Privacy has a particularly high priority in our company.
The use of the websites of APART ELISABETH KG is generally possible without any indication of personal data. However, if a data subject wishes to make use of special services of our company via our website, the processing of personal data may become necessary.
If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.
For questions, you can reach us at office@apart-elisabeth.at
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject, always takes place in accordance with the General Data Protection Regulation and in compliance with the country-specific data protection regulations applicable to APART ELISABETH KG.
By means of this privacy policy, our company wishes to inform the public about the type, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects are informed of their rights by means of this privacy policy.
APART ELISABETH KG, as the controller responsible for processing, has implemented numerous technical and organizational measures to ensure the most complete protection possible of personal data processed through this website. Nevertheless, internet-based data transmissions can generally have security gaps, so absolute protection cannot be guaranteed.
For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.
1. Definitions
The privacy policy of APART ELISABETH KG is based on the terminology used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for the public, as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.
a) Personal data
Personal data means any information relating to an identified or identifiable natural person (hereinafter “data subject”).
An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
b) Data subject
A data subject is any identified or identifiable natural person whose personal data is processed by the controller.
c) Processing
Processing means any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.
e) Profiling
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
f) Pseudonymisation
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
g) Controller or controller responsible for processing
Controller or controller responsible for processing 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.
Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
h) Processor
Processor is a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
i) Recipient
Recipient is a natural or legal person, public authority, agency, or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry under Union or Member State law shall not be regarded as recipients.
j) Third party
Third party is a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
k) Consent
Consent is any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. Name and address of the controller
Controller for the purposes of the GDPR, other data protection laws applicable in Member States of the European Union, and other provisions related to data protection is:
APART ELISABETH KG
Föhrenweg 17
6414 Mieming
Austria
Phone: +43 5264 5261
E-Mail: office@apart-elisabeth.at
Website: www.apart-elisabeth.at
3. Cookies
The websites of APART ELISABETH KG use cookies. Cookies are text files that are stored on a computer system via an internet browser.
Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string of characters through which websites and servers can be assigned to the specific internet browser in which the cookie was stored.
This enables the visited websites and servers to distinguish the individual browser of the data subject from other internet browsers that contain other cookies. A specific internet browser can be recognized and identified by the unique cookie ID.
By using cookies, APART ELISABETH KG can provide users of this website with more user-friendly services that would not be possible without the cookie setting.
By means of a cookie, the information and offers on our website can be optimized in the sense of the user. Cookies enable us, as mentioned, to recognize the users of our website. The purpose of this recognition is to make it easier for users to utilize our website.
For example, a user of a website that uses cookies does not have to enter access data again each time they visit the website, because this is taken over by the website and the cookie stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop. The online shop remembers the articles that a customer has placed in the virtual shopping cart via a cookie.
The data subject may prevent the setting of cookies by our website at any time by means of a corresponding setting of the internet browser used and thus may permanently deny the setting of cookies. Furthermore, cookies already set may be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers.
If the data subject deactivates the setting of cookies in the internet browser used, not all functions of our website may be fully usable.
Necessary cookies
These cookies enable basic functions and are necessary for the proper functioning of the website.
Cookie name | Description | Duration |
Spamshield | This extension sets a cookie to test whether the visitor is a bot. It secures form entries. | Session |
PHPSESSID | gsrv001.easy-booking.at – This cookie is native to PHP applications. The cookie is used to store and identify a user’s unique session ID to manage the user session on the website. | Session |
Functional cookies
Cookie name | Description | Duration |
hcweb_branch | This cookie is set by the provider HolidayCheck. HolidayCheck uses third-party ad servers to place ads on the website. This cookie is used for data transfer to HolidayCheck. | 14 days |
internal_traffic | Holiday Check | 16 years 3 months 10 days 18 hours |
mobile_detected | This cookie is set by the provider HolidayCheck. This is a session cookie used to activate the HolidayCheck widget. | Session |
hcweb_www | Holiday Check | Session |
TAUnique | This cookie is set by the provider TripAdvisor. It is used to display travel information and ads based on user preferences. | 2 years |
TACds | This cookie is set by the provider TripAdvisor. It is used to display travel information and ads based on user preferences. | 2 month |
TADCID | TripAdvisor sets this cookie to store a unique ID for users so that they can display embedded content from TripAdvisor. | 10 years |
TASession | This cookie is set by the provider TripAdvisor. It is used for user tracking and the display of embedded TripAdvisor content, e.g. the payment of referral commission fees. | Session |
ServerPool | This cookie is set by the provider TripAdvisor. It is used for user tracking and the display of embedded TripAdvisor content, e.g. the payment of referral commission fees. | Session |
__vt | www.tripadvisor.at | 1 Stunde |
4. Collection of general data and information
The website of APART ELISABETH KG collects a series of general data and information each time the website is accessed by a data subject or an automated system. These general data and information are stored in the server log files.
