With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as "data" for short) that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part of the provision of our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as the "Online Offer").
The terms used are not gender-specific.
Last updated 29.11.2022
Table of contents
Boris Woynowski
Hindenburgstrasse 45
82467 Garmisch-Partenkirchen
Germany
E-Mail: bw@alpenferienwohnungen.de
Imprint: www.alpenferienwohnungen.de/impressum
Overview of processing operations
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
Special categories of data
Categories of data subjects
Purposes of processing
In the following, we share the legal bases of the General Data Protection Regulation (GDPR) on the basis of which we process personal data. Please note that in addition to the regulations of the DSGVO, the national data protection regulations in your or our country of residence and domicile may apply. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.
National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, the processing for other purposes and the transmission and automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. Furthermore, data protection laws of the individual federal states may apply.
We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. We also have procedures in place to ensure the exercise of data subjects' rights, the deletion of data and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
SSL encryption (https): In order to protect your data transmitted via our online offer, we use SSL encryption. You can recognise such encrypted connections by the prefix https:// in the address line of your browser.
Transfer and disclosure of personal data
In the course of our processing of personal data, the data may be transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. The recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.
Data transfer within the organisation: We may transfer personal data to other bodies within our organisation or grant them access to this data. Where this transfer is for administrative purposes, the transfer of data is based on our legitimate business and commercial interests or is made where it is necessary for the performance of our contract-related obligations or where there is consent from the data subjects or legal permission.
Data processing in third party countries
If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this is only done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognised level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).
Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user's computer. A cookie is primarily used to store information about a user during or after their visit within an online offering. Stored information may include, for example, language settings on a website, login status, a shopping cart or where a video was watched. The term cookies also includes other technologies that perform the same functions as cookies (e.g. where user details are stored using pseudonymous online identifiers, also known as "user IDs").
The following cookie types and functions are distinguished:
Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is your declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfil our contractual obligations.
Storage period: If we do not provide you with explicit information on the storage period of permanent cookies (e.g. during a so-called.
General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent you have given or to object to the processing of your data by cookie technologies (collectively referred to as "opt-out"). You can initially declare your objection by means of your browser settings, e.g. by deactivating the use of cookies (whereby this may also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared by means of a variety of services, especially in the case of tracking, via the https://optout.aboutads.info and https://www.youronlinechoices.com/ websites. In addition, you can obtain further instructions on how to object in the context of the information on the service providers and cookies used.
Processing of cookie data on the basis of consent: Before we process or have data processed in the context of the use of cookies, we ask users for consent that can be revoked at any time. Before consent has been given, cookies will only be used if they are absolutely necessary for the operation of our online offer..
Commercial and business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners") in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer enquiries.
We process this data to fulfil our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as for business organisation. Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or with the consent of the persons concerned (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.
We inform the contractual partners which data is required for the aforementioned purposes before or in the course of data collection, e.g. in online forms, by means of special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.
We delete the data after the expiry of legal warranty and comparable obligations, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. as long as it must be kept for legal archiving reasons (e.g. for tax purposes generally 10 years). We delete data disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, generally after the end of the order.
Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.
Customer account: Contractual partners can create an account within our online offer (e.g. customer or user account, "customer account" for short). If registration of a customer account is required, contractual partners will be informed of this and of the information required for registration. The customer accounts are not public and cannot be indexed by search engines. Within the scope of registration and subsequent logins and uses of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove the registration and to prevent any misuse of the customer account.
If customers have terminated their customer account, the data relating to the customer account will be deleted, unless their retention is required for legal reasons. It is the responsibility of customers to back up their data when their account is terminated.
Economic analyses and market research: For economic reasons and in order to be able to recognise market trends, wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., whereby the group of persons concerned may include contractual partners, interested parties, customers, visitors and users of our online offer.
The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we may, if available, take into account the profiles of registered users together with their details, e.g. regarding services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarised, i.e. anonymised values. Furthermore, we take the privacy of the users into consideration and process the data for the analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as summarised data).
