Auktionshaus Ulrich Felzmann
privacy policy
preamble
With the following data protection declaration, we would like to inform you about which types of your personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent. This data protection declaration applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offering").
The terms used are not gender-specific.
As of May 30, 2023
table of contents
preamble
responsible person
Contact Data Protection Officer
Overview of processing
Relevant legal bases
security measures
transmission of personal data
deletion of data
use of cookies
Business Services
provision of the online offer and web hosting
blogs and publication media
contact and inquiry management
newsletters and electronic notifications
Advertising communication via email, post, fax or telephone
sweepstakes and competitions
surveys and polls
web analysis, monitoring and optimization
Presences in social networks (social media)
Plugins and embedded functions and content
Change and update of the privacy policy
rights of the data subjects
definitions of terms
responsible person
Auktionshaus
Ulrich Felzmann
GmbH & Co. KG
Immermannstr. 51
40210 Düsseldorf
Authorized representatives:
Dr. Reinhard Fischer, Managing Director
Email address:
info@felzmann.de
Phone:
+49 (0) 211 – 550 440
Imprint:
Impressum
Impressum Auktionshaus Ulrich Felzmann GmbH & Co. KG. Vertreten durch: Dr. Reinhard Fischer, Geschäftsführer
Contact Data Protection Officer
Data protection officer:
Hans-Jürgen Zieger
datenschutz@felzmann.de
Overview of processing
The following overview summarises the types of data processed and the purposes of their processing and refers to the persons concerned.
types of data processed
inventory data.
payment details.
location data.
contact details.
content data.
contract data.
usage data.
Meta-, communication- and procedural data.
Event data (Facebook).
categories of data subjects
Customers.
interested parties.
communication partner.
users.
prize draw and competition participants.
business and contractual partners.
Participant.
purposes of processing
Provision of contractual services and customer service.
contact requests and communication.
security measures.
direct marketing.
reach measurement.
tracking.
office and organizational procedures.
Managing and responding to inquiries.
Conducting prize draws and competitions.
feedback.
Marketing.
Profiles with user-related information.
Provision of our online offering and user-friendliness.
Information technology infrastructure.
Relevant legal bases
Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.
Consent (Article 6 (1) sentence 1 lit. a) GDPR) – The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
Contract performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR) – The processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.
Legal obligation (Article 6 (1) sentence 1 lit. c) GDPR) – The processing is necessary to fulfill a legal obligation to which the controller is subject.
Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR) – Processing is necessary to protect the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject which require protection of personal data prevail.
In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes in particular the law on protection against misuse of personal data in data processing (Federal Data Protection Act - BDSG). The BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission and automated decision-making in individual cases, including profiling. It also regulates data processing for the purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. In addition, state data protection laws of the individual federal states may apply.
security measures
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, to ensure a level of protection appropriate to the risk.
The measures include in particular ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, transfer, securing availability and separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to threats to data. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
Shortening of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not necessary, the IP address is shortened (also known as "IP masking"). The last two digits or the last part of the IP address after a period are removed or replaced by placeholders. The shortening of the IP address is intended to prevent or significantly complicate the identification of a person based on their IP address.
TLS encryption (https): We use TLS encryption to protect the data you transmit via our online service. You can recognize encrypted connections of this type by the prefix https:// in the address bar of your browser.
transmission of personal data
As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons or that it is disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.
Data transfer within the organization: We may transfer personal data to other departments within our organization or grant them access to this data. If this transfer is for administrative purposes, the data is transferred based on our legitimate business and commercial interests or if it is necessary to fulfill our contractual obligations or if there is consent from the data subject or legal permission.
deletion of data
The data we process is deleted in accordance with legal requirements as soon as the consents to processing are revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or it is no longer required for the purpose). If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.
