Data protection
This privacy policy informs you about the nature, scope, and purpose of the processing of personal data (hereinafter referred to as "data") within the scope of providing our services and within our online offering and the associated websites, functions, and content, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as "online offering"). With regard to the terms used, such as "processing" or "controller," we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
Controller
Marco Brodbeck
Practice for Energy and Environmental Medicine
Spinnlerstrasse 2
4410 Liestal
Phone: +41 (0) 76 572 50 84
Email: praxis@energy-med.ch
Controller: M. Brodbeck
Types of processed data
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Inventory data (e.g., personal master data, names, or addresses).
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Contact data (e.g., email, telephone numbers).
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Content data (e.g., text inputs, photographs, videos).
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Usage data (e.g., visited websites, interest in content, access times).
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Meta/communication data (e.g., device information, IP addresses).
Categories of data subjects Visitors and users of the online offering (hereinafter collectively referred to as "users").
Purpose of processing
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Provision of the online offering, its functions, and content.
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Responding to contact inquiries and communicating with users.
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Security measures.
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Reach measurement/marketing.
Definitions used "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie), or one or more specific characteristics expressing the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
"Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and includes practically any handling of data.
"Pseudonymization" means 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 is not attributed to an identified or identifiable natural person.
"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.
The "controller" is the natural or legal person, authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
"Processor" means a natural or legal person, authority, institution, or other body processing personal data on behalf of the controller.
Legal basis for processing
In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. For users within the scope of the General Data Protection Regulation (GDPR), i.e., the EU and the European Economic Area (EEA), the following applies if the legal basis is not mentioned in the privacy policy:
The legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 GDPR. The legal basis for the processing to fulfill our services and perform contractual measures is Art. 6(1)(b) GDPR. The legal basis for processing to fulfill our legal obligations is Art. 6(1)(c) GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6(1)(d) GDPR serves as the legal basis. The legal basis for the processing required to perform a task carried out in the public interest or in the exercise of official authority vested in the controller is Art. 6(1)(e) GDPR. The legal basis for processing to safeguard our legitimate interests is Art. 6(1)(f) GDPR. The processing of data for purposes other than those for which the data was originally collected is governed by the provisions of Art. 6(4) GDPR. The processing of special categories of data (e.g., health data) according to Art. 9(1) GDPR is based on Art. 9(2) GDPR.
Security measures
We take appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, implementation costs, and the nature, scope, context, and purposes of processing, as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk.
Measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as access, input, disclosure, availability, and segregation of data. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, the deletion of data, and the response to data breaches. We also take the protection of personal data into account when developing or selecting hardware, software, and procedures, in accordance with the principle of data protection through technology design and data protection-friendly default settings.
Cooperation with data processors and third parties
If, in the course of our processing, we disclose data to other persons and companies (data processors, joint controllers, or third parties), transfer it to them, or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g., if a transfer of the data to third parties, such as payment service providers, is necessary for the performance of the contract), users have consented to such a transfer, a legal obligation provides for it, or based on our legitimate interests (e.g., when using agents, web hosts, etc.).
If we disclose, transmit, or grant access to data to other companies within our corporate group, this is done for administrative purposes, based on our legitimate interests, and within a legally permissible framework.
Transfers to third countries
If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA), or the Swiss Confederation) or if this is done in the context of using third-party services or disclosing, or transferring data to other persons or companies, this will only occur if it is done to fulfill our (pre)contractual obligations, with your consent, on the basis of a legal obligation, or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special requirements of Art. 44 ff. GDPR are met. This means that the processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to the EU (e.g., for the USA through the "Privacy Shield") or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").
Rights of Data Subjects
You have the right to request confirmation as to whether or not personal data concerning you is being processed, and to obtain information about this data and a copy of it in accordance with legal requirements.
You have the right, in accordance with legal requirements, to demand the completion of your personal data or the rectification of inaccurate data concerning you.
You have the right, according to legal requirements, to request that the relevant data be deleted immediately or, alternatively, to demand that the processing of the data be restricted.
You have the right, in accordance with legal requirements, to receive the personal data concerning you that you have provided to us and to request its transmission to other responsible parties.
Furthermore, according to legal requirements, you have the right to lodge a complaint with the competent supervisory authority.
