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Privacy Policy
We are delighted that you have shown interest in our company. Data protection is of a particularly high priority for the management of Logo Consult AG. The use of the Internet pages of Logo Consult AG is generally possible without any indication of personal data. However, if a data subject wishes to use special services of our company via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.
The processing of personal data, such as the name, address, e-mail address or telephone number of a data subject, shall always be in line with the General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection regulations applicable to Logo Consult AG. By means of this Privacy Policy, our company would like to inform the general public of the nature, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this Privacy Policy, of the rights to which they are entitled.
As the controller, Logo Consult AG has implemented numerous technical and organisational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.
1. Definitions
The Privacy Policy of Logo Consult AG is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our Privacy Policy should be easy to read and understand for the general public as well as for our customers and business partners. To ensure this, we would like first to explain the terminology used.
In this Privacy Policy, we use, inter alia, the following terms:
a) Personal data
Personal data means any information relating to an identified or identifiable natural person (hereinafter “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) Data subject
Data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.
c) Processing
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
e) Profiling
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
f) Pseudonymisation
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
g) Controller or controller responsible for the processing
Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
h) Processor
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
i) Recipient
Recipient is a natural or legal person, public authority, agency or another body to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.
j) Third party
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
k) Consent
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. Name and address of the controller
The controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member States of the European Union and other provisions related to data protection is:
Logo Consult AG
Enzianstraße 4
82319 Starnberg
Germany
Website: logo-consult.com
3. Cookies
The Internet pages of Logo Consult AG use cookies. Cookies are text files that are stored in a computer system via an Internet browser.
Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognised and identified using the unique cookie ID.
Through the use of cookies, Logo Consult AG can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.
By means of a cookie, the information and offers on our website can be optimised with the user in mind. As already mentioned, cookies enable us to recognise the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to enter their access data again each time they visit the website, because this is taken over by the website and the cookie stored on the user’s computer system. Another example is the cookie of a shopping basket in an online shop. The online shop remembers the articles that a customer has placed in the virtual shopping basket by means of a cookie.
The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently object to the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.
4. Collection of general data and information
The website of Logo Consult AG collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites which are accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using these general data and information, Logo Consult AG does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimise the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Logo Consult AG analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our company, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
5. Registration on our website
The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for the controller’s own purposes. The controller may request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to the controller.
By registering on the website of the controller, the IP address assigned by the Internet service provider (ISP) and used by the data subject, as well as the date and time of the registration, are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offences. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.
The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.
The controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. A data protection officer named in this Privacy Policy, as well as the entirety of the controller’s employees, are available to the data subject in this respect as contact persons.
6. Subscription to our newsletter
On the website of Logo Consult AG, users are given the opportunity to subscribe to our company’s newsletter. The personal data transmitted to the controller when the newsletter is ordered are determined by the input mask used for this purpose.
Logo Consult AG informs its customers and business partners regularly by means of a newsletter about the company’s offers. Our company’s newsletter may, in principle, only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter mailing. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for the newsletter mailing, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to verify whether the owner of the e-mail address as the data subject has authorised receipt of the newsletter.
During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.
The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller, or to communicate this to the controller in a different way.
7. Newsletter tracking
The newsletters of Logo Consult AG contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, Logo Consult AG may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.
Such personal data collected in the tracking pixels contained in the newsletters are stored and analysed by the controller in order to optimise the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double opt-in procedure. After a revocation, these personal data will be deleted by the controller. Logo Consult AG automatically regards a withdrawal from the receipt of the newsletter as a revocation.
8. Contact possibility via the website
The website of Logo Consult AG contains information that enables a quick electronic contact to our company, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address), in accordance with statutory provisions. If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.
9. Comments function in the blog on the website
Logo Consult AG offers users the possibility to leave individual comments on individual blog posts on a blog located on the website of the controller. A blog is a portal maintained on a website, usually publicly accessible, in which one or more persons, called bloggers or web bloggers, may post articles or write down thoughts in so-called blog posts. The blog posts can usually be commented on by third parties.
If a data subject leaves a comment on the blog published on this website, in addition to the comments left by the data subject, information on the time at which the comment was entered and on the user name (pseudonym) chosen by the data subject is stored and published. Furthermore, the IP address assigned to the data subject by the Internet service provider (ISP) is also logged. This storage of the IP address takes place for security reasons and in the event that the data subject violates the rights of third parties or posts unlawful content through a submitted comment. The storage of these personal data is therefore in the controller’s own interest, so that the controller could, where applicable, exculpate itself in the event of an infringement. These collected personal data will not be passed on to third parties unless such a transfer is required by law or serves the legal defence of the controller.
