Privacy Policy My Ice Hockey

Overview of how your data is handled on www.myice.hockey and app.myice.hockey:

 

Content overview

  • Controller
  • Contact Data Protection Officer
  • Overview of processing operations
  • Representatives in the European Union
  • Relevant legal bases
  • Security measures
  • Transfer of personal data
  • Deletion of data
  • Use of cookies
  • Business services
  • Vendors and services used in the course of business
  • Provision of online services and web hosting
  • Contact and inquiry management
  • Chatbots and chat functions
  • Video conferencing, Online meetings, webinars, and screen sharing
  • Newsletters and electronic notifications
  • Web analytics, Monitoring and optimization
  • Presence on social networks (social media)
  • Plugins and embedded features and content
  • Management, Organization and Support Tools
  • Change and Update of Privacy Policy
  • Definitions of Terms

Responsible

Force8 AG
Seefeldstrasse 233
Mühle Tiefenbrunnen
8008 Zurich – Switzerland

Persons authorized to represent the company: Marco Bäschlin

E-mail address: info (at) myice.hockey

Phone: +41 79 150 36 71

Imprint: https://myice.hockey/en/contact

Contact Data Protection Officer

Marco Bäschlin

Force8 AG
Seefeldstrasse 233
8008 Zurich – Switzerland

Phone: +41 79 150 36 71
Email: info (at) myice.hockey
Website: www.myice.hockey

Representative in the European Union

Francisco Barreto

Force8 Ltd c/o ING
Rua Brito Pais No 8 5 Esq
1495-028 Algés – Portugal

Email: southeurope (at) myice.hockey
Website: www.myice.hockey

Overview of the 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

  • Inventory Data
  • Payment Data
  • Contact Data
  • Content Data
  • Contract Data
  • Use Data
  • Meta/Communication Data
  • Contact Information (Facebook)
  • Event Data (Facebook)

Categories of Data Subjects

  • Customers
  • Interested parties
  • Communication partners
  • Users
  • Business and contractual partners

Purposes of processing

  • Provision of contractual services and customer service
  • Contact requests and communication
  • Direct marketing
  • Reach measurement
  • Office and organization procedures
  • Remarketing
  • Conversion measurement
  • Management and response to requests
  • Feedback
  • Marketing
  • Profiles with user-related information
  • Provision of our online offer and user friendliness

Relevant legal bases

The following is an overview of the legal bases of the GDPR, on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Furthermore, should more specific legal bases be decisive in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO) – The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or purposes.
  • Contractual performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO) – The processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures taken at the request of the data subject.
  • Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO) – The processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Rightful interests (Art. 6 para. 1 p. 1 lit. f. DSGVO) – Processing is necessary to protect the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
  • Contractual performance and pre-contractual requests (EKD) (§ 6 no. 5 DSG-EKD) – The processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures carried out at the request of the data subject.

In addition to the data protection rules of the General Data Protection Regulation, national data protection regulations apply in Switzerland. These include, in particular, the Federal Data Protection Act (FADP). The DPA applies in particular when no EU/EEC citizens are involved and, for example, only data of Swiss citizens are processed.

Security measures

We take appropriate technical and organizational measures 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, in order to ensure a level of protection appropriate to the risk.

Measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to data as well as access to, entry into, disclosure of, assurance of availability of, and segregation of data concerning them. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data, and responses to data compromise. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software as well as procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

SSL encryption (https): To protect your data transmitted via our online offer, we use SSL encryption. You will recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Transmission of personal data

In the course of our processing of personal data, it happens that the data are transmitted to other bodies, companies, legally independent organizational units or persons or that they are disclosed to them. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with 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 organization: we may transfer personal data to other entities within our organization or grant them access to this data. Where this transfer is for administrative purposes, the transfer of data is based on our legitimate corporate and business interests or is made where it is necessary for the performance of our contract-related obligations or where we have the consent of the data subjects or legal permission.

Deletion of data

The data processed by us will be deleted in accordance with legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not necessary 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. That is, the data will be 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 defense of legal claims or for the protection of the rights of another natural person or legal entity.