Right to Withdraw Consent
You have the right to revoke any consent given in the future with effect for the future.
Right to Object
You can object to the future processing of data concerning you at any time in accordance with legal requirements. The objection can be made, in particular, against the processing for purposes of direct advertising.
Cookies and Right to Object to Direct Advertising
"Cookies" are small files that are stored on users' computers. Different information can be stored within cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after the user's visit within an online offering. Temporary cookies, or "session cookies" or "transient cookies," are cookies that are deleted after a user leaves an online offering and closes their browser. Such a cookie, for example, can store the contents of a shopping cart in an online shop or a login status. "Permanent" or "persistent" cookies are cookies that remain stored even after the browser is closed. For example, the login status can be stored if users visit the site again after several days. Likewise, such a cookie can store users' interests, which are used for range measurement or marketing purposes. "Third-party cookies" are cookies that are offered by providers other than the person responsible for operating the online offering (if only the person responsible's cookies are used, they are referred to as "first-party cookies").
We may use both temporary and permanent cookies and provide information about this in our privacy policy.
If users do not want cookies to be stored on their computer, they are asked to disable the corresponding option in their browser's system settings. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offering.
A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that in this case, not all functions of this online offering may be used.
Deletion of Data
The data processed by us will be deleted or restricted in their processing in accordance with legal requirements. Unless explicitly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose, and there are no legal retention obligations preventing their deletion.
If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
Changes and Updates to the Privacy Policy
We ask you to inform yourself regularly about the contents of our privacy policy. We will adjust the privacy policy as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g., consent) or other individual notification.
Business-related Processing
In addition, we process:
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Contract data (e.g., contract subject, duration, customer category).
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Payment data (e.g., bank details, payment history) from our customers, prospects, and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising, and market research.
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Order processing in the online shop and customer account
We process the data of our customers as part of the ordering process in our online shop to enable them to select and order the chosen products and services, as well as to make payment and delivery or execution possible.
The processed data includes inventory data, communication data, contract data, payment data, and the data subjects include our customers, prospects, and other business partners. The processing is carried out for the purpose of providing contractual services in the operation of an online shop, billing, delivery, and customer service. Hereby, we use session cookies for storing the contents of the shopping cart and permanent cookies for storing the login status.
The processing is carried out to fulfill our services and perform contractual measures (e.g., processing of orders) and as far as it is required by law (e.g., legally required archiving of business transactions for commercial and tax purposes). The data will only be disclosed to third parties within the scope of delivery, payment, or within the scope of the statutory permissions and obligations, as well as if this is done on the basis of our legitimate interests, about which we inform you in the context of this privacy policy (e.g., to legal and tax advisors, financial institutions, freight companies, and authorities).
Users can optionally create a user account, in which they can view their orders. During registration, the necessary mandatory information will be communicated to the users. User accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data with respect to the user account will be deleted, subject to their retention is necessary for commercial or tax reasons. Information in the customer account remains until its deletion with subsequent archiving in case of a legal obligation or our legitimate interests (e.g., in case of legal disputes). It is the responsibility of the users to secure their data before the end of the contract in case of termination.
As part of the registration and re-registration as well as the use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the users' interest in protection against misuse and other unauthorized use. This data will not be passed on to third parties unless it is necessary to pursue our legal claims as a legitimate interest or there is a legal obligation to do so.
Deletion takes place after the expiration of legal warranty and comparable obligations; the necessity of data retention is reviewed every three years; in the case of archiving obligations, deletion takes place after their expiration.
Agency services
We process the data of our customers as part of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/consulting, or maintenance, implementation of campaigns and processes/handling, server administration, data analysis/consulting services, and training services.
In doing so, we process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., email, telephone numbers), content data (e.g., text inputs, photographs, videos), contract data (e.g., subject matter of the contract, term), payment data (e.g., bank details, payment history), usage and metadata (e.g., as part of the evaluation and success measurement of marketing measures). We do not generally process special categories of personal data, unless they are part of a commissioned processing. The data subjects include our customers, prospects, and their customers, users, website visitors, or employees as well as third parties. The purpose of the processing is to provide contractual services, billing, and customer service. The legal basis for the processing results from Art. 6 Para. 1 lit. b GDPR (contractual services), Art. 6 Para. 1 lit. f GDPR (analysis, statistics, optimization, security measures). We process data that is necessary for the establishment and fulfillment of the contractual services and point out the necessity of their information. Disclosure to external parties only takes place if it is necessary within the scope of an order. When processing the data provided to us within the framework of an order, we act in accordance with the instructions of the client and the legal requirements of order processing pursuant to Art. 28 GDPR and process the data for no other purposes than those required by the order.