The following may be collected: (1) browser types and versions used, (2) the operating system used, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the sub-websites, (5) the date and time of access, (6) an Internet Protocol address (IP address), (7) the internet service provider of the accessing system, and (8) other similar data and information used for security in the event of attacks on our information technology systems.
When using these general data and information, APART ELISABETH KG does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website and its advertising, (3) ensure the long-term viability of our IT systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber attack.
The anonymously collected data and information are therefore statistically evaluated and further analyzed with the aim of increasing data protection and data security in our company, and ultimately ensuring an optimal level of protection for the personal data we process.
5. Registration on our website
The data subject has the possibility to register on the website of the controller by providing personal data. Which personal data are transmitted to the controller results from the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for the controller’s own purposes. The controller may arrange for transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose attributable to the controller.
By registering on the website of the controller, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of these data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offences. In this respect, the storage of these data is necessary to secure the controller. These data are not passed on to third parties unless there is a legal obligation to pass them on, or the disclosure serves the purpose of criminal prosecution.
The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.
The controller shall, at any time and upon request, provide information to each data subject as to what personal data are stored about the data subject. In addition, the controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. All employees of the controller are available in this respect to the data subject as contact persons.
6. Subscription to our newsletter
On the website of APART ELISABETH KG, users are given the opportunity to subscribe to our company’s newsletter. Which personal data are transmitted to the controller when ordering the newsletter results from the input mask used for this purpose.
APART ELISABETH KG informs its customers and business partners regularly by means of a newsletter about company offers. Our company’s newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter mailing. For legal reasons, a confirmation e-mail is sent to the e-mail address entered by a data subject for the first time for newsletter dispatch, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.
When registering for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of registration, as well as the date and time of registration. The collection of these data is necessary in order to be able to trace the (possible) misuse of the e-mail address of a data subject at a later date, and therefore serves the legal protection of the controller.
The personal data collected in the context of a registration for the newsletter will be used exclusively for sending our newsletter. Furthermore, subscribers to the newsletter could be informed by e-mail, if this is necessary for the operation of the newsletter service or a registration in question, as could be the case in the event of changes to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for receiving the newsletter, may be revoked at any time. For the purpose of revoking consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller, or to inform the controller of this in another way.
7. Newsletter tracking
The newsletters of APART ELISABETH KG contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows for a statistical evaluation of the success or failure of online marketing campaigns.
Based on the embedded tracking pixel, APART ELISABETH KG may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.
Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the newsletter delivery and to better adapt the content of future newsletters to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the separate declaration of consent given through the double opt-in procedure. After a revocation, these personal data will be deleted by the controller. Unsubscribing from the receipt of the newsletter is automatically interpreted as a revocation.
8. Contact possibility via the website
Due to legal regulations, the website of APART ELISABETH KG contains information that enables quick electronic contact to our company, as well as direct communication with us, which also includes a general address of so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored.
Such personal data transmitted on a voluntary basis by a data subject to the controller are stored for the purpose of processing or contacting the data subject. There is no transfer of these personal data to third parties.
