Preamble
With the following privacy policy, we would like to inform you about what types of your personal data (hereinafter also referred to as “data”) we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).
The terms used are not gender-specific.
Status: October 2, 2023
Table of contents
- Preamble
- Person responsible
- Overview of processing
- Relevant legal bases
- Security measures
- Transmission of personal data
- International data transfers
- Deletion of data
- Rights of the data subjects
- Use of cookies
- Business services
- Providers and services used in the course of business activities
- Payment procedure
- Provision of the online offer and web hosting
- Contact and inquiry management
- Presence in social networks (social media)
- Management, organization and support tools
- Amendment and updating of the privacy policy
- Definitions of terms
Person responsible
Matthew Pettersson
Manuka Kontor GmbH
Karl-Marx-Str. 64
16816 Neuruppin
GERMANY
E-mail address: info@manukakontor.com
Imprint: https://madhuhoney.shop/impressum/
Overview of processing
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.
- Payment data.
- Contact details.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and process data.
Categories of affected persons
- Customers.
- Interested parties.
- Communication partner.
- Users.
- Business and contractual partners.
Purposes of the processing
- Provision of contractual services and fulfillment of contractual obligations.
- Contact requests and communication.
- Safety measures.
- Office and organizational procedures.
- Managing and responding to inquiries.
- Feedback.
- Marketing.
- Provision of our online services and user-friendliness.
- Information technology infrastructure.
Relevant legal bases
Relevant legal bases according to the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.
- Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) – The data subject has given their consent to the processing of their personal data for one or more specific purposes.
- Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Act on the 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. The data protection laws of the individual federal states may also apply.
National data protection regulations in Austria: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Austria. These include, in particular, the Federal Act on the Protection of Natural Persons with regard to the Processing of Personal Data (Data Protection Act – DSG). In particular, the Data Protection Act contains special regulations on the right to information, the right to rectification or erasure, the processing of special categories of personal data, processing for other purposes and transfer as well as automated decision-making in individual cases.
Relevant legal bases according to the Swiss Data Protection Act: If you are located in Switzerland, we process your data on the basis of the Federal Act on Data Protection (“Swiss FADP” for short). This also applies if our processing of your data otherwise affects you in Switzerland and you are affected by the processing. In principle, the Swiss FADP does not stipulate (unlike the GDPR, for example) that a legal basis for the processing of personal data must be specified. We only process personal data if the processing is lawful, is carried out in good faith and is proportionate (Art. 6 para. 1 and 2 of the Swiss FADP). Furthermore, we only obtain personal data for a specific purpose that is recognizable to the data subject and only process it in such a way that it is compatible with these purposes (Art. 6 para. 3 of the Swiss FADP).
Note on the applicability of the GDPR and Swiss FADP: This data protection notice serves to provide information in accordance with both the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). For this reason, please note that the terms of the GDPR are used due to the broader geographical application and comprehensibility. In particular, instead of the terms “processing” of “personal data”, “overriding interest” and “sensitive personal data” used in the Swiss DPA, the terms “processing” of “personal data”, “legitimate interest” and “special categories of data” used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of application of the Swiss DPA.
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 the access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data threats. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
TLS/SSL encryption (https): To protect user data transmitted via our online services, we use TLS/SSL encryption. Secure Sockets Layer (SSL) is the standard technology for securing internet connections by encrypting the data transmitted between a website or app and a browser (or between two servers). Transport Layer Security (TLS) is an updated and more secure version of SSL. Hyper Text Transfer Protocol Secure (HTTPS) is displayed in the URL when a website is secured by an SSL/TLS certificate.
Transmission of personal data
As part of our processing of personal data, the data may be transferred to other bodies, companies, legally independent organizational units or persons or disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.
International data transfers
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, bodies or companies, this will only take place in accordance with the legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data will only be transferred if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 para. 2 lit. c) GDPR), express consent or in the case of contractual or legally required transfer (Art. 49 para. 1 GDPR). In addition, we will inform you of the basis for third country transfers with the individual providers from the third country, whereby the adequacy decisions take precedence. Information on third country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de.