We delete the data after the expiration of legal warranty and comparable obligations. The necessity of data retention is reviewed every three years; in the case of statutory archiving obligations, deletion takes place after their expiration (6 years, pursuant to § 257 Para. 1 HGB, 10 years, pursuant to § 147 Para. 1 AO). In the case of data disclosed to us within the framework of an order by the client, we delete the data in accordance with the specifications of the order, generally after the end of the order.
Therapeutic Services and Coaching
We process the data of our clients, prospects, and other contract partners (collectively referred to as "clients") in accordance with Art. 6(1)(b) GDPR to provide them with our contractual or pre-contractual services. The data processed, its type, scope, purpose, and necessity for processing are determined by the underlying contractual relationship. The processed data generally includes basic and master data of the clients (e.g., name, address, etc.), as well as contact details (e.g., email address, telephone, etc.), contract data (e.g., services used, fees, names of contact persons, etc.), and payment data (e.g., bank details, payment history, etc.).
As part of our services, we may also process special categories of data pursuant to Art. 9(1) GDPR, particularly health-related information of the clients, potentially related to their sex life or sexual orientation, ethnic origin, or religious or philosophical beliefs. For this purpose, we obtain explicit consent from the clients in accordance with Art. 6(1)(a), Art. 7, Art. 9(2)(a) GDPR, and otherwise process the special categories of data for health-related purposes based on Art. 9(2)(h) GDPR, § 22(1)(1b) BDSG.
If necessary for contract fulfillment or required by law, we disclose or transmit the clients' data to other professionals, third parties involved in contract fulfillment, or necessary third parties, such as billing agencies or similar service providers, if this serves the provision of our services pursuant to Art. 6(1)(b) GDPR, is required by law pursuant to Art. 6(1)(c) GDPR, serves our or the clients' interests in efficient and cost-effective healthcare as a legitimate interest pursuant to Art. 6(1)(f) GDPR, or is necessary to protect the vital interests of the clients or another natural person or within the scope of consent pursuant to Art. 6(1)(a), Art. 7 GDPR.
Data will be deleted when it is no longer necessary to fulfill contractual or statutory duties of care or to handle any warranty and comparable obligations. The necessity of data retention is reviewed every three years; otherwise, the statutory retention obligations apply.
Contractual Services
We process the data of our contract partners and prospects, as well as other clients, customers, clients, or contract partners (collectively referred to as "contract partners") in accordance with Art. 6(1)(b) GDPR to provide them with our contractual or pre-contractual services. The data processed, its type, scope, purpose, and necessity for processing are determined by the underlying contractual relationship.
The processed data includes master data of our contract partners (e.g., names and addresses), contact details (e.g., email addresses and phone numbers), contract data (e.g., services used, contract content, contractual communication, names of contact persons), and payment data (e.g., bank details, payment history).
We generally do not process special categories of personal data unless they are part of a commissioned or contractually agreed-upon processing.
We process data that is necessary for the establishment and fulfillment of contractual services and point out the necessity of their provision if this is not evident to the contract partners. Disclosure to external individuals or companies will only occur if it is necessary within the scope of a contract. When processing data provided to us within the framework of an order, we act in accordance with the instructions of the clients and legal requirements.
As part of the use of our online services, we may store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the interests of users in protection against misuse and other unauthorized use. This data will not be disclosed to third parties unless it is necessary to pursue our claims pursuant to Art. 6(1)(f) GDPR or there is a legal obligation pursuant to Art. 6(1)(c) GDPR.
Data will be deleted when it is no longer necessary to fulfill contractual or statutory duties of care or to handle any warranty and comparable obligations. The necessity of data retention is reviewed every three years; otherwise, the statutory retention obligations apply.