10. Subscription to comments in the blog on the website
The comments made in the blog of Logo Consult AG may, as a matter of principle, be subscribed to by third parties. In particular, a commenter may subscribe to the comments following his or her comment on a particular blog post.
If a data subject decides to subscribe to comments, the controller will send an automatic confirmation e-mail in order to check, using the double opt-in procedure, whether the owner of the specified e-mail address has actually chosen this option. The option to subscribe to comments may be terminated at any time.
11. Routine erasure and blocking of personal data
The controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is provided for by the European legislator or another legislator in laws or regulations to which the controller is subject.
If the storage purpose no longer applies, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with the statutory provisions.
12. Rights of the data subject
a) Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed. Should a data subject wish to exercise this right of confirmation, he or she may, at any time, contact our data protection officer or another employee of the controller.
b) Right of access
Each data subject shall have the right granted by the European legislator to obtain from the controller, at any time and free of charge, information about the personal data stored about his or her person and a copy of this information. Furthermore, the European legislator has granted the data subject access to the following information:
the purposes of the processing
the categories of personal data concerned
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing
the existence of the right to lodge a complaint with a supervisory authority
where the personal data are not collected from the data subject: any available information as to their source
the existence of automated decision-making, including profiling, referred to in Art. 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject
Furthermore, the data subject shall have the right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall also have the right to be informed of the appropriate safeguards relating to the transfer.
Should a data subject wish to exercise this right of access, he or she may, at any time, contact our data protection officer or another employee of the controller.
c) Right to rectification
Each data subject shall have the right granted by the European legislator to obtain without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Should a data subject wish to exercise this right to rectification, he or she may, at any time, contact our data protection officer or another employee of the controller.
d) Right to erasure (right to be forgotten)
Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay where one of the following grounds applies, as long as the processing is not necessary:
The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
The data subject withdraws consent on which the processing is based according to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, and where there is no other legal ground for the processing.
The data subject objects to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21(2) GDPR.
The personal data have been unlawfully processed.
The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
The personal data have been collected in relation to the offer of information society services referred to in Art. 8(1) GDPR.
If one of the aforementioned grounds applies and a data subject wishes to request the erasure of personal data stored by Logo Consult AG, he or she may, at any time, contact our data protection officer or another employee of the controller. The data protection officer of Logo Consult AG or another employee shall ensure that the erasure request is complied with without undue delay.
Where Logo Consult AG has made the personal data public and our company, as the controller, is obliged pursuant to Art. 17(1) GDPR to erase the personal data, Logo Consult AG, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the published personal data that the data subject has requested erasure by such other controllers of any links to, or copy or replication of, those personal data, as far as the processing is not necessary. The data protection officer of Logo Consult AG or another employee will arrange the necessary measures in individual cases.
e) Right to restriction of processing
Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use.
The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
The data subject has objected to processing pursuant to Art. 21(1) GDPR, pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned conditions is met and a data subject wishes to request the restriction of personal data stored by Logo Consult AG, he or she may, at any time, contact our data protection officer or another employee of the controller. The data protection officer of Logo Consult AG or another employee will arrange the restriction of the processing.
f) Right to data portability
Each data subject shall have the right granted by the European legislator to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format. He or she shall also have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, or on a contract pursuant to Art. 6(1)(b) GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Art. 20(1) GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact the data protection officer designated by Logo Consult AG or another employee.
g) Right to object
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her which is based on Art. 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions.
Logo Consult AG shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
If Logo Consult AG processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Logo Consult AG to the processing for direct marketing purposes, Logo Consult AG will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by Logo Consult AG for scientific or historical research purposes, or for statistical purposes pursuant to Art. 89(1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the data subject may contact the data protection officer of Logo Consult AG or another employee directly. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise his or her right to object by automated means using technical specifications.
h) Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) it is based on the data subject's explicit consent, Logo Consult AG shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
If the data subject wishes to exercise the rights concerning automated decision-making, he or she may, at any time, contact our data protection officer or another employee of the controller.
i) Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw consent, he or she may, at any time, contact our data protection officer or another employee of the controller.