Our data protection notices may also contain further information on the storage and deletion of data, which apply primarily to the respective processing operations.
use of cookies
Cookies are small text files or other storage notes that store information on end devices and read information from the end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed or the functions used in an online service. Cookies can also be used for different purposes, e.g. to ensure the functionality, security and convenience of online services and to create analyses of visitor flows.
Notes on consent: We use cookies in accordance with legal regulations. We therefore obtain prior consent from users, unless this is not required by law. Consent is not necessary in particular if the storage and reading of information, including cookies, is absolutely necessary in order to provide users with a telemedia service expressly requested by them (i.e. our online offering). Strictly necessary cookies generally include cookies with functions that serve to display and operate the online offering, load balancing, security, storing user preferences and choices, or similar purposes related to providing the main and secondary functions of the online offering requested by users. Revocable consent is clearly communicated to users and contains information about the respective cookie usage.
Notes on data protection legal bases: The data protection legal basis on which we process users' personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and improving its usability) or, if this is done as part of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We will explain the purposes for which we process cookies in the course of this data protection declaration or as part of our consent and processing processes.
Storage period: With regard to the storage period, the following types of cookies are distinguished:
Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed his or her device (e.g. browser or mobile application).
Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The user data collected using cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.
General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also object to processing in accordance with the legal requirements in Art. 21 GDPR. Users can also declare their objection via the settings of their browser, e.g. by deactivating the use of cookies (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ .
Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
Complianz: Cookie consent management; Service provider: Hosted locally on our server, no data passed on to third parties; Website: https://complianz.io/ ; Privacy policy: https://complianz.io/legal/ ; Further information: An individual user ID, language as well as types of consent and the time of their submission are stored on the server side and in the cookie on the user's device.
Business Services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) within the framework of contractual and comparable legal relationships as well as related measures and within the framework of communication with the contractual partners (or pre-contractually), e.g. to answer inquiries.
We process this data in order to fulfil our contractual obligations. This includes in particular the obligations to provide the agreed services, any updating obligations and remedy in the event of warranty and other service disruptions. In addition, we process the data to protect our rights and for the purposes of the administrative tasks associated with these obligations and the company organization. In addition, we process the data on the basis of our legitimate interests in proper and economical business management and in security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. The contractual partners are informed about other forms of processing, e.g. for marketing purposes, in the context of this data protection declaration.
We inform our contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by special marking (e.g. colours) or symbols (e.g. asterisks or similar), or in person.
We delete the data after statutory warranty and similar obligations have expired, i.e., generally after 4 years, unless the data is saved in a customer account, e.g. as long as it must be kept for legal archiving reasons. The statutory retention period is ten years for documents relevant for tax purposes as well as for commercial books, inventories, opening balance sheets, annual financial statements, the work instructions required to understand these documents and other organizational documents and accounting documents, and six years for received commercial and business letters and reproductions of sent commercial and business letters. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, opening balance sheet, annual financial statements or management report was drawn up, the commercial or business letter was received or sent, or the accounting document was created, the recording was made or the other documents were created.
To the extent that we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply to the relationship between the users and the providers.
Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. e-mail, telephone numbers); contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
Affected persons: customers; interested parties; business and contractual partners.
Purposes of processing: provision of contractual services and customer service; security measures; contact requests and communications; office and organizational procedures; administration and response to requests.
Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR); Legal obligation (Art. 6 Para. 1 Clause 1 Letter c) GDPR); Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).
Further information on processing procedures, methods and services:
Shop and e-commerce: We process our customers' data to enable them to select, purchase or order the selected products, goods and associated services, as well as to pay for and deliver or execute them. If necessary to execute an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution for our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such in the order or comparable purchase process and includes the information required for delivery, provision and billing, as well as contact information in order to be able to hold any consultations; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).
provision of the online offer and web hosting
We process user data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or device.
Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status); content data (e.g. entries in online forms).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of our online offer and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); Security measures.
Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files". The server log files can include the address and name of the websites and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (particularly in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR); Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that needs to be retained for evidentiary purposes will not be deleted until the incident in question has been finally resolved.
