Privacy Policy

 

1. An overview of data protection

General information

The following information will provide you with an easy to navigate
overview of what will happen with your personal data when you visit this
website. The term “personal data” comprises all data that can be used to
personally identify you. For detailed information about the subject matter
of data protection, please consult our Data Protection Declaration, which
we have included beneath this copy.

Data recording on this website

Who is the responsible party for the recording of data on this website (i.e. the “controller”)?

The data on this website is processed by the operator of the website, whose contact information is available under section
“Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Policy.

How do we record your data?

We collect your data as a result of your sharing of your data with us.
This may, for instance be information you enter into our contact form.

Other data shall be recorded by our IT systems automatically or after you
consent to its recording during your website visit. This data comprises
primarily technical information (e.g. web browser, operating system, or
time the site was accessed). This information is recorded automatically
when you access this website.

What are the purposes we use your data for?

A portion of the information is generated to guarantee the error free
provision of the website. Other data may be used to analyze your user
patterns.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients,
and purposes of your archived personal data at any time without having to
pay a fee for such disclosures. You also have the right to demand that
your data are rectified or eradicated. If you have consented to data
processing, you have the option to revoke this consent at any time, which
shall affect all future data processing. Moreover, you have the right to
demand that the processing of your data be restricted under certain
circumstances. Furthermore, you have the right to log a complaint with the
competent supervising agency.

Please do not hesitate to contact us at any time if you have questions
about this or any other data protection related issues.

Analysis tools and tools provided by third parties

There is a possibility that your browsing patterns will be statistically
analyzed when your visit this website. Such analyses are performed
primarily with what we refer to as analysis programs.

For detailed information about these analysis programs please consult our
Data Protection Declaration below.

2. Hosting and Content Delivery Networks (CDN)

External Hosting

This website is hosted by an external service provider (host). Personal
data collected on this website are stored on the servers of the host.
These may include, but are not limited to, IP addresses, contact requests,
metadata and communications, contract information, contact information,
names, web page access, and other data generated through a web site.

The host is used for the purpose of fulfilling the contract with our
potential and existing customers (Art. 6 para. 1 lit. b GDPR) and in the
interest of secure, fast, and efficient provision of our online services
by a professional provider (Art. 6 para. 1 lit. f GDPR).

Our host will only process your data to the extent necessary to fulfil its
performance obligations and to follow our instructions with respect to
such data.

We are using the following host:

domainfactory GmbH
Oskar-Messter-Str. 33
85737 Ismaning

Execution of a contract data processing agreement

In order to guarantee processing in compliance with data protection
regulations, we have concluded an order processing contract with our host.

Cloudflare

We use the “Cloudflare” service provided by Cloudflare Inc., 101 Townsend
St., San Francisco, CA 94107, USA. (hereinafter referred to as
“Cloudflare”).

Cloudflare offers a content delivery network with DNS that is available
worldwide. As a result, the information transfer that occurs between your
browser and our website is technically routed via Cloudflare’s network.
This enables Cloudflare to analyze data transactions between your browser
and our website and to work as a filter between our servers and
potentially malicious data traffic from the Internet. In this context,
Cloudflare may also use cookies or other technologies deployed to
recognize Internet users, which shall, however, only be used for the
herein described purpose.

The use of Cloudflare is based on our legitimate interest in a provision
of our website offerings that is as error free and secure as possible
(Art. 6 Sect. 1 lit. f GDPR).

Data transmission to the US is based on the Standard Contractual Clauses
(SCC) of the European Commission. Details can be found here:
https://www.cloudflare.com/media/pdf/cloudflare-customer-dpa.pdf.

For more information on Cloudflare’s security precautions and data privacy
policies, please follow this link:
https://www.cloudflare.com/privacypolicy/.

Execution of a contract data processing agreement

In order to guarantee processing in compliance with data protection
regulations, we have concluded an order processing contract with
Cloudflare.

3. General information and mandatory information

Data protection

The operators of this website and its pages take the protection of your
personal data very seriously. Hence, we handle your personal data as
confidential information and in compliance with the statutory data
protection regulations and this Data Protection Declaration.

Whenever you use this website, a variety of personal information will be
collected. Personal data comprises data that can be used to personally
identify you. This Data Protection Declaration explains which data we
collect as well as the purposes we use this data for. It also explains
how, and for which purpose the information is collected.

We herewith advise you that the transmission of data via the Internet
(i.e. through e-mail communications) may be prone to security gaps. It is
not possible to completely protect data against third-party access.