9. Routine erasure and blocking of personal data
The controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or insofar as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
10. Rights of the data subject
a) Right of confirmation
Every data subject shall have the right, granted by the European legislator, to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.
b) Right of access
Every data subject shall have the right, granted by the European legislator, to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European legislator has granted the data subject access to the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
- the existence of the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from the data subject: any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.
c) Right to rectification
Every data subject shall have the right, granted by the European legislator, to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.
d) Right to erasure (Right to be forgotten)
Every data subject shall have the right, granted by the European legislator, to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- The data subject withdraws consent on which the processing is based according to point (a) of Article 6(1) GDPR, or point (a) of Article 9(2) GDPR, and where there is no other legal ground for the processing.
- The data subject objects to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) GDPR.
- The personal data have been unlawfully processed.
- The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.
- If one of the above reasons applies, and a data subject wishes to request the erasure of personal data stored by APART ELISABETH KG, he or she may, at any time, contact any employee of the controller. An employee of APART ELISABETH KG shall promptly ensure that the erasure request is complied with immediately.
- Where the controller has made personal data public and is obliged pursuant to Article 17(1) GDPR to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, insofar as processing is not required. An employee of APART ELISABETH KG will arrange the necessary measures in individual cases.
e) Right of restriction of processing
Every data subject shall have the right, granted by the European legislator, to obtain from the controller restriction of processing where one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
- The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use.
- The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise, or defense of legal claims.
The data subject has objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
- If one of the above conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by APART ELISABETH KG, he or she may at any time contact any employee of the controller. The employee of APART ELISABETH KG will arrange the restriction of processing.
f) Right to data portability
Every data subject shall have the right, granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) GDPR or point (a) of Article 9(2) GDPR, or on a contract pursuant to point (b) of Article 6(1) GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact any employee of APART ELISABETH KG.
g) Right to object
Every data subject shall have the right, granted by the European legislator, to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) GDPR. This also applies to profiling based on these provisions.
APART ELISABETH KG shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims.
If APART ELISABETH KG processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to APART ELISABETH KG to the processing for direct marketing purposes, APART ELISABETH KG will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by APART ELISABETH KG for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the data subject may contact any employee of APART ELISABETH KG.
h) Automated individual decision-making, including profiling
Every data subject shall have the right, granted by the European legislator, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights, freedoms, and legitimate interests, or (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, APART ELISABETH KG shall implement suitable measures to safeguard the data subject’s rights, freedoms, and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view, and to contest the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of APART ELISABETH KG.
i) Right to withdraw data protection consent
Every data subject shall have the right, granted by the European legislator, to withdraw his or her consent to the processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw consent, he or she may, at any time, contact any employee of APART ELISABETH KG.
11. Data protection in applications and the application procedure
The controller collects and processes the personal data of applicants for the purpose of managing the application procedure. Processing may also take place electronically. This is particularly the case if an applicant submits relevant application documents to the controller by electronic means, for example by e-mail or via a web form on the website.
If the controller concludes an employment contract with an applicant, the transmitted data will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions.
If the controller does not conclude an employment contract with the applicant, the application documents will automatically be erased six months after notification of the rejection decision, provided that no other legitimate interests of the controller conflict with such erasure. Another legitimate interest in this sense could be, for example, a burden of proof in proceedings under the General Equal Treatment Act (AGG).
12. Data protection provisions on the use and application of Facebook
On this website, the controller has integrated components of the company Facebook. Facebook is a social network
A social network is a social meeting place operated on the Internet, an online community that usually allows users to communicate with each other and to interact in a virtual space. A social network may serve as a platform for exchanging opinions and experiences, or enables the Internet community to provide personal or company-related information. Facebook allows users of the social network to create private profiles, upload photos, and network through friend requests, among other things.
The operating company of Facebook is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
Each time one of the individual pages of this website, which is operated by the controller and on which a Facebook component (Facebook plug-in) has been integrated, is called up, the Internet browser on the information technology system of the data subject is automatically prompted by the respective Facebook component to download a display of the corresponding Facebook component from Facebook. A complete overview of all Facebook plug-ins may be accessed at developers.facebook.com/docs/plugins/. As part of this technical procedure, Facebook is informed about which specific sub-page of our website is visited by the data subject.