Brokerage and mediation services: We process the data of our customers, clients and prospective customers (uniformly referred to as "customers") in accordance with the underlying mandate of the customers. We may also process information about the characteristics and circumstances of persons or property belonging to them if this forms part of the subject matter of our mandate. This may include, for example, information on personal circumstances, movable or immovable property and financial situation.
If required for the performance of the contract or required by law or approved by the clients or based on our legitimate interests, we disclose or transfer the clients' data to providers of the brokered services/objects, insurers, reinsurers, broker pools, technical service providers, other service providers, such as cooperating associations, in the context of coverage requests, conclusions and the processing of contracts. e.g. cooperating associations, as well as financial service providers, credit institutions and investment companies as well as social insurance institutions, tax authorities, tax advisors, legal advisors, auditors, insurance ombudsmen and the Federal Financial Supervisory Authority (BaFin). Furthermore, subject to other agreements, we may engage subcontractors, such as sub-brokers.
Hotel and accommodation services: We process the data of our guests, visitors and interested parties (uniformly referred to as "guests") in order to provide our accommodation and related services of a touristic or gastronomic nature and in order to invoice the services provided.
In the context of our commissioning, it may be necessary for us to process special categories of data within the meaning of Article 9 (1) of the Data Protection Regulation, in particular information on a person's health or information relating to their religious beliefs. The processing is carried out in order to protect the health interests of visitors (e.g. in the case of information on allergies) or otherwise to meet their physical or mental needs at their request and with their consent.
If required for the fulfilment of the contract or required by law, or consented to by guests, or if it is based on our legitimate interests, we disclose or transfer the guests' data e.g. to the service providers involved in the fulfilment of our services or from authorities, accounting offices and in the area of IT, office or comparable services.
Travel-related services: We process the data of our customers and prospective customers (uniformly referred to as "customers") in accordance with the underlying contractual relationship. We may also process information about the characteristics and circumstances of persons or things belonging to them if this is necessary in the context of the contractual relationship. This may include, for example, information on personal circumstances, movable tangible property and financial situation.
In the context of our commissioning, it may be necessary for us to process special categories of data within the meaning of Art. 9 (1) DSGVO, in particular information about a person's health. The processing is done to protect the health interests of the clients and otherwise only with the consent of the clients.
If required for the performance of the contract or required by law, or consented to by customers or on the basis of our legitimate interests, we disclose or transfer the customers' data, for example, to the service providers involved in the performance of the travel services.
Rental services: We process the data of our tenants and of interested parties (uniformly referred to as "tenants", including in the case of leases) in accordance with the underlying lease or similar contract. We may also process details of the characteristics and circumstances of persons or property belonging to them if this is necessary in the context of the tenancy. This may include, for example, information on personal circumstances, movable or immovable property and financial situation.
Within the scope of our commissioning, it may be necessary for us to process special categories of data within the meaning of Art. 9 (1) DSGVO, in particular information on a person's health. The processing takes place in order to be able to protect the health interests of the tenants and otherwise only with the consent of the tenants.
If required for the fulfilment of the contract or required by law or approved by the tenants or on the basis of our legitimate interests, we disclose or transfer the tenants' data in the context of cover requests, conclusion and processing of contracts, e.g. to financial service providers, credit institutions, utilities (e.g. electricity) or authorities.
Further information on commercial services: We process the data of our customers and clients (hereinafter uniformly referred to as "customers") in order to enable them to select, purchase or commission the selected services or works as well as associated activities and to pay for and deliver them or to execute or provide them.
The required information is identified as such in the context of the conclusion of the order, purchase order or comparable contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations.
Data processing contract with:
vOffice GmbH, with the VAT ID 321 071 133, the commercial register entry AG Lübeck, HRB 18338 HL and the address Am Holm 25, 23730 Neustadt.