Information about the responsible party (referred to as the “controller”
in the GDPR)

The data processing controller on this website is:

Kino-Hotel Meyer
Kino-Hotel Meyer Inh. M. Engelmann
Marktstraße 17,
21698 Harsefeld

Telefon: +49 4164 / 814 60
E-Mail: anfrage -at- kino-hotel -dot- de

The controller is the natural person or legal entity that single-handedly
or jointly with others makes decisions as to the purposes of and resources
for the processing of personal data (e.g. names, e-mail addresses, etc.).

Storage duration

Unless a more specific storage period has been specified in this privacy
policy, your personal data will remain with us until the purpose for which
it was collected no longer applies. If you assert a justified request for
deletion or revoke your consent to data processing, your data will be
deleted, unless we have other legally permissible reasons for storing your
personal data (e.g. tax or commercial law retention periods); in the
latter case, the deletion will take place after these reasons cease to
apply.

Information on data transfer to the USA

Our website uses, in particular, tools from companies based in the USA.
When these tools are active, your personal information may be transferred
to the US servers of these companies. We must point out that the USA is
not a safe third country within the meaning of EU data protection law. US
companies are required to release personal data to security authorities
without you as the data subject being able to take legal action against
this. The possibility cannot therefore be excluded that US authorities
(e.g. secret services) may process, evaluate, and permanently store your
data on US servers for monitoring purposes.  We have no influence over
these processing activities.

Revocation of your consent to the processing of data

A wide range of data processing transactions are possible only subject to
your express consent. You can also revoke at any time any consent you have
already given us. This shall be without prejudice to the lawfulness of any
data collection that occurred prior to your revocation.

Right to object to the collection of data in special cases; right to
object to direct advertising (Art. 21 GDPR)

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6 SECT. 1 LIT. E
OR F GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF
YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION.
THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE
THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT
THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO
LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO
PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR
DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE
OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL
ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21 SECT. 1 GDPR).

IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT
ADVERTISING, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF
YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING. THIS
ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH
DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO
LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART.
21 SECT. 2 GDPR).

Right to log a complaint with the competent supervisory agency

In the event of violations of the GDPR, data subjects are entitled to log
a complaint with a supervisory agency, in particular in the member state
where they usually maintain their domicile, place of work or at the place
where the alleged violation occurred. The right to log a complaint is in
effect regardless of any other administrative or court proceedings
available as legal recourses.

Right to data portability

You have the right to demand that we hand over any data we automatically
process on the basis of your consent or in order to fulfil a contract be
handed over to you or a third party in a commonly used, machine readable
format. If you should demand the direct transfer of the data to another
controller, this will be done only if it is technically feasible.

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential
content, such as purchase orders or inquiries you submit to us as the
website operator, this website uses either an SSL or a TLS encryption
program. You can recognize an encrypted connection by checking whether the
address line of the browser switches from “http://” to “https://” and also
by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, data you transmit to us cannot
be read by third parties.

Encrypted payment transactions on this website

If you are under an obligation to share your payment information (e.g.
account number if you give us the authority to debit your bank account)
with us after you have entered into a fee-based contract with us, this
information is required to process payments.

Payment transactions using common modes of paying (Visa/MasterCard, debit
to your bank account) are processed exclusively via encrypted SSL or TLS
connections. You can recognize an encrypted connection by checking whether
the address line of the browser switches from “http://” to “https://” and
also by the appearance of the lock icon in the browser line.

If the communication with us is encrypted, third parties will not be able
to read the payment information you share with us.

Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the
right to at any time demand information about your archived personal data,
their source and recipients as well as the purpose of the processing of
your data. You may also have a right to have your data rectified or
eradicated. If you have questions about this subject matter or any other
questions about personal data, please do not hesitate to contact us at any
time.

Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the
processing of your personal data is concerned. To do so, you may contact
us at any time. The right to demand restriction of processing applies in
the following cases:

  • In the event that you should dispute the correctness of your data
    archived by us, we will usually need some time to verify this claim.
    During the time that this investigation is ongoing, you have the right
    to demand that we restrict the processing of your personal data.
  • If the processing of your personal data was/is conducted in an unlawful
    manner, you have the option to demand the restriction of the processing
    of your data in lieu of demanding the eradication of this data.
  • If we do not need your personal data any longer and you need it to
    exercise, defend or claim legal entitlements, you have the right to
    demand the restriction of the processing of your personal data instead
    of its eradication.
  • If you have raised an objection pursuant to Art. 21 Sect. 1 GDPR, your
    rights and our rights will have to be weighed against each other. As
    long as it has not been determined whose interests prevail, you have the
    right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data –
with the exception of their archiving – may be processed only subject to
your consent or to claim, exercise or defend legal entitlements or to
protect the rights of other natural persons or legal entities or for
important public interest reasons cited by the European Union or a member
state of the EU.

