
Frederic Wolny | Social Media Performance
PRIVACY POLICY
1. An overview of data protection
General information
The following information will provide you with an easy to navigate overview of what will happen with your
personal data when you visit this website. The term “personal data” comprises all data that can be used to
personally identify you. For detailed information about the subject matter of data protection, please consult
our Data Protection Declaration, which we have included beneath this copy.
Data recording on this website
Who is the responsible party for the recording of data on this website (i.e., the “controller”)?
The data on this website is processed by the operator of the website, whose contact information is available
under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this
Privacy Policy.
How do we record your data?
We collect your data as a result of your sharing of your data with us. This may, for instance be information
you enter into our contact form.
Other data shall be recorded by our IT systems automatically or after you consent to its recording during
your website visit. This data comprises primarily technical information (e.g., web browser, operating system,
or time the site was accessed). This information is recorded automatically when you access this website.
What are the purposes we use your data for?
4 / 20A portion of the information is generated to guarantee the error free provision of the website. Other data
may be used to analyze your user patterns. If contracts can be concluded or initiated via the website, the
transmitted data will also be processed for contract offers, orders or other order enquiries.
What rights do you have as far as your information is concerned?
You have the right to receive information about the source, recipients, and purposes of your archived
personal data at any time without having to pay a fee for such disclosures. You also have the right to demand
that your data are rectified or eradicated. If you have consented to data processing, you have the option to
revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to
demand that the processing of your data be restricted under certain circumstances. Furthermore, you have
the right to log a complaint with the competent supervising agency.
Please do not hesitate to contact us at any time if you have questions about this or any other data protection
related issues.
Analysis tools and tools provided by third parties
There is a possibility that your browsing patterns will be statistically analyzed when your visit this website.
Such analyses are performed primarily with what we refer to as analysis programs.
For detailed information about these analysis programs please consult our Data Protection Declaration
below.
2. Hosting
We are hosting the content of our website at the following provider:
WIX
The provider is the Wix.com Ltd., 40 Namal Tel Aviv St., Tel Aviv 6350671, Israel (hereinafter: “WIX”).
WIX is a tool for creating and hosting websites. When you visit our website, WIX analyses user behavior,
visitor sources, region of website visitors and visitor numbers. The WIX stores cookies on your browser,
which are necessary for the presentation of the website and to ensure security (necessary cookies).
Date recorded via WIX may be stored on a variety of servers around the globe. Among other locations, WIX
servers are also located in the USA.
Details can be found in the privacy policy of WIX:
https://de.wix.com/about/privacy.
According to WIX, the transfer of data to the United States as well as other non-EU countries is based on the
standard contract clauses of the EU Commission or comparable warranties pursuant to Art. 46 GDPR. For
details, please go to:
https://de.wix.com/about/privacy-dpa-users.
The WIX is used on the basis of Art. 6(1)(f) GDPR. We have a legitimate interest the most reliable
presentation of our website. If appropriate consent has been obtained, the processing is carried out
exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of
cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning
of the TDDDG. This consent can be revoked at any time.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an
5 / 20agreement between the European Union and the US, which is intended to ensure compliance with European
data protection standards for data processing in the US. Every company certified under the DPF is obliged to
comply with these data protection standards. For more information, please contact the provider under the
following link:
https://www.dataprivacyframework.gov/participant/5626.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a
contract mandated by data privacy laws that guarantees that they process personal data of our website
visitors only based on our instructions and in compliance with the GDPR.
3. General information and mandatory information
Data protection
The operators of this website and its pages take the protection of your personal data very seriously. Hence,
we handle your personal data as confidential information and in compliance with the statutory data
protection regulations and this Data Protection Declaration.
Whenever you use this website, a variety of personal information will be collected. Personal data comprises
data that can be used to personally identify you. This Data Protection Declaration explains which data we
collect as well as the purposes we use this data for. It also explains how, and for which purpose the
information is collected.
We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications)
may be prone to security gaps. It is not possible to completely protect data against third-party access.