Use of online marketplaces for e-commerce
We offer our services on online platforms operated by other service providers. In this context, the data protection notices of the respective platforms apply in addition to our data protection notices. This applies in particular with regard to the reach measurement and interest-based marketing procedures used on the platforms..
Within the scope of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other payment service providers in addition to banks and credit institutions for this purpose (collectively "payment service providers").
The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e. we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the terms and conditions and data protection information of the payment service providers.
The terms and conditions and data protection information of the respective payment service providers apply to the payment transactions and can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and assertion of revocation, information and other data subject rights.
Services used and service providers:
Provision of the online offer and web hosting
In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.
The data processed in the course of providing the hosting service may include all information relating to the users of our online service that is generated in the course of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.
E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of recognising SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption procedure is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.
Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.
The server log files may be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks) and to ensure the utilisation of the servers and their stability.
Content delivery network: We use a "content delivery network" (CDN). A CDN is a service with the help of which the content of an online offer, especially large media files such as graphics or programme scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet..
Data processing with:
vOffice GmbH, with the VAT ID 321 071 133, the commercial register entry AG Lübeck, HRB 18338 HL and the address Am Holm 25, 23730 Neustadt..
Registration, login and user account
Users can create a user account. As part of the registration process, users are provided with the required mandatory information and this information is processed for the purpose of providing the user account on the basis of contractual obligation fulfilment. The processed data includes in particular the login information (name, password and an e-mail address). The data entered during registration is used for the purposes of using the user account and its purpose.
Users may be informed by e-mail about processes relevant to their user account, such as technical changes. If users have terminated their user account, their data relating to the user account will be deleted, subject to any legal obligation to retain it. It is the responsibility of the users to save their data in the event of termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract.
Within the scope of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. This storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorised use. As a matter of principle, this data is not passed on to third parties unless it is necessary for the pursuit of our claims or there is a legal obligation to do so..
We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data are processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.
Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.
Furthermore, we reserve the right, on the basis of our legitimate interests, to process users' details for the purpose of spam detection.
On the same legal basis, we reserve the right to store the IP addresses of users for the duration of surveys and to use cookies in order to avoid multiple voting.
The personal information provided in the context of comments and contributions, any contact and website information as well as the content-related information will be permanently stored by us until the user objects.
When contacting us (e.g. via contact form, email, telephone or via social media), the information of the inquiring persons is processed to the extent that this is necessary to answer the contact enquiries and any requested measures.
The response to contact enquiries in the context of contractual or pre-contractual relationships is carried out to fulfil our contractual obligations or to respond to (pre)contractual enquiries and otherwise on the basis of the legitimate interests in responding to the enquiries..
We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, on encryption, on the use of the metadata of the communication and on your objection options.
You can also contact us in alternative ways, e.g. via telephone or e-mail. Please use the contact options provided to you or the contact options provided within our online offer.
In the case of end-to-end encryption of content (i.e., the content of your message and attachments), we point out that the communication content (i.e., the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messenger with encryption enabled to ensure that the message content is encrypted.
However, we also point out to our communication partners that although the messenger providers cannot view the content, they can find out that and when communication partners communicate with us and that technical information on the device used by the communication partners and, depending on the settings of their device, location information (so-called metadata) is processed.
Notes on legal basis: If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and they contact us on their own initiative, for example, we use Messenger in relation to our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners for communication via Messenger. Furthermore, we would like to point out that we do not transmit the contact data provided to us to the messengers for the first time without your consent.
Revocation, objection and deletion: You can revoke your consent at any time and object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete the messages in accordance with our general deletion guidelines (i.e., e.g., as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information provided by the communication partners, if no reference to a previous conversation is to be expected and the deletion does not conflict with any statutory retention obligations.
Reservation of reference to other communication channels: Finally, we would like to point out that we reserve the right not to answer enquiries via Messenger for reasons of your security. This is the case if, for example, internal contractual information requires special confidentiality or an answer via Messenger does not meet formal requirements. In such cases we refer you to more adequate communication channels.