E-mail sending and hosting: The web hosting services we use also include the sending, receiving and storing of e-mails. For these purposes, the addresses of the recipients and senders as well as other information regarding the e-mail sending (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data can also be processed for the purposes of detecting SPAM. Please note that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We cannot therefore accept any responsibility for the transmission path of the e-mails between the sender and the reception on our server; legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
blogs and publication media
We use blogs or similar means of online communication and publication (hereinafter "publication medium"). Readers' data is only processed for the purposes of the publication medium to the extent that it is necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium in the context of this data protection notice.
Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of contractual services and customer service; feedback (e.g. collecting feedback via online form); provision of our online offer and user-friendliness; security measures; administration and response to inquiries.
Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
Comments and contributions: When users leave comments or other contributions, their IP addresses can be stored on the basis of our legitimate interests. This is done for our security in case someone leaves illegal content in comments and contributions (insults, prohibited political propaganda, etc.). In this case, we ourselves can be held liable for the comment or contribution and are therefore interested in the identity of the author. Furthermore, we reserve the right to process the user's information for the purpose of spam detection on the basis of our legitimate interests. On the same legal basis, we reserve the right to store the IP addresses of users for the duration of surveys and to use cookies to avoid multiple voting. The personal information provided in the context of comments and contributions, any contact and website information as well as the content information will be stored by us permanently until the user objects; legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).
Access to WordPress emojis and smileys: Access to WordPress emojis and smileys - Within our WordPress blog, graphic emojis (or smileys), i.e. small graphic files that express emotions, are used for the purpose of efficiently integrating content elements, obtained from external servers. The server providers collect the IP addresses of the users. This is necessary so that the emoji files can be transmitted to the users' browsers; Service provider: Aut O'Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR); Website: https://automattic.com ; Data protection declaration: https://automattic.com/privacy .
Akismet anti-spam check: Akismet anti-spam check - We use the "Akismet" service based on our legitimate interests. Akismet is used to distinguish between real people's comments and spam comments. All comment details are sent to a server in the USA, where they are analyzed and stored for four days for comparison purposes. If a comment is classified as spam, the data is stored beyond this time. This information includes the name entered, the email address, the IP address, the comment content, the referrer, information on the browser used, the computer system and the time of entry. Users are welcome to use pseudonyms or refrain from entering their name or email address. You can prevent the transmission of data completely by not using our comment system. That would be a shame, but unfortunately we don't see any alternatives that work just as effectively; Service provider: Aut O'Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR); Website: https://automattic.com ; Privacy Policy: https://automattic.com/privacy .
UpdraftPlus: backup software and backup storage; service provider: Simba Hosting Ltd., 11, Barringer Way, St. Neots, Cambs., PE19 1LW, GB; legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR); website: https://updraftplus.com/ ; data protection declaration: https://updraftplus.com/data-protection-and-privacy-centre/ .
contact and inquiry management
When you contact us (e.g. by post, contact form, e-mail, telephone or via social media) and within the framework of existing user and business relationships, the information provided by the inquiring persons is processed to the extent necessary to answer the contact inquiries and any requested measures.
Types of data processed: contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
Data subjects: communication partners.
Purposes of processing: contact requests and communication; administration and response to inquiries; feedback (e.g. collecting feedback via online form); provision of our online offer and user-friendliness.
Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR); Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).
Further information on processing procedures, methods and services:
Contact form: If users contact us via our contact form, email or other communication channels, we process the data communicated to us in this context to process the communicated request; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
newsletters and electronic notifications
We only send newsletters, emails and other electronic notifications (hereinafter "newsletters") with the consent of the recipient or with legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user's consent. Otherwise, our newsletters contain information about our services and us.
To subscribe to our newsletter, it is generally sufficient to provide your email address. However, we may ask you to provide a name for the purpose of addressing you personally in the newsletter or other information if this is necessary for the purposes of the newsletter.