Rejection of unsolicited e-mails

We herewith object to the use of contact information published in
conjunction with the mandatory information to be provided in our Site
Notice to send us promotional and information material that we have not
expressly requested. The operators of this website and its pages reserve
the express right to take legal action in the event of the unsolicited
sending of promotional information, for instance via SPAM messages.

4. Recording of data on this website

Cookies

Our websites and pages use what the industry refers to as “cookies.”
Cookies are small text files that do not cause any damage to your device.
They are either stored temporarily for the duration of a session (session
cookies) or they are permanently archived on your device (permanent
cookies). Session cookies are automatically deleted once you terminate
your visit. Permanent cookies remain archived on your device until you
actively delete them, or they are automatically eradicated by your web
browser.

In some cases, it is possible that third-party cookies are stored on your
device once you enter our site (third-party cookies). These cookies enable
you or us to take advantage of certain services offered by the third party
(e.g. cookies for the processing of payment services).

Cookies have a variety of functions. Many cookies are technically
essential since certain website functions would not work in the absence of
the cookies (e.g. the shopping cart function or the display of videos).
The purpose of other cookies may be the analysis of user patterns or the
display of promotional messages.

Cookies, which are required for the performance of electronic
communication transactions (required cookies) or for the provision of
certain functions you want to use (functional cookies, e.g. for the
shopping cart function) or those that are necessary for the optimization
of the website (e.g. cookies that provide measurable insights into the web
audience), shall be stored on the basis of Art. 6 Sect. 1 lit. f GDPR,
unless a different legal basis is cited. The operator of the website has a
legitimate interest in the storage of cookies to ensure the technically
error free and optimized provision of the operator’s services. If your
consent to the storage of the cookies has been requested, the respective
cookies are stored exclusively on the basis of the consent obtained (Art.
6 Sect. 1 lit. a GDPR); this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will
be notified any time cookies are placed and to permit the acceptance of
cookies only in specific cases. You may also exclude the acceptance of
cookies in certain cases or in general or activate the delete function for
the automatic eradication of cookies when the browser closes. If cookies
are deactivated, the functions of this website may be limited.

In the event that third-party cookies are used or if cookies are used for
analytical purposes, we will separately notify you in conjunction with
this Data Protection Policy and, if applicable, ask for your consent.

Cookie Consent with Cookiebot

Our website uses Cookie Content technology from Cookiebot to obtain your
consent to the storage of certain cookies on your end device and to
document this in a data protection-compliant manner. The provider of this
technology is Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark
(hereinafter “Cookiebot”).

When you enter our website, a connection is established with the Cookiebot
servers to obtain your consent and provide you with other explanations
regarding the use of cookies. Cookiebot will then store a cookie in your
browser to identify the consent you have given or its revocation. The data
collected in this way is stored until you request us to delete it, delete
the Cookiebot cookie itself or the purpose for which the data is stored no
longer applies. Mandatory legal storage obligations remain unaffected.

Cookiebot is used to obtain the legally required consent for the use of
cookies. The legal basis for this is Art. 6(1)(1)(c) GDPR.

Contract data processing agreement

Our company has executed a Contract Data Processing Agreement with
Cookiebot. This is an agreement mandated by data privacy protection
legislation that warrants that Cookiebot processes all personal data of
our website visitors exclusively in compliance with our instructions and
in compliance with the GDPR.

Server log files

The provider of this website and its pages automatically collects and
stores information in so-called server log files, which your browser
communicates to us automatically. The information comprises:

  • The type and version of browser used
  • The used operating system
  • Referrer URL
  • The hostname of the accessing computer
  • The time of the server inquiry
  • The IP address

This data is not merged with other data sources.

This data is recorded on the basis of Art. 6 Sect. 1 lit. f GDPR. The
operator of the website has a legitimate interest in the technically error
free depiction and the optimization of the operator’s website. In order to
achieve this, server log files must be recorded.

Contact form

If you submit inquiries to us via our contact form, the information
provided in the contact form as well as any contact information provided
therein will be stored by us in order to handle your inquiry and in the
event that we have further questions. We will not share this information
without your consent.