Push notifications
With the consent of users, we may send users so-called "push notifications". These are messages that are displayed on users' screens, devices or browsers even when our online service is not actively being used.
To sign up for the push messages, users must confirm their browser or device's request to receive the push messages. This consent process is documented and stored. The storage is necessary to recognise whether users have consented to receive the push messages and to be able to prove consent. For these purposes, a pseudonymous identifier of the browser (so-called "push token") or the device ID of an end device is stored.
On the one hand, the push messages may be necessary for the fulfilment of contractual obligations (e.g. technical and organisational information relevant to the use of our online offer) and are otherwise sent on the basis of user consent, unless specifically mentioned below. Users can change the receipt of push messages at any time using the notification settings of their respective browsers or end devices..
Video conferencing, online meetings, webinars and screen sharing
We use platforms and applications of other providers (hereinafter referred to as "third party providers") for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings. When selecting the third-party providers and their services, we observe the legal requirements.
In this context, data of the communication participants are processed and stored on the servers of the third-party providers, insofar as these are part of communication processes with us. This data may include, in particular, registration and contact data, visual and vocal contributions as well as entries in chats and shared screen contents.
If users are referred to the third-party providers or their software or platforms in the course of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security, service optimisation or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.
Notes on legal bases: If we ask users for their consent to the use of the third-party providers or certain functions (e.g. consent to a recording of conversations), the legal basis of the processing is consent. Furthermore, their use may be a component of our (pre-)contractual services, provided that the use of the third-party providers was agreed within this framework. Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners. In this context, we would also like to refer you to the information on the use of cookies in this data protection declaration..
Services used and service providers:
Cloud services
We use software services accessible via the Internet and running on the servers of their providers (so-called "cloud services", also referred to as "software as a service") for the following purposes: document storage and management, calendar management, sending e-mails, spreadsheets and presentations, exchanging documents, content and information with specific recipients or publishing web pages, forms or other content and information, as well as chats and participation in audio and video conferences.
In this context, personal data may be processed and stored on the servers of the providers to the extent that these are part of communication processes with us or are otherwise processed by us as set out in the context of this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents. The cloud service providers also process usage data and metadata used by them for security purposes and service optimisation.
If we use the cloud services to provide forms or other documents and content to other users or publicly accessible websites, the providers may store cookies on the users' devices for the purpose of web analysis or to remember the users' settings (e.g. in the case of media control).
Notes on legal bases: Where we ask for consent to use cloud services, the legal basis for processing is consent. Furthermore, their use may be a component of our (pre)contractual services, provided that the use of the cloud services has been agreed within this framework. Otherwise, users' data is processed on the basis of our legitimate interests (i.e., interest in efficient and secure management and collaboration processes).
Services used and service providers:
Data processing in connection with the digital guest card
Through the obligatory visitor's tax, the guest has the right to use the digital guest card, which the provider makes available to him. The use requires the disclosure of the following data:
The data will be processed in order to provide the guest with the services associated with the digital Services at the disposal of the guest. To this extent, the data processing is based on Art. 6 para. 1 p. 1 lit b) DSGVO.
For the use of the registration obligation via the digital guest card, the use requires the disclosure of the following data:
This data (with the exception of the email address) is used to fulfill the registration obligation of the Guest in accordance with Section 30 of the Federal Registration Act. To this extent, the data processing is based on Art. 6 para. 1 p. 1 lit c) DSGVO. The retention period is twelve months. After that the data will be deleted. The provider uses the company vOffice GmbH, Am Holm 25, 23730 Neustadt i. H. as a Processor for the processing of the obligation to register via the guest card, as well as for the handling of the fulfillment of the obligation to provide the guest card for the purpose of claiming benefits. The data will be deleted when possible claims of the guest based on the provision of the guest card have expired, namely three years after the end of the year in which the claim arose.
