Privacy

Privacy policy

Introduction

With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as “data” for short) that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part 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 the “Online Offer”).

The terms used are not gender-specific.

Status: February 17, 2024

Table of contents

  • Introduction
  • Person responsible
  • Overview of processing operations
  • Applicable legal basis
  • Security measures
  • Transfer of personal data
  • Data processing in third countries
  • Deletion of data
  • Use of cookies
  • Provision of the online offer and web hosting
  • Blogs and publication media
  • Contact and inquiry management
  • Web analysis, monitoring and optimization
  • Online marketing
  • Affiliate programs and affiliate links
  • Presence in social networks (social media)
  • Plugins and embedded functions and content
  • Modification and updating of the privacy policy
  • Rights of data subjects
  • Definitions

Responsible

ADULT UNIVERSE LTD.

Rua 31 de Janeiro, N. 12 e – 6 Andar,

Porta X 9050-011 Funchal

E-Mail-Adresse:

hey@all-actresses.com

Overview of processing operations

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

  • Inventory data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta/communication data.

Categories of data subjects

  • Communication partners.
  • Users.

Purposes of processing

  • Provision of contractual services and customer service.
  • Contact requests and communication.
  • Security measures.
  • Reach measurement.
  • Affiliate tracking.
  • Managing and responding to inquiries.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online services and user experience.

Relevant legal bases

Below you will find an overview of the legal bases of the DSGVO, 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. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO) – The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
  • Performance of a contract and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO) – Processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures carried out at the data subject’s request.
  • Legal obligation (Art. 6 (1) p. 1 lit. c. DSGVO) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 (1) p. 1 lit. f. DSGVO) – Processing is necessary for the purposes of the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, 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, as well as automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for employment purposes (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. Furthermore, 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, in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data, and responses to data compromise. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software as well as procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

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

Transmission of personal data

In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. 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 comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

Data processing in third countries

If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies, this will only be done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not necessary for the purpose).

If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. I.e., the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.

Our data protection notices may also contain further information on the retention and deletion of data, which will take precedence for the respective processing operations.

Use of cookies

Cookies are small text files, or other memory notes, which store information on end devices and read information from the end devices. For example, to store the login status in a user account, a shopping cart content in an e-shop, the content accessed or functions used of an online offer. Cookies can further be used for various purposes, e.g. for purposes of functionality, security and comfort of online offers as well as the creation of analyses of visitor flows.

Notes on consent: We use cookies in accordance with legal requirements. Therefore, we obtain prior consent from users except where it is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary to provide the user with a telemedia service (i.e., our online offering) that they have expressly requested. The revocable consent is clearly communicated to the users and contains the information on the respective cookie use.

Notes on legal bases under data protection law: the legal basis under data protection law on which we process users’ personal data using 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 a business operation of our online offer and improvement of its usability) or, if this is done in the context of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. For what purposes the cookies are processed by us, we clarify in the course of this privacy policy or in the context of our consent and processing procedures.

Storage duration: With regard to the storage duration, 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 offer and closed his end device (e.g. browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the end 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. Likewise, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., as part of 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 file an objection to processing in accordance with the legal requirements in Art. 21 DSGVO (further information on objection is provided as part of this privacy policy). Users can also declare their objection using the settings of their browser.

Further notes on processing processes, procedures and services:

  • Processing of cookie data based on consent: We use a cookie consent management procedure, under which the consent of users to the use of cookies, or the processing operations and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users. Here, the declaration of consent is stored in order not to have to repeat its query and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies), in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. Here, a pseudonymous user identifier is formed and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used.

Cookie consent with Complianz

Our website uses the cookie consent technology of “Complianz GDPR/CCPA Cookie Consent“ to obtain your consent to store certain cookies in your browser and to document this in a data protection compliant manner. The provider of this technology is Complianz B.V., Atoomweg 6b, 9743 AK Groningen, Netherlands (hereinafter Complianz).

When you enter our website, a Complianz cookie is stored in your browser, in which the consents you have given or the revocation of these consents are stored.

The data collected will be stored until you request us to delete it or delete the Complianz cookie yourself, or until the purpose for storing the data no longer applies. Mandatory legal retention periods remain unaffected. Details on Complianz’s data processing can be found at https://complianz.io/privacy-statement.

Complianz cookie consent technology is used to obtain the legally required consent for the use of cookies. The legal basis for this is Art. 6 para. 1 p. 1 lit. c DSGVO.

Provision of the online offer and web hosting

In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services.

The data processed as part of the provision of the hosting offer may include all information relating to the users of our online offer, which is generated as part of the use and communication. This regularly includes the IP address, which is necessary to deliver the content of online offers to browsers, and all entries made within our online offer or from websites.

