Privacy Policy
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,
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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
We are hosting the content of our website at the following provider:
External Hosting
This website is hosted externally. 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 external hosting serves the purpose of fulfilling the contract with our potential and existing customers
(Art. 6(1)(b) GDPR) and in the interest of secure, fast, and efficient provision of our online services by a
professional provider (Art. 6(1)(f) GDPR). If appropriate consent has been obtained, the processing is carried
out exclusively on the basis of Art. 6 (1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the
storage of cookies or the access to information in the user's end device (e.g., device fingerprinting) within the
meaning of the TTDSG. This consent can be revoked at any time.
Our host(s) 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(s):
1&1 IONOS SE
Elgendorfer Str. 57
56410 Montabaur
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Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a
contract mandated by data privacy laws that guarantees that they process personal data of our website
visitors only based on our instructions and in compliance with the GDPR.
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:
smartfillment GmbH
Stendaler Chaussee 8
39638 Gardelegen
Phone: 03907 3592670
E-mail: team@smartfillment.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.
General information on the legal basis for the data processing on this website
If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or
Art. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) DSGVO. In the case of
explicit consent to the transfer of personal data to third countries, the data processing is also based on Art.
49 (1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end
device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TTDSG. The
consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the
implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR.
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Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art.
6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest
according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in
the following paragraphs of this privacy policy.
Information on data transfer to the USA and other non-EU countries
Among other things, we use tools of companies domiciled in the United States or other from a data
protection perspective non-secure non-EU countries. If these tools are active, your personal data may
potentially be transferred to these non-EU countries and may be processed there. We must point out that in
these countries, a data protection level that is comparable to that in the EU cannot be guaranteed. For
instance, U.S. enterprises are under a mandate to release personal data to the security agencies and you as
the data subject do not have any litigation options to defend yourself in court. Hence, it cannot be ruled out
that U.S. agencies (e.g., the Secret Service) may process, analyze, and permanently archive your personal
data for surveillance purposes. We have no control 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(1)(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(1) GDPR).
IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING,
YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR
THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. 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(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
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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.
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(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.
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.
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
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Our websites and pages use what the industry refers to as “cookies.” Cookies are small data packages 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.
Cookies can be issued by us (first-party cookies) or by third-party companies (so-called third-party cookies).
Third-party cookies enable the integration of certain services of third-party companies into websites (e.g.,
cookies for handling payment services).
Cookies have a variety of functions. Many cookies are technically essential since certain website functions
would not work in the absence of these cookies (e.g., the shopping cart function or the display of videos).
Other cookies may be used to analyze user behavior or for promotional purposes.
Cookies, which are required for the performance of electronic communication transactions, for the provision
of certain functions you want to use (e.g., for the shopping cart function) or those that are necessary for the
optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web
audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The
operator of the website has a legitimate interest in the storage of required cookies to ensure the technically
error-free and optimized provision of the operator’s services. If your consent to the storage of the cookies
and similar recognition technologies has been requested, the processing occurs exclusively on the basis of
the consent obtained (Art. 6(1)(a) GDPR and § 25 (1) TTDSG); 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.
Which cookies and services are used on this website can be found in this privacy policy.
Consent with Usercentrics
This website uses the consent technology of Usercentrics to obtain your consent to the storage of certain
cookies on your device or for the use of specific technologies, and to document the former in a data
protection compliant manner. The party offering this technology is Usercentrics GmbH, Sendlinger Straße 7,
80331 München, Germany, website:
https://usercentrics.com/ (hereinafter referred to as “Usercentrics”).
Whenever you visit our website, the following personal data will be transferred to Usercentrics:
Your declaration(s) of consent or your revocation of your declaration(s) of consent
Your IP address
Information about your browser
Information about your device
The date and time you visited our website
Moreover, Usercentrics shall store a cookie in your browser to be able to allocate your declaration(s) of
consent or any revocations of the former. The data that are recorded in this manner shall be stored until you
ask us to eradicate them, delete the Usercentrics cookie or until the purpose for archiving the data no longer
exists. This shall be without prejudice to any mandatory legal retention periods.