If the data subject is logged in at the same time on Facebook, Facebook detects with each call-up to our website by the data subject—and for the entire duration of their stay on our website—which specific sub-page of our Internet page was visited by the data subject. This information is collected by the Facebook component and assigned by Facebook to the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our website, for example the “Like” button, or if the data subject submits a comment, then Facebook assigns this information to the personal Facebook user account of the data subject and stores these personal data.
Facebook always receives, through the Facebook component, information about a visit to our website by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our website. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our website is made.
The data policy published by Facebook, available at www.facebook.com/about/privacy/, provides information about the collection, processing, and use of personal data by Facebook. It also explains which setting options Facebook offers to protect the privacy of the data subject. In addition, various configuration options are made available to allow the elimination of data transmission to Facebook. These applications may be used by the data subject to eliminate a data transmission to Facebook.
13. Data protection provisions on the use and application of Google AdSense
On this website, the controller has integrated Google AdSense. Google AdSense is an online service that enables the placement of advertisements on third-party websites. Google AdSense is based on an algorithm that selects the advertisements displayed on third-party sites according to the content of the respective third-party site. Google AdSense allows an interest-based targeting of the Internet user, which is implemented by generating individual user profiles.
The operating company of Google AdSense is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
The purpose of the Google AdSense component is the integration of advertisements on our website. Google AdSense places a cookie on the information technology system of the data subject. What cookies are has already been explained above. By placing the cookie, Alphabet Inc. is enabled to analyze the use of our website. Each time one of the individual pages of this website, which is operated by the controller and on which a Google AdSense component has been integrated, is called up, the Internet browser on the information technology system of the data subject is automatically prompted by the respective Google AdSense component to submit data to Alphabet Inc. for the purpose of online advertising and the settlement of commissions. As part of this technical procedure, Alphabet Inc. gains knowledge of personal data, such as the IP address of the data subject, which serves Alphabet Inc., among other things, to understand the origin of visitors and clicks and subsequently to enable commission settlements.
The data subject may, as already stated above, prevent the setting of cookies by our website at any time by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Alphabet Inc. from setting a cookie on the information technology system of the data subject. In addition, cookies already set by Alphabet Inc. may be deleted at any time via the Internet browser or other software programs.
Furthermore, Google AdSense also uses so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in web pages to enable log file recording and analysis, which allows statistical evaluation. Based on the embedded tracking pixel, Alphabet Inc. is able to recognize whether and when a website was opened by a data subject and which links were clicked on. Tracking pixels serve, among other things, to evaluate the flow of visitors to a website.
Via Google AdSense, personal data and information—which also includes the IP address, and is necessary for the collection and accounting of the displayed advertisements—are transmitted to Alphabet Inc. in the United States of America. These personal data are stored and processed in the United States of America. Google may disclose the personal data collected via this technical procedure to third parties.
Google AdSense is explained in more detail at www.google.com/intl/en/adsense/start/.
14. Data protection provisions on the use and application of Google Analytics (with anonymization function)
On this website, the controller has integrated the component of Google Analytics (with the anonymization function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and evaluation of data about the behavior of visitors to websites. A web analysis service collects, among other things, data about from which website a data subject came to a website (so-called referrer), which sub-pages of the website were accessed, or how often and for which period of time a sub-page was viewed. A web analysis is mainly used for the optimization of a website and for the cost-benefit analysis of Internet advertising.
The operating company of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
For web analytics through Google Analytics, the controller uses the application “_gat._anonymizeIp”. By means of this application, the IP address of the Internet connection of the data subject is shortened by Google and anonymized when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, among other things, to evaluate the use of our website, to compile online reports showing the activities on our websites, and to provide other services concerning the use of our Internet site for us.
Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies was explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. Each time one of the individual pages of this website, which is operated by the controller and on which a Google Analytics component has been integrated, is called up, the Internet browser on the information technology system of the data subject is automatically prompted by the respective Google Analytics component to submit data for the purpose of online analysis to Google. In the course of this technical procedure, Google gains knowledge of personal data, such as the IP address of the data subject, which serves Google, among other things, to understand the origin of visitors and clicks and subsequently create commission settlements.
By means of the cookie, personal information, for example the access time, the place from which access was made, and the frequency of visits to our website by the data subject, is stored. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, are transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.
In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google, and the chance to preclude any such. For this purpose, the data subject must download and install a browser add-on under the link tools.google.com/dlpage/gaoptout. This browser add-on tells Google Analytics via JavaScript that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-on is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.
Further information and the applicable data protection provisions of Google may be retrieved under www.google.com/intl/en/policies/privacy/ and under www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following link: www.google.com/analytics/.
15. Data protection provisions on the use and application of Google Remarketing
On this website, the controller has integrated Google Remarketing services. Google Remarketing is a function of Google AdWords which allows a company to display advertising to Internet users who have previously visited the company’s website. The integration of Google Remarketing therefore allows a company to create user-related advertising and thus to show relevant advertisements to interested Internet users.
The operating company of the Google Remarketing services is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
The purpose of Google Remarketing is the insertion of interest-relevant advertising. Google Remarketing allows us to display ads via the Google network or to have them displayed on other websites tailored to the individual needs and interests of Internet users.
Google Remarketing sets a cookie on the information technology system of the data subject. The definition of cookies was explained above. With the setting of the cookie, Google enables the recognition of the visitor to our website if he or she subsequently calls up websites that are also members of the Google advertising network. With each call-up to a website on which the service has been integrated by Google Remarketing, the Internet browser of the data subject identifies itself automatically to Google. As part of this technical procedure, Google receives personal information, such as the IP address or the surfing behavior of the user, which Google uses, among other things, for the insertion of interest-relevant advertising.
The cookie is used to store personal information, e.g. the Internet pages visited by the data subject. Each time our Internet pages are visited, personal data, including the IP address of the Internet access used by the data subject, are transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies by our website at any time by means of a corresponding adjustment of the Internet browser used and thus permanently deny the setting of cookies. Such an adjustment of the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, a cookie set by Google Analytics may be deleted at any time via the Internet browser or other software programs.
In addition, the data subject has the possibility of objecting to interest-based advertising by Google. For this purpose, the data subject must call up the link www.google.de/settings/ads from each of the Internet browsers he or she uses and make the desired settings there.
Further information and the applicable data protection provisions of Google may be retrieved under www.google.com/intl/en/policies/privacy/.
16. Data protection provisions on the use and application of Google AdWords
On this website, the controller has integrated Google AdWords. Google AdWords is an Internet advertising service that allows advertisers to place ads both in Google’s search engine results and in the Google advertising network. Google AdWords enables an advertiser to predefine certain keywords, by means of which an ad will only be displayed in Google’s search engine results when the user uses the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed to relevant web pages using an automatic algorithm, taking into account the previously defined keywords.
The operating company of Google AdWords is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
The purpose of Google AdWords is the promotion of our website by the inclusion of relevant advertising on the websites of third parties and in the search engine results of the search engine Google and an insertion of third-party advertising on our website.
If a data subject reaches our website via a Google ad, a conversion cookie is placed on the information technology system of the data subject by Google. The definition of cookies was explained above. A conversion cookie loses its validity after thirty days and is not used to identify the data subject. Provided the cookie has not yet expired, the conversion cookie is used to check whether certain sub-pages, e.g. the shopping cart of an online shop system, were called up on our website. Through the conversion cookie, both we and Google can understand whether a person who reached our website via an AdWords ad generated sales, i.e. executed or canceled a purchase of goods.
The data and information collected through the use of the conversion cookie are used by Google to create visit statistics for our website. These visit statistics are used in order to determine the total number of users who have been served through AdWords ads, in order to determine the success or failure of each AdWords ad and to optimize our AdWords ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject.