Newsletter and electronic notifications
We send newsletters, e-mails and other electronic notifications (hereinafter "newsletter") only with the consent of the recipients or a legal permission. Insofar as the contents of the newsletter are specifically described in the course of registration, they are decisive for the consent of the user. Apart from that, our newsletters contain information about our services and us.
In order to subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name, for the purpose of personal address in the newsletter, or further details, if these are necessary for the purposes of the newsletter.
Double opt-in procedure: The registration for our newsletter is always carried out in a so-called double opt-in procedure. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other people's e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored with the dispatch service provider are also logged.
Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove consent previously given. The processing of this data will be limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list (so-called "block list") for this purpose alone.
The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.
Notes on legal basis: The newsletter is sent on the basis of the recipients' consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of existing customer advertising. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to demonstrate that it has been carried out in accordance with the law.
Content: Information about us, our services, promotions and offers.
Analysis and performance measurement: The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from our server or, if we use a dispatch service provider, from their server when the newsletter is opened. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and the time of the retrieval, are initially collected.
This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our intention nor, if used, that of the dispatch service provider to observe individual users. The evaluations serve us rather to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
The evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves both our business interests and meets the expectations of the users.
Unfortunately, a separate revocation of the performance measurement is not possible; in this case, the entire newsletter subscription must be cancelled or revoked.
Prerequisite for the use of free services: Consent to the sending of mailings can be made dependent as a prerequisite for the use of free services (e.g. access to certain content or participation in certain promotions). If users wish to take advantage of the free service without subscribing to the newsletter, please contact us.
Services used and service providers:
Promotional communication via e-mail, post, fax or telephone
We process personal data for the purposes of promotional communication, which may take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.
Recipients have the right to revoke consent given at any time or to object to promotional communication at any time.
After revocation or objection, we may store the data required to prove consent for up to three years based on our legitimate interests before deleting it. The processing of this data is limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.
The surveys and polls we conduct (hereinafter "surveys") are evaluated anonymously. Personal data is only processed insofar as this is necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address in order to display the survey in the user's browser or to enable the survey to be resumed with the aid of a temporary cookie (session cookie)) or users have consented to this.
Notes on legal basis: If we ask participants for consent to process their data, this is the legal basis for the processing, otherwise the processing of participants' data is based on our legitimate interests in conducting an objective survey.
Web analysis, monitoring and optimisation
Web analytics (also referred to as "reach measurement") is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the reach analysis, we can, for example, recognise at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimisation.
In addition to web analysis, we may also use test procedures, e.g. to test and optimise different versions of our online offer or its components.
For these purposes, so-called user profiles may be created and stored in a file (so-called "cookie") or similar procedures may be used with the same purpose. This information may include, for example, content viewed, websites visited and elements used there and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed, depending on the provider.
The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimisation, but pseudonyms. This means that we as well as the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.
Notes on legal basis: If we ask users for their consent to use the third-party providers, the legal basis for processing data is consent. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Services used and service providers:
We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the display of promotional and other content (collectively, "content") based on the potential interests of users and the measurement of its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar procedures are used, by means of which the information about the user relevant to the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed.
The IP addresses of users are also stored. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored within the framework of the online marketing process, but pseudonyms. This means that we as well as the providers of the online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can generally also be read later on other websites that use the same online marketing procedure and analysed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.
Exceptionally, clear data can be assigned to the profiles. This is the case if, for example, the users are members of a social network whose online marketing procedure we use and the network links the users' profiles with the aforementioned data. We ask you to note that users may enter into additional agreements with the providers, e.g. by giving their consent as part of the registration process.
In principle, we only receive access to summarised information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to a conclusion of a contract with us. The conversion measurement is used solely to analyse the success of our marketing measures.
Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.
Notes on legal bases: Where we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this data protection declaration.
Services used and service providers:
Affiliate programmes and affiliate links
We include so-called affiliate links or other references (which may include, for example, search masks, widgets or discount codes) to the offers and services of third-party providers in our online offer (collectively referred to as "affiliate links"). If users follow the Affiliate Links or subsequently take advantage of the offers, we may receive a commission or other benefits from those third parties (collectively, "Commission").