Information about the responsible party (referred to as the “controller” in the GDPR)
The data processing controller on this website is:
Frederic Wolny
Marshall-Heights-Ring 3R
97318 Kitzingen
Phone: 015678 887243
E-mail: wolny.frederic@gmail.com
The controller is the natural person or legal entity that single-handedly or jointly with others makes
decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail
addresses, etc.).
Storage duration
Unless a more specific storage period has been specified in this privacy policy, your personal data will remain
with us until the purpose for which it was collected no longer applies. If you assert a justified request for
deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally
permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the
latter case, the deletion will take place after these reasons cease to apply.
General information on the legal basis for the data processing on this website
If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or
6 / 20Art. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) DSGVO. In the case of
explicit consent to the transfer of personal data to third countries, the data processing is also based on Art.
49 (1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end
device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TDDDG. The
consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the
implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR.
Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art.
6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest
according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in
the following paragraphs of this privacy policy.
Information on the data transfer to third-party countries that are not secure under data
protection law and the transfer to US companies that are not DPF-certified
We use, among other technologies, tools from companies located in third-party countries that are not safe
under data protection law, as well as US tools whose providers are not certified under the EU-US Data
Privacy Framework (DPF). If these tools are enabled, your personal data may be transferred to and
processed in these countries. We would like you to note that no level of data protection comparable to that
in the EU can be guaranteed in third countries that are insecure in terms of data protection law.
We would like to point out that the US, as a secure third-party country, generally has a level of data
protection comparable to that of the EU. Data transfer to the US is therefore permitted if the recipient is
certified under the “EU-US Data Privacy Framework” (DPF) or has appropriate additional assurances.
Information on transfers to third-party countries, including the data recipients, can be found in this Privacy
Policy.
Recipients of personal data
In the scope of our business activities, we cooperate with various external parties. In some cases, this also
requires the transfer of personal data to these external parties. We only disclose personal data to external
parties if this is required as part of the fulfillment of a contract, if we are legally obligated to do so (e.g.,
disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Art. 6 (1)(f)
GDPR, or if another legal basis permits the disclosure of this data. When using processors, we only disclose
personal data of our customers on the basis of a valid contract on data processing. In the case of joint
processing, a joint processing agreement is concluded.
Revocation of your consent to the processing of data
A wide range of data processing transactions are possible only subject to your express consent. You can also
revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness
of any data collection that occurred prior to your revocation.
Right to object to the collection of data in special cases; right to object to direct
advertising (Art. 21 GDPR)
IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE
THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON
GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED
ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS
BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE
WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO
PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA,
THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE
PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION
7 / 20PURSUANT TO ART. 21(1) GDPR).
IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING,
YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR
THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE
EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL
DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES
(OBJECTION PURSUANT TO ART. 21(2) GDPR).
Right to log a complaint with the competent supervisory agency
In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory
agency, in particular in the member state where they usually maintain their domicile, place of work or at the
place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other
administrative or court proceedings available as legal recourses.
Right to data portability
You have the right to have data that we process automatically on the basis of your consent or in fulfillment of
a contract handed over to you or to a third party in a common, machine-readable format. If you should
demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.
Information about, rectification and eradication of data
Within the scope of the applicable statutory provisions, you have the right to demand information about
your archived personal data, their source and recipients as well as the purpose of the processing of your data
at any time. You may also have a right to have your data rectified or eradicated. If you have questions about
this subject matter or any other questions about personal data, please do not hesitate to contact us at any
time.
Right to demand processing restrictions
You have the right to demand the imposition of restrictions as far as the processing of your personal data is
concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in
the following cases:
In the event that you should dispute the correctness of your data archived by us, we will usually need
some time to verify this claim. During the time that this investigation is ongoing, you have the right to
demand that we restrict the processing of your personal data.
If the processing of your personal data was/is conducted in an unlawful manner, you have the option to
demand the restriction of the processing of your data instead of demanding the eradication of this data.
If we do not need your personal data any longer and you need it to exercise, defend or claim legal
entitlements, you have the right to demand the restriction of the processing of your personal data instead
of its eradication.