The processing of these data is based on Art. 6 para. 1 lit. b GDPR, if
your request is related to the execution of a contract or if it is
necessary to carry out pre-contractual measures. In all other cases the
processing is based on our legitimate interest in the effective processing
of the requests addressed to us (Art. 6 Para. 1 lit. f GDPR) or on your
agreement (Art. 6 Para. 1 lit. a GDPR) if this has been requested.

The information you have entered into the contact form shall remain with
us until you ask us to eradicate the data, revoke your consent to the
archiving of data or if the purpose for which the information is being
archived no longer exists (e.g. after we have concluded our response to
your inquiry). This shall be without prejudice to any mandatory legal
provisions – in particular retention periods.

Request by e-mail, telephone, or fax

If you contact us by e-mail, telephone or fax, your request, including all
resulting personal data (name, request) will be stored and processed by us
for the purpose of processing your request. We do not pass these data on
without your consent.

These data are processed on the basis of Art. 6 Sect. 1 lit. b GDPR if
your inquiry is related to the fulfillment of a contract or is required
for the performance of pre-contractual measures. In all other cases, the
data are processed on the basis of our legitimate interest in the
effective handling of inquiries submitted to us (Art. 6 Sect. 1 lit. f
GDPR) or on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR) if it
has been obtained.

The data sent by you to us via contact requests remain with us until you
request us to delete, revoke your consent to the storage or the purpose
for the data storage lapses (e.g. after completion of your request).
Mandatory statutory provisions - in particular statutory retention periods
- remain unaffected.

5. Analysis tools and advertising

Google Analytics

This website uses functions of the web analysis service Google Analytics.
The provider of this service is Google Ireland Limited (“Google”), Gordon
House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior
patterns of website visitors. To that end, the website operator receives a
variety of user data, such as pages accessed, time spent on the page, the
utilized operating system and the user’s origin. Google may consolidate
these data in a profile that is allocated to the respective user or the
user’s device.

Google Analytics uses technologies that make the recognition of the user
for the purpose of analyzing the user behavior patterns (e.g. cookies or
device fingerprinting). The website use information recorded by Google is,
as a rule transferred to a Google server in the United States, where it is
stored.

This analysis tool is used on the basis of Art. 6 Sect. 1 lit. f GDPR. The
operator of this website has a legitimate interest in the analysis of user
patterns to optimize both, the services offered online and the operator’s
advertising activities. If a corresponding agreement has been requested
(e.g. an agreement to the storage of cookies), the processing takes place
exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can
be revoked at any time.

Data transmission to the US is based on the Standard Contractual Clauses
(SCC) of the European Commission. Details can be found here:
https://privacy.google.com/businesses/controllerterms/mccs/.

IP anonymization

On this website, we have activated the IP anonymization function. As a
result, your IP address will be abbreviated by Google within the member
states of the European Union or in other states that have ratified the
Convention on the European Economic Area prior to its transmission to the
United States. The full IP address will be transmitted to one of Google’s
servers in the United States and abbreviated there only in exceptional
cases. On behalf of the operator of this website, Google shall use this
information to analyze your use of this website to generate reports on
website activities and to render other services to the operator of this
website that are related to the use of the website and the Internet. The
IP address transmitted in conjunction with Google Analytics from your
browser shall not be merged with other data in Google’s possession.

Browser plug-in

You can prevent the recording and processing of your data by Google by
downloading and installing the browser plugin available under the
following link:
https://tools.google.com/dlpage/gaoptout?hl=en.

For more information about the handling of user data by Google Analytics,
please consult Google’s Data Privacy Declaration at:
https://support.google.com/analytics/answer/6004245?hl=en.

Contract data processing

We have executed a contract data processing agreement with Google and are
implementing the stringent provisions of the German data protection
agencies to the fullest when using Google Analytics.

Demographic parameters provided by Google Analytics

This website uses the “demographic characteristics” function of Google
Analytics, to be able to display to the website visitor compatible ads
within the Google advertising network. This allows reports to be created
that contain information about the age, gender, and interests of the
website visitors. The sources of this information are interest-related
advertising by Google as well as visitor data obtained from third-party
providers. This data cannot be allocated to a specific individual. You
have the option to deactivate this function at any time by making
pertinent settings changes for advertising in your Google account or you
can generally prohibit the recording of your data by Google Analytics as
explained in section “Objection to the recording of data”.

Archiving period

Data on the user or incident level stored by Google linked to cookies,
user IDs or advertising IDs (e.g. DoubleClick cookies, Android advertising
ID) will be anonymized or deleted after 14 month. For details please click
the following link:
https://support.google.com/analytics/answer/7667196?hl=en

Google Ads

The website operator uses Google Ads. Google Ads is an online promotional
program of Google Ireland Limited (“Google”), Gordon House, Barrow Street,
Dublin 4, Ireland.