In order to be able to track whether users have taken advantage of the offers of an affiliate link used by us, it is necessary that the respective third-party providers learn that the users have followed an affiliate link used within our online offer. The assignment of the affiliate links to the respective business transactions or to other actions (e.g. purchases) serves the sole purpose of commission accounting and will be cancelled as soon as it is no longer necessary for the purpose.
For the purposes of the aforementioned allocation of the affiliate links, the affiliate links may be supplemented by certain values which are a component of the link or may be stored elsewhere, e.g. in a cookie. The values may include in particular the source website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer and an online identifier of the user.
Notes on legal basis: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Furthermore, their use may be a component of our (pre-)contractual services, provided that the use of the third-party providers was agreed within this framework. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this data protection declaration.
Offer of an Affiliate Programme
We offer an affiliate programme, i.e., commission or other benefits (collectively, "Commission") to users (referred to as "Affiliates") who refer to our offers and services. The referral is made by means of a link or other method (e.g. discount codes) associated with the relevant Affiliate which allows us to identify that the use of our services was based on the referral (collectively, "Affiliate Links").
In order to track whether users have taken advantage of our services as a result of the Affiliate Links used by Affiliates, it is necessary for us to know that users have followed an Affiliate Link. The assignment of the affiliate links to the respective business transactions or other use of our services is solely for the purpose of commission accounting and will be cancelled as soon as it is no longer necessary for the purpose.
For the purposes of the aforementioned assignment of the affiliate links, the affiliate links may be supplemented by certain values which are a component of the link or may be stored elsewhere, e.g. in a cookie. The values may include in particular the source website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer and an online identifier of the user.
Notes on legal basis: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Furthermore, their use may be a component of our (pre-)contractual services, provided that the use of the third-party providers was agreed within this framework. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this data protection declaration.
We participate in rating procedures in order to evaluate, optimise and promote our services. If users rate us or otherwise provide feedback via the participating rating platforms or procedures, the general terms and conditions of business or use and the data protection information of the providers also apply. As a rule, the rating also requires registration with the respective providers.
In order to ensure that the persons rating have actually used our services, we transmit, with the consent of the customers, the data required for this with regard to the customer and the service used to the respective rating platform (including name, e-mail address and order number or item number). This data is used solely to verify the authenticity of the user.
Presence in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for the users because, for example, it could make it more difficult to enforce the rights of the users.
Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behaviour and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behaviour and the interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).
For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can take appropriate measures and provide information directly. Should you nevertheless require assistance, you can contact us.
Facebook: We are jointly responsible with Facebook Ireland Ltd for collecting (but not further processing) data from visitors to our Facebook page (known as a "Fan Page"). This data includes information about the types of content users view or interact with, or the actions they take (see under "Things You and Others Do and Provide" in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices users use (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under "Device Information" in the Facebook Data Policy Statement: https://www.facebook.com/policy). As explained in the Facebook Privacy Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services called "Page Insights" to Page operators to provide them with insights into how people interact with their Pages and the content associated with them. We have entered into a special agreement with Facebook ("Page Insights Information", https://www.facebook.com/legal/terms/page_controller_addendum), which in particular regulates which security measures Facebook must observe and in which Facebook has agreed to fulfil the data subject rights (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information on Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data).
Services used and service providers:
Plugins and embedded functions and content
We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These can be, for example, graphics, videos or social media buttons as well as posts (hereinafter uniformly referred to as "content").
The integration always requires that the third-party providers of this content process the IP address of the user, as without the IP address they could not send the content to their browser. The IP address is thus required for the presentation of these contents or functions. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to analyse information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offering, as well as being linked to such information from other sources.
Notes on legal basis: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this data protection declaration.
