing below if we have further information on this. For example, security programs store data until you or we revoke the data storage. In general, personal data is only stored for as long as is absolutely necessary for the provision of the services. Unfortunately, in many cases we do not receive precise information from the providers about the length of storage.

Right of objection

You also have the right and the option to withdraw your consent to the use of cookies or third-party security software at any time. This works either via our cookie management tool or via other opt-out functions. For example, you can also prevent data collection by cookies by managing, deactivating or deleting cookies in your browser.

As such security services may also use cookies, we recommend that you read our general privacy policy on cookies. To find out exactly which of your data is stored and processed, you should read the privacy policies of the respective tools.

Legal basis

We use the security services mainly on the basis of our legitimate interests (Art. 6 para. 1 lit. f GDPR) in a good security system against various cyber attacks.

Certain processing operations, in particular the use of cookies and the use of security functions, require your consent. If you have consented to your data being processed and stored by integrated security services, this consent is the legal basis for data processing (Art. 6 para. 1 lit. a GDPR). Most of the services we use set cookies in your browser to store data. We therefore recommend that you read our data protection text on cookies carefully and view the privacy policy or cookie guidelines of the respective service provider.

Information on special tools – if available – can be found in the following sections.

Google reCAPTCHA privacy policy

Google reCAPTCHA privacy policy summary
๐Ÿ‘ฅ Data subjects: Visitors to the website
๐Ÿค Purpose: Optimization of our service performance and protection against cyber attacks
๐Ÿ““ Processed data: Data such as IP address, browser information, your operating system, limited location and usage data
More details can be found below in this privacy policy.
๐Ÿ“… Storage duration: depending on the stored data
โš–๏ธ Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is reCAPTCHA?

Our primary goal is to secure and protect our website for you and for us in the best possible way. To ensure this, we use Google reCAPTCHA from Google Inc. For the European region, the company Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland) is responsible for all Google services. With reCAPTCHA we can determine whether you are really a flesh and blood person and not a robot or other spam software. By spam we mean any unsolicited information that is sent to us electronically. With the classic CAPTCHAs, you usually had to solve text or picture puzzles to verify your identity. With reCAPTCHA from Google, we don’t usually have to bother you with such puzzles. In most cases, all you have to do is tick a box to confirm that you are not a bot. With the new Invisible reCAPTCHA version, you no longer even have to tick the box. You can find out exactly how this works and, above all, which data is used for this in the course of this privacy policy.

reCAPTCHA is a free captcha service from Google that protects websites from spam software and misuse by non-human visitors. This service is most commonly used when you fill out forms on the Internet. A Captcha service is a type of automatic Turing test that is designed to ensure that an action on the Internet is performed by a human and not by a bot. In the classic Turing test (named after the computer scientist Alan Turing), a human determines the difference between a bot and a human. With captchas, this is also done by a computer or software program. Classic captchas work with small tasks that are easy for humans to solve but present considerable difficulties for machines. With reCAPTCHA, you no longer have to actively solve puzzles. The tool uses modern risk techniques to distinguish humans from bots. All you have to do here is tick the “I am not a robot” text field, and with Invisible reCAPTCHA even this is no longer necessary. With reCAPTCHA, a JavaScript element is integrated into the source code and then the tool runs in the background and analyzes your user behaviour. The software calculates a so-called captcha score from these user actions. Google uses this score to calculate the probability that you are human even before you enter the captcha. reCAPTCHA or captchas in general are always used when bots could manipulate or abuse certain actions (e.g. registrations, surveys, etc.).

Why do we use reCAPTCHA on our website?

We only want to welcome people of flesh and blood on our site. Bots and spam software of all kinds can safely stay at home. That’s why we do everything we can to protect ourselves and offer you the best possible user-friendliness. For this reason, we use Google reCAPTCHA from Google. This way we can be pretty sure that we remain a “bot-free” website. By using reCAPTCHA, data is transmitted to Google to determine whether you are actually a human being. reCAPTCHA therefore serves to ensure the security of our website and, by extension, your security. For example, without reCAPTCHA it could happen that a bot registers as many e-mail addresses as possible during registration in order to subsequently “spam” forums or blogs with unwanted advertising content. With reCAPTCHA, we can prevent such bot attacks.

What data is stored by reCAPTCHA?

reCAPTCHA collects personal data from users in order to determine whether the actions on our website actually originate from people. The IP address and other data that Google requires for the reCAPTCHA service may therefore be sent to Google. IP addresses are almost always truncated within the member states of the EU or other signatory states to the Agreement on the European Economic Area before the data is sent to a server in the USA. The IP address is not combined with other Google data unless you are logged in with your Google account while using reCAPTCHA. First, the reCAPTCHA algorithm checks whether Google cookies from other Google services (YouTube, Gmail, etc.) have already been placed on your browser. Then reCAPTCHA places an additional cookie in your browser and takes a snapshot of your browser window.

The following list of collected browser and user data does not claim to be exhaustive. Rather, they are examples of data that, to our knowledge, are processed by Google.