  • Types of data processed: Content data (e.g. entries in online forms); Usage data (e.g. web pages visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: provision of our online offer and user-friendliness; provision of contractual services and customer service.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Further notes on processing processes, procedures and services:

  • Collection of access data and log files: we ourselves (or our web hosting provider) collect data on each access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume 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 may be used, on the one hand, for security purposes, e.g., to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability; deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.
  • WordPress.com: hosting platform for blogs / websites; service provider: Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA; Website: https://wordpress.com; Privacy policy:https: //automattic.com/de/privacy/; Order processing agreement: concluded with provider: https: //wordpress.com/support/data-processing-agreements/.
  • ALL-INKL: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacity); Service provider: ALL-INKL.COM – Neue Medien Münnich, Owner: René Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany; Website: https://all-inkl.com/; Privacy policy:https: //all-inkl.com/datenschutzinformationen/; Order processing contract: concluded with provider .

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data are processed for the purposes of the publication medium only to the extent 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 within the scope 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 data (e.g., device information, IP addresses).
  • 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); security measures; provision of our online offer and user-friendliness; administration and response to inquiries.
  • Legal grounds: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO); legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Further notes on processing operations, procedures and services:

  • Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author. Furthermore, we reserve the right, on the basis of our legitimate interests, to process users’ details for the purpose of spam detection. On the same legal basis, we reserve the right, in the case of surveys, to store the IP addresses of users for their duration and to use cookies to avoid multiple votes. The personal information provided in the context of comments and contributions, any contact and website information as well as the content-related information will be stored permanently by us until the user objects.
  • Akismet anti-spam check: Akismet anti-spam check – We use the “Akismet” service based on our legitimate interests. With the help of Akismet, comments from real people are distinguished from spam comments. For this purpose, 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 has been classified as spam, the data is stored beyond this time. This information includes the name entered, the e-mail address, the IP address, the comment content, the referrer, information about the browser used as well as the computer system and the time of the entry. Users are welcome to use pseudonyms or to refrain from entering their name or email address. You can completely prevent the transfer of data by not using our commenting system. That would be a shame, but unfortunately we don’t see any alternatives that work as effectively; Service Provider: Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA; Website: https://automattic.com; Privacy policy: https://automattic.com/privacy.
  • Profile pictures from Gravatar: Profile pictures – We use the service Gravatar within our online offer and especially in the blog. Gravatar is a service where users can register and store profile pictures and their e-mail addresses. If users leave posts or comments on other online presences (especially blogs) with the respective e-mail address, their profile pictures can be displayed next to the posts or comments. For this purpose, the e-mail address provided by users is transmitted to Gravatar in encrypted form for the purpose of checking whether a profile is stored for it. This is the sole purpose of the transmission of the email address. It is not used for other purposes, but is deleted afterwards. The use of Gravatar is based on our legitimate interests, as we use Gravatar to offer post and comment authors the opportunity to personalize their posts with a profile picture. By displaying the images, Gravatar obtains the IP address of users, as this is necessary for a communication between a browser and an online service. If users do not want a user image associated with their email address on Gravatar to appear in the comments, they should use an email address that is not on file with Gravatar to comment. We also point out that it is also possible to use an anonymous email address or no email address at all if users do not want their email address to be sent to Gravatar. Users can completely prevent the transmission of data by not using our commenting system; service provider: Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA; 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, UK; website:https: //updraftplus.com/; privacy policy:https: //updraftplus.com/data-protection-and-privacy-centre/.
  • Wordfence: firewall and security and error detection features; service provider: Defiant, Inc, 800 5th Ave Ste 4100, Seattle, WA 98104, USA; website: https://www.wordfence.com; privacy policy:https: //www.wordfence.com/privacy-policy/; standard contractual clauses (ensuring level of data protection for processing in third countries): https://www.wordfence.com/standard-contractual-clauses/.

Contact and inquiry management

When contacting us (e.g. via contact form, email, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

The response to the contact inquiries as well as the management of contact and inquiry data in the context of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to respond to (pre)contractual inquiries and otherwise on the basis of legitimate interests in responding to the inquiries and maintaining user or business relationships.

  • 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).
  • Data subjects: Communication partners.
  • Purposes of processing: contact requests and communication; provision of contractual services and customer service.
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO); Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO).

Further notes on processing operations, procedures and services:

  • Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context for the purpose of processing the communicated request. For this purpose, we process personal data in the context of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfillment, and otherwise on the basis of our legitimate interests as well as the interests of the communication partners in responding to the concerns and our legal retention obligations.

Web analysis, monitoring and optimization

Web analytics (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can recognize, for example, at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimization.

In addition to web analytics, we may also use testing procedures, for example, to test and optimize different versions of our online offering or its components.

Unless otherwise stated below, profiles, i.e. data summarized for a usage process, may be created for these purposes and information may be stored in a browser, or in a terminal 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 agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed.