Usercentrics uses cookies to obtain the declarations of consent mandated by law. The legal basis for the use
of specific technologies is Art. 6(1)(c) GDPR.
Data processing
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We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a
contract mandated by data privacy laws that guarantees that they process personal data of our website
visitors only based on our instructions and in compliance with the GDPR.
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(1)(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(1)(f) GDPR) or
on your agreement (Art. 6(1)(a) GDPR) if this has been requested; the consent can be revoked at any time.
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(1)(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(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained; the consent can be
revoked at any time.
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.
Communication via WhatsApp
For communication with our customers and other third parties, one of the services we use is the instant
messaging service WhatsApp. The provider is WhatsApp Ireland Limited, 4 Grand Canal Square, Grand
Canal Harbour, Dublin 2, Ireland.
The communication is encrypted end-to-end (peer-to-peer), which prevents WhatsApp or other third parties
from gaining access to the communication content. However, WhatsApp does gain access to metadata
created during the communication process (for example, sender, recipient, and time). We would also like to
point out that WhatsApp has stated that it shares personal data of its users with its U.S.-based parent
company Meta. Further details on data processing can be found in the WhatsApp privacy policy at:
https://www.whatsapp.com/legal/#privacy-policy.
The use of WhatsApp is based on our legitimate interest in communicating as quickly and effectively as
possible with customers, interested parties and other business and contractual partners (Art. 6(1)(f) GDPR).
If a corresponding consent has been requested, data processing is carried out exclusively on the basis of the
consent; this consent may be revoked at any time with effect for the future.
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The communication content exchanged between and on WhatsApp remains with us until you request us to
delete it, revoke your consent to storage or the purpose for which the data is stored ceases to apply (e.g.
after your request has been processed). Mandatory legal provisions, in particular retention periods, remain
unaffected.
We use WhatsApp in the “WhatsApp Business” variant.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European
Commission. Details can be found here:
https://www.whatsapp.com/legal/business-data-transfer-addendum?lang=en.
Zoho CRM
We use Zoho CRM on this website. Provider is Zoho Corporation GmbH., Estancia IT Park, Plot No. 140 151,
GST Road, Vallancherry Village, Chengalpattu Taluk, Kanchipuram District 603 202, India (hereinafter “Zoho
CRM”).
Zoho CRM enables us, in particular, to manage existing and potential customers and customer contacts and
to organize sales and communication processes. Using the CRM system also enables us to analyze and
optimize our customer-related processes. The customer data is stored on Zoho CRM's servers. Details of
Zoho CRM's functions can be found here:
https://www.zoho.com/de/crm/help/getting-started/key-functions.html.
The use of Zoho CRM is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest the most
efficient customer management and customer communication. If appropriate consent has been obtained, the
processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the
consent includes the storage of cookies or the access to information in the user’s end device (e.g., device
fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.
The data transfer to third countries outside the European Union is based on the standard contractual clauses
of the EU Commission.
Details can be found in the Zoho CRM privacy policy:
https://www.zoho.com/privacy.html and
https://www.zoho.com/gdpr.html.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a
contract mandated by data privacy laws that guarantees that they process personal data of our website
visitors only based on our instructions and in compliance with the GDPR.
5. Social media
We have integrated elements of the social network Facebook on this website. The provider of this service is
Meta Platforms 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.
An overview of the Facebook social media elements is available under the following link:
https://developers.facebook.com/docs/plugins/.
If the social media element has been activated, a direct connection between your device and the Facebook
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server will be established. As a result, Facebook will receive information confirming your visit to this website
with your IP address. If you click on the Facebook Like button while you are logged into your Facebook
account, you can link content of this website to your Facebook profile. Consequently, Facebook will be able
to allocate your visit to this website to your user account. We have to emphasize that we as the provider of
the website do not receive any information on the content of the transferred data and its use by Facebook.
For more information, please consult the Data Privacy Policy of Facebook at:
https://de-de.facebook.com/privacy/explanation.