Google Ads enables us to display ads in the Google search engine or on
third-party websites, if the user enters certain search terms into Google
(keyword targeting). It is also possible to place targeted ads based on
the user data Google has in its possession (e.g. location data and
interests; target group targeting). As the website operator, we can
analyze these data quantitatively, for instance by analyzing which search
terms resulted in the display of our ads and how many ads led to
respective clicks.

The use of Google Ads is based on  Art. 6 Sect. 1 lit. et seq. GDPR. The
website operator has a legitimate interest in marketing the operator’s
services and products as effectively as possible.

Data transmission to the US is based on the Standard Contractual Clauses
(SCC) of the European Commission. Details can be found here:
https://privacy.google.com/businesses/controllerterms/mccs/.

Google DoubleClick

This website uses features of Google DoubleClick. The provider is Google
Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4,
Ireland, (hereinafter “DoubleClick”).

DoubleClick is used to show you interest-based ads across the Google
Network. Advertisements can be tailored to the interests of the viewer
using DoubleClick.  For example, our ads may appear in Google search
results or in banners associated with DoubleClick.

To be able to display interest adequate promotional content to users,
DoubleClick must recognize the respective visitor so that it can allocate
the websites visited, the clicks and other user pattern information to the
user. To do this, DoubleClick deploys cookies or comparable recognition
technologies (e.g. device fingerprinting). The recorded information is
consolidated into a pseudonym user profile so that the respective user can
be shown interest adequate advertising.

The use of Google DoubleClick takes place in the interest of targeted
advertising measures. This constitutes a legitimate interest within the
meaning of Art. 6 para. 1 lit. f GDPR. If a corresponding agreement has
been requested (e.g. an agreement to the storage of cookies), the
processing takes place exclusively on the basis of Art. 6 para. 1 lit. a
GDPR; the agreement can be revoked at any time.

For further information on how to object to the advertisements displayed
by Google, please see the following links:
https://policies.google.com/technologies/ads
and
https://adssettings.google.com/authenticated.

Facebook Pixel

To measure conversion rates, this website uses the visitor activity pixel
of Facebook. The provider of this service is Facebook Ireland Limited, 4
Grand Canal Square, Dublin 2, Ireland. According to Facebook’s statement
the collected data will be transferred to the USA and other third-party
countries too.

This tool allows the tracking of page visitors after they have been linked
to the website of the provider after clicking on a Facebook ad. This makes
it possible to analyze the effectiveness of Facebook ads for statistical
and market research purposes and to optimize future advertising campaigns.

For us as the operators of this website, the collected data is anonymous.
We are not in a position to arrive at any conclusions as to the identity
of users. However, Facebook archives the information and processes it, so
that it is possible to make a connection to the respective user profile
and Facebook is in a position to use the data for its own promotional
purposes in compliance with the
Facebook Data Usage Policy. This enables Facebook to display ads on Facebook pages as well as in
locations outside of Facebook. We as the operator of this website have no
control over the use of such data.

The use of Facebook Pixel is based on Art. 6 Sect. 1 lit. f GDPR. The
operator of the website has a legitimate interest in effective advertising
campaigns, which also include social media. If a corresponding agreement
has been requested (e.g. an agreement to the storage of cookies), the
processing takes place exclusively on the basis of Art. 6 para. 1 lit. a
GDPR; the agreement can be revoked at any time.

Data transmission to the US is based on the Standard Contractual Clauses
(SCC) of the European Commission. Details can be found here:
https://www.facebook.com/legal/EU_data_transfer_addendum
und
https://de-de.facebook.com/help/566994660333381.

In Facebook’s Data Privacy Policies, you will find additional information
about the protection of your privacy at:
https://www.facebook.com/about/privacy/.

You also have the option to deactivate the remarketing function “Custom
Audiences” in the ad settings section under  https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you first have to log into Facebook.

If you do not have a Facebook account, you can deactivate any user based
advertising by Facebook on the website of the European Interactive Digital
Advertising Alliance:
http://www.youronlinechoices.com/de/praferenzmanagement/.

6. Newsletter

Newsletter data

If you would like to subscribe to the newsletter offered on this website,
we will need from you an e-mail address as well as information that allow
us to verify that you are the owner of the e-mail address provided and
consent to the receipt of the newsletter. No further data shall be
collected or shall be collected only on a voluntary basis. We shall use
such data only for the sending of the requested information and shall not
share such data with any third parties.