The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, in the context of web analysis, A/B testing and optimization, no clear data of the users (such as e-mail addresses or names) are stored, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

Notes on legal bases: If we ask users for their consent to use the third-party providers, the legal basis for processing data is consent. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this Privacy Policy.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Further notes on processing processes, procedures and services:

Online marketing

We process personal data for online marketing purposes, which may include, in particular, marketing advertising space or displaying promotional and other content (collectively, “content”) based on potential user interests and measuring its effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which the information about the user relevant to the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information, such as the browser used, the computer system used and information on usage times and functions used. If users have consented to the collection of their location data, this may also be processed.

The IP addresses of users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that we, as well as the providers of the online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can later generally be read on other websites that use the same online marketing procedure and analyzed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.

Exceptionally, clear data can be assigned to the profiles. This is the case if, for example, the users are members of a social network whose online marketing procedure we use and the network links the profiles of the users with the aforementioned data. We ask to note that users may make additional arrangements with the providers, e.g., by giving consent as part of the registration process.

In principle, we only receive access to summarized information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e., for example, to a conclusion of a contract with us. The conversion measurement is used solely to analyze the success of our marketing measures.

Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.

Notes on legal bases: if we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this Privacy Policy.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: marketing; profiling with user-related information (creating user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal grounds: consent (Art. 6 para. 1 p. 1 lit. a. DSGVO); legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
  • Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the objection options given to the providers (so-called “opt-out”). If no explicit opt-out option has been specified, you have the option of disabling cookies in your browser settings. However, this may restrict functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for the respective areas: a) Europe: https: //www.youronlinechoices.eu. b) Canada: https: //www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-territory: https://optout.aboutads.info.

Further information on processing, procedures and services:

Affiliate programs and affiliate links

We include so-called affiliate links or other references (which may include, for example, search masks, widgets or discount codes) to the offers and services of third-party providers (collectively referred to as “affiliate links”) in our online offer. If users follow the Affiliate Links or subsequently take advantage of the offers, we may receive a commission or other benefits from those third parties (collectively, “Commission”).

In order to be able to track whether users have taken advantage of the offers of an affiliate link used by us, it is necessary that the respective third-party providers learn that the users have followed an affiliate link used within our online offer. The assignment of the affiliate links to the respective business transactions or to other actions (e.g. purchases) serves the sole purpose of commission accounting and will be cancelled as soon as it is no longer necessary for the purpose.

For the purposes of the aforementioned assignment of the affiliate links, the affiliate links may be supplemented by certain values that are a component of the link or may be stored elsewhere, e.g. in a cookie. The values may include, in particular, the source website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer and an online identifier of the user.

Notes on legal bases: if we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Furthermore, their use may be a component of our (pre)contractual services, provided that the use of the third-party providers has been agreed within this framework. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: contractual data (e.g. subject matter of contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: affiliate tracking.
  • Legal grounds: consent (Art. 6 para. 1 p. 1 lit. a. DSGVO); contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO); legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Further notes on processing processes, procedures and services:

  • Amazon Affiliate Program: affiliate partner program (Amazon and the Amazon logo are trademarks of Amazon.com, Inc. or one of its affiliates); Service Provider: Amazon Europe Core S.à.r.l., Amazon EU S.à.r.l, Amazon Services Europe S.à.r.l. and Amazon Media EU S.à.r.l., all four located at 38, avenue John F. Kennedy, L-1855 Luxembourg, and Amazon Instant Video Germany GmbH, Domagkstr. 28, 80807 Munich, Germany (collectively, “Amazon Europe”); parent company: Amazon.com, Inc, 2021 Seventh Ave, Seattle, Washington 98121, USA; website: https://www.amazon.de; privacy policy:https: //www.amazon.de/gp/help/customer/display.html?nodeId=201909010.
  • Digistore24 Affiliate Program: affiliate marketing affiliate program; service provider: Digistore24 GmbH, St.-Godehard-Straße 32, 31139 Hildesheim, Germany; Website: https://www.digistore24.com; Privacy policy:https: //www.digistore24.com/page/privacy.

Presence in social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with 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 the users because, for example, it could make it more difficult to enforce the rights of the users.

Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behavior and interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).

For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the privacy statements 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 also point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need assistance, you can contact us.

  • Types of data processed: 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 data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: contact requests and communication; feedback (e.g. collecting feedback via online form); marketing.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Further notes on processing operations, procedures and services:

  • Instagram: social network; service provider: Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA; 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 the collection (but not the further processing) of 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 under “Things You and Others Do and Provide” in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices users use (e.g., IP addresses, operating system, browser type, language settings, cookie data; see under “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 to provide them with insights into how people interact with their Pages and with content associated with them. We have entered into a special agreement with Facebook (“Page Insights Information,” 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 data subject rights (i.e., users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent 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; Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Standard contractual clauses (ensuring level of data protection in case of processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Further information: Shared Responsibility Agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data.