Facebook plugins and content: We are jointly responsible with Facebook Ireland Ltd. for collecting or receiving in transmission (but not further processing) "Event Data" that Facebook collects or receives in transmission through the Facebook social plugins (and content embedding features) that run on our Online Service for the purposes of: a) displaying content and advertising information that is relevant to users' perceived interests; b) delivering commercial and transactional messages (e.g., targeting users via Facebook Messenger); c) improving ad delivery and personalising features and content (e.g., improving recognition of which content or ads are relevant to which users). (c) improving ad delivery and personalising features and content (e.g., improving the identification of which content or advertising information is likely to be relevant to users' interests). We have entered into a specific agreement with Facebook ("Controller Addendum", https://www.facebook.com/legal/controller_addendum), which in particular regulates which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfil the data subject rights (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with metrics, analytics and reports (which are aggregated, i.e. do not receive details of individual users and are anonymous to us), then this processing is not carried out under shared responsibility but on the basis of a commissioned processing agreement ("Data Processing Terms and Conditions", https://www.facebook.com/legal/terms/dataprocessing), the "Data Security Terms and Conditions" (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of standard contractual clauses ("Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority), are not restricted by the agreements with Facebook.
Instagram plugins and content: We are jointly responsible with Facebook Ireland Ltd. for collecting or receiving in the course of a transmission (but not further processing) "Event Data" that Facebook collects or receives in the course of a transmission through Instagram features (e.g., content embedding features) running on our Online Service for the purposes of: a) displaying content and promotional information that is relevant to users' perceived interests; b) delivering commercial and transactional messages (e.g., targeting users via Facebook Messenger); c) improving ad delivery and personalisation of features and content (e.g., improving recognition of which content or ads are relevant to which users). (c) improving ad delivery and personalising features and content (e.g., improving the identification of which content or advertising information is likely to be relevant to users' interests). We have entered into a specific agreement with Facebook ("Controller Addendum", https://www.facebook.com/legal/controller_addendum), which in particular regulates which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfil the data subject rights (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with metrics, analytics and reports (which are aggregated, i.e. do not receive details of individual users and are anonymous to us), then this processing is not carried out under shared responsibility but on the basis of a commissioned processing agreement ("Data Processing Terms and Conditions", ), the "Data Security Terms and Conditions" (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of standard contractual clauses ("Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority), are not restricted by the agreements with Facebook.
Services used and service providers:
Planning, organisation and auxiliary tools
We use services, platforms and software from other providers (hereinafter referred to as "third-party providers") for the purposes of organising, managing, planning and providing our services. When selecting the third-party providers and their services, we observe the legal requirements.
In this context, personal data may be processed and stored on the servers of the third-party providers. This may involve various data which we process in accordance with this data protection declaration. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents.
If users are referred to the third-party providers or their software or platforms in the course of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimisation or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.
Notes on legal basis: If we ask users for their consent to use the third-party providers, the legal basis for processing data is consent. Furthermore, their use may be a component of our (pre-)contractual services, provided that the use of the third-party providers was agreed within this framework. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this data protection declaration.
Data processing contract with:
vOffice GmbH, with the VAT ID 321 071 133, the commercial register entry AG Lübeck, HRB 18338 HL and the address Am Holm 25, 23730 Neustadt.
The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose for processing this data has ceased to apply or it is not required for the purpose).
If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.
Further information on the deletion of personal data can also be found in the individual data protection notices of this privacy policy.
Amendment and updating of the data protection declaration
We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organisations in this data protection declaration, please note that the addresses may change over time and please check the information before contacting us..
Rights of the persons concerned
As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
Regulatory authority responsible for us:
Bayerisches Landesamt für Datenschutzaufsicht
Promenade 18
91522 Ansbach
Germany
Postal address:
Postfach 1349, 91504 Ansbach
Telephone: 0049 981/180093-0
Fax: 0049 981/180093-800
E-mail: poststelle@lda.bayern.de
Website: https://www.lda.bayern.de
This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined primarily in Art. 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.