External Payment Service Providers
We use external payment service providers through whose platforms users and we can carry out payment transactions (e.g., with links to the privacy policy, PayPal (https://www.paypal.com/de/webapps/mpp/ua/privacy-full), Klarna (https://www.klarna.com/de/datenschutz/), Skrill (https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/), Giropay (https://www.giropay.de/rechtliches/datenschutz-agb/), Visa (https://www.visa.de/datenschutz), Mastercard (https://www.mastercard.de/de-de/datenschutz.html), American Express (https://www.americanexpress.com/de/content/privacy-policy-statement.html).
In the context of fulfilling contracts, we use payment service providers based on Art. 6(1)(b) GDPR. Otherwise, we use external payment service providers based on our legitimate interests pursuant to Art. 6(1)(f) GDPR to offer our users effective and secure payment options.
The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs, and checksums, as well as contract, sum, and recipient-related information. This information is required to carry out the transactions. However, the data entered will only be processed and stored by the payment service providers. We do not receive any account or credit card-related information, but rather information with confirmation or negative disclosure of the payment. Under certain circumstances, data may be transmitted by the payment service providers to credit reporting agencies. The purpose of this transmission is to check identity and creditworthiness. For this, we refer to the terms and privacy policy of the payment service providers.
For payment transactions, the terms and conditions and the data protection information of the respective payment service providers apply, which can be accessed within the respective websites or transaction applications. We also refer to these for further information and to assert the right of withdrawal, access, and other data subject rights.
Trillon (TRIL) Stablecoin
If you wish to pay with Trillon, please select prepayment, and I will send you the POS link via email. Please note that there is a fee of 15% for processing payments with Trillon, which includes fees for the Trillando marketplace, processing fees, exchange fees, and bank fees for converting to fiat currency. Currently, there are many orders, so please plan for some waiting time.
Administration, Financial Accounting, Office Organization, Contact Management
We process data as part of administrative tasks, organizing our operations, financial accounting, and compliance with legal obligations, such as archiving. The data processed in this context is the same as the data we process in the provision of our contractual services. The legal bases for processing are Art. 6(1)(c) GDPR and Art. 6(1)(f) GDPR. Clients, prospects, business partners, and website visitors are affected by the processing. The purpose and our interest in processing lie in administration, financial accounting, office organization, data archiving, and tasks serving the maintenance of our business activities, the performance of our tasks, and the provision of our services. The deletion of data concerning contractual services and contractual communication corresponds to the information provided in these processing activities.
We disclose or transmit data to the tax authorities, consultants such as tax advisors or auditors, as well as other fee agencies and payment service providers.
Furthermore, based on our business interests, we store information about suppliers, organizers, and other business partners, for example, for future contact. We generally store this predominantly company-related data permanently.
Business Analysis and Market Research
In order to operate our business economically, recognize market trends, and understand the needs of our contractual partners and users, we analyze the data available to us concerning business transactions, contracts, inquiries, etc. We process inventory data, communication data, contract data, payment data, usage data, and metadata based on Art. 6(1)(f) GDPR. The data subjects include contractual partners, prospects, customers, visitors, and users of our online offerings.
The analyses are carried out for the purpose of business evaluation, marketing, and market research. In doing so, we may consider the profiles of registered users, including information about the services they have used. The analyses serve us to increase user-friendliness, optimize our offerings, and improve economic efficiency. The analyses are for our own use only and are not disclosed externally, unless they are anonymous analyses with aggregated values.
If these analyses or profiles are person-related, they will be deleted or anonymized upon termination of the users, otherwise after two years from the conclusion of the contract. In all other respects, the overall business analyses and general trend determinations are created as anonymously as possible.
Participation in Affiliate Partner Programs
Within our online offering, we use industry-standard tracking measures based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offering) pursuant to Art. 6(1)(f) GDPR. This is necessary for the operation of the affiliate system. Below, we inform users about the technical background.
The services offered by our contractual partners can also be advertised and linked on other websites (so-called affiliate links or after-buy systems, if, for example, links or services of third parties are offered after the conclusion of a contract). The operators of the respective websites receive a commission if users follow the affiliate links and then take advantage of the offers.