If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be
weighed against each other. As long as it has not been determined whose interests prevail, you have the
right to demand a restriction of the processing of your personal data.
If you have restricted the processing of your personal data, these data – with the exception of their archiving –
may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to
protect the rights of other natural persons or legal entities or for important public interest reasons cited by
the European Union or a member state of the EU.
SSL and/or TLS encryption
8 / 20For security reasons and to protect the transmission of confidential content, such as purchase orders or
inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption
program. You can recognize an encrypted connection by checking whether the address line of the browser
switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.
If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.
4. Recording of data on this website
Cookies
Our websites and pages use what the industry refers to as “cookies.” Cookies are small data packages that do
not cause any damage to your device. They are either stored temporarily for the duration of a session
(session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are
automatically deleted once you terminate your visit. Permanent cookies remain archived on your device
until you actively delete them, or they are automatically eradicated by your web browser.
Cookies can be issued by us (first-party cookies) or by third-party companies (so-called third-party cookies).
Third-party cookies enable the integration of certain services of third-party companies into websites (e.g.,
cookies for handling payment services).
Cookies have a variety of functions. Many cookies are technically essential since certain website functions
would not work in the absence of these cookies (e.g., the shopping cart function or the display of videos).
Other cookies may be used to analyze user behavior or for promotional purposes.
Cookies, which are required for the performance of electronic communication transactions, for the provision
of certain functions you want to use (e.g., for the shopping cart function) or those that are necessary for the
optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web
audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The
operator of the website has a legitimate interest in the storage of required cookies to ensure the technically
error-free and optimized provision of the operator’s services. If your consent to the storage of the cookies
and similar recognition technologies has been requested, the processing occurs exclusively on the basis of
the consent obtained (Art. 6(1)(a) GDPR and § 25 (1) TDDDG); this consent may be revoked at any time.
You have the option to set up your browser in such a manner that you will be notified any time cookies are
placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of
cookies in certain cases or in general or activate the delete-function for the automatic eradication of cookies
when the browser closes. If cookies are deactivated, the functions of this website may be limited.
Which cookies and services are used on this website can be found in this privacy policy.
Contact form
If you submit inquiries to us via our contact form, the information provided in the contact form as well as any
contact information provided therein will be stored by us in order to handle your inquiry and in the event
that we have further questions. We will not share this information without your consent.
The processing of these data is based on Art. 6(1)(b) GDPR, if your request is related to the execution of a
contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based
on our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or
on your agreement (Art. 6(1)(a) GDPR) if this has been requested; the consent can be revoked at any time.
The information you have entered into the contact form shall remain with us until you ask us to eradicate the
data, revoke your consent to the archiving of data or if the purpose for which the information is being
9 / 20archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without
prejudice to any mandatory legal provisions, in particular retention periods.
Request by e-mail, telephone, or fax
If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name,
request) will be stored and processed by us for the purpose of processing your request. We do not pass these
data on without your consent.
These data are processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a
contract or is required for the performance of pre-contractual measures. In all other cases, the data are
processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art.
6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained; the consent can be
revoked at any time.
The data sent by you to us via contact requests remain with us until you request us to delete, revoke your
consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request).
Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.
Communication via WhatsApp
For communication with our customers and other third parties, one of the services we use is the instant
messaging service WhatsApp. The provider is WhatsApp Ireland Limited, 4 Grand Canal Square, Grand
Canal Harbour, Dublin 2, Ireland.
The communication is encrypted end-to-end (peer-to-peer), which prevents WhatsApp or other third parties
from gaining access to the communication content. However, WhatsApp does gain access to metadata
created during the communication process (for example, sender, recipient, and time). We would also like to
point out that WhatsApp has stated that it shares personal data of its users with its U.S.-based parent
company Meta. Further details on data processing can be found in the WhatsApp privacy policy at:
https://www.whatsapp.com/legal/#privacy-policy.
The use of WhatsApp is based on our legitimate interest in communicating as quickly and effectively as
possible with customers, interested parties and other business and contractual partners (Art. 6(1)(f) GDPR).