As part of our privacy notices, we may provide users with further information regarding the deletion as well as the retention of data that is specific to the processing operation in question.

Use of cookies

Cookies are small text files, or other storage notes, that store information on terminal devices and read information from terminal devices. E.g. to store the login status in a user account, a shopping cart content in an e-shop, the content accessed or used functions of an online offer. Cookies can further be used for various purposes, e.g. for purposes of functionality, security and comfort of online offers as well as the creation of analyses of visitor flows.

Notes on consent: We use cookies in accordance with the law. Therefore, we obtain prior consent from users, except where it is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, are absolutely necessary to provide the user with a telemedia service (i.e. our online offer) expressly requested by them. The revocable consent is clearly communicated to the users and contains the information about the respective cookie use.

Notes on legal bases under data protection law: On which legal basis under data protection law we process users’ personal data using cookies depends on whether we ask users for consent. If users consent, the legal basis for the processing of your data is the declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in a business operation of our online offer and improvement of its usability) or, if this is done in the context of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. For what purposes the cookies are processed by us, we clarify in the course of this privacy policy or in the context of our consent and processing processes.

Storage period: With regard to the storage period, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his terminal device (e.g. browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after closing the terminal device. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., as part of obtaining consent), users should assume that cookies are permanent and the storage period can be up to two years.

General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also file an objection to processing in accordance with the legal requirements in Art. 21 DSGVO (further information on objection is provided as part of this privacy policy). Users can also declare their objection by means of the settings of their browser.

  • Types of data processed: Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and customer service.
  • Legal basis: Legitimate interests (Art. 6 para 1 p. 1 lit. f. DSGVO).

Further notes on processing processes, procedures and services:

    • Processing of cookie data based on consent: We use a cookie consent management procedure, in the context of which the consent of users to the use of cookies, or the processing and providers mentioned in the cookie consent management procedure can be obtained and managed and revoked by users. Here, the declaration of consent is stored in order not to have to repeat its query and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies), in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. Here, a pseudonymous user identifier is formed and stored with the time of consent, information on the scope of consent (e.g., which categories of cookies and / or service providers), as well as the browser, system and end device used.

WordPress.com: hosting platform for blogs / websites; service provider: Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA; website: https://wordpress.com; privacy policy: https://automattic.com/de/privacy/; contract: concluded with provider: https://wordpress. com/support/data-processing-agreements/.

Business Services

We process data of our contractual and business partners, e.g. customers and prospective customers (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 the Contractual Partners (or pre-contractual), for example, to answer inquiries.

We process this data in order to fulfill our contractual obligations. This includes, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other performance disruptions. In addition, we process the data to safeguard our rights and for the purpose of administrative tasks associated with these obligations and company organization. Furthermore, we process the data on the basis of our legitimate interests in proper and business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). 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 to fulfill legal obligations. Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope 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 marking (e.g. colors) or symbols (e.g. asterisks or similar), or personally.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e., in principle after the expiry of 4 years, unless the data is stored in a customer account, for example, as long as they must be kept for legal reasons of archiving (e.g., for tax purposes usually 10 years). We delete data disclosed to us by the contractual partner in the context of an order in accordance with the specifications of the order, in principle after the end of the order.

To the extent that we use third-party providers or platforms to provide our services, the terms and conditions and privacy notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.

Offer of software and platform services

We process the data of our users, registered users and any test users (hereinafter uniformly referred to as “users”) in order to be able to provide our contractual services to them as well as on the basis of legitimate interests in order to ensure the security of our offer and to be able to develop it further. The required information is identified as such in the context of the order, purchase order or comparable contract conclusion 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.

  • Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. e-mail, telephone numbers); contract data (e.g. subject matter of the contract, term, customer category).
  • Data subjects: Interested parties; Business and contractual partners.
  • Purposes of processing: Providing contractual services and customer service; Contact requests and communication; Office and organizational procedures; Administration and response to requests.
  • Legal basis: Contract performance and pre-contractual requests (Art. 6 para 1 p. 1 lit. b. DSGVO); Legal obligation (Art. 6 para 1 p. 1 lit. c. DSGVO); Legitimate interests (Art. 6 para 1 p. 1 lit. f. DSGVO).