13. Data protection in applications and the application procedure
The controller shall collect and process the personal data of applicants for the purpose of handling the application procedure. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents to the controller by electronic means, for example by e-mail or by means of a web form on the website. If the controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If no employment contract is concluded with the applicant by the controller, the application documents shall be automatically erased two months after notification of the rejection decision, provided that no other legitimate interests of the controller are opposed to the erasure. Other legitimate interest in this sense is, for example, a burden of proof in proceedings under the General Equal Treatment Act (AGG).
14. Data protection provisions about the application and use of Adobe Analytics (Omniture) / Adobe Marketing Cloud
On this website, the controller has integrated components of the company Adobe. Adobe Analytics (Omniture) or the Adobe Marketing Cloud (hereinafter referred to as "Omniture") is a tool that enables more efficient online marketing and web analysis. Omniture is part of the Adobe Marketing Cloud. The Adobe Marketing Cloud enables real-time analysis of visitor flows on websites. The real-time analyses include project reports and allow ad hoc analysis of website visitors. Customer interactions are presented in such a way that the controller gains a better overview of the online activities of the users of this website, by displaying the data in simple and interactive dashboards and converting them into reports. This enables the controller to obtain information in real time and thereby identify problems that arise more quickly.
The operating company of these services is Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Republic of Ireland.
Omniture places a cookie on the information technology system of the data subject (cookies have already been explained above; the relevant information can be read there). By means of a server setting, the controller ensures that the tracking data records transmitted to Adobe's data centre are anonymised prior to geolocation. The anonymisation is implemented by replacing the last part of the IP address. The controller has made server-side settings by which the IP address of the data subject is anonymised independently for geolocation and for reach measurement prior to each respective processing. On behalf of the controller, Adobe will use the data and information obtained via our website to evaluate the user behaviour of the data subject. Furthermore, Adobe will use the data to create reports on user activities on our behalf and to provide further services for our company in connection with the use of our website. The IP address of the data subject is not merged by Adobe with other personal data.
As already stated above, the data subject may, at any time, prevent the setting of cookies by our website by means of a corresponding setting of the internet browser used and thus permanently object to the setting of cookies. Such a setting of the internet browser used would also prevent Omniture from setting a cookie on the information technology system of the data subject. In addition, cookies already set by Omniture may be deleted at any time via an internet browser or other software programs.
Furthermore, the data subject has the possibility of objecting to, and preventing, the collection of the data generated by the Adobe cookie and relating to the use of this website, as well as the processing of these data by Adobe. For this purpose, the data subject must press the opt-out button under the link , which sets an opt-out cookie. The opt-out cookie set with the objection is stored on the information technology system used by the data subject. If the cookies on the data subject's system are deleted after an objection, the data subject must call up the link again and set a new opt-out cookie.
However, by setting the opt-out cookie, there is a possibility that the controller's websites may no longer be fully usable by the data subject.
The applicable data protection provisions of Adobe may be accessed via this link.
15. Data protection provisions on the use and application of econda
The controller has integrated components of the company econda on this website. Econda is a web analytics service. Web analytics is the collection, gathering and evaluation of data about the behaviour of visitors to websites. A web analytics service collects, inter alia, data about the website from which a data subject came to a website (the so-called referrer), which sub-pages of the website were accessed, or how often and for what duration a sub-page was viewed. Web analytics is mainly used for the optimisation of a website and for the cost-benefit analysis of internet advertising.
The operating company of econda is econda GmbH, Eisenlohrstr. 43, 76135 Karlsruhe, Germany.
Econda places a cookie on the information technology system of the data subject. What cookies are has already been explained above. Each time one of the individual pages of this website, which is operated by the controller and on which a econda component has been integrated, is called up, the internet browser on the information technology system of the data subject is automatically prompted by the respective econda component to transmit data to econda for marketing and optimisation purposes. In the course of this technical procedure, econda obtains knowledge of data that are subsequently used to create pseudonymous usage profiles. The usage profiles obtained in this way serve to analyse the behaviour of the data subject who has accessed the controller's website and are evaluated with the aim of improving and optimising the website. The data collected via the econda component are not used to identify the data subject without first obtaining the separate and express consent of the data subject. These data are not merged with personal data or with other data containing the same pseudonym.
As already stated above, the data subject may prevent the setting of cookies by our website at any time by means of a corresponding setting of the internet browser used and thus permanently object to the setting of cookies. Such a setting of the internet browser used would also prevent econda from setting a cookie on the information technology system of the data subject. In addition, cookies already set by econda may be deleted at any time via an internet browser or other software programmes.
