Privacy Policy
1. General scope of data processing
Data protection has a high priority in our society. We comply with the General Data Protection Regulation (GDPR), which regulates the processing of personal data uniformly for the entire European Union and other national data protection laws of the member states as well as other data protection regulations. In principle, we collect, process, and use personal data only insofar as this is necessary for the provision of a functional website and for the presentation of our offers, and the provision of our services.
As a user, you can generally visit our website without providing any personal information. Personal data is only collected and used to the extent necessary to provide a functional website and our content and services. In principle, your personal data will only be collected and used with your consent. An exception applies in such cases in which it is not possible to obtain prior consent for actual reasons or the collection and processing of the data is permitted by statutory provisions.
For security reasons, we use an SSL certificate on our website to provide secure connections by encrypting all incoming and outgoing data traffic. You can recognize the encryption by the lock symbol in your browser line and by the fact that "https://" is displayed there.
2. Name and address of the person responsible for data processing
The person responsible within the meaning of the GDPR is:EMKE(UK) LIMITE
Ciba Building, C/O Bath & Homes Limited, 146 Hagley Road Birmingham, B16 9NX, UK
service@emkedirect.co.uk
Telephone: +44 1384 385894
3. Definitions
The terms used in this data protection declaration correspond to those from Article 4 of GDPR. For the purposes of this Regulation, the term means "Personal Data" - any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more special features that express the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
"Data subject" - any identified or identifiable natural person, whose personal data is processed by the controller.
"Processing" - any process carried out with or without the help of automated processes or any such series of processes in connection with personal data such as collecting, recording, organizing, organizing, storing, adapting or changing, reading out, querying, using, disclosure by transmission, distribution or any other form of making available, matching or linking, restriction, deletion or destruction;
"Restriction of processing" - the marking of stored personal data with the aim of restricting their future processing;
"Profiling" - any type of automated processing of personal data consisting in using this personal data to evaluate certain personal aspects relating to a natural person, in particular aspects related to work performance, economic situation, health, analyze or predict personal preferences, interests, reliability, behavior, location or relocation of that natural person;
"Responsible" - the natural or legal person, public authority, agency, or other body that alone or jointly with others decides on the purposes and means of the processing of personal data; if the purposes and means of this processing are specified by Union law or the law of the Member States, the person responsible or the specific criteria for his naming can be provided for by Union law or the law of the Member States;
"Recipient" - a natural or legal person, public authority, agency, or other body to which personal data are disclosed, whether a third party or not. However, authorities that may receive personal data in the context of a specific investigation mandate under Union or Member State law are not considered recipients; the processing of this data by said authorities is carried out in accordance with the applicable data protection regulations, according to the purposes of the processing;
"Third party" - a natural or legal person, public authority, agency, or body other than the Data Subject, Controller, Processor, and persons who, under the direct responsibility of the Controller or Processor, are authorized to process the Personal Data;
"Consent" - the data subject voluntarily, for the specific case, in an informed manner and unequivocally given expression of will in the form of a declaration or other clear affirmative action, with which the data subject indicates that they are processing their personal data agrees.
4. General legal bases for the processing of personal data
In so far as we obtain the consent of the person concerned for the processing of personal data, Article 6 (1) (a) of the EU General Data Protection Regulation (GDPR) is the legal basis for the processing of personal data.
Article 6 (1) (b) GDPR is the legal basis for the processing of personal data required to fulfill a contract to which the data subject is a party. This also applies to processing operations that are necessary to carry out pre-contractual measures.
In so far as the processing of personal data is necessary to fulfill a legal obligation to which we are subject, Article 6 (1) (c) GDPR is the legal basis.
In the event that the vital interests of the data subject or another natural person require the processing of personal data, Article 6 Paragraph 1 lit. d GDPR is the legal basis.
If the necessary processing serves to safeguard our legitimate interests or those of a third party and if the interests, fundamental rights, and fundamental freedoms of the data subject do not outweigh the former interest, Article 6 Paragraph 1 lit. f GDPR is the legal basis for the processing.
5. Data erasure and storage duration
Your personal data stored by us will be deleted or blocked as soon as the purpose of storage no longer applies. Storage can also take place if this has been provided for by the European or national legislator in EU regulations, laws, or other regulations to which we are subject, e.g. due to tax and commercial law storage and documentation obligations. The data will also be blocked or deleted if a storage period prescribed by the standards mentioned expires unless there is a need for further storage of the data for the conclusion or fulfillment of a contract.
6. Collection of technical access data, server log files
Each time our website is accessed, our web server automatically collects data and information from the computer system of the accessing computer you are using. The following data is collected here:
- Browser name and version used
- Operating system used
- Internet Service Providers
- IP address
- Date and time of access
- The website from which you access our website (referrer URL)
- Operating system language
- Location Data (State, Country, Province)
The data is temporarily stored in the log files of the web server we use. A storage of this data together with your other personal data does not take place. Your data cannot be assigned to specific persons by us. We only use this technical log data for statistical purposes and to optimize our website and its security. The legal basis for the temporary storage of the data and the log files is Article 6 (1) (f) GDPR.