If your approval (consent) has been obtained the use of the abovementioned service shall occur on the basis
of Art. 6 Sect. 1 lit. a GDPR and § 25 TTDSG (German Telecommunications Act). Such consent may be
revoked at any time. If your consent was not obtained, the use of the service will occur on the basis of our
legitimate interest in making our information as comprehensively visible as possible on social media.
Insofar as personal data is collected on our website with the help of the tool described here and forwarded to
Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2,
Ireland are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited
exclusively to the collection of the data and its forwarding to Facebook. The processing by Facebook that
takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us
jointly have been set out in a joint processing agreement. The wording of the agreement can be found under:
https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for
providing the privacy information when using the Facebook tool and for the privacy-secure implementation
of the tool on our website. Facebook is responsible for the data security of Facebook products. You can
assert data subject rights (e.g., requests for information) regarding data processed by Facebook directly with
Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook.
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://de-de.facebook.com/help/566994660333381 and
https://www.facebook.com/policy.php.
We have integrated functions of the public media platform Instagram into this website. These functions are
being offered by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2,
Ireland.
If the social media element has been activated, a direct connection between your device and Instagram’s
server will be established. As a result, Instagram will receive information on your visit to this website.
If you are logged into your Instagram account, you may click the Instagram button to link contents from this
website to your Instagram profile. This enables Instagram to allocate your visit to this website to your user
account. We have to point out that we as the provider of the website and its pages do not have any
knowledge of the content of the data transferred and its use by Instagram.
If your approval (consent) has been obtained the use of the abovementioned service shall occur on the basis
of Art. 6(1)(a) GDPR and § 25 TTDSG (German Telecommunications Act). Such consent may be revoked at
any time. If your consent was not obtained, the use of the service will occur on the basis of our legitimate
interest in making our information as comprehensively visible as possible on social media.
Insofar as personal data is collected on our website with the help of the tool described here and forwarded to
Facebook or Instagram, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal
Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 DSGVO). The joint
responsibility is limited exclusively to the collection of the data and its forwarding to Facebook or Instagram.
The processing by Facebook or Instagram that takes place after the onward transfer is not part of the joint
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responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The
wording of the agreement can be found under:
https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for
providing the privacy information when using the Facebook or Instagram tool and for the privacy-secure
implementation of the tool on our website. Facebook is responsible for the data security of Facebook or
Instagram products. You can assert data subject rights (e.g., requests for information) regarding data
processed by Facebook or Instagram directly with Facebook. If you assert the data subject rights with us, we
are obliged to forward them to Facebook.
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 more information on this subject, please consult Instagram’s Data Privacy Declaration at:
https://instagram.com/about/legal/privacy/.
This website uses elements of the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company,
Wilton Plaza, Wilton Place, Dublin 2, Ireland.
Any time you access a page of this website that contains elements of LinkedIn, a connection to LinkedIn’s
servers is established. LinkedIn is notified that you have visited this website with your IP address. If you click
on LinkedIn’s “Recommend” button and are logged into your LinkedIn account at the time, LinkedIn will be in
a position to allocate your visit to this website to your user account. We have to point out that we as the
provider of the websites do not have any knowledge of the content of the transferred data and its use by
LinkedIn.
If your approval (consent) has been obtained the use of the abovementioned service shall occur on the basis
of Art. 6 (1)(a) GDPR and § 25 TTDSG (German Telecommunications Act). Such consent may be revoked at
any time. If your consent was not obtained, the use of the service will occur on the basis of our legitimate
interest in making our information as comprehensively visible as possible on social media.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European
Commission. Details can be found here:
lang=en.
For further information on this subject, please consult LinkedIn’s Data Privacy Declaration at:
https://www.linkedin.com/legal/privacy-policy.
6. Analysis tools and advertising
Google Tag Manager
We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street,
Dublin 4, Ireland
The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other
technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store
cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via
it. However, the Google Tag Manager does collect your IP address, which may also be transferred to
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Google’s parent company in the United States.
The Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate
interest in the quick and uncomplicated integration and administration of various tools on his website. If
appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a)
GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in
the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be
revoked at any time.
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. This data is summarized in a user-ID and assigned to the
respective end device of the website visitor.