EU-US Trans-Atlantic Data Privacy Framework: As part of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the level of data protection for certain companies from the USA as secure as part of the adequacy decision of 10.07.2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/. As part of the data protection information, we will inform you which service providers we use are certified under the Data Privacy Framework.
Disclosure of personal data abroad: In accordance with the Swiss Data Protection Act (DSG), we only disclose personal data abroad if adequate protection of the data subjects is guaranteed (Art. 16 Swiss DSG). If the Federal Council has not determined adequate protection (list: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we take alternative security measures. These may include international contracts, specific guarantees, data protection clauses in contracts, standard data protection clauses approved by the Federal Data Protection and Information Commissioner (FDPIC) or internal company data protection regulations recognized in advance by the FDPIC or a competent data protection authority in another country.
According to Art. 16 of the Swiss DPA, exceptions may be made for the disclosure of data abroad if certain conditions are met, including consent of the data subject, performance of a contract, public interest, protection of life or physical integrity, data made public or data from a register provided for by law. These disclosures are always made in accordance with legal requirements.
Deletion of data
The data processed by us will be deleted in accordance with the legal requirements as soon as the consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data no longer applies or it is not required for the purpose). If the data is not deleted because it is required for other and legally permissible purposes, its processing is restricted 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 commercial or tax law reasons or whose storage is necessary for the assertion, exercise or defense of legal claims or to protect the rights of another natural or legal person. As part of our data protection information, we can provide users with further information on the deletion and retention of data that applies specifically to the respective processing operations.
Rights of the data subjects
Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
- Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw your consent at any time.
- Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with the legal requirements.
- Right to rectification: In accordance with the statutory provisions, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
- Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
- Right to data portability: You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request its transmission to another controller.
- Complaint to a supervisory authority: In accordance with the statutory provisions and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State in which you are habitually resident, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.
Rights of data subjects under the Swiss DPA:
As a data subject, you have the following rights in accordance with the provisions of the Swiss Data Protection Act:
- Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed and to receive the information necessary for you to exercise your rights under this law and to ensure transparent data processing.
- Right to data surrender or transfer: You have the right to request the surrender of your personal data that you have provided to us in a commonly used electronic format.
- Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
- Right to object, erasure and destruction: You have the right to object to the processing of your data and to request that the personal data concerning you be erased or destroyed.
Use of cookies
Cookies are small text files or other storage notes that store information on end devices and read information from the end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed or functions used in an online offering. Cookies can also be used for various purposes, e.g. to ensure the functionality, security and convenience of online services and to analyze visitor flows.
Notes on consent: We use cookies in accordance with the statutory provisions. We therefore obtain prior consent from users, unless this is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide the user with a telemedia service expressly requested by them (i.e. our online offer). Strictly necessary cookies generally include cookies with functions that serve the display and operability of the online service, load balancing, security, storage of user preferences and selection options or similar purposes related to the provision of the main and secondary functions of the online service requested by the user. The revocable consent is clearly communicated to the users and contains the information on the respective use of cookies.
Information on legal bases under data protection law: The legal basis under data protection law on which we process users’ personal data with the help of cookies depends on whether we ask users for their consent. If users consent, the legal basis for processing their data is the consent they have given. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and improving its usability) or, if this is done in the context of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We explain the purposes for which we process cookies in the course of this privacy policy or as part of our consent and processing procedures.
Storage period: With regard to the storage period, a distinction is made between the following types of cookies:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their 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. The user data collected with the help of cookies can also be used to measure reach. Unless we provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and can be stored for up to two years.