Providers and services used as part of our business activities

As part of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers (in short, “services”) that may process user data, in compliance with legal requirements. In this context, the privacy notices of the respective Services apply in addition to our privacy notices.

Notes on legal bases: Insofar as 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 to provide our business services or, if not necessary for the performance of the contract, on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services).

  • Types of data processed: Contact Information (Facebook) (“Contact Information” is data that (clearly) identifies data subjects, such as names, email addresses and phone numbers, which may be transmitted to Facebook, e.g. via Facebook Pixel or Upload for matching purposes for the purpose of building Custom Audiences; After matching for the purpose of building audiences, the Contact Information will be deleted); Event Data (Facebook) (“Event Data” is data that may be transmitted, e.g. via Facebook Pixel (via Apps or in other ways) can be transmitted by us to Facebook and relate to persons or their actions; The data includes, for example, information about visits to websites, interactions with content, functions, installations of Apps, purchases of products, etc.; The Event Data is processed for the purpose of forming target groups for content and advertising information (Custom Audiences); Event Data does not include the actual content (such as written comments), no login information and no contact information (i.e. no names, email addresses and phone numbers). Event data will be deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
  • People concerned: Customers; Interested parties; Users (e. e.g. website visitors, users of online services); business and contractual partners; communication partners.
  • Purposes of processing: provision of contractual services and customer service; conversion measurement (measurement of the effectiveness of marketing measures); remarketing; direct marketing (eg. e.g. by e-mail or postal mail).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO); Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Further notes on processing processes, procedures and services:

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, which 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 web pages.

  • Types of data processed: Content data (e.g. input in online forms); Usage data (e.g. web pages visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: users (e.g. website visitors, users of online services).
  • Purposes of processing: provision of our online offer and user experience; provision of contractual services and customer service.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Further notes on processing processes, procedures and services:

  • Collection of access data and log files: We ourselves (or our web hosting provider) collect data on each access to the server (so-called server log files). The server log files may include the address and name of the retrieved web pages and files, date and time of retrieval, amount of data transferred, notification of successful retrieval, browser type and version, the operating system of the user, referrer URL (the previously visited page) and usually IP addresses and the requesting provider.The server log files can be used on the one hand for security purposes, for example, to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the utilization of the servers and their stability; Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is exempt from deletion until the final clarification of the respective incident.
  • WordPress.com: hosting platform for blogs / websites; Service provider: Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA; Website: https://wordpress.com; Privacy Policy: https://automattic. com/en/privacy/; Purchase order processing contract: concluded with provider: https://wordpress.com/support/data-processing-agreements/.
  • PT ISP: Web hosting and email services; Service provider: PT ISP
    Portugal
    https://ptisp.pt; Website: https://ptisp.pt/; Privacy Policy: https://ptisp.pt/company/legal.

Contact and Inquiry Management

When contacting us (e.g. via contact form, email, phone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed as far as this is necessary to answer the contact inquiries and any requested actions.

The answering of contact inquiries as well as the administration of contact and inquiry data in the context of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of legitimate interests in answering inquiries and maintaining user or business relationships.

  • Types of data processed: Inventory data (e.g., names, addresses); contact data (e.g., e-mail, telephone numbers); content data (e.g., input in online forms).
  • Data subjects: Communication partners.
  • Purposes of processing: Contact inquiries and communication; provision of contractual services and customer service.
  • Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO); Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO).

Further notes on processing operations, procedures and services:

  • Contact form: When users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context to process the communicated request. For this purpose, we process personal data in the context of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfillment and otherwise on the basis of our legitimate interests as well as the interests of the communication partners in responding to the requests and our legal retention obligations.

Chatbots and chat functions

We offer online chats and chatbot functions as a communication option (collectively referred to as “chat services”). A chat is an online conversation conducted with some degree of timeliness. A chatbot is software that answers users’ questions or notifies them of messages. When you use our chat features, we may process your personal data.