Double opt-in procedure: Registration for our newsletter is always carried out using a so-called double opt-in procedure. This means that after registration you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register using someone else's email address. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider are also logged.
Deletion and restriction of processing: We can store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address in a block list (so-called "block list") for this purpose alone.
The registration process is logged on the basis of our legitimate interests for the purpose of proving that it was carried out correctly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure shipping system.
Contents:
Information about us, our services, promotions and offers.
Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status); usage data (e.g. websites visited, interest in content, access times).
Data subjects: communication partners.
Purposes of processing: direct marketing (e.g. by e-mail or post).
Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR).
Opt-out option: You can cancel your subscription to 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 use one of the contact options listed above, preferably email.
Further information on processing procedures, methods and services:
Measuring opening and click rates: The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from its server. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, is initially collected. This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. The evaluations help us to recognize the reading habits of our users and adapt our content to them or to send different content according to the interests of our users. The measurement of opening rates and click rates as well as storage of the measurement results in the user profiles; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Advertising communication via email, post, fax or telephone
We process personal data for the purposes of advertising communication, which can take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.
The recipients have the right to revoke consent given or to object to advertising communication at any time.
After revocation or objection, we store the data required to prove previous authorization for contacting or sending for up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. On the basis of the legitimate interest in permanently respecting the user's revocation or objection, we also store the data required to avoid further contact (e.g., depending on the communication channel, the email address, telephone number, name).
Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers).
Data subjects: communication partners.
Purposes of processing: direct marketing (e.g. by e-mail or post).
Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR); Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
sweepstakes and competitions
We only process personal data of participants in prize draws and competitions in compliance with the relevant data protection regulations, insofar as the processing is contractually necessary for the provision, implementation and processing of the prize draw, the participants have consented to the processing or the processing serves our legitimate interests (e.g. in the security of the prize draw or the protection of our interests against misuse through possible collection of IP addresses when submitting prize draw entries).
If entries from participants are published as part of the competition (e.g. as part of a vote or presentation of the competition entries or the winners or reporting on the competition), we would like to point out that the names of the participants may also be published in this context. Participants can object to this at any time.
If the competition takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as the "online platform"), the terms of use and data protection provisions of the respective platforms also apply. In these cases, we would like to point out that we are responsible for the information provided by participants as part of the competition and that inquiries regarding the competition should be directed to us.
Participants' data will be deleted as soon as the prize draw or competition has ended and the data is no longer required to inform the winners or because queries about the prize draw are expected. Participants' data will generally be deleted no later than 6 months after the end of the prize draw. Winners' data may be retained for longer, for example to answer queries about the prizes or to fulfill the prize-winning services; in this case, the retention period depends on the type of prize and is up to three years for items or services, for example, in order to process warranty claims. Participants' data may also be stored for longer, for example in the form of reports on the prize draw in online and offline media.
If data was collected for other purposes as part of the competition, its processing and the retention period are governed by the data protection information for this use (e.g. in the case of registration for the newsletter as part of a competition).
Types of data processed: inventory data (e.g. names, addresses); content data (e.g. entries in online forms); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
Affected persons: participants in prize draws and competitions.
Purpose of processing: Conducting prize draws and competitions.
Legal basis: Contractual performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR).
surveys and polls
We conduct surveys and questionnaires to collect information for the respective communicated survey or questionnaire purpose. The surveys and questionnaires we conduct (hereinafter "surveys") are evaluated anonymously. Personal data is only processed to the extent that this is necessary for the provision and technical implementation of the surveys (e.g. processing the IP address in order to display the survey in the user's browser or to enable the survey to be resumed using a cookie).
Types of data processed: contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
Persons affected: communication partners; participants.
Purposes of processing: Feedback (e.g. collecting feedback via online form).
Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
web analysis, monitoring and optimization
Web analysis (also known as "reach measurement") is used to evaluate the flow of visitors to our online offering and can include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at what time our online offering or its functions or content are most frequently used or invite reuse. We can also understand which areas require optimization.