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.
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1)
TTDSG. You may revoke your consent 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.
Demographic parameters provided by Google Analytics
This website uses the “demographic characteristics” function of Google Analytics, to be able to display to the
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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”.
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.
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 these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1)
TTDSG. You may revoke your consent 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://policies.google.com/privacy/frameworks and
https://privacy.google.com/businesses/controllerterms/mccs/.
Google AdSense (not personalized)
This website uses Google AdSense, an ad embedding service provided by Google Ireland Limited (“Google”),
Gordon House, Barrow Street, Dublin 4, Ireland.
We use Google AdSense in the “non-personalized” mode. Contrary to the personalized mode, the ads are not
based on your previous user patterns and the service does not generate a user profile for you. Instead, the
service uses so-called “context information” to choose the ads that are posted for you to view. The selected
ads are thus based e.g., on your location, the content of the website you are visiting at the time, or the search
terms you are using. To learn more about the distinct differences between personalized targeting and
targeting that has not been personalized by Google AdSense, please click on the following link:
https://support.google.com/adsense/answer/9007336.
Please keep in mind that if Google Adsense is used in the non-personalized mode, it is possible that cookies
are stored or comparable recognition technologies (e.g., device fingerprinting) are used.
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1)
TTDSG. You may revoke your consent 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/.
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You have the option to autonomously adjust the advertising settings in your user account. To do so, please
click on the link provided below and log in:
https://adssettings.google.com/authenticated.
For more information about Google’s advertising technologies, please click here:
https://policies.google.com/technologies/ads and
https://www.google.de/intl/de/policies/privacy/.
Google Ads Remarketing
This website uses the functions of Google Ads Remarketing. The provider of these solutions is Google
Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
With Google Ads Remarketing, we can assign people who interact with our online offering to specific target
groups in order to subsequently display interest-based advertising to them in the Google advertising
network (remarketing or retargeting).
Moreover, it is possible to link the advertising target groups generated with Google Ads Remarketing to
device encompassing functions of Google. This makes it possible to display interest-based customized
advertising messages, depending on your prior usage and browsing patterns on a device (e.g., cell phone) in a
manner tailored to you as well as on any of your devices (e.g., tablet or PC).
If you have a Google account, you have the option to object to personalized advertising under the following
link:
https://www.google.com/settings/ads/onweb/.
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1)
TTDSG. You may revoke your consent at any time.
For further information and the pertinent data protection regulations, please consult the Data Privacy
Policies of Google at:
https://policies.google.com/technologies/ads?hl=en.
Formation of Target Groups with Customer Reconciliation
For the formation of target groups, we use, among other things, the Google Ads Remarketing customer
reconciliation feature. To achieve this, we transfer certain customer data (e.g., email addresses) from our
customer lists to Google. If the respective customers are Google users and are logged into their Google
accounts, matching advertising messages within the Google network (e.g., YouTube, Gmail or in a search
engine) are displayed for them to view.
Google Conversion-Tracking
This website uses Google Conversion Tracking. The provider of this service is Google Ireland Limited
(“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
With the assistance of Google Conversion Tracking, we are in a position to recognize whether the user has
completed certain actions. For instance, we can analyze the how frequently which buttons on our website
have been clicked and which products are reviewed or purchased with particular frequency. The purpose of
this information is to compile conversion statistics. We learn how many users have clicked on our ads and
which actions they have completed. We do not receive any information that would allow us to personally
identify the users. Google as such uses cookies or comparable recognition technologies for identification
purposes.
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1)
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TTDSG. You may revoke your consent at any time.
For more information about Google Conversion Tracking, please review Google’s data protection policy at:
https://policies.google.com/privacy?hl=en
Meta-Pixel (formerly Facebook Pixel)
To measure conversion rates, this website uses the visitor activity pixel of Facebook/Meta. The provider of
this service is Meta Platforms 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 (
https://www.facebook.com/about/privacy/). 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 these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1)
TTDSG. You may revoke your consent at any time.