If you use our chat services within an online platform, your identification number will additionally be stored within the respective platform. We may also collect information about which users interact with our chat services and when. Furthermore, we store the content of your conversations via the chat services and log registration and consent processes in order to be able to prove them according to legal requirements.

We draw users’ attention to the fact that the respective platform provider can find out that and when users communicate with our chat services as well as collect technical information about the device used by the users and, depending on the settings of their device, also location information (so-called metadata) for purposes of optimizing the respective services and for security purposes. Likewise, the metadata of the communication via chat services (i.e., for example, the information about who communicated with whom) could be used by the respective platform providers in accordance with their provisions, to which we refer for further information, for marketing purposes or to display advertising tailored to users.

If users agree to a chatbot to activate information with regular messages, they have the option to unsubscribe from the information at any time in the future. The chatbot instructs users how and with which terms they can unsubscribe from the messages. Unsubscribing from chatbot messages deletes user data from the list of message recipients.

We use the foregoing information to operate our chat services, for example, to personally address users, to respond to their inquiries, to deliver any requested content, and also to improve our chat services (e.g., to “teach” chatbots answers to frequently asked questions or to identify unanswered inquiries).

Notes on legal basis: We use chat services on the basis of consent where we have obtained prior permission from users to process their data as part of our chat services (this applies to cases where users are asked for consent, for example, for a chatbot to send them messages on a regular basis). If we use chat services to answer users’ inquiries about our services or our company, this is done for contractual and pre-contractual communication. Otherwise, we use chat services based on our legitimate interests in optimizing the chat services, their operational efficiency, and enhancing the positive user experience.

Revocation, objection and deletion: You can revoke any consent given or object to the processing of your data within the scope of our chat services at any time.

  • Types of data processed: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. web pages visited, interest in content, access times); Meta/communication data (e.g.. e.g. device information, IP addresses).
  • Data subjects: communication partners.
  • Purposes of processing: contact requests and communication; direct marketing (eg. by e-mail or postal mail).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO); Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Further notes on processing operations, procedures and services:

Video Conferencing, Online Meetings, Webinars and Screen Sharing

We use third-party platforms and applications (hereinafter referred to as “Conference Platforms”) for purposes of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as “Conference”). In selecting the Conference Platforms and their services, we comply with the legal requirements.

Data processed by conference platforms:In the course of participating in a conference, the conference platforms process the personal data of the participants mentioned below. The scope of the processing depends, on the one hand, on which data is requested in the context of a specific conference (e.g., indication of access data or clear names) and which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants’ data may also be processed by the conference platforms for security purposes or service optimization. The processed data includes personal data (first name, last name), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the Internet access, information on the participants’ terminal devices, their operating system, the browser and its technical and language settings, information on the content of communications, i.e. entries in chats and audio and video data, as well as the use of other available functions (e.g. surveys). Content of communications is encrypted to the extent technically provided by the conference providers. If participants are registered as users with the conference platforms, then further data may be processed in accordance with the agreement with the respective conference provider.

Logging and recordings: If text entries, participation results (e.g. from surveys) as well as video or audio recordings are logged, this will be transparently communicated to the participants in advance and they will be asked – if necessary – for consent.

Data protection measures of the participants: Please note the details of the processing of your data by the conference platforms their data protection notices and choose within the settings of the conference platforms, the security and privacy settings that are optimal for you. Furthermore, please ensure data and privacy protection in the background of your recording for the duration of a videoconference (e.g., by notifying roommates, locking doors, and using the background obscuring function, if technically possible). Links to the conference rooms as well as access data, may not be disclosed to unauthorized third parties.

Notes on legal bases: Insofar as, in addition to the conference platforms, we also process users’ data and ask users for their consent to use the conference platforms or certain functions (e.g. consent to a recording of conferences), the legal basis of the processing is this consent. Furthermore, our processing may be necessary for the fulfillment of our contractual obligations (e.g. in lists of participants, in the case of reprocessing of call results, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.

  • Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Data subjects: communication partners; users (e.g. website visitors, users of online services).
  • Purposes of processing: provision of contractual services and customer service; contact requests and communication; office and organizational procedures.
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO); Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Further information about processing operations, procedures and services:

  • Google Hangouts / Meet: Messenger and conferencing software; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent Company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://hangouts.google.com/; privacy statement: https://policies. google.com/privacy.