Furthermore, the data subject has the possibility of objecting to and preventing the collection of the data generated by the econda cookie relating to the use of this website and the processing of these data by econda. To do so, the data subject must press the submit button under the link that sets the opt-out cookie. The opt-out cookie set with the objection is stored on the information technology system used by the data subject. If the cookies on the data subject's system are deleted after an objection, the data subject must call up the link again and set a new opt-out cookie.
However, by setting the opt-out cookie, there is a possibility that the controller's websites may no longer be fully usable by the data subject.
The applicable data protection provisions of econda may be accessed via this link.
16. Data protection provisions on the use and application of etracker
The controller has integrated components of the company etracker on this website. Etracker is a web analytics service. Web analytics is the collection, gathering and evaluation of data about the behaviour of the visitors to websites. A web analytics service collects, inter alia, data about the website from which a data subject came to a website (the so-called referrer), which sub-pages of the website were accessed, or how often and for what duration a sub-page was viewed. Web analytics is mainly used for the optimisation of a website and for the cost-benefit analysis of internet advertising.
The operating company of etracker is etracker GmbH, Erste Brunnenstraße 1, 20459 Hamburg, Germany.
Etracker places a cookie on the information technology system of the data subject. What cookies are has already been explained above. Each time one of the individual pages of this website, which is operated by the controller and on which a etracker component has been integrated, is called up, the internet browser on the information technology system of the data subject is automatically prompted by the respective etracker component to transmit data to etracker for marketing and optimisation purposes. In the course of this technical procedure, etracker obtains knowledge of data that are subsequently used to create pseudonymous usage profiles. The usage profiles obtained in this way serve to analyse the behaviour of the data subject who has accessed the controller's website and are evaluated with the aim of improving and optimising the website. The data collected via the etracker component are not used to identify the data subject without first obtaining the separate and express consent of the data subject. These data are not merged with personal data or with other data containing the same pseudonym.
As already stated above, the data subject may prevent the setting of cookies by our website at any time by means of a corresponding setting of the internet browser used and thus permanently object to the setting of cookies. Such a setting of the internet browser used would also prevent etracker from setting a cookie on the information technology system of the data subject. In addition, cookies already set by etracker may be deleted at any time via the internet browser or other software programmes.
Furthermore, the data subject has the possibility of objecting to and preventing the collection of the data generated by the etracker cookie relating to the use of this website and the processing of these data by etracker. To do so, the data subject must press the set cookie button under the link that sets an opt-out cookie. The opt-out cookie set with the objection is stored on the information technology system used by the data subject. If the cookies on the data subject's system are deleted after an objection, the data subject must call up the link again and set a new opt-out cookie.
However, by setting the opt-out cookie, there is a possibility that the controller's websites may no longer be fully usable by the data subject.
The applicable data protection provisions of etracker may be accessed via this link.
17. Data protection provisions on the use and application of Google Analytics (with anonymisation function)
The controller has integrated the component Google Analytics (with anonymisation function) on this website. Google Analytics is a web analytics service. Web analytics is the collection, gathering and evaluation of data about the behaviour of visitors to websites. A web analytics service collects, inter alia, data about the website from which a data subject came to a website (the so-called referrer), which sub-pages of the website were accessed, or how often and for what duration a sub-page was viewed. Web analytics is mainly used for the optimisation of a website and for the cost-benefit analysis of internet advertising.
The operating company of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
For web analytics through Google Analytics, the controller uses the extension “_gat._anonymizeIp”. By means of this extension, the IP address of the data subject's internet connection is shortened and anonymised by Google if our websites are accessed from a Member State of the European Union or from another state party to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyse the visitor flows on our website. Google uses the data and information obtained, inter alia, to evaluate the use of our website, to compile online reports for us showing the activities on our websites, and to provide other services relating to the use of our website.
Google Analytics places a cookie on the information technology system of the data subject. What cookies are has already been explained above. Setting the cookie enables Google to analyse the use of our website. Each time one of the individual pages of this website, which is operated by the controller and on which a Google Analytics component has been integrated, is called up, the internet browser on the information technology system of the data subject is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. In the course of this technical procedure, Google obtains knowledge of personal data, such as the IP address of the data subject, which serve Google, inter alia, to trace the origin of visitors and clicks and subsequently to enable commission settlements.
By means of the cookie, personal information, for example the time of access, the location from which access was made and the frequency of the data subject's visits to our website, is stored. With each visit to our websites, these personal data, including the IP address of the internet connection used by the data subject, are transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass on these personal data collected through the technical procedure to third parties.