  • Referrer URL (the address of the page from which the visitor comes)
  • IP address (e.g. 256.123.123.1)
  • Information about the operating system (the software that enables your computer to operate. Common operating systems are Windows, Mac OS X or Linux)
  • Cookies (small text files that store data in your browser)
  • Mouse and keyboard behavior (every action you perform with the mouse or keyboard is saved)
  • Date and language settings (which language or date you have preset on your PC is saved)
  • All JavaScript objects (JavaScript is a programming language that enables websites to adapt to the user. JavaScript objects can collect all kinds of data under one name)
  • Screen resolution (indicates how many pixels the image display consists of)

It is undisputed that Google uses and analyzes this data even before you click on the “I am not a robot” checkbox. With the Invisible reCAPTCHA version, you don’t even have to check the box and the entire recognition process runs in the background. Google does not tell you in detail exactly how much and what data it stores.

The following cookies are used by reCAPTCHA: Here we refer to the reCAPTCHA demo version from Google at https://www.google.com/recaptcha/api2/demo. All these cookies require a unique identifier for tracking purposes. Here is a list of cookies that Google reCAPTCHA has set on the demo version:

Name: IDE
Value: WqTUmlnmv_qXyi_DGNPLESKnRNrpgXoy1K-pAZtAkMbHI-112967475-8
Purpose: This cookie is set by the company DoubleClick (also owned by Google) to register and report the actions of a user on the website in dealing with advertisements. This allows the effectiveness of advertising to be measured and appropriate optimization measures to be taken. IDE is stored in browsers under the domain doubleclick.net.
Expiration date: after one year

Name: 1P_JAR
Value: 2019-5-14-12
Purpose: This cookie collects statistics on website usage and measures conversions. A conversion occurs, for example, when a user becomes a buyer. The cookie is also used to display relevant advertisements to users. The cookie can also be used to prevent a user from seeing the same ad more than once.
Expiration date: after one month

Name: ANID
Wert: U7j1v3dZa1129674750xgZFmiqWppRWKOr
Purpose: We were unable to find out much information about this cookie. In Google’s privacy policy, the cookie is mentioned in connection with “advertising cookies” such as “DSID”, “FLC”, “AID”, “TAID”. ANID is stored under domain google.com.
Expiration date: after 9 months

Name: CONSENT
Value: YES+AT.de+20150628-20-0
Purpose: The cookie stores the status of a user’s consent to the use of various Google services. CONSENT is also used for security purposes to verify users, prevent fraudulent login information and protect user data from unauthorized attacks.
Expiration date: after 19 years

Name: NID
Wert: 0WmuWqy112967475zILzqV_nmt3sDXwPeM5Q
Intended use: NID is used by Google to customize advertisements to your Google searches. With the help of the cookie, Google “remembers” your most frequently entered search queries or your previous interaction with ads. So you always get customized ads. The cookie contains a unique ID to collect the user’s personal settings for advertising purposes.
Expiration date: after 6 months

Name: DV
Wert: gEAABBCjJMXcI0dSAAAANbqc112967475-4
Intended use: As soon as you have checked the “I am not a robot” box, this cookie is set. The cookie is used by Google Analytics for personalized advertising. DV collects information in anonymized form and is also used to make user distinctions.
Expiration date: after 10 minutes

Note: This list cannot claim to be exhaustive, as experience has shown that Google changes its choice of cookies from time to time.

How long and where is the data stored?

By inserting reCAPTCHA, data is transferred from you to the Google server. Where exactly this data is stored is not made clear by Google, even after repeated requests. Without having received confirmation from Google, it can be assumed that data such as mouse interaction, time spent on the website or language settings are stored on the European or American Google servers. The IP address that your browser transmits to Google is not merged with other Google data from other Google services. However, if you are logged into your Google account while using the reCAPTCHA plug-in, the data will be merged. The deviating data protection provisions of Google apply.

How can I delete my data or prevent data storage?

If you do not want any data about you and your behavior to be transmitted to Google, you must log out of Google completely and delete all Google cookies before you visit our website or use the reCAPTCHA software. In principle, the data is automatically transmitted to Google as soon as you visit our website. To delete this data, you must contact Google support at https://support.google.com/?hl=de&tid=112967475.

Therefore, when you use our website, you consent to Google LLC and its representatives automatically collecting, processing and using data.

Please note that when using this tool, your data may also be stored and processed outside the EU. Most third countries (including the USA) are not considered secure under current European data protection law. Data may therefore not simply be transferred to insecure third countries, stored and processed there, unless there are suitable guarantees (such as EU standard contractual clauses) between us and the non-European service provider.

Legal basis

If you have consented to the use of Google reCAPTCHA, the legal basis for the corresponding data processing is this consent. According to Art. 6 para. 1 lit. a GDPR (consent) represents the legal basis for the processing of personal data, as may occur when Google reCAPTCHA is used to collect data.