The temporary storage of the IP address by our web server is necessary to enable the delivery of the accessed web pages to your computer. To do this, the IP address of the calling computer must be saved for the duration of the session. Storage in log files takes place to ensure the functionality of the website. In addition, we use the data to optimize the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context. Our legitimate interest in data processing in accordance with Article 6 (1) (f) GDPR also lies in the above purposes.
The stored data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. The collection of the data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. There is therefore no possibility of objection and removal on your part.
7. Use of cookies
We use "cookies" on our website. "Cookies" are text files that are stored in the Internet browser or by the Internet browser on the calling computer system. If you call up a website, a cookie can be stored on the operating system of the computer you are using. This cookie contains a characteristic character string that enables the browser to be clearly identified when the website is called up again.
The purpose of using cookies is to make it easier for you to use websites. Some functions of our website cannot be offered without the use of cookies. For this it is necessary that the browser is recognized even after a page change, e.g. log-in information, the content of the shopping cart, adoption of language settings, and remembering search terms. The user data collected by technically necessary cookies are not used to create user profiles. The data processed by cookies are required for the purposes mentioned to safeguard our legitimate interests in a customer-friendly website design in accordance with Article 6 Paragraph 1 Clause 1 Letter f GDPR or are carried out in accordance with Article 6 Paragraph 1 Letter b GDPR to carry out the contract.
We work with advertising partners who help us make our website more interesting for you. For this purpose, cookies from partner companies are also stored on your hard drive when you visit our website (third-party cookies). You will be informed individually and separately in the following sections about the use of such cookies and the scope of the information collected in each case.
Cookies are stored on your computer and transmitted to our website. Therefore, as a user, you also have full control over the use of cookies. By changing the settings in your Internet browser, you can deactivate or restrict the transmission of cookies. Cookies that have already been saved can be deleted at any time. Depending on the browser, this can also be done automatically. You can find setting options for your browser on the website of the respective provider of your browser.
Please note that the functionality of our website may be restricted if cookies are not accepted.
8. Age query
If your order includes goods whose sale is subject to age restrictions, we use a reliable process that includes a personal identity and age check to ensure that the customer has reached the required minimum age. For this purpose, the SCHUFA identity check is used on our website. This service is operated by SCHUFA Holding AG, Kormoranweg 5, 65201 Wiesbaden, Germany (hereinafter: SCHUFA).
In order to ensure the required minimum age, individual personal data (e.g. name, address, and date of birth) are transmitted to SCHUFA Holding AG. A so-called identity check is then carried out with Q-Bit, which was positively evaluated by the Commission for Youth Media Protection (KJM) for age verification. According to Article 6 Paragraph 1 Clause 1 Letter f GDPR, the data transmission to SCHUFA serves to protect our overriding legitimate interests in ensuring an offer that complies with youth protection law and compliance with the statutory provisions on the protection of minors. A credit check does not take place in this respect.
9. Comment function in the blog
On our blog (web log book with contributions from the website operator) you have the opportunity to make individual comments on individual blog posts. If you leave a comment on a published blog post, information about the time you entered the comment and the user name (pseudonym) you have chosen will be saved and published in addition to the comments you have added. We also log the IP address assigned by your internet service provider (ISP). The IP address is stored for security reasons and in the event that you violate the rights of third parties or post illegal content by submitting a comment and we have to defend ourselves against this. Our legitimate interest in data processing in accordance with Article 6 (1) (f) GDPR also lies in the above purposes. Except in cases of necessary legal defense or in cases prescribed by law, the personal data collected will not be passed on to third parties.
10. Comment function on products
On our product pages, you have the opportunity to submit individual comments on individual product offers. If you leave a comment on a product, information about the time you entered the comment and the user name (pseudonym) you have chosen will be saved and published in addition to the comments you have entered. We also log the IP address assigned by your internet service provider (ISP). The IP address is stored for security reasons and in the event that you violate the rights of third parties or post illegal content by submitting a comment and we have to defend ourselves against this. Our legitimate interest in data processing in accordance with Article 6 (1) (f) GDPR also lies in the above purposes. Except in cases of necessary legal defense or in cases prescribed by law, the personal data collected will not be passed on to third parties.
11. Newsletters
If you have the option of subscribing to a free newsletter on our website, the following applies: When you register for the newsletter, the data from the input mask is transmitted to us. Your e-mail address is one of the data requested in the input mask. Providing your first and last name is voluntary so that we can address you personally in the newsletter. Your consent will be obtained for the processing of the data as part of the registration process and reference will be made to this data protection declaration.
We use the so-called double opt-in procedure to send newsletters. This means that we will not send you an email newsletter unless you have expressly confirmed to us that you consent to receive such a newsletter. You will then receive a confirmation e-mail from us in which we ask you to confirm that you would like to receive newsletters in the future by clicking on a corresponding link. By clicking on the confirmation link, you give us your consent to use your personal data in accordance with Article 6 (1) (a) GDPR. In addition, the IP address of the calling computer and the date and time of the registration are also collected during registration in order to prevent misuse of the services or the e-mail address used or to be able to trace a complaint. Our legitimate interest in data processing in accordance with Article 6