As already stated above, the data subject may prevent the setting of cookies by our website at any time by means of a corresponding setting of the internet browser used and thus permanently object to the setting of cookies. Such a setting of the internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, a cookie already set by Google Analytics may be deleted at any time via the internet browser or other software programmes.
Furthermore, the data subject has the possibility of objecting to and preventing the collection of the data generated by Google Analytics relating to the use of this website and the processing of these data by Google. To do so, the data subject must download and install a browser add-on via this link. This browser add-on informs Google Analytics via JavaScript that no data and information concerning visits to websites may be transmitted to Google Analytics. The installation of the browser add-on is regarded by Google as an objection. If the information technology system of the data subject is deleted, formatted or reinstalled at a later time, the data subject must reinstall the browser add-on in order to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or by another person within their sphere of control, it is possible to reinstall or reactivate the browser add-on.
Further information and the applicable data protection provisions of Google may be accessed via this link and via this link. Google Analytics is explained in more detail under this link.
18. Legal basis for the processing
Art. 6(1)(a) GDPR serves as the legal basis for our company for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, with processing operations necessary for the supply of goods or the provision of any other service or consideration, the processing is based on Art. 6(1)(b) GDPR. The same applies to processing operations necessary for carrying out pre-contractual measures, for example in the case of enquiries concerning our products or services. If our company is subject to a legal obligation which requires the processing of personal data, for example for the fulfilment of tax obligations, the processing is based on Art. 6(1)(c) GDPR. In rare cases, the processing of personal data may become necessary in order to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured on our premises and their name, age, health insurance data or other vital information then had to be passed on to a doctor, hospital or other third party. The processing would then be based on Art. 6(1)(d) GDPR. Finally, processing operations could be based on Art. 6(1)(f) GDPR. Processing operations which are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary for the purposes of a legitimate interest pursued by our company or by a third party, provided that the interests, fundamental rights and freedoms of the data subject do not override. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this respect, the legislator took the view that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47, sentence 2 GDPR).
19. Legitimate interests pursued by the controller or by a third party
Where the processing of personal data is based on Art. 6(1)(f) GDPR, our legitimate interest is the conduct of our business for the benefit of the well-being of all our employees and our shareholders.
20. Period for which the personal data will be stored
The criterion used to determine the period of storage of personal data is the respective statutory retention period. After expiry of that period, the corresponding data are routinely erased, provided that they are no longer necessary for the performance of the contract or the initiation of a contract.
21. Statutory or contractual requirements to provide the personal data; necessity for the conclusion of a contract; obligation of the data subject to provide the personal data; possible consequences of failure to provide such data
We hereby inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary for the conclusion of a contract that a data subject provides us with personal data which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company concludes a contract with them. Failure to provide the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data are provided by the data subject, the data subject must contact our data protection officer. Our data protection officer will inform the data subject on a case-by-case basis whether the provision of the personal data is required by law or by contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and what the consequences of failure to provide the personal data would be.
22. Existence of automated decision-making
As a responsible company, we do not use automated decision-making or profiling.
23. Web analytics: Hotjar
On our website we use Hotjar. This is a web analytics service of Hotjar Ltd., Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta, Europe, hereinafter referred to as “Hotjar”.
We use Hotjar to analyse user behaviour on our website. The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest lies in the analysis, optimisation and economic operation of our website.
Hotjar enables us to record and evaluate your usage behaviour on our website, such as your mouse movements or mouse clicks. Your visit to our website is, however, anonymised in the process. In addition, Hotjar evaluates information about your operating system, your internet browser, incoming or outgoing references (“links”), geographical origin and the type and resolution of the device you use, and processes it for statistical purposes. Hotjar may also obtain direct feedback from you. Furthermore, Hotjar provides further data protection information via this link.
In addition, you have the option of ending the analysis of your usage behaviour by means of a so-called opt-out. By confirming the link, a cookie is stored on your device via your internet browser which prevents further analysis. Please note, however, that you must click the above link again if you delete the cookies stored on your device.
Section 23 was generated using the privacy policy generator of the law firm Weiß & Partner.
24. Analysis: OpenAI
For the internal processing and analysis of user input, we transmit certain content to the interface of the service provider OpenAI, L.L.C., USA.
The processing is carried out exclusively for the specified purpose within the framework of a data processing agreement pursuant to Art. 28 GDPR.
OpenAI does not store the data permanently. A transfer to the USA is possible; in this case, it takes place on the basis of appropriate safeguards pursuant to Art. 46 GDPR (standard contractual clauses).
Further information is available at: https://openai.com/privacy
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