In summary, it is necessary for our online offering to be able to track whether users who are interested in affiliate links and/or the offers available from us then perceive the offers on the occasion of the affiliate links or our online platform. For this purpose, the affiliate links and our offers are supplemented by certain values that can be part of the link or otherwise, e.g., in a cookie. These values include, in particular, the referrer website (the source from which the user came to the affiliate link), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as tracking-specific values such as the advertisement ID, partner ID, and categorizations.
The online identifiers of the users used by us are pseudonymous values. This means that the online identifiers themselves do not contain personal data such as names or email addresses. Instead, they help us determine if the same user who clicked on an affiliate link or was interested in an offer through our online offering subsequently took advantage of the offer, i.e., for example, concluded a contract with the provider. However, the online identifier is personal insofar as the partner company and we have the online identifier along with other user data. Only in this way can the partner company tell us whether the user has taken advantage of the offer and we can, for example, pay out the bonus.
Data Protection Notice in the Application Process
We process applicant data solely for the purpose and within the scope of the application process in accordance with legal requirements. The processing of applicant data is carried out to fulfill our (pre)contractual obligations within the application process, as defined in Art. 6(1)(b) GDPR and Art. 6(1)(f) GDPR, provided that data processing becomes necessary for us, e.g., within the scope of legal proceedings (in Germany, § 26 BDSG also applies).
The application process requires applicants to provide us with their applicant data. The necessary applicant data is indicated, unless we offer an online form, in the job descriptions and generally includes personal information, postal and contact addresses, and application documents, such as cover letters, resumes, and certificates. Additionally, applicants may voluntarily provide us with additional information.
By submitting the application to us, applicants consent to the processing of their data for the purposes of the application process, in accordance with the scope and nature outlined in this data protection notice.
If, within the application process, special categories of personal data within the meaning of Art. 9(1) GDPR are voluntarily disclosed by applicants, their processing will also take place in accordance with Art. 9(2)(b) GDPR (e.g., health data, such as severely disabled status or ethnic origin). If, within the application process, special categories of personal data within the meaning of Art. 9(1) GDPR are requested from applicants, their processing will also take place in accordance with Art. 9(2)(a) GDPR (e.g., health data, if necessary for the exercise of the profession).
If provided, applicants can submit their applications to us using an online form on our website. The data will be transmitted to us in encrypted form according to the state of the art. Additionally, applicants can submit their applications to us via email. However, please note that emails are generally not encrypted during transmission, and applicants must ensure encryption themselves. Therefore, we cannot take responsibility for the transmission path of the application between the sender and our server and recommend using an online form or postal mail instead. If applicants prefer to send their application by post, this option is also available.
In the event of a successful application, the data provided by applicants can be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicant's data will be deleted. The applicant's data will also be deleted if an application is withdrawn, to which applicants have a right at any time.
Deletion will take place, subject to a legitimate withdrawal by the applicants, after a period of six months so that we can answer any follow-up questions regarding the application and meet our obligations to provide evidence under the General Equal Treatment Act. Invoices for any travel reimbursement will be archived in accordance with tax regulations.
Registration Function
Users can create a user account. During the registration process, users will be informed about the required information and the processing of this data is based on Art. 6(1)(b) GDPR for the purpose of providing the user account. The data processed includes login information (name, password, and an email address). The data entered during the registration process will be used for the purpose of operating the user account and its intended purpose.
Users can be informed by email about information relevant to their user account, such as technical changes. If users have canceled their user account, their data will be deleted concerning the user account, subject to a legal retention requirement. It is the users' responsibility to secure their data before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract.
As part of the registration and login process and the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests and user protection against misuse and other unauthorized use. This data will not be passed on to third parties unless there is a legal obligation to do so under Art. 6(1)(c) GDPR. IP addresses are anonymized or deleted at the latest after 7 days.
Contact
When contacting us (e.g., via contact form, email, telephone, or social media), the user's details will be processed for processing the contact request and its handling in accordance with Art. 6(1)(b) GDPR (within the framework of contractual/pre-contractual relationships) and Art. 6(1)(f) GDPR (other inquiries). The user's details may be stored in a customer relationship management system (CRM system) or similar inquiry organization.
We delete the inquiries if they are no longer necessary. We review the necessity every two years; the legal archiving obligations also apply.