Insofar as personal data is collected on our website with the help of the tool described here and forwarded to
Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2,
Ireland are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited
exclusively to the collection of the data and its forwarding to Facebook. The processing by Facebook that
takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us
jointly have been set out in a joint processing agreement. The wording of the agreement can be found under:
https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for
providing the privacy information when using the Facebook tool and for the privacy-secure implementation
of the tool on our website. Facebook is responsible for the data security of Facebook products. You can
assert data subject rights (e.g., requests for information) regarding data processed by Facebook directly with
Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook.
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.
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/.
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7. Newsletter
Newsletter data
If you would like to receive the newsletter offered on the website, we require an e-mail address from you as
well as information that allows us to verify that you are the owner of the e-mail address provided and that
you agree to receive the newsletter. Further data is not collected or only on a voluntary basis. For the
handling of the newsletter, we use newsletter service providers, which are described below.
Zoho Campaigns
This website uses Zoho Campaigns to send out newsletters. Provider is Zoho Corporation GmbH., Estancia
IT Park, Plot no. 140 151, GST Road, Vallancherry Village, Chengalpattu Taluk, Kanchipuram District 603
202, India (hereinafter “Zoho Campaigns”).
Zoho Campaigns is a service that can be used, in particular, to organize and analyze the sending of
newsletters. The information you enter to subscribe to the newsletter is stored on Zoho Campaigns’ servers.
Data analysis by Zoho Campaigns
Zoho Campaigns allows us to analyze our newsletter campaigns. For example, we can see whether a
newsletter message has been opened and which links have been clicked on, if any. In this way we can
determine which links have been clicked on most often.
We can also see if certain previously defined actions were performed after opening/clicking (conversion
rate). For example, we can see whether you have made a purchase after clicking on the newsletter. If you do
not want to receive analyses of Zoho Campaigns, you must unsubscribe from the newsletter. We provide a
link to this in every newsletter message. Zoho Campaigns also allows us to classify the recipients of the
newsletter into different categories ("clustering"). The newsletter recipients can be classified, for example,
by age, gender, or place of residence. In this way, the newsletter can be better adapted to the respective
target groups. If you do not wish to receive analyses of Zoho Campaigns, you must unsubscribe from the
newsletter. You will find a link to this in every newsletter message.
Detailed information about the characteristics of Zoho Campaigns can be found at the following link:
https://www.zoho.com/campaigns/features.html.
The Zoho Campaigns’ privacy policy can be found at
https://www.zoho.com/privacy.html and
https://www.zoho.com/gdpr.html.
Legal basis
The data processing is based on your consent (Art. 6(1)(a) GDPR). You can revoke this consent at any time
with effect for the future.
The data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can
be found here:
https://www.zoho.com/privacy.html.
Duration of storage
The data that you provide us with for the purpose of subscribing to the newsletter will be stored by us or the
newsletter service provider until you unsubscribe from the newsletter and will be deleted from the
newsletter distribution list or deleted after the newsletter has been cancelled. We reserve the right to delete
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email addresses within the scope of our legitimate interest under Art. 6(1)(f) GDPR. Data stored by us for
other purposes remain unaffected.
After you have been removed from the newsletter distribution list, your email address may be stored by us
or the newsletter service provider in a blacklist, if such action is necessary to prevent future mailings. The
data from the blacklist will only be used for this purpose and will not be merged with other data. This serves
both your interest and our interest in compliance with legal requirements when sending out newsletters
(legitimate interest in the sense of Art. 6(1)(f) GDPR). The storage in the blacklist is not limited in time. You
can object to the storage if your interests outweigh our legitimate interest.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a
contract mandated by data privacy laws that guarantees that they process personal data of our website
visitors only based on our instructions and in compliance with the GDPR.
8. Plug-ins and Tools
YouTube with expanded data protection integration
Our website embeds videos of the website YouTube. The website operator is Google Ireland Limited
(“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
We use YouTube in the expanded data protection mode. According to YouTube, this mode ensures that
YouTube does not store any information about visitors to this website before they watch the video.
Nevertheless, this does not necessarily mean that the sharing of data with YouTube partners can be ruled
out as a result of the expanded data protection mode. For instance, regardless of whether you are watching a
video, YouTube will always establish a connection with the Google DoubleClick network.