The conversion cookie stores personal information, e.g. the Internet pages visited by the data subject. Each time our Internet pages are visited, personal data, including the IP address of the Internet access used by the data subject, are transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, at any time, prevent the setting of cookies by our website, as already stated above, by means of a corresponding adjustment of the Internet browser used and thus permanently deny the setting of cookies. Such an adjustment of the Internet browser used would also prevent Google from placing a conversion cookie on the information technology system of the data subject. In addition, a cookie set by Google AdWords may be deleted at any time via the Internet browser or other software programs.
The data subject has a possibility of objecting to interest-based advertising by Google. Therefore, the data subject must access from each of the Internet browsers he or she uses the link www.google.de/settings/ads and set the desired settings.
Further information and the applicable data protection provisions of Google may be retrieved under www.google.com/intl/en/policies/privacy/.
17. Data protection provisions on the use and application of Instagram
On this website, the controller has integrated components of the service Instagram. Instagram is a service that may be qualified as an audiovisual platform, which allows users to share photos and videos, as well as to disseminate such data on other social networks.
The operating company of the Instagram services is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
Each time one of the individual pages of this website, which is operated by the controller and on which an Instagram component (Insta button) has been integrated, is called up, the Internet browser on the information technology system of the data subject is automatically prompted by the respective Instagram component to download a display of the corresponding component of Instagram. As part of this technical procedure, Instagram becomes aware of which specific sub-page of our website is visited by the data subject.
If the data subject is logged in at the same time on Instagram, Instagram detects with each call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-page of our website the data subject visited. This information is collected by the Instagram component and is assigned to the respective Instagram account of the data subject by Instagram. If the data subject clicks on one of the Instagram buttons integrated on our website, then Instagram matches this information with the personal Instagram user account of the data subject and stores the personal data.
Instagram receives information via the Instagram component that the data subject has visited our website, provided that the data subject is logged in at Instagram at the time of the call to our website. This occurs regardless of whether the person clicks on the Instagram button or not. If such a transmission of information to Instagram is not desirable for the data subject, then he or she can prevent this by logging off from their Instagram account before a call-up to our website is made.
Further information and the applicable data protection provisions of Instagram may be retrieved under help.instagram.com/519522125107875 and www.instagram.com/about/legal/privacy/.
18. Data protection provisions on the use and application of YouTube
On this website, the controller has integrated components of YouTube. YouTube is an Internet video portal that enables video publishers to set video clips and other users to view, review, and comment on them free of charge. YouTube allows the publication of all kinds of videos, so that both complete film and television broadcasts, as well as music videos, trailers, or videos made by users themselves, can be accessed via the Internet portal.
The operating company of YouTube is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
With each call-up to one of the individual pages of this website, which is operated by the controller and into which a YouTube component (YouTube video) has been integrated, the Internet browser on the information technology system of the data subject is automatically prompted by the respective YouTube component to download a display of the corresponding YouTube component from YouTube. Further information about YouTube can be obtained at www.youtube.com/yt/about/. As part of this technical procedure, YouTube and Google gain knowledge of which specific sub-page of our website was visited by the data subject.
If the data subject is logged in on YouTube, YouTube recognizes with each call-up to a sub-page that contains a YouTube video, which specific sub-page of our Internet site the data subject visited. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.
YouTube and Google receive information through the YouTube component that the data subject has visited our website whenever the data subject is logged in at YouTube at the time of calling up our website. This occurs regardless of whether the person clicks on a YouTube video or not. If such a transmission of this information to YouTube and Google is not desirable for the data subject, the delivery can be prevented if the data subject logs off from their own YouTube account before a call-up to our website is made.
YouTube’s data protection provisions, available at www.google.com/intl/en/policies/privacy/, provide information about the collection, processing, and use of personal data by YouTube and Google.
19. Payment method: Data protection provisions about the use of Klarna as a payment method
On this website, the controller has integrated Klarna components. Klarna is an online payment service provider that enables purchase on account or flexible installment payments. Klarna also offers other services, such as buyer protection or identity and credit checks.