If a corresponding consent has been requested, data processing is carried out exclusively on the basis of the
consent; this consent may be revoked at any time with effect for the future.
The communication content exchanged between you and us on WhatsApp remains with us until you request
us to delete it, revoke your consent to storage or the purpose for which the data is stored ceases to apply
(e.g. after your request has been processed). Mandatory legal provisions, in particular retention periods,
remain unaffected.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an
agreement between the European Union and the US, which is intended to ensure compliance with European
data protection standards for data processing in the US. Every company certified under the DPF is obliged to
comply with these data protection standards. For more information, please contact the provider under the
following link:
https://www.dataprivacyframework.gov/participant/7735.
We use WhatsApp in the “WhatsApp Business” variant.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European
Commission. Details can be found here:
https://www.whatsapp.com/legal/business-data-transfer-addendum?lang=en.
10 / 205. Analysis tools and advertising
Google Tag Manager
We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street,
Dublin 4, Ireland
The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other
technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store
cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via
it. However, the Google Tag Manager does collect your IP address, which may also be transferred to
Google’s parent company in the United States.
The Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate
interest in the quick and uncomplicated integration and administration of various tools on his website. If
appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a)
GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information
in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be
revoked at any time.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an
agreement between the European Union and the US, which is intended to ensure compliance with European
data protection standards for data processing in the US. Every company certified under the DPF is obliged to
comply with these data protection standards. For more information, please contact the provider under the
following link:
https://www.dataprivacyframework.gov/participant/5780.
Google Analytics
This website uses functions of the web analysis service Google Analytics. The provider of this service is
Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that
end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the
utilized operating system and the user’s origin. This data is assigned to the respective end device of the user.
An assignment to a user-ID does not take place.
Furthermore, Google Analytics allows us to record your mouse and scroll movements and clicks, among
other things. Google Analytics uses various modeling approaches to augment the collected data sets and
uses machine learning technologies in data analysis.
Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing the
user behavior patterns (e.g., cookies or device fingerprinting). The website use information recorded by
Google is, as a rule transferred to a Google server in the United States, where it is stored.
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1)
TDDDG. You may revoke your consent at any time.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European
Commission. Details can be found here:
https://privacy.google.com/businesses/controllerterms/mccs/.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an
agreement between the European Union and the US, which is intended to ensure compliance with European
11 / 20data protection standards for data processing in the US. Every company certified under the DPF is obliged to
comply with these data protection standards. For more information, please contact the provider under the
following link:
https://www.dataprivacyframework.gov/participant/5780.
IP anonymization
Google Analytics IP anonymization is active. As a result, your IP address will be abbreviated by Google within
the member states of the European Union or in other states that have ratified the Convention on the
European Economic Area prior to its transmission to the United States. The full IP address will be
transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases.
On behalf of the operator of this website, Google shall use this information to analyze your use of this
website to generate reports on website activities and to render other services to the operator of this website
that are related to the use of the website and the Internet. The IP address transmitted in conjunction with
Google Analytics from your browser shall not be merged with other data in Google’s possession.
Browser plug-in
You can prevent the recording and processing of your data by Google by downloading and installing the
browser plugin available under the following link:
https://tools.google.com/dlpage/gaoptout?hl=en.
For more information about the handling of user data by Google Analytics, please consult Google’s Data
Privacy Declaration at:
https://support.google.com/analytics/answer/6004245?hl=en.
Google Signals
We use Google Signals. Whenever you visit our website, Google Analytics records, among other things, your
location, the progression of your search and YouTube progression as well as demographic data (site visitor
data). This data may be used for customized advertising with the assistance of Google Signal. If you have a
Google account, your site visitor information will be linked to your Google account by Google Signal and
used to send you customized promotional messages. The data is also used to compile anonymized statistics
of our users’ online patterns.
Contract data processing
We have executed a contract data processing agreement with Google and are implementing the stringent
provisions of the German data protection agencies to the fullest when using Google Analytics.