The processing of the information entered into the newsletter subscription
form shall occur exclusively on the basis of your consent (Art. 6 Sect. 1
lit. a GDPR). You may revoke the consent you have given to the archiving
of data, the e-mail address and the use of this information for the
sending of the newsletter at any time, for instance by clicking on the
“Unsubscribe” link in the newsletter. This shall be without prejudice to
the lawfulness of any data processing transactions that have taken place
to date.

The data deposited with us for the purpose of subscribing to the
newsletter will be stored by us until you unsubscribe from the newsletter
or the newsletter service provider and deleted from the newsletter
distribution list after you unsubscribe from the newsletter or after the
purpose has ceased to apply. We reserve the right to delete or block
e-mail addresses from our newsletter distribution list at our own
discretion within the scope of our legitimate interest in accordance with
Art. 6(1)(f) GDPR.

After you unsubscribe from the newsletter distribution list, your e-mail
address may be stored by us or the newsletter service provider in a
blacklist to prevent future mailings. The data from the blacklist is used
only for this purpose and not merged with other data. This serves both
your interest and our interest in complying with the legal requirements
when sending newsletters (legitimate interest within the meaning of Art. 6
para. 1 lit. f GDPR). The storage in the blacklist is indefinite.
You may object to the storage if your interests outweigh our legitimate
interest.

Sendinblue

This website uses Sendinblue for the sending of newsletters. The provider
is the Sendinblue GmbH, Köpenicker Straße 126, 10179 Berlin, Germany.

Sendinblue services can, among other things, be used to organize and
analyze the sending of newsletters. The data you enter for the purpose of
subscribing to the newsletter are archived on Sendinblue’s servers in
Germany.

If you do not want to permit an analysis by Sendinblue, you must
unsubscribe from the newsletter. We provide a link for you to do this in
every newsletter message. Moreover, you can also unsubscribe from the
newsletter right on the website.

Data analysis by Sendinblue

Sendinblue enables us to analyze our newsletter campaigns. For instance,
it allows us to see whether a newsletter message has been opened and, if
so, which links may have been clicked. This enables us to determine, which
links drew an extraordinary number of clicks.

Moreover, we are also able to see whether once the e-mail was opened or a
link was clicked, any previously defined actions were taken (conversion
rate). This allows us to determine whether you have made a purchase after
clicking on the newsletter.

Sendinblue also enables us to divide the subscribers to our newsletter
into various categories (i.e. to “cluster” recipients). For instance,
newsletter recipients can be categorized based on age, gender, or place of
residence. This enables us to tailor our newsletter more effectively to
the needs of the respective target groups.

For detailed information on the functions of Sendinblue please follow this
link:
https://www.sendinblue.com/newsletter-software/.

Legal basis

The data is processed based on your consent (Art. 6 Sect. 1 lit. a GDPR).
You may revoke any consent you have given at any time by unsubscribing
from the newsletter. This shall be without prejudice to the lawfulness of
any data processing transactions that have taken place prior to your
revocation.

Storage period

The data deposited with us for the purpose of subscribing to the
newsletter will be stored by us until you unsubscribe from the newsletter
or the newsletter service provider and deleted from the newsletter
distribution list after you unsubscribe from the newsletter. Data stored
for other purposes with us remain unaffected.

After you unsubscribe from the newsletter distribution list, your e-mail
address may be stored by us or the newsletter service provider in a
blacklist to prevent future mailings. The data from the blacklist is used
only for this purpose and not merged with other data. This serves both
your interest and our interest in complying with the legal requirements
when sending newsletters (legitimate interest within the meaning of Art. 6
para. 1 lit. f GDPR). The storage in the blacklist is indefinite.
You may object to the storage if your interests outweigh our legitimate
interest.

For more details, please consult the Data Protection Regulations of
Sendinblue at:
https://de.sendinblue.com/datenschutz-uebersicht/.

Execution of a contract data processing agreement

We have executed a contract with Sendinblue, in which we require
Newsletters2Go to protect our customers’ data and to refrain from sharing
such data with third parties.

7. Plug-ins and Tools

Google Web Fonts (local embedding)

This website uses so-called Web Fonts provided by Google to ensure the
uniform use of fonts on this site. These Google fonts are locally
installed so that a connection to Google’s servers will not be established
in conjunction with this application.

For more information on Google Web Fonts, please follow this link:
https://developers.google.com/fonts/faq
and consult Google’s Data Privacy Declaration under:
https://policies.google.com/privacy?hl=en.