The operating company of Klarna is Klarna Bank AB, Sveavägen 46, 111 34 Stockholm, Sweden.
If the data subject selects “purchase on account” or “installment purchase” as a payment option during the ordering process in our online shop, the data of the data subject are automatically transmitted to Klarna. By selecting one of these payment options, the data subject consents to the transmission of personal data required for the processing of the invoice or installment purchase, for identity verification, and for creditworthiness checks.
The personal data transmitted to Klarna are usually first name, surname, address, date of birth, gender, e-mail address, IP address, telephone number, mobile phone number, as well as other data necessary for processing an invoice or installment purchase. Personal data that are related to the respective order are also necessary for the processing of the purchase contract. In particular, this may include exchange of payment information such as bank details, card number, validity period, CVC code, number of items, product number, data on goods and services, prices, and tax charges, as well as information about previous purchase behavior or other details about the financial situation of the data subject.
The transmission of the data is intended in particular for identity verification, administration of payment transactions, and fraud prevention. The controller will transfer personal data to Klarna especially if there is a legitimate interest for the transfer. The personal data exchanged between Klarna and the controller will be transmitted by Klarna to credit reference agencies. The purpose of this transmission is to check identity and creditworthiness. Klarna also passes on the personal data to affiliated companies (Klarna Group) and service providers or subcontractors, insofar as this is necessary to fulfill contractual obligations or if the data are to be processed on behalf of Klarna.
Klarna collects and uses data and information about the previous payment behavior of the data subject, as well as probability values for their behavior in the future (so-called scoring), in order to decide on the establishment, implementation, or termination of a contractual relationship. The calculation of scoring is carried out on the basis of scientifically recognized mathematical-statistical methods.
The data subject has the possibility to revoke their consent to Klarna handling personal data at any time. A revocation does not affect personal data that must be processed, used, or transmitted for contractual payment processing.
The applicable privacy policy of Klarna can be retrieved at cdn.klarna.com/1.0/shared/content/legal/terms/0/en_gb/privacy.
20. Payment method: Data protection provisions about the use of PayPal as a payment method
On this website, the controller has integrated PayPal components. PayPal is an online payment service provider. Payments are processed via so-called PayPal accounts, which represent virtual private or business accounts. In addition, PayPal offers the option to process virtual payments via credit cards if a user does not maintain a PayPal account. A PayPal account is managed via an e-mail address, which is why there is no classic account number. PayPal makes it possible to initiate online payments to third parties or to receive payments as well. PayPal also assumes trustee functions and offers buyer protection services.
The operating company of PayPal in Europe is PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg.
If the data subject chooses “PayPal” as the payment option during the ordering process in our online shop, the data of the data subject are automatically transmitted to PayPal. By selecting this payment option, the data subject consents to the transmission of personal data required for payment processing.
The personal data transmitted to PayPal are usually first name, last name, address, e-mail address, IP address, telephone number, mobile phone number, or other data necessary for payment processing. In order to process the purchase contract, such personal data are also necessary that are in connection with the respective order.
The transmission of the data is intended for payment processing and fraud prevention. The controller will transmit personal data to PayPal in particular if there is a legitimate interest for the transmission. The personal data exchanged between PayPal and the controller may be transmitted by PayPal to credit reference agencies. The purpose of this transmission is to check identity and creditworthiness.
PayPal may pass on the personal data to affiliated companies and service providers or subcontractors, insofar as this is necessary to fulfill the contractual obligations or if the data are to be processed on behalf of PayPal.
The data subject has the possibility to revoke consent to the handling of personal data at any time from PayPal. A revocation shall not affect personal data which must be processed, used, or transmitted for (contractual) payment processing.
The applicable data protection provisions of PayPal may be retrieved at www.paypal.com/webapps/mpp/ua/privacy-full.
21. Payment method: Data protection provisions about the use of SOFORT as a payment method
On this website, the controller has integrated components of SOFORT. SOFORT is a payment service that enables cashless payment of products and services on the Internet. SOFORT is a technical procedure by which the online merchant immediately receives a payment confirmation. This allows a merchant to deliver goods, services, or downloads to the customer immediately after the order is placed.