Newsletters and Electronic Notifications

We send newsletters, emails and other electronic notifications (hereinafter “Newsletters”) only with the consent of the recipients or a legal permission. Insofar as in the context of a registration for the newsletter its contents are specifically circumscribed, they are decisive for the consent of the users. Otherwise, our newsletters contain information about our services and us.

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 other information, provided that this is necessary for the purposes of the newsletter.

Double-Opt-In-Procedure: The registration for our newsletter takes place in principle in a so-called double-opt-in procedure. That is, you will receive an email after registration, in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise, the changes to your data stored with the shipping service provider are 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 to prove consent formerly given. The processing of this data will be limited to the purpose of a possible defense 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 purposes of proving its proper course. Insofar as we commission a service provider with the dispatch of e-mails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system.

Notes on legal bases: The dispatch of newsletters is based on the consent of the recipients 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 in efficient and secure dispatch. The registration process is recorded on the basis of our legitimate interests to prove that it was carried out in accordance with the law.

Contents:

Information about us, our products, services, promotions and offers.

  • Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); meta/communication data (e.g. device information, IP addresses); usage data (e.g. websites visited, interest in content, access times).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g.. E.g. by e-mail or postal mail).
  • Legal basis: Consent (Art. 6 para 1 p. 1 lit. a. DSGVO); Legitimate interests (Art. 6 para 1 p. 1 lit. f. DSGVO).
  • Opposition (Opt-Out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consents, or object to further receipt. A link to cancel the newsletter can be found either at the end of each newsletter or you can otherwise use one of the above contact options, preferably e-mail, for this purpose.

More information about processing, procedures and services:

Web analytics, monitoring and optimization

Web analytics (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can recognize, for example, 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 require optimization.

In addition to web analytics, we may also use testing procedures, for example, to test and optimize different versions of our online offering or its components.

Unless otherwise stated below, profiles, i.e. data summarized for a usage process, may be created for these purposes and information may be stored in a browser, or in a terminal device and read from it. The information collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used, and information on usage times. If users have agreed to the collection of their location data to us or to the providers of the services we use, location data may also be processed.

The IP addresses of users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, in the context of web analysis, A/B testing and optimization, no clear data of the users (such as e-mail addresses or names) are stored, 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 purposes of the respective procedures.

Notes on legal bases: Insofar as 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, 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 privacy policy.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Users (e.g.. E.g. website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Further notes on processing processes, procedures and services:

Presence on 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 point out that this may involve processing user data outside the area of the European Union. This may result in risks for users, because, for example, the enforcement of the rights of users could be made more difficult.

Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior 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 behavior and 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 privacy statements and information provided by the operators of the respective networks.

Also in the case of information requests and the assertion of data subject rights, we 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. If you still need help, then you can contact us.

  • Types of data processed: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. input in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
  • People concerned: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Contact requests and communication; feedback (e.g. collecting feedback via online form); marketing.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Further information on processing operations, procedures and services:

Plugins and embedded functions and content

We include in our online offer functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may be, for example, graphics, videos or city maps (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, since 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 strive to use only such content whose respective providers use the IP address only for the delivery of 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 analyze 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 offer as well as be linked to such information from other sources.

Notes on legal bases: Insofar as 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, 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 privacy policy.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses); inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g.. e.g. entries in online forms).
  • Data subjects: users (e.g. website visitors, users of online services).
  • Purposes of processing: provision of our online offer and user-friendliness; provision of contractual services and customer service.
  • Legal basis: Consent (Art. 6 para 1 p. 1 lit. a. DSGVO); Contract performance and pre-contractual requests (Art. 6 para 1 p. 1 lit. b. DSGVO); Legitimate interests (Art. 6 para 1 p. 1 lit. f. DSGVO).