We also have a legitimate interest in using Google reCAPTCHA to optimize our online service and make it more secure. The legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests) . Nevertheless, we only use Google reCAPTCHA if you have given your consent.

Google also processes your data in the USA, among other places. Google is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA. You can find more information on this at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Google also uses so-called standard contractual clauses (= Art. 46 (2) and (3) GDPR). Standard Contractual Clauses (SCCs) are templates provided by the EU Commission and are intended to ensure that your data complies with European data protection standards even if it is transferred to third countries (such as the USA) and stored there. Through the EU-US Data Privacy Framework and the standard contractual clauses, Google undertakes to comply with the European level of data protection when processing your relevant data, even if the data is stored, processed and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding standard contractual clauses here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de

The Google Ads Data Processing Terms, which refer to the standard contractual clauses, can be found at https://business.safety.google/intl/de/adsprocessorterms/.

You can find out a little more about reCAPTCHA on Google’s web developer page at https://developers.google.com/recaptcha/. Although Google goes into more detail here about the technical development of reCAPTCHA, you will search in vain for precise information about data storage and data protection issues. A good overview of the basic use of data at Google can be found in the company’s own privacy policy at https://policies.google.com/privacy.

Explanation of terms used

We always endeavor to write our privacy policy as clearly and comprehensibly as possible. However, this is not always easy, especially when it comes to technical and legal topics. It often makes sense to use legal terms (such as personal data) or certain technical terms (such as cookies, IP address). However, we do not want to use these without explanation. Below you will find an alphabetical list of important terms used, which we may not have sufficiently addressed in the previous privacy policy. If these terms have been taken from the GDPR and are definitions, we will also quote the GDPR texts here and add our own explanations if necessary.

Processor

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term:

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

Explanation: As a company and website owner, we are responsible for all data that we process from you. In addition to controllers, there may also be so-called processors. This includes any company or person that processes personal data on our behalf. In addition to service providers such as tax consultants, processors can therefore also be hosting or cloud providers, payment or newsletter providers or large companies such as Google or Microsoft.

Consent

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term:

“Consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

Explanation: As a rule, websites obtain such consent via a cookie consent tool. You are probably familiar with this. Whenever you visit a website for the first time, you are usually asked via a banner whether you agree or consent to data processing. In most cases, you can also make individual settings and decide for yourself which data processing you allow and which you do not. If you do not give your consent, your personal data may not be processed. In principle, consent can of course also be given in writing, i.e. not via a tool.

Personal data

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term:

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

Explanation: Personal data is therefore all data that can identify you as a person. This is usually data such as:

  • name
  • Your address
  • E-mail address
  • Postal address
  • Telephone number
  • Date of birth
  • Identification numbers such as social security number, tax identification number, identity card number or matriculation number
  • Bank details such as account number, credit information, account balances, etc.

According to the European Court of Justice (ECJ), your IP address is also considered personal data. IT experts can use your IP address to determine at least the approximate location of your device and, subsequently, you as the owner of the connection. Therefore, the storage of an IP address also requires a legal basis within the meaning of the GDPR. There are also so-called “special categories” of personal data, which are also particularly worthy of protection. These include

  • racial and ethnic origin
  • political opinions
  • religious or ideological convictions
  • trade union membership
  • genetic data, such as data taken from blood or saliva samples
  • biometric data (i.e. information on mental, physical or behavioral characteristics that can identify a person).
    Health data
  • Data on sexual orientation or sexual life

Profiling

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term:

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

Explanation: Profiling involves collecting various pieces of information about a person in order to find out more about them. In the web sector, profiling is often used for advertising purposes or for credit checks. For example, web and advertising analysis programs collect data about your behavior and interests on a website. This results in a special user profile that can be used to target advertising to a specific target group.

Person responsible

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term:

“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; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

Explanation: In our case, we are responsible for the processing of your personal data and are therefore the “controller”. If we pass on collected data to other service providers for processing, they are “processors”. An “order processing contract (AVV)” must be signed for this.

Processing

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term:

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

Note: When we refer to processing in our privacy policy, we mean any kind of data processing. As mentioned above in the original GDPR declaration, this includes not only the collection but also the storage and processing of data.

Closing words

Congratulations! If you are reading this, you have really “fought” your way through our entire privacy policy, or at least scrolled this far. As you can see from the scope of our privacy policy, we do not take the protection of your personal data lightly.
It is important to us to inform you about the processing of personal data to the best of our knowledge and belief. However, we not only want to tell you what data is processed, but also explain the reasons for using various software programs. As a rule, privacy policies sound very technical and legal. However, as most of you are not web developers or lawyers, we wanted to take a different approach in terms of language and explain the facts in simple and clear language. Of course, this is not always possible due to the subject matter. The most important terms are therefore explained in more detail at the end of the privacy policy.
If you have any questions about data protection on our website, please do not hesitate to contact us or the responsible body. We wish you a pleasant time and hope to welcome you back to our website soon.

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Source: Privacy Policy created with the Privacy Policy Generator for Austria by AdSimple