Privacy Policy

INTRODUCTION

With the following data protection declaration we would like to inform you about the types of personal data (hereinafter also referred to as “data”) 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 in the context of providing our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter also referred to collectively as “online offer”).

The terms used are not gender-specific.

Status: June 14, 2020

CONTENT OVERVIEW

• Introduction
• Responsible
• Overview of the processing operation
• Relevant legal bases
• Security measures
• Use of cookies
• Provision of the online offer and web hosting
• Blogs and publication media
• Contact
• online marketing
• Presence in social networks (social media)
  deletion of data
• Amendment and update of the privacy policy
• Rights of data subjects
• Definitions of terms

RESPONSIBLE

Carsten Fröhlich
Lohmarer Str. 57
53840 Troisdorf

E-mail address: fragmich@troistones.eu

OVERVIEW OF THE PROCESSING

The following table summarises the types of data processed and the purposes of their processing, and refers to the data subjects.

TYPES OF DATA PROCESSED

• inventory data (e.g. names, addresses).
• Content data (e.g. text entries, photographs, videos).
• Contact data (e.g. e-mail, telephone numbers)
• Meta/communication data (e.g. device information, IP addresses).
• Usage data (e.g. websites visited, interest in content, access times).

CATEGORIES OF AFFECTED PERSONS

• Interested parties.
• Communication partners.
• Users (e.g. website visitors, users of online services).

PURPOSES OF PROCESSING

• Visit action evaluation.
• Feedback (for example, collecting feedback via online form).
• Interest based and behavioral marketing.
• Contact requests and communication.
• Conversion measurement (measuring the effectiveness of marketing measures).
• Profiling (creation of user profiles).
• remarketing.
• Reach measurement (e.g. access statistics, recognition of returning visitors).
• security measures.
• Tracking (e.g. interest/behavioural profiling, use of cookies).
• Contractual performance and service.
• Management and response to inquiries.

RELEVANT LEGAL BASIS

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

• Consent (Art. 6 para. 1 sentence 1 letter a DSGVO) – The data subject has given his or her consent to the processing of personal data relating to him or her for one or more specific purposes.
• Fulfilment of a contract and pre-contractual requests (Art. 6 para. 1 sentence 1 letter b. FADP) – Processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the request of the data subject.
• Protection of vital interests (Art. 6 para. 1 sentence 1 lit. d. FADP) – The processing is necessary to protect the vital interests of the data subject or of another natural person.

National data protection regulations in Germany: In addition to the data protection regulations of the Basic Data Protection Regulation, national regulations on data protection apply in Germany. These include in particular the law 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 deletion, the right of objection, 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 the purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

SECURITY MEASURE

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 commensurate with the risk.

Such measures shall include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, safeguarding of availability and segregation of data relating to them. Furthermore, we have established procedures to ensure that data subjects’ rights are exercised, data is deleted, and responses are made to any threats to the data. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes in accordance with the principle of data protection, by designing technology and by using data protection-friendly default settings.

Abbreviation of the IP address: If it is possible or not necessary for us to save the IP address, we will shorten or have your IP address shortened. In the case of shortening the IP address, also known as “IP masking”, the last octet, i.e. the last two numbers of an IP address, are deleted (in this context, the IP address is an identifier individually assigned to an Internet connection by the online access provider). The purpose of shortening the IP address is to prevent or make it considerably more difficult to identify a person on the basis of their IP address.

SSL encryption (https): 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 line of your browser.

USE OF COOKIES

Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after his visit within an online offer. The stored information can include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was viewed. The term “cookies” also includes other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also referred to as “user IDs”)

The following cookie types and functions are distinguished:

Information on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed with the aid of cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfil our contractual obligations.

Duration of storage: Unless we provide you with explicit information on the duration of storage of permanent cookies (e.g. within the framework of a so-called cookie opt-in), please assume that the storage period can be up to two years.

General notes on revocation and objection (opt-out): Depending on whether processing is based on consent or legal permission, you have the option at any time to revoke any consent given or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection by means of the settings of your browser, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online service). An objection to the use of cookies for online marketing purposes can also be declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further notices of objection in the context of the information on the service providers and cookies used.

Processing of cookie data based on consent: Before we process or have processed data in the context of the use of cookies, we ask users for their consent, which can be revoked at any time. Before consent has not been given, we will only use cookies that are absolutely necessary for the operation of our online service.