In addition to web analysis, we can also use testing procedures to test and optimize, for example, different versions of our online offering or its components.
Unless otherwise stated below, profiles, i.e. data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in a device and read from it. The information collected includes in particular websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to us or the providers of the services we use collecting their location data, location data can also be processed.
The IP addresses of the users are also stored. However, we use an IP masking process (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored as part of web analysis, A/B testing and optimization, but rather pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.
Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles); tracking (e.g. interest/behavior-related profiling, use of cookies); provision of our online offer and user-friendliness.
Security measures: IP masking (pseudonymization of the IP address).
Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR).
Further information on processing procedures, methods and services:
Google Analytics: web analysis, reach measurement and measurement of user flows; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); website: https://marketingplatform.google.com/intl/de/about/analytics/ ; privacy policy: https://policies.google.com/privacy ; order processing agreement: https://business.safety.google/adsprocessorterms ; standard contractual clauses (guaranteeing data protection level when processing in third countries): https://business.safety.google/adsprocessorterms ; possibility of objection (opt-out): opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de , settings for the display of advertisements: https://adssettings.google.com/authenticated ; Further information: https://privacy.google.com/businesses/adsservices (types of processing and data processed).
Presences in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for users because it could, for example, make it more difficult to enforce user rights.
Furthermore, the data of users within social networks is usually processed for market research and advertising purposes. For example, user profiles can be created based on the user's usage behavior and the resulting interests. The user profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the user's interests. For these purposes, cookies are usually stored on the user's computers in which the user's usage behavior and interests are stored. Furthermore, data can also be stored in the user profiles regardless of the devices used by the user (especially if the users are members of the respective platforms and are logged in to them).
For a detailed description of the respective processing methods and the options for objection (opt-out), please refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the user data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
Types of data processed: contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: contact requests and communication; feedback (e.g. collecting feedback via online form); marketing.
Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
Instagram: social network; service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR); website: https://www.instagram.com ; privacy policy: https://instagram.com/about/legal/privacy .
Facebook Pages: Profiles within the social network Facebook - We are jointly responsible with Meta Platforms Ireland Limited for collecting (but not further processing) data from visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see "Things you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/policy ), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see "Device information" in the Facebook Data Policy: https://www.facebook.com/policy ). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services called "Page Insights" to page operators so that they can gain insights into how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook (“Information on Page Insights”, https://www.facebook.com/legal/terms/page_controller_addendum ), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of those affected (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular the right to information, deletion, objection and complaint to the responsible supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information on Page Insights” ( https://www.facebook.com/legal/terms/information_about_page_insights_data ); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR); Website: https://www.facebook.com ; Privacy Policy: https://www.facebook.com/about/privacy ; Standard contractual clauses (ensuring data protection level when processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum ; Further information: Agreement on joint responsibility: https://www.facebook.com/legal/terms/information_about_page_insights_data. The joint controllership is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular the transmission of the data to the parent company Meta Platforms, Inc. in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
LinkedIn: social network; service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR); website: https://www.linkedin.com ; privacy policy: https://www.linkedin.com/legal/privacy-policy ; contract processing agreement: https://legal.linkedin.com/dpa ; standard contractual clauses (guaranteeing data protection level when processing in third countries): https://legal.linkedin.com/dpa ; option to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out .
YouTube: social network and video platform; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR); data protection declaration: https://policies.google.com/privacy ; possibility of objection (opt-out): https://adssettings.google.com/authenticated .
Xing: social network; service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); website: https://www.xing.de ; data protection declaration: https://privacy.xing.com/de/datenschutzerklaerung .
Plugins and embedded functions and content
We incorporate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may include, for example, graphics, videos or city maps (hereinafter referred to uniformly as "content").
The integration always requires that the third-party providers of this content process the IP address of the user, since without the IP address they would not be able to send the content to their browser. The IP address is therefore required to display this content or functions. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers can also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user's device and can contain, among other things, technical information about the browser and operating system, referring websites, the time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.
Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status); inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); location data (information on the geographical position of a device or person); Event data (Facebook) ("Event data" is data that we can transmit to Facebook, for example via Facebook pixel (via apps or other means) and that relates to people or their actions; the data includes, for example, information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.; the event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); event data does not contain the actual content (such as comments written), login information, or contact information (i.e. no names, email addresses, or phone numbers). Event data is deleted by Facebook after a maximum of two years, and the target groups created from it when our Facebook account is deleted).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of our online offer and user-friendliness; marketing; profiles with user-related information (creation of user profiles).
Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR).
Further information on processing procedures, methods and services:
Facebook plugins and content: Facebook social plugins and content – This can include content such as images, videos or texts and buttons that users can use to share content from this website within Facebook. The list and appearance of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/ – We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt during a transmission (but not the further processing) of “event data” that Facebook collects using the Facebook social plugins (and content embedding functions) that run on our website or receives during a transmission for the following purposes: a) displaying content and advertising information that corresponds to the presumed interests of users; b) delivering commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) Improving ad delivery and personalizing functions and content (e.g. improving the recognition of which content or advertising information presumably corresponds to the interests of users). We have concluded a special agreement with Facebook ("Addendum for Controllers", https://www.facebook.com/legal/controller_addendum ), which regulates in particular which security measures Facebook must observe ( https://www.facebook.com/legal/terms/data_security_terms ) and in which Facebook has agreed to fulfill the rights of those affected (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with measurements, analyses and reports (which are aggregated, i.e. do not contain any information about individual users and are anonymous to us), then this processing does not take place within the framework of joint responsibility, but on the basis of a data processing agreement ("Data Processing Terms", https://www.facebook.com/legal/terms/dataprocessing ), the "Data Security Terms" ( https://www.facebook.com/legal/terms/data_security_terms ) and, with regard to processing in the USA, on the basis of standard contractual clauses ("Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum ). The rights of users (in particular the right to information, deletion, objection and complaint to the responsible supervisory authority) are not restricted by the agreements with Facebook; service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.facebook.com ; Privacy Policy: https://www.facebook.com/about/privacy .
Font Awesome (provision on own server): display of fonts and symbols; service provider: the Font Awesome icons are hosted on our server, no data is transmitted to the provider of Font Awesome; legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Google Maps: We integrate the maps of the “Google Maps” service provided by Google. The data processed may include, in particular, IP addresses and location data of users; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR); Website: https://mapsplatform.google.com/ ; Privacy Policy: https://policies.google.com/privacy .
Instagram plugins and content: Instagram plugins and content – This can include, for example, content such as images, videos or texts and buttons that users can use to share content from this website within Instagram. – We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt during a transmission (but not the further processing) of “event data” that Facebook collects using Instagram functions (e.g. embedding functions for content) that are executed on our website or receives during a transmission for the following purposes: a) Displaying content and advertising information that corresponds to the presumed interests of users; b) Delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) Improving ad delivery and personalizing functions and content (e.g. improving the recognition of which content or advertising information presumably corresponds to the interests of users). We have concluded a special agreement with Facebook (“Addendum for Controllers”, https://www.facebook.com/legal/controller_addendum ), which regulates in particular which security measures Facebook must observe ( https://www.facebook.com/legal/terms/data_security_terms ) and in which Facebook has agreed to fulfill the rights of those affected (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with measurements, analyses and reports (which are aggregated, i.e. do not contain any information about individual users and are anonymous to us), then this processing does not take place within the framework of joint responsibility, but on the basis of a data processing agreement ("Data Processing Terms", https://www.facebook.com/legal/terms/dataprocessing ), the "Data Security Terms" ( https://www.facebook.com/legal/terms/data_security_terms ) and, with regard to processing in the USA, on the basis of standard contractual clauses ("Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum ). The rights of users (in particular the right to information, deletion, objection and complaint to the responsible supervisory authority) are not restricted by the agreements with Facebook; service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR); Website: https://www.instagram.com ; Privacy Policy: https://instagram.com/about/legal/privacy .