Font Awesome (local embedding)

This website uses Font Awesome to ensure the uniform use of fonts on this
site. Font Awesome is locally installed so that a connection to Fonticons,
Inc.’s servers will not be established in conjunction with this
application.

For more information on Font Awesome, please and consult the Data Privacy
Declaration for Font Awesome under:
https://fontawesome.com/privacy.

Wordfence

We have included Wordfence on this website. The provider is Defiant Inc,
Defiant, Inc, 800 5th Ave Ste 4100, Seattle, WA 98104, USA (hereinafter
Wordfence).

Wordfence is designed to protect our website from unwanted access or
malicious cyberattacks. To accomplish this, our website establishes a
permanent connection with Wordfence’s servers, which check and block their
databases against access to our website.

The use of Wordfence is based on Art. 6(1)(f) GDPR. The website operator
has a legitimate interest in the most effective protection of his website
against cyberattacks. If the appropriate consent has been requested,
processing will be carried out exclusively on the basis of Art. 6 para. 1
letter a GDPR; consent may be revoked at any time.

Data transmission to the USA is based on the standard contractual clauses
of the EU Commission. Details can be found here:
https://www.wordfence.com/help/general-data-protection-regulation/.

Execution of a contract data processing agreement

We have concluded an order processing contract with Wordfence. This is a
data protection contract that is required by data protection law and
ensures that Wordfence processes the personal data of our website visitors
only according to our instructions and in compliance with the GDPR.

8. eCommerce and payment service providers

Processing of data (customer and contract data)

We collect, process, and use personal data only to the extent necessary
for the establishment, content organization or change of the legal
relationship (data inventory). These actions are taken on the basis of
Art. 6 Sect. 1 lit. b GDPR, which permits the processing of data for the
fulfilment of a contract or pre-contractual actions. We collect, process
and use personal data concerning the use of this website (usage data) only
to the extent that this is necessary to make it possible for users to
utilize the services and to bill for them.

The collected customer data shall be eradicated upon completion of the
order or the termination of the business relationship. This shall be
without prejudice to any statutory retention mandates.

Payment services

We integrate payment services of third-party companies on our website.
When you make a purchase from us, your payment data (e.g. name, payment
amount, bank account details, credit card number) are processed by the
payment service provider for the purpose of payment processing. For these
transactions, the respective contractual and data protection provisions of
the respective providers apply. The use of the payment service providers
is based on Art. 6(1)(b) GDPR (contract processing) and in the interest of
a smooth, convenient, and secure payment transaction (Art. 6(1)(f) GDPR).
Insofar as your consent is requested for certain actions, Art. 6(1)(a)
GDPR is the legal basis for data processing; consent may be revoked at any
time for the future.

We use the following payment services / payment service providers within
the scope of this website:

PayPal

The provider of this payment service is PayPal (Europe) S.à.r.l. et Cie,
S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter “PayPal”).

Data transmission to the US is based on the Standard Contractual Clauses
(SCC) of the European Commission. Details can be found here:
https://www.paypal.com/de/webapps/mpp/ua/pocpsa-full.

Details can be found in PayPal’s privacy policy:
https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

9. Custom Services

Job Applications

We offer website visitors the opportunity to submit job applications to us
(e.g. via e-mail, via postal services on by submitting the online job
application form). Below, we will brief you on the scope, purpose and use
of the personal data collected from you in conjunction with the
application process. We assure you that the collection, processing and use
of your data will occur in compliance with the applicable data privacy
rights and all other statutory provisions and that your data will always
be treated as strictly confidential.

Scope and purpose of the collection of data

If you submit a job application to us, we will process any affiliated
personal data (e.g. contact and communications data, application
documents, notes taken during job interviews, etc.), if they are required
to make a decision concerning the establishment or an employment
relationship. The legal grounds for the aforementioned are § 26 New GDPR
according to German Law (Negotiation of an Employment Relationship), Art.
6 Sect. 1 lit. b GDPR (General Contract Negotiations) and – provided you
have given us your consent – Art. 6 Sect. 1 lit. a GDPR. You may revoke
any consent given at any time. Within our company, your personal data will
only be shared with individuals who are involved in the processing of your
job application.

If your job application should result in your recruitment, the data you
have submitted will be archived on the grounds of § 26 New GDPR and Art. 6
Sect. 1 lit. b GDPR for the purpose of implementing the employment
relationship in our data processing system.