Google Ads
The website operator uses Google Ads. Google Ads is an online promotional program of Google Ireland
Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Ads enables us to display ads in the Google search engine or on third-party websites, if the user
enters certain search terms into Google (keyword targeting). It is also possible to place targeted ads based
on the user data Google has in its possession (e.g., location data and interests; target group targeting). As the
website operator, we can analyze these data quantitatively, for instance by analyzing which search terms
resulted in the display of our ads and how many ads led to respective clicks.
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1)
TDDDG. You may revoke your consent at any time.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European
12 / 20Commission. Details can be found here:
https://policies.google.com/privacy/frameworks and
https://business.safety.google/controllerterms/.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an
agreement between the European Union and the US, which is intended to ensure compliance with European
data protection standards for data processing in the US. Every company certified under the DPF is obliged to
comply with these data protection standards. For more information, please contact the provider under the
following link:
https://www.dataprivacyframework.gov/participant/5780.
Google Conversion-Tracking
This website uses Google Conversion Tracking. The provider of this service is Google Ireland Limited
(“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
With the assistance of Google Conversion Tracking, we are in a position to recognize whether the user has
completed certain actions. For instance, we can analyze the how frequently which buttons on our website
have been clicked and which products are reviewed or purchased with particular frequency. The purpose of
this information is to compile conversion statistics. We learn how many users have clicked on our ads and
which actions they have completed. We do not receive any information that would allow us to personally
identify the users. Google as such uses cookies or comparable recognition technologies for identification
purposes.
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1)
TDDDG. You may revoke your consent at any time.
For more information about Google Conversion Tracking, please review Google’s data protection policy at:
https://policies.google.com/privacy?hl=en
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an
agreement between the European Union and the US, which is intended to ensure compliance with European
data protection standards for data processing in the US. Every company certified under the DPF is obliged to
comply with these data protection standards. For more information, please contact the provider under the
following link:
https://www.dataprivacyframework.gov/participant/5780.
Meta Pixel (formerly Facebook Pixel)
To measure conversion rates, this website uses the visitor activity pixel of Meta. The provider of this service
is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Meta’s statement
the collected data will be transferred to the USA and other third-party countries too.
This tool allows the tracking of page visitors after they have been linked to the website of the provider after
clicking on a Meta ad. This makes it possible to analyze the effectiveness of Meta ads for statistical and
market research purposes and to optimize future advertising campaigns.
For us as the operators of this website, the collected data is anonymous. We are not in a position to arrive at
any conclusions as to the identity of users. However, Meta archives the information and processes it, so that
it is possible to make a connection to the respective user profile on Facebook or Instagram and Meta is in a
position to use the data for its own promotional purposes in compliance with the Meta Data Usage Policy (
https://www.facebook.com/about/privacy/). This enables Meta to display ads on Facebook or Instagram and
other advertising channels. We as the operator of this website have no control over the use of such data.
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1)
13 / 20TDDDG. You may revoke your consent at any time.
Within the meta pixel, we are using the expanded alignment function.
The expanded alignment allows us to transfer to Meta different types of data (e.g., place of residence, federal
state, zip code, hashed email addresses, names, gender, date of birth or phone number) of our customers and
prospects we collect through our website. Herewith, we can tailor the offers presented in our advertising
campaigns on Facebook and Instagram to individuals interested in what we offer even more precisely.
Moreover, this expanded alignment optimizes the allocation of website conversions and expands custom
audiences.
Insofar as personal data is collected on our website with the help of the tool described here and forwarded to
Meta, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland
are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited exclusively
to the collection of the data and its forwarding to Meta. The processing by Meta that takes place after the
onward transfer is not part of the joint responsibility. The obligations incumbent on us have been jointly set
out in a joint processing agreement. The wording of the agreement can be found under:
https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for
providing the privacy information when using the Meta tool and for the privacy-secure implementation of
the tool on our website. Meta is responsible for the data security of Meta products. You can assert data
subject rights (e.g., requests for information) regarding data processed by Facebook or Instagram directly
with Meta. If you assert the data subject rights with us, we are obliged to forward them to Meta.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European
Commission. Details can be found here:
https://www.facebook.com/legal/EU_data_transfer_addendum and
https://de-de.facebook.com/help/566994660333381.