LinkedIn plugins and content: LinkedIn plugins and content - This can include, for example, content such as images, videos or texts and buttons that users can use to share content from this online offering within LinkedIn; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.linkedin.com ; Privacy policy: https://www.linkedin.com/legal/privacy-policy ; Contract processing agreement: https://legal.linkedin.com/dpa ; Standard contractual clauses (guaranteeing data protection level when processing in third countries): https://legal.linkedin.com/dpa ; Possibility of objection (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out .
YouTube videos: video content; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR); website: https://www.youtube.com ; privacy policy: https://policies.google.com/privacy ; possibility of objection (opt-out): opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de , settings for the display of advertisements: https://adssettings.google.com/authenticated .
YouTube videos: video content; YouTube videos are embedded via a special domain (recognizable by the component “youtube-nocookie”) in the so-called “extended data protection mode”, which means that no cookies are collected on user activities in order to personalize video playback. Nevertheless, information on the user’s interaction with the video (e.g. remembering the last playback point) can be stored; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR); website: https://www.youtube.com ; data protection declaration: https://policies.google.com/privacy .
We use https://www.yumpu.com/ from i-magazine AG (Gewerbestrasse 3, 9444 Diepoldsau, CH) on our website. Yumpu provides a digital platform for publishing magazines, brochures or catalogs.
You can find the privacy policy and cookie policy of Yumpu (i-magazine AG) here:
Yumpu privacy policy: https://www.yumpu.com/de/info/privacy_policy
Yumpu cookie policy: https://www.yumpu.com/de/info/cookie_policy
Change and update of the privacy policy
We ask you to regularly inform yourself about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting us.
rights of the data subjects
As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:
Right to object: You have the right to object at any time to the processing of personal data concerning you which is carried out on the basis of Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you are processed in order to conduct direct advertising, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct advertising.
Right to withdraw consent: You have the right to withdraw consent at any time.
Right to information: You have the right to request confirmation as to whether data concerning you is being processed and to request information about this data as well as further information and a copy of the data in accordance with legal requirements.
Right to rectification: You have the right, in accordance with the statutory provisions, to request that the data concerning you be completed or that inaccurate data concerning you be rectified.
Right to erasure and restriction of processing: You have the right, in accordance with the statutory provisions, to request that data concerning you be erased immediately or, alternatively, to request that the processing of the data be restricted in accordance with the statutory provisions.
Right to data portability: You have the right to receive the data concerning you that you have made available to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transmitted to another controller.
Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right 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 concerning you violates the provisions of the GDPR.
The supervisory authority responsible for us:
State Commissioner for Data Protection and Freedom of Information North Rhine-Westphalia
Kavalleriestr. 2-4
40213 Düsseldorf
Telephone: 0211/38424-0
Fax: 0211/38424-999
E-mail: poststelle@ldi.nrw.de
definitions of terms
This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined primarily in Art. 4 GDPR. The legal definitions are binding. The following explanations, however, are primarily intended to help you understand. The terms are sorted alphabetically.
Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “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 (e.g. a cookie) or to one or more special characteristics that express the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any type of automated processing of personal data that consists in using this personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information relating to demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, recognize at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
Location data: Location data is generated when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, a WLAN or similar technical intermediaries and location determination functions. Location data is used to indicate the geographically definable position on earth of the respective device. Location data can be used, for example, to display map functions or other location-dependent information.
Tracking: “Tracking” is when the behavior of users can be tracked across multiple online offerings. As a rule, behavior and interest information relating to the online offerings used is stored in cookies or on servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to show users advertisements that are likely to correspond to their interests.
Controller: The “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of processing personal data.
Processing: “Processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it collection, evaluation, storage, transmission or deletion.