Further notes on processing processes, procedures and services:

  • Google Fonts: We integrate the fonts (“Google Fonts”) of the provider Google, whereby the users’ data is used solely for the purpose of displaying the fonts in the users’ browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform presentation and taking into account possible licensing restrictions for their integration; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent Company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://fonts.google.com/; privacy policy: https://policies.google.com/privacy.
  • Google Maps: We integrate the maps of the service “Google Maps” of the provider Google. The processed data may include, in particular, IP addresses and location data of users, which, however, are not collected without their consent (usually executed in the context of the settings of their mobile devices); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://cloud.google.com/maps-platform; privacy policy: https://policies.google.com/privacy; opt-out: opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • reCAPTCHA: We include the function “reCAPTCHA” to be able to recognize whether entries (eg in online forms) are made by humans and not by automatic machines (so-called “bots”). The processed data may include IP addresses, information on operating systems, devices or browsers used, language settings, location, mouse movements, keyboard strokes, time spent on websites, previously visited websites, interactions with ReCaptcha on other websites, possibly cookies as well as results of manual recognition processes (e.g. answering questions asked or selecting objects in images); Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent Company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://www.google.com/recaptcha/; privacy statement: https://policies.google. com/privacy; Opposition (Opt-Out): Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Ad Display Settings: https://adssettings.google.com/authenticated.
  • YouTube Videos: video content; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent Company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://www.youtube.com; privacy policy: https://policies.google.com/privacy; opt-out: opt-out plugin: https://tools.google. com/dlpage/gaoptout?hl=en, Ad Display Settings: https://adssettings.google.com/authenticated.

Management, Organization and Support Tools

We use services, platforms and software from other providers (hereinafter referred to as “Third Party Providers”) for purposes of organizing, managing, planning as well as 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 that we process in accordance with 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.

If users are not informed of the data processed, the data may be stored on the servers of the third-party providers.

Where users are referred to the third-party providers or their software or platforms as part of communications, business or other relationships with us, the third-party providers may process usage data and metadata for security, service optimization or marketing purposes. We therefore ask you to observe the privacy notices of the respective third-party providers.

Notes on legal bases: Insofar as 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 privacy policy.

  • Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Data subjects: communication partners; users (e.g. website visitors, users of online services).
  • Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles).
  • Legal basis: Consent (Art. 6 para 1 p. 1 lit. a. DSGVO); Contract performance and pre-contractual requests (Art. 6 para 1 p. 1 lit. b. DSGVO); Legitimate interests (Art. 6 para 1 p. 1 lit. f. DSGVO); Contract performance and pre-contractual requests (EKD) (§ 6 No. 5 DSG-EKD).

Further notes on processing operations, procedures and services:

Modification and updating of the privacy policy

We ask you to regularly check the content of our privacy policy. We adapt the Privacy Policy as soon as the changes in the data processing activities we carry out make it 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.

Where we provide addresses and contact information for companies and organizations in this Privacy Policy, please note that addresses may change over time and please check the information before contacting us.

Definitions of Terms

This section provides an overview of the terms used in this privacy statement. Many of the terms are taken from the law and defined primarily in Article 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are sorted alphabetically.

  • Conversion measurement: Conversion measurement (also referred to as “visit action evaluation”) is a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the devices of the users within the websites on which the marketing measures take place and then retrieved again on the target website. For example, we can thus track whether the ads we have placed on other websites were successful.
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (eg. e.g. cookie) or to one or more special characteristics that are an expression of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any type of automated processing of personal data that consists of using such personal data to identify certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behavior and interests, such as. e.g., interaction with websites and their content, etc.) to analyze, evaluate or, to predict (e.g., interests in certain content or products, click behavior on a website or location). For profiling purposes, cookies and web beacons are often used.
  • Range measurement: Range measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offer and may include the behavior or interests of visitors in certain information, such as content of web pages. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Remarketing: One speaks of “remarketing” or “retargeting” when, for example, for advertising purposes, it is noted for which products a user was interested on a website, in order to remind the user of these products on other websites, e.g. in advertisements.
  • Controller: The “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data, whether collecting, evaluating, storing, transmitting or deleting.

This is an automated translation of our original policy “Datenschutzerklärung” in German. In any case of translation uncertainty, the German version apply.

This data protection declaration is valid from: 04 March 2019