Data Archiving Period

If we are unable to make you a job offer or you reject a job offer or
withdraw your application, we reserve the right to retain the data you
have submitted on the basis of our legitimate interests (Art. 6 para. 1
lit. f GDPR) for up to 6 months from the end of the application procedure
(rejection or withdrawal of the application). Afterwards the data will be
deleted, and the physical application documents will be destroyed. The
storage serves in particular as evidence in the event of a legal dispute.
If it is evident that the data will be required after the expiry of the
6-month period (e.g. due to an impending or pending legal dispute),
deletion will only take place when the purpose for further storage no
longer applies.

Longer storage may also take place if you have given your agreement
(Article 6 (1) (a) GDPR) or if statutory data retention requirements
preclude the deletion.

Our social media appearances

Data processing through social networks

We maintain publicly available profiles in social networks. The individual
social networks we use can be found below.

Social networks such as Facebook, Twitter etc. can generally analyze your
user behavior comprehensively if you visit their website or a website with
integrated social media content (e.g. like buttons or banner ads). When
you visit our social media pages, numerous data protection-relevant
processing operations are triggered. In detail:

If you are logged in to your social media account and visit our social
media page, the operator of the social media portal can assign this visit
to your user account. Under certain circumstances, your personal data may
also be recorded if you are not logged in or do not have an account with
the respective social media portal. In this case, this data is collected,
for example, via cookies stored on your device or by recording your IP
address.

Using the data collected in this way, the operators of the social media
portals can create user profiles in which their preferences and interests
are stored. This way you can see interest-based advertising inside and
outside of your social media presence. If you have an account with the
social network, interest-based advertising can be displayed on any device
you are logged in to or have logged in to.

Please also note that we cannot retrace all processing operations on the
social media portals. Depending on the provider, additional processing
operations may therefore be carried out by the operators of the social
media portals. Details can be found in the terms of use and privacy policy
of the respective social media portals.

Legal basis

Our social media appearances should ensure the widest possible presence on
the Internet. This is a legitimate interest within the meaning of Art. 6
(1) lit. f GDPR. The analysis processes initiated by the social networks
may be based on divergent legal bases to be specified by the operators of
the social networks (e.g. consent within the meaning of Art. 6 (1) (a)
GDPR).

Responsibility and assertion of rights

If you visit one of our social media sites (e.g., Facebook), we, together
with the operator of the social media platform, are responsible for the
data processing operations triggered during this visit. You can in
principle protect your rights (information, correction, deletion,
limitation of processing, data portability and complaint) vis-à-vis us as
well as vis-à-vis the operator of the respective social media portal (e.g.
Facebook).

Please note that despite the shared responsibility with the social media
portal operators, we do not have full influence on the data processing
operations of the social media portals. Our options are determined by the
company policy of the respective provider.

Storage time

The data collected directly from us via the social media presence will be
deleted from our systems as soon as the purpose for their storage lapses,
you ask us to delete it, you revoke your consent to the storage or the
purpose for the data storage lapses. Stored cookies remain on your device
until you delete them. Mandatory statutory provisions - in particular,
retention periods - remain unaffected.

We have no control over the storage duration of your data that are stored
by the social network operators for their own purposes. For details,
please contact the social network operators directly (e.g. in their
privacy policy, see below).

Individual social networks

Facebook

We have a profile on Facebook. The provider of this service is Facebook
Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2,
Ireland. According to Facebook’s statement the collected data will also be
transferred to the USA and to other third-party countries.

We have signed an agreement with Facebook on shared responsibility for the
processing of data (Controller Addendum). This agreement determines which
data processing operations we or Facebook are responsible for when you
visit our Facebook Fanpage. This agreement can be viewed at the following
link:
https://www.facebook.com/legal/terms/page_controller_addendum.

You can customize your advertising settings independently in your user
account. Click on the following link and log in:

https://www.facebook.com/settings?tab=ads.

Data transmission to the US is based on the Standard Contractual Clauses
(SCC) of the European Commission. Details can be found here:
https://www.facebook.com/legal/EU_data_transfer_addendum
and
https://de-de.facebook.com/help/566994660333381.

Details can be found in the Facebook privacy policy:
https://www.facebook.com/about/privacy/.

Instagram

We have a profile on Instagram. The provider is Instagram Inc., 1601
Willow Road, Menlo Park, CA, 94025, USA.

Data transmission to the US is based on the Standard Contractual Clauses
(SCC) of the European Commission. Details can be found here:
https://www.facebook.com/legal/EU_data_transfer_addendum,
https://help.instagram.com/519522125107875
and
https://de-de.facebook.com/help/566994660333381.

For details on how they handle your personal information, see the
Instagram Privacy Policy:
https://help.instagram.com/519522125107875.