As soon as you start to play a YouTube video on this website, a connection to YouTube’s servers will be
established. As a result, the YouTube server will be notified, which of our pages you have visited. If you are
logged into your YouTube account while you visit our site, you enable YouTube to directly allocate your
browsing patterns to your personal profile. You have the option to prevent this by logging out of your
YouTube account.
Furthermore, after you have started to play a video, YouTube will be able to place various cookies on your
device or comparable technologies for recognition (e.g. device fingerprinting). In this way YouTube will be
able to obtain information about this website’s visitors. Among other things, this information will be used to
generate video statistics with the aim of improving the user friendliness of the site and to prevent attempts
to commit fraud.
Under certain circumstances, additional data processing transactions may be triggered after you have
started to play a YouTube video, which are beyond our control.
The use of YouTube is based on our interest in presenting our online content in an appealing manner.
Pursuant to Art. 6(1)(f) GDPR, this is a legitimate interest. If appropriate consent has been obtained, the
processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the
consent includes the storage of cookies or the access to information in the user’s end device (e.g., device
fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.
For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy
under:
https://policies.google.com/privacy?hl=en.
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Google Fonts
To ensure that fonts used on this website are uniform, this website uses so-called Google Fonts provided by
Google. When you access a page on our website, your browser will load the required fonts into your browser
cache to correctly display text and fonts.
To do this, the browser you use will have to establish a connection with Google’s servers. As a result, Google
will learn that your IP address was used to access this website. The use of Google Fonts is based on Art.
6(1)(f) GDPR. The website operator has a legitimate interest in a uniform presentation of the font on the
operator’s website. If appropriate consent has been obtained, the processing is carried out exclusively on the
basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the
access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG.
This consent can be revoked at any time.
If your browser should not support Google Fonts, a standard font installed on your computer will be used.
For more information on Google 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.
Google reCAPTCHA
We use “Google reCAPTCHA” (hereinafter referred to as “reCAPTCHA”) on this website. The provider is
Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
The purpose of reCAPTCHA is to determine whether data entered on this website (e.g., information entered
into a contact form) is being provided by a human user or by an automated program. To determine this,
reCAPTCHA analyzes the behavior of the website visitors based on a variety of parameters. This analysis is
triggered automatically as soon as the website visitor enters the site. For this analysis, reCAPTCHA
evaluates a variety of data (e.g., IP address, time the website visitor spent on the site or cursor movements
initiated by the user). The data tracked during such analyses are forwarded to Google.
reCAPTCHA analyses run entirely in the background. Website visitors are not alerted that an analysis is
underway.
Data are stored and analyzed on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate
interest in the protection of the operator’s websites against abusive automated spying and against SPAM. If
appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a)
GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in
the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be
revoked at any time.
For more information about Google reCAPTCHA please refer to the Google Data Privacy Declaration and
Terms Of Use under the following links:
https://policies.google.com/privacy?hl=en and
https://policies.google.com/terms?hl=en.
9. eCommerce and payment service providers
Processing of Customer and Contract Data
We collect, process, and use personal customer and contract data for the establishment, content
arrangement and modification of our contractual relationships. Data with personal references to the use of
this website (usage data) will be collected, processed, and used only if this is necessary to enable the user to
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use our services or required for billing purposes. The legal basis for these processes is Art. 6(1)(b) GDPR.
The collected customer data shall be deleted upon completion of the order or termination of the business
relationship and upon expiration of any existing statutory archiving periods. This shall be without prejudice
to any statutory archiving periods.
Data transfer upon closing of contracts for services and digital content
We share personal data with third parties only if this is necessary in conjunction with the handling of the
contract; for instance, with the financial institution tasked with the processing of payments.
Any further transfer of data shall not occur or shall only occur if you have expressly consented to the
transfer. Any sharing of your data with third parties in the absence of your express consent, for instance for
advertising purposes, shall not occur.
The basis for the processing of data is Art. 6(1)(b) GDPR, which permits the processing of data for the
fulfilment of a contract or for pre-contractual actions.