The operating company of SOFORT is SOFORT GmbH, Fußbergstraße 1, 82131 Gauting, Germany. SOFORT GmbH is part of the Klarna Group (Klarna Bank AB, Sveavägen 46, 111 34 Stockholm, Sweden).
If the data subject selects “SOFORT” as the payment option during the ordering process in our online shop, data of the data subject are automatically transmitted to SOFORT. By selecting this payment option, the data subject consents to the transmission of personal data required for payment processing.
In the case of purchase processing via SOFORT, the buyer transmits the PIN and TAN to SOFORT GmbH. SOFORT then carries out a transfer to the online merchant after a technical check of the account balance and retrieval of further data to check funds. The execution of the financial transaction is then communicated to the online merchant automatically.
The personal data exchanged with SOFORT are first name, last name, address, e-mail address, IP address, telephone number, mobile phone number, or other data necessary for payment processing. The transmission of data is intended for payment processing and fraud prevention. The controller will also transmit other personal data to SOFORT if there is a legitimate interest in the transmission.
SOFORT may pass on the personal data to affiliated companies of the Klarna Group and service providers or subcontractors, insofar as this is necessary to fulfill contractual obligations or if the data are to be processed on behalf of SOFORT.
The data subject has the possibility to revoke consent to the handling of personal data at any time from SOFORT. A revocation shall not affect personal data which must necessarily be processed, used, or transmitted for (contractual) payment processing.
The applicable data protection provisions of SOFORT may be retrieved at www.klarna.com/sofort/datenschutz/.
22. Legal basis of processing
Article 6(1)(a) GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose.
If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or the provision of another service or consideration, the processing is based on Article 6(1)(b) GDPR. The same applies to processing operations that are necessary for carrying out pre-contractual measures, for example in the case of inquiries about our products or services.
If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Article 6(1)(c) GDPR.
In rare cases, the processing of personal data may be necessary in order to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his or her name, age, health insurance data, or other vital information had to be passed on to a doctor, hospital, or another third party. Then the processing would be based on Article 6(1)(d) GDPR.
Finally, processing operations could be based on Article 6(1)(f) GDPR. This legal basis is used for processing operations which are not covered by any of the aforementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject that require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47, Sentence 2 GDPR).
23. Legitimate interests pursued by the controller or a third party
Where the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is to carry out our business activities for the benefit of the well-being of all our employees and our shareholders.
24. Duration for which personal data are stored
The criterion used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data are routinely deleted, provided they are no longer necessary for the fulfillment of the contract or the initiation of a contract.
25. Provision of personal data as a statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; Possible consequences of failure to provide such data
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary, for the conclusion of a contract, that a data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of personal data would have the consequence that the contract with the data subject could not be concluded.
Before personal data are provided by the data subject, the data subject must contact one of our employees. Our employee clarifies to the data subject whether the provision of the personal data is required by law or contract, or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and the consequences of non-provision of the personal data.
26. Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.
27. Data protection provisions on the use of web fonts
This website uses so-called web fonts, provided by Google, for the uniform display of fonts. When a page is called up, the browser loads the required web fonts into the browser cache in order to display texts and fonts correctly.
For this purpose, the browser used by the data subject must connect to Google’s servers. As a result, Google becomes aware that our website was accessed via the IP address of the data subject. The use of Google Web Fonts is in the interest of a uniform and appealing presentation of our online offerings. This constitutes a legitimate interest within the meaning of Article 6(1)(f) GDPR.
If the browser of the data subject does not support web fonts, a standard font will be used by the computer of the data subject.
Further information on Google Web Fonts can be found at
www.google.com/fonts
www.google.com/policies/privacy/
Developed by the SaaS LegalTech specialists at Willing & Able, who also developed the system for implementing the online GDPR training.
The texts of the privacy policy generator were created and published by Prof. Dr. h.c. Heiko Jonny Maniero and attorney-at-law Christian Solmecke.