Plugins and embedded functions and content

We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These can be, for example, graphics, videos or city maps (hereinafter uniformly referred to 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 could not send the content to their browser. The IP address is thus required for the display of this content or functionality. We strive to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may 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 analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer as well as be linked to such information from other sources.

Notes on legal basis: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this Privacy Policy.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses); inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); 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; provision of contractual services and customer service; marketing; profiles with user-related information (creation of user profiles).
  • Legal bases: consent (Art. 6 para. 1 p. 1 lit. a. DSGVO); contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO); legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Further notes on processing processes, procedures and services:

  • Google Fonts: we integrate the fonts (“Google Fonts”) of the provider Google, whereby the users’ data is used solely for the purposes of displaying the fonts in the users’ browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform presentation and taking into account possible licensing restrictions for their integration; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://fonts.google.com/; privacy policy:https: //policies.google.com/privacy.
  • Google Maps: We integrate the maps of the service “Google Maps” of the provider Google. The data processed may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually executed as part of the settings of their mobile devices); service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://cloud.google.com/maps-platform; privacy policy:https: //policies.google.com/privacy; opt-out: opt-out plugin: https: //tools.google.com/dlpage/gaoptout?hl=de, settings for displaying ads: https: //adssettings.google.com/authenticated.
  • Instagram plugins and content: Instagram Plugins and Content – This may include, for example, content such as images, videos or text and buttons that allow users to share content from this online offering within Instagram. – We are jointly responsible withMeta Platforms Ireland Limited for collecting or receiving in the course of a transmission (but not further processing) “Event Data” that Facebook collects or receives in the course of a transmission by means of Instagram features (e.g., content embedding features) running on our Online Offer for the purposes of: a) displaying content as well as advertising information that matches users’ presumed interests; b) delivering commercial and transactional messages (e.g.. E.g., targeting users via Facebook Messenger); c) improving ad delivery and personalization of features and content (e.g., improving the detection of which content or advertising information presumably matches users’ interests). We have entered into a special agreement with Facebook (“Addendum for Responsible Parties”, 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 data subject rights (i.e., users can, for example, provide information or make deletion requests directly to Facebook). Note: When Facebook provides us with metrics, analytics, and reports (which are aggregated, i.e., do not receive information about individual users and are anonymous to us), this processing is not done under shared responsibility, but rather on the basis of a data processing contract (“Data Processing Terms “, https://www.facebook.com/legal/terms/dataprocessing) , the “Data Security Terms and Conditions”(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 to information, deletion, objection and complaint to the competent supervisory authority), are not restricted by the agreements with Facebook; service provider: Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA; website: https://www.instagram.com; privacy policy:https: //instagram.com/about/legal/privacy.
  • YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://www.youtube.com; privacy policy:https: //policies.google.com/privacy; opt-out: opt-out plugin: https: //tools.google.com/dlpage/gaoptout?hl=de, ad display settings: https: //adssettings.google.com/authenticated.

Change and update of the privacy policy

We ask you to regularly inform yourself about the content of our privacy policy. We adapt the privacy policy as soon as the changes in the data processing carried out by us make it necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

Insofar as we provide addresses and contact information of companies and organizations in this data protection declaration, we ask you to 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 of objection: you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to revoke any consent given at any time.
  • Right to information: you have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
  • Right torectification: you have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be rectified.
  • Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be deleted without delay, or alternatively, in accordance with the legal requirements, to demand restriction of the processing of the data.
  • Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements, or to demand its transfer to another responsible party.
  • Complaint to 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 infringes the requirements of the GDPR.

Definitions

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 defined primarily in Article 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are sorted alphabetically.

  • Affiliate tracking: In the context of affiliate tracking, links with the help of which the linking websites refer users to websites with product or other offers are logged. The operators of the respective linking websites may receive a commission if users follow these so-called affiliate links and subsequently take advantage of the offers (e.g. buy goods or use services). For this purpose, it is necessary for the providers to be able to track whether users who are interested in certain offers subsequently take advantage of them at the instigation of the affiliate links. It is therefore necessary for the functionality of affiliate links that they are supplemented with certain values that become part of the link or are stored elsewhere, e.g. in a cookie. The values include, in particular, the source website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user as well as tracking-specific values, such as, for example, advertising media ID, affiliate ID and categorizations
  • Personal data: “Personal data” means 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 (e.g. cookie) or to one or more factors specific to 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 of using such personal data to analyze, evaluate or to predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning 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.
  • Reachmeasurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and may include visitors’ behavior or interests in certain information, such as website content. With the help of reach analysis, website owners can see, for example, 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 reach analysis purposes, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Controller: “Controller” is 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.
  • Processing: “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data, be it collection, evaluation, storage, transmission or deletion.