In Meta’s Data Privacy Policies, you will find additional information about the protection of your privacy at:
https://www.facebook.com/about/privacy/.
You also have the option to deactivate the remarketing function “Custom Audiences” in the ad settings
section under
to log into Facebook.
https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you first have
If you do not have a Facebook or Instagram account, you can deactivate any user-based advertising by Meta
on the website of the European Interactive Digital Advertising Alliance:
http://www.youronlinechoices.com/de/praferenzmanagement/.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an
agreement between the European Union and the US, which is intended to ensure compliance with European
data protection standards for data processing in the US. Every company certified under the DPF is obliged to
comply with these data protection standards. For more information, please contact the provider under the
following link:
https://www.dataprivacyframework.gov/participant/4452.
Meta Custom Audiences
We use Meta Custom Audiences. The provider of this service is Meta Platforms Ireland Limited, 4 Grand
Canal Square, Dublin 2, Ireland.
Whenever you visit or use our website and apps, utilize our portfolio (e.g., participation in sweepstakes),
transfer data to us or interact with the Facebook or Instagram content of our company, we record related
personal data. In the event that you have given us your consent to the use of Meta Custom Audiences, we
14 / 20will share these data with Meta to put Meta in a position to send you compatible ads. These data may also be
used to defined target audiences (Lookalike Audiences).
Meta processes these data as our contract processor. For details, please consult the user agreement of Meta:
https://www.facebook.com/legal/terms/customaudience.
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1)
TDDDG. You may revoke your consent at any time.
The transfer of date to the USA is based on the standard contract clauses of the EU Commission. For details
please see:
https://www.facebook.com/legal/terms/customaudience and
https://www.facebook.com/legal/terms/dataprocessing.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an
agreement between the European Union and the US, which is intended to ensure compliance with European
data protection standards for data processing in the US. Every company certified under the DPF is obliged to
comply with these data protection standards. For more information, please contact the provider under the
following link:
https://www.dataprivacyframework.gov/participant/4452.
TikTok Pixel
We have integrated TikTok pixel on this website. The provider is TikTok Technology Limited, 10 Earlsfort
Terrace, Dublin, D02 T380, Ireland (hereinafter TikTok).
With the help of TikTok Pixel, we can display interest-based advertisements on TikTok to website visitors
who have viewed our offers (TikTok Ads). At the same time, TikTok Pixel allows us to determine how
effective our advertising is on TikTok. This allows us to evaluate the effectiveness of the TikTok Ads for
statistical and market research purposes and to optimize them for future advertising efforts. For this
purpose, various usage data are processed, such as IP address, page views, time spent, operating system used
and origin of the user, information about the ad on which a person clicked on TikTok or an event that was
triggered (timestamp). This data is summarized in a user ID and assigned to the respective end device of the
website visitor.
The use of this tool is based on Art. 6(1)(a) GDPR and § 25 (1) TDDDG. This consent can be revoked at any
time.
Data transfer to third-party countries is based on the standard contractual clauses of the EU Commission.
Details can be found here:
https://www.tiktok.com/legal/page/eea/privacy-policy/de-DE and
https://ads.tiktok.com/i18n/official/policy/controller-to-controller.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a
contract mandated by data privacy laws that guarantees that they process personal data of our website
visitors only based on our instructions and in compliance with the GDPR.
LinkedIn Insight Tag
This website uses the Insight tag from LinkedIn. This service is provided by LinkedIn Ireland Unlimited
Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
Data processing by LinkedIn Insight tag
15 / 20We use the LinkedIn Insight tag to obtain information about visitors to our website. Once a website visitor is
registered with LinkedIn, we can analyze the key occupational data (e.g., career level, company size, country,
location, industry, job title) of our website visitors to help us better target our site to the relevant audience.