Cookie settings/ possibility of objection:

Cookie settings

• Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Data subjects: Users (e.g. website visitors, users of online services).
• Legal basis: Consent (Art. 6 para. 1 sentence 1 letter a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 letter f. DSGVO).

PROVISION OF THE ONLINE OFFER AND WEB HOSTING

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

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

E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as other information concerning the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of SPAM detection. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but (unless an end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). Server log files may include the address and name of the web pages and files accessed, date and time of access, data volume transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the capacity utilisation of the servers and their stability.

• Processed data types: Content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Affected persons: Users (e.g. website visitors, users of online services).
• Legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

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 for communication between authors and readers or for security reasons. In addition, we refer to the information on the processing of visitors to our publication medium in the context of this data protection notice.

Comments and contributions: If 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 contributions (insults, prohibited political propaganda, etc.) In this case we can be prosecuted ourselves for the comment or contribution and are therefore interested in the identity of the author.

Furthermore, based on our legitimate interests, we reserve the right to process user information 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 the duration of the survey and to use cookies to avoid multiple votes.

The personal information provided in the comments and contributions, any contact and website information as well as the content information will be permanently stored by us until the users object.

• Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Affected persons: Users (e.g. website visitors, users of online services).
• Purposes of processing: contractual services and performance, feedback (e.g. collecting feedback via online forms), security measures, administration and answering of inquiries.
  Legal basis: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO), consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), protection of vital interests (Art. 6 para. 1 sentence 1 lit. d. DSGVO).

CONTACT

When contacting us (e.g. via contact form, e-mail, telephone or via social media), the data of the inquiring persons will be processed to the extent necessary to answer the contact inquiries and any requested measures.

The answering of contact inquiries within the scope of contractual or pre-contractual relations is carried out in order to fulfil our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of the legitimate interest in answering the inquiries.

• Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Affected persons: communication partners.
• Purposes of processing: contact requests and communication.
• Legal basis: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

ONLINE MARKETING

We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the display of advertising and other content (collectively referred to as “Content”) based on the potential interests of users and the measurement of 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 user data relevant to the presentation of the aforementioned contents are stored. This information may include, for example, the content viewed, websites visited, online networks used, but also communication partners and technical details such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this data 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 the users. In general, no clear user data (such as e-mail addresses or names) are stored in the context 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.

As a rule, the information in the profiles is stored in the cookies or by means of similar procedures. These cookies can later be read out and analysed for the purpose of presenting content on other websites that use the same online marketing procedure, and can also be supplemented with additional data and stored on the server of the online marketing procedure provider.

As an exception, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing procedure we use and the network links the user profiles with the aforementioned data. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.

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

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

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, the users’ data will be 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 draw your attention to the information on the use of cookies in this privacy policy.

• Processed types of data: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Affected persons: Users (e.g. website visitors, users of online services), interested parties.
• Purposes of processing: Tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, visitor action evaluation, interest/behavioural marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors).
• Security measures: IP-Masking (pseudonymization of the IP address).
  Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
• Possibility of objection (opt-out): We refer to the data protection information of the respective providers and the possibilities of objection stated for the providers (so-called “opt-out”). If no explicit opt-out has been specified, it is possible to switch off cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary form 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-regional: https://optout.aboutads.info.

Used services and service providers:

• Google Analytics: online marketing and web analytics; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; Opt-Out: Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertising: https://adssettings.google.com/authenticated.

Opt-Out:

Verbiete Google Analytics, mich zu verfolgen

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 the users active there or to offer information about us.

Please note that user data may be processed outside the European Union. This can result in risks for the users, because the enforcement of the users’ rights could be made more difficult. With regard to US providers that are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we would like to point out that they thereby undertake to comply with the data protection standards of the EU.

Furthermore, user data within social networks is generally processed for market research and advertising purposes. Thus, for example, user profiles can be created on the basis of user behaviour and the resulting interests of the users. The user 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 behaviour and interests of the users are stored. Furthermore, data may also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).

For a detailed description of the respective forms of processing and the possibilities of objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.

Also in the case of requests for information and the assertion of data subject rights, we would like to point out that these can most effectively be asserted with the providers. Only the providers have access to the data of the users and can take appropriate measures and provide information directly. Should you nevertheless require assistance, you can contact us.

• Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Affected persons: Users (e.g. website visitors, users of online services).
• Purposes of processing: contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
• Legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Used services and service providers:

• Facebook: Social network; service provider: Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy Statement: https://www.facebook.com/about/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Opt-Out: Settings for advertisements: https://www.facebook.com/settings?tab=ads; Additional Privacy Notice: Agreement on Joint Processing of Personal Data on Facebook Pages: https://www.facebook.com/legal/terms/page_controller_addendum, Privacy Notice for Facebook Pages: https://www.facebook.com/legal/terms/information_about_page_insights_data.

DELETION OF DATA

The data processed by us will be deleted in accordance with the legal requirements as soon as their consent permitted for processing is revoked or other permissions cease to apply (e.g. if the purpose for which the data were processed ceases to apply or if they are not necessary for the purpose).

Unless the data are deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that 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 that must be stored for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person.

Further information on the deletion of personal data can also be provided in the individual data protection notes of this data protection declaration.

AMENDMENT AND UPDATE OF THE DATA PROTECTION DECLARATION

We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes make it necessary for you to take action to cooperate (e.g. to give your consent) or to receive other individual notification.

If we provide addresses and contact information of companies and organisations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.

RIGHTS OF THE PERSONS CONCERNED

As a data subject, you are entitled to various rights under the DSGVO, which result in particular from Art. 15 to 21 DSGVO:

• Right of objection: You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data relating to you which is carried out pursuant to Art. 6, para. 1, letters e or f FADP; this also applies to profiling based on these provisions. If the personal data concerning you are 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, including profiling, insofar as it is linked to such direct marketing.
• Right to withdraw consent: You have the right to withdraw any consent given at any time.
• Right of access: You have the right to obtain confirmation as to whether or not data in question is being processed and to obtain information about such data and to receive further information and a copy of the data in accordance with the law.
• Right of rectification: You have the right to ask for the completion of the data concerning you or the rectification of incorrect data concerning you, in accordance with the law.
• Right to erasure and limitation of processing: You have the right to request that data concerning you be erased immediately in accordance with the law or, alternatively, that the processing of such data be limited in accordance with the law.
• Right to data transferability: You have the right to obtain, in accordance with the law, data concerning you that you have provided to us in a structured, common and machine-readable format or to request that it be transferred to another responsible party.
• Complaints to the supervisory authority: You also have the right, in accordance with the statutory provisions, to lodge a complaint with a supervisory authority, in particular in the Member State in which you have your habitual residence, your place of work or the place where the alleged infringement occurred, if you believe that the processing of personal data relating to you is in breach of the DPA.

DEFINITIONS OF TERMS

This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined above all in Art. 4 DSGVO. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.

• Conversion tracking: “Conversion tracking” refers to a procedure that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user’s devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, we can use this to track whether the ads we have placed on other websites have been successful).
• IP-Masking: “IP-Masking” is a method in which the last octet, i.e. the last two numbers of an IP address, are deleted so that the IP address can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymising processing methods, especially in online marketing
• Interest-based and behavioral marketing: We speak of interest-based and/or behavioral marketing when the potential interests of users in ads and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behaviour (e.g. visiting and staying on certain websites, buying behaviour or interaction with other users), which is stored in a so-called profile. As a rule, cookies are used for these purposes.
• Conversion measurement: Conversion measurement is a method by which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users’ devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this enables us to track whether the ads we have placed on other websites have been successful.
• Personal data: ‘personal data’ shall mean any information relating to an identified or identifiable natural person (hereinafter referred to as ‘data subject’); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, a location data, an online identifier (e.g. a cookie) or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
• Profiling: “Profiling” is any automated processing of personal data which consists of using personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information about age, gender, location and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
• Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behaviour or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, identify at what time visitors visit their website and what content they are interested in. This enables them to better adapt the contents of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for the purpose of range analysis in order to recognise returning visitors and thus obtain more precise analyses of the use of an online offering.
• Remarketing: One speaks of “remarketing” or “retargeting”, for example, when it is noted for advertising purposes in which products a user on a website was interested, in order to remind the user on other websites of these products, e.g. in advertisements.
• Tracking: We speak of “tracking” when the behaviour of users can be traced across several online offers. As a rule, behavioral and interest information regarding the online offers used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
• Person responsible: The term “person responsible” refers to the natural or legal person, public authority, institution or other body which, alone or jointly with others, decides on the purposes and means of processing personal data.
• Processing: “processing” shall mean any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually all processing of data, whether it be collection, analysis, storage, communication or deletion.

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