General information on revocation and objection (so-called “opt-out”): Users can revoke the consent they have given at any time and object to processing in accordance with the legal requirements. Among other things, users can restrict the use of cookies in their browser settings (although this may also restrict the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing operations, procedures and services:
- Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the consent of users to the use of cookies or the processing and providers mentioned in the cookie consent management procedure can be obtained, managed and revoked by users. The declaration of consent is stored so that it does not have to be requested again and the consent can be proven in accordance with the legal obligation. Consent can be stored on the server 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: Consent may be stored for up to two years. A pseudonymous user identifier is created 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; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Real Cookie Banner: We use the “Real Cookie Banner” consent tool to manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents. Details on how “Real Cookie Banner” works can be found at https://devowl.io/de/rcb/datenverarbeitung/.Rechtsgrundlagen for the processing of personal data in this context are Art. 6 para. 1 lit. c GDPR and Art. 6 para. 1 lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents; the provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consent.
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Business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships and associated measures and in the context of communication with the contractual partners (or pre-contractual), e.g. to answer inquiries.
We process this data in order to fulfill our contractual obligations. These include, in particular, the obligations to provide the agreed services, any updating obligations and remedies in the event of warranty and other service disruptions. In addition, we process the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations and the company organization. In addition, we process the data on the basis of our legitimate interests in proper and efficient business management and in security measures to protect our contractual partners and our business operations from misuse, threats to their data, secrets, information and rights (e.g. to involve telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about other forms of processing, e.g. for marketing purposes, as part of this privacy policy.
We inform the contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks or similar), or personally.
We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal archiving reasons. The statutory retention period is ten years for documents relevant under tax law as well as for trading books, inventories, opening balance sheets, annual financial statements, the work instructions required to understand these documents and other organizational documents and accounting records, and six years for commercial and business letters received and reproductions of commercial and business letters sent. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was prepared, the commercial or business letter was received or sent or the accounting document was created, the record was made or the other documents were created.
Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.
- Processed data types: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. email, telephone numbers); contract data (e.g. subject matter of contract, duration, customer category); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Persons affected: Customers; interested parties. Business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; security measures; contact requests and communication; office and organizational procedures. Managing and responding to inquiries.
- Legal basis: Fulfilment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Customer account: Customers can create an account within our online offering (e.g. customer or user account, “customer account” for short). If it is necessary to register a customer account, customers will be informed of this and of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. As part of the registration process and subsequent logins and use of the customer account, we store the IP addresses of customers together with the access times in order to be able to prove registration and prevent any misuse of the customer account. If the customer account has been terminated, the customer account data will be deleted after the termination date, unless it is stored for purposes other than provision in the customer account or must be stored for legal reasons (e.g. internal storage of customer data, order processes or invoices). It is the customer’s responsibility to back up their data when the customer account is terminated; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- Wish list: Customers can create a product/wish list. In this case, the products are stored as part of the fulfillment of our contractual obligations until the account is deleted, unless the product list entries are removed by the customer or we expressly inform the customer of different storage periods; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- Store and e-commerce: We process the data of our customers to enable them to select, purchase or order the selected products, goods and associated services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution for our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such in the context of the order or comparable purchase process and includes the information required for delivery or provision and billing as well as contact information in order to be able to hold any consultation; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Providers and services used in the course of business activities
As part of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers (“services” for short) in compliance with legal requirements. Their use is based on our interests in the proper, lawful and economic management of our business operations and our internal organization.
- Processed data types: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); contract data (e.g. subject matter of the contract, term, customer category).
- Data subjects: Customers; interested parties; users (e.g. website visitors, users of online services). Business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Office and organizational procedures.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Payment procedure
In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the data subjects efficient and secure payment options and use other service providers in addition to banks and credit institutions (collectively “payment service providers”).
The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored by them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the general terms and conditions and the data protection information of the payment service providers.
Payment transactions are subject to the terms and conditions and data protection notices of the respective payment service providers, which can be accessed on the respective websites or transaction applications. We also refer to these for further information and the assertion of rights of revocation, information and other rights of data subjects.
- Processed data types: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of the contract, duration, customer category); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Persons affected: Customers. Interested parties.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations.
- Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing operations, procedures and services:
- PayPal: Payment services (technical connection of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.paypal.com/de. Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
Provision of the online offer and web hosting
We process users’ data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or end device.
- Processed data types: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status); content data (e.g. entries in online forms).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called “web host”); legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files”. The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes 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 for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks) and to ensure the utilization of the servers and their stability; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
- 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 relating to the sending of e-mails (e.g. the providers involved) and the content of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, emails are encrypted in transit, but not on the servers from which they are sent and received (unless an end-to-end encryption method is used). We can therefore accept no responsibility for the transmission path of the emails between the sender and receipt on our server; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Service provider: undefined; Website: undefined. Privacy policy: undefined.
- ALL-INKL: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: ALL-INKL.COM – Neue Medien Münnich, Owner: René Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://all-inkl.com/; Privacy Policy: https://all-inkl.com/datenschutzinformationen/. Data processing agreement: Provided by the service provider.
Contact and inquiry management
When contacting us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the data of the inquiring persons will be processed to the extent necessary to answer the contact requests and any requested measures.
- Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Affected persons: Communication partner.
- Purposes of Processing: Contact requests and communication; Managing and responding to inquiries; Feedback (e.g. collecting feedback via online form). Provision of our online services and user-friendliness.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information 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 provided to us in this context to process the communicated request; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
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.
We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users’ rights.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of 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 generally stored on the user’s computer, in which the user’s usage behavior and interests are stored. Furthermore, data can 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 opt-out options, please refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
- Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: contact requests and communication; feedback (e.g. collecting feedback via online form). Marketing.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com. Privacy Policy: https://instagram.com/about/legal/privacy.
- Facebook pages: Profiles within the Facebook social network – 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 (known as a “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 used by users (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, known as “Page Insights”, for page operators to help them understand how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook (“Information on Page Insights”, https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of data subjects (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, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses(https://www.facebook.com/legal/EU_data_transfer_addendum). Further information: Agreement on joint controllership: https://www.facebook.com/legal/terms/information_about_page_insights_data. The joint controllership is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.)
Management, organization and support tools
We use services, platforms and software from other providers (hereinafter referred to as “third-party providers”) for the purposes of organizing, managing, planning and providing our services. When selecting third-party providers and their services, we observe the legal requirements.
In this context, personal data may be processed and stored on the servers of third-party providers. This may affect various data that we process in accordance with this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their content.
If users are referred to the third-party providers or their software or platforms in the context of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimization or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.
- Processed data types: Content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Communication partners; users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Office and organizational procedures.
Security
To protect this website, we use the Wordfence plugin. This is provided by Defiant. Inc, 1700 Westlake Ave N Ste 200, Seattle, WA 98109, USA (hereinafter referred to as “Wordfence”). It is used in accordance with Article 6(1)(f) of the General Data Protection Regulation (GDPR) on the basis of our legitimate interests.
Wordfence serves to protect this website from viruses, malware, comment spam and unauthorized access (including cyber attacks such as brute force and DDoS attacks). To ensure effective protection, the IP addresses of visitors to this website are stored by Wordfence on its own servers. IP addresses that are classified as safe are added to a white list, while attackers such as hackers are denied access to this website. Thanks to the increased security that Wordfence offers this website, its visitors are also better protected against viruses and malware. Wordfence uses cookies to distinguish between human visitors and bots. The protection of this website and its visitors constitutes a legitimate interest pursuant to Article 6(1)(f) of the GDPR.
Further information on the collection and use of data by Wordfence can be found in Defiant’s privacy policy: https://www.wordfence.com/privacy-policy/
The transfer of data to the USA is based on the standard contractual clauses of the European Commission. Further details can be found here: https://www.wordfence.com/help/general-data-protection-regulation/
Amendment and updating of the privacy policy
We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing we carry out make this 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.
If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.
Definitions of terms
This section provides you with an overview of the terms used in this privacy policy. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.
- Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Controller: The “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 on personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it collection, analysis, storage, transmission or deletion.