We can also use LinkedIn Insight tags to measure whether visitors to our websites make a purchase or
perform other actions (conversion measurement). Conversion measurement can also be carried out across
devices (e.g. from PC to tablet). LinkedIn Insight Tag also features a retargeting function that allows us to
display targeted advertising to visitors to our website outside of the website. According to LinkedIn, no
identification of the advertising addressee takes place.
LinkedIn itself also collects log files (URL, referrer URL, IP address, device and browser characteristics and
time of access). The IP addresses are shortened or (if they are used to reach LinkedIn members across
devices) hashed (pseudonymized). The direct identifiers of LinkedIn members are deleted by LinkedIn after
seven days. The remaining pseudonymized data will then be deleted within 180 days.
The data collected by LinkedIn cannot be assigned by us as a website operator to specific individuals.
LinkedIn will store the personal data collected from website visitors on its servers in the USA and use it for
its own promotional activities. For details, please see LinkedIn’s privacy policy at
https://www.linkedin.com/legal/privacy-policy#choices-oblig.
Legal basis
If your approval (consent) has been obtained the use of the abovementioned service shall occur on the basis
of Art. 6(1)(a) GDPR and § 25 TDDDG (German Telecommunications Act). Such consent may be revoked at
any time. If your consent was not obtained, the use of the service will occur on the basis of Art. 6(1)(f) GDPR;
the website operator has a legitimate interest in effective advertising promotions that include the utilization
of social media.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European
Commission. Details can be found here:
https://www.linkedin.com/legal/l/dpa and
https://www.linkedin.com/legal/l/eu-sccs.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an
agreement between the European Union and the US, which is intended to ensure compliance with European
data protection standards for data processing in the US. Every company certified under the DPF is obliged to
comply with these data protection standards. For more information, please contact the provider under the
following link:
https://www.dataprivacyframework.gov/participant/5448.
Objection to the use of LinkedIn Insight Tag
You can object to LinkedIn’s analysis of user behavior and targeted advertising at the following link:
https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
In addition, LinkedIn members can control the use of their personal information for promotional purposes in
the account settings. To prevent LinkedIn from linking information collected on our site to your LinkedIn
account, you must log out of your LinkedIn account before you visit our site.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a
contract mandated by data privacy laws that guarantees that they process personal data of our website
visitors only based on our instructions and in compliance with the GDPR.
16 / 20Pinterest-Tag
We have integrated Pinterest-Tag into this website. The provider is Pinterest Europe Ltd., Palmerston
House, 2nd Floor, Fenian Street, Dublin 2, Ireland.
The purpose of Pinterest-Tag is to record certain actions you perform on our website. Subsequently, the
data can be used to display promotions to you that meet your interests on our website or on another
Pinterest-Tag website.
For this purpose, Pinterest-Tag records, among other things, a Tag ID, your location, and the referrer URL.
Furthermore, action specific data, such as the order value, ordered quantity, order number, the category of
the purchased item and video views may be recorded.
Pinterest-Tag uses technologies that make the recognition of the user across sites possible, so that the user
patterns can be analyzed (e.g., cookies or device fingerprinting).
If your approval (consent) has been obtained the use of the abovementioned service shall occur on the basis
of Art. 6(1)(a) GDPR and § 25 TDDDG (German Telecommunications Act). Such consent may be revoked at
any time. If your consent was not obtained, the use of the service will occur on the basis of Art. 6(1)(f) GDPR;
the website operator has a legitimate interest in ensuring the maximum effectiveness of the operator’s
marketing activities.
Pinterest is an enterprise that does business around the globe, so that data may also be transmitted into the
United States. Based on Pinterest’s statements, this data transmission is based on the standard contractual
clauses of the EU Commissions. For details please visit:
https://policy.pinterest.com/de/privacy-policy.
For more Pinterest-Tag information please visit:
https://help.pinterest.com/de/business/article/track-conversions-with-pinterest-tag.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a
contract mandated by data privacy laws that guarantees that they process personal data of our website
visitors only based on our instructions and in compliance with the GDPR.