Newsletter
With the following information, we inform you about the contents of our newsletter as well as the registration, shipping, and statistical evaluation procedures, and your right of objection. By subscribing to our newsletter, you agree to receive it and the described procedures.
Newsletter Content: We send newsletters, emails, and other electronic notifications with promotional information (hereinafter "Newsletter") only with the recipient's consent or a legal permission. If the contents of the newsletter are specifically described within the framework of the registration, they are decisive for the user's consent. Otherwise, our newsletters contain information about our services and us.
Double Opt-In and Logging: Registration for our newsletter is carried out using a double opt-in procedure. After registration, users receive an email asking them to confirm their registration. This confirmation is necessary to prevent unauthorized persons from registering with someone else's email address. Newsletter registrations are logged to provide evidence of the registration process in accordance with legal requirements. This includes storing the login and confirmation times and the IP address. Changes to your data stored with the shipping service provider are also logged.
Registration Data: To subscribe to the newsletter, it is sufficient to provide your email address. Optionally, we ask users to provide a name for personal address in the newsletter.
Newsletter dispatch and the related success measurement are based on the user's consent in accordance with Art. 6(1)(a), Art. 7 GDPR, in conjunction with § 7(2)(3) German Unfair Competition Act (UWG), or, if consent is not required, on the basis of our legitimate interests in direct marketing pursuant to Art. 6(1)(f) GDPR, in conjunction with § 7(3) UWG.
The logging of the registration process is based on our legitimate interests in accordance with Art. 6(1)(f) GDPR. We are interested in using a user-friendly and secure newsletter system that serves both our business interests and the expectations of the users and also allows us to provide evidence of consent.
Cancellation/Revocation: Users can cancel the receipt of our newsletter at any time, i.e., revoke their consent. You will find a link to cancel the newsletter at the end of each newsletter. We may store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them to provide evidence of a previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time if the former existence of consent is confirmed.
Newsletter - Shipping Service Provider
The newsletter is sent using the shipping service provider [NAME, ADDRESS, COUNTRY]. The privacy policy of the shipping service provider can be viewed here: [LINK TO PRIVACY POLICY]. The shipping service provider is used on the basis of our legitimate interests according to Art. 6(1)(f) GDPR and an order processing contract according to Art. 28(3)(1) GDPR.
The shipping service provider may use the recipients' data in pseudonymous form, i.e., without allocation to a user, to optimize or improve its own services, e.g., for technical optimization of shipping and the presentation of newsletters or for statistical purposes. However, the shipping service provider does not use the data of our newsletter recipients to contact them directly or to pass the data on to third parties.
Newsletter - Success Measurement
The newsletters contain a so-called "web beacon," a pixel-sized file that is retrieved from our server, or, if we use a shipping service provider, from its server, when the newsletter is opened. Within this retrieval, technical information, such as browser and system information as well as the IP address and time of access, is initially collected.
This information is used for the technical improvement of the services based on technical data or audience behavior, such as access locations (which can be determined with the help of the IP address) or access times. The statistical analyses also include determining whether the newsletters are opened when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is not our intention, nor, if used, that of the shipping service provider, to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
A separate revocation of the success measurement is unfortunately not possible. In this case, the entire newsletter subscription must be canceled.
Hosting and Emailing
We use hosting services to provide the following services: infrastructure and platform services, computing capacity, storage space, and database services, email delivery, security services, and technical maintenance services that we use for the purpose of operating this online offering.
Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta, and communication data of customers, interested parties, and visitors to this online offering on the basis of our legitimate interests in an efficient and secure provision of this online offering pursuant to Art. 6(1)(f) GDPR in conjunction with Art. 28 GDPR (conclusion of an order processing contract).
Collection of Access Data and Log Files
We, or our hosting provider, collect data on each access to the server on which this service is located (so-called server log files) based on our legitimate interests within the meaning of Art. 6(1)(f) GDPR. The access data includes the name of the accessed webpage, file, date and time of access, transferred data volume, notification of successful access, browser type and version, the user's operating system, referrer URL (previously visited page), IP address, and the requesting provider.
Log file information is stored for security reasons (e.g., to investigate misuse or fraud) for a maximum of 7 days and then deleted. Data that is necessary for evidence purposes is excluded from deletion until the respective incident is finally clarified.