6. Online-based Audio and Video Conferences (Conference tools)
Data processing
We use online conference tools, among other things, for communication with our customers. The tools we
use are listed in detail below. If you communicate with us by video or audio conference using the Internet,
your personal data will be collected and processed by the provider of the respective conference tool and by
us. The conferencing tools collect all information that you provide/access to use the tools (email address
and/or your phone number). Furthermore, the conference tools process the duration of the conference, start
and end (time) of participation in the conference, number of participants and other “context information”
related to the communication process (metadata).
Furthermore, the provider of the tool processes all the technical data required for the processing of the
online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type,
operating system type and version, client version, camera type, microphone or loudspeaker and the type of
connection.
Should content be exchanged, uploaded, or otherwise made available within the tool, it is also stored on the
17 / 20servers of the tool provider. Such content includes, but is not limited to, cloud recordings, chat/ instant
messages, voicemail uploaded photos and videos, files, whiteboards, and other information shared while
using the service.
Please note that we do not have complete influence on the data processing procedures of the tools used. Our
possibilities are largely determined by the corporate policy of the respective provider. Further information
on data processing by the conference tools can be found in the data protection declarations of the tools
used, and which we have listed below this text.
Purpose and legal bases
The conference tools are used to communicate with prospective or existing contractual partners or to offer
certain services to our customers (Art. 6(1)(b) GDPR). Furthermore, the use of the tools serves to generally
simplify and accelerate communication with us or our company (legitimate interest in the meaning of Art.
6(1)(f) GDPR). Insofar as consent has been requested, the tools in question will be used on the basis of this
consent; the consent may be revoked at any time with effect from that date.
Duration of storage
Data collected directly by us via the video and conference tools will be deleted from our systems
immediately after you request us to delete it, revoke your consent to storage, or the reason for storing the
data no longer applies. Stored cookies remain on your end device until you delete them. Mandatory legal
retention periods remain unaffected.
We have no influence on the duration of storage of your data that is stored by the operators of the
conference tools for their own purposes. For details, please directly contact the operators of the conference
tools.
Conference tools used
We employ the following conference tools:
Zoom
We use Zoom. The provider of this service is Zoom Communications Inc, San Jose, 55 Almaden Boulevard,
6th Floor, San Jose, CA 95113, USA. For details on data processing, please refer to Zoom’s privacy policy:
https://explore.zoom.us/en/privacy/.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European
Commission. Details can be found here:
https://explore.zoom.us/en/privacy/.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an
agreement between the European Union and the US, which is intended to ensure compliance with European
data protection standards for data processing in the US. Every company certified under the DPF is obliged to
comply with these data protection standards. For more information, please contact the provider under the
following link:
https://www.dataprivacyframework.gov/participant/5728.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a
contract mandated by data privacy laws that guarantees that they process personal data of our website
visitors only based on our instructions and in compliance with the GDPR.
18 / 20Microsoft Teams
We use Microsoft Teams. The provider is the Microsoft Ireland Operations Limited, One Microsoft Place,
South County Business Park, Leopardstown, Dublin 18, Ireland. For details on data processing, please refer
to the Microsoft Teams privacy policy:
https://privacy.microsoft.com/en-us/privacystatement.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an
agreement between the European Union and the US, which is intended to ensure compliance with European
data protection standards for data processing in the US. Every company certified under the DPF is obliged to
comply with these data protection standards. For more information, please contact the provider under the
following link:
https://www.dataprivacyframework.gov/participant/6474.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a
contract mandated by data privacy laws that guarantees that they process personal data of our website
visitors only based on our instructions and in compliance with the GDPR.
Google Meet
We use Google Meet. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4,
Ireland. For details on data processing, please see the Google privacy policy:
https://policies.google.com/privacy?hl=en.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an
agreement between the European Union and the US, which is intended to ensure compliance with European
data protection standards for data processing in the US. Every company certified under the DPF is obliged to
comply with these data protection standards. For more information, please contact the provider under the
following link:
https://www.dataprivacyframework.gov/participant/5780.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a
contract mandated by data privacy laws that guarantees that they process personal data of our website
visitors only based on our instructions and in compliance with the GDPR.