Google Analytics:
We use Google Analytics, a web analytics service provided by Google LLC ("Google"), based on our legitimate interests (i.e., our interest in analyzing, optimizing, and economically operating our online offering) in accordance with Art. 6(1)(f) GDPR. Google uses cookies. The information generated by the cookie about the use of our online offering by users is generally transmitted to a Google server in the USA and stored there.
Google is certified under the Privacy Shield agreement, which ensures compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online offering by users, to compile reports on the activities within this online offering, and to provide us with further services related to the use of this online offering and internet usage. Pseudonymous user profiles can be created from the processed data.
We use Google Analytics with IP anonymization enabled. This means that the IP address of users is truncated by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there.
The IP address transmitted by the user's browser is not merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent Google from collecting and processing the data generated by the cookie related to their use of our online offering by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
For more information on Google's data usage, settings, and opt-out options, please refer to Google's privacy policy (https://policies.google.com/privacy) and the settings for displaying ads by Google (https://adssettings.google.com/authenticated).
The personal data of users will be deleted or anonymized after 14 months.
Google Adsense with personalized ads:
Based on our legitimate interests (i.e., our interest in analyzing, optimizing, and economically operating our online offering) in accordance with Art. 6(1)(f) GDPR, we use the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google").
Google is certified under the Privacy Shield agreement, which ensures compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
We use the AdSense service to display ads on our website and receive compensation for their display or other use. For this purpose, usage data such as clicking on an ad and users' IP addresses are processed, with the IP address being truncated by the last two digits. Therefore, the processing of user data is pseudonymized.
We use Adsense with personalized ads. Google uses the websites or apps visited by users and the user profiles created from them to draw conclusions about their interests. Advertisers use this information to target their campaigns to users' interests, which benefits both users and advertisers. Ads are personalized by Google when collected or known data determine or influence the ad selection. This includes previous search queries, activities, website visits, app usage, demographic and location information. Specifically, this includes demographic targeting, targeting based on interests, remarketing, and targeting lists for customer match and audience lists uploaded to DoubleClick Bid Manager or Campaign Manager.
For more information on Google's data usage, settings, and opt-out options, please refer to Google's privacy policy (https://policies.google.com/technologies/ads) and the settings for displaying ads by Google (https://adssettings.google.com/authenticated).
Facebook Pixel, Custom Audiences, and Facebook Conversion:
We use the Facebook Pixel of the social network Facebook, operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are located in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, based on our legitimate interests (i.e., our interest in analyzing, optimizing, and economically operating our online offering) in accordance with Art. 6(1)(f) GDPR.
Facebook is certified under the Privacy Shield agreement, which ensures compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
With the help of the Facebook Pixel, Facebook can determine the visitors of our online offering as a target group for displaying ads (so-called "Facebook Ads"). Therefore, we use the Facebook Pixel to display our Facebook Ads only to Facebook users who have shown an interest in our online offering or who exhibit certain characteristics (e.g., interests in specific topics or products determined based on the visited web pages), which we transmit to Facebook (so-called "Custom Audiences"). With the Facebook Pixel, we also want to ensure that our Facebook Ads correspond to the potential interests of users and are not annoying. Additionally, the Facebook Pixel allows us to track the effectiveness of Facebook advertisements for statistical and market research purposes, by seeing if users were redirected to our website after clicking on a Facebook advertisement (so-called "Conversion").
The processing of data by Facebook is carried out within the framework of Facebook's data usage policy. For general information about displaying Facebook Ads and Facebook's data usage policy, visit: https://www.facebook.com/policy. For specific information and details about the Facebook Pixel and its functionality, visit the Facebook Help Center: https://www.facebook.com/business/help/651294705016616.
Users can object to the collection by the Facebook Pixel and the use of their data for displaying Facebook Ads. To adjust which types of ads are shown to you on Facebook, you can visit the page set up by Facebook and follow the instructions on usage-based advertising settings: https://www.facebook.com/settings?tab=ads. These settings apply across all devices, such as desktop computers or mobile devices.
You can also object to the use of cookies for audience measurement and advertising purposes through the deactivation page of the Network Advertising Initiative (http://optout.networkadvertising.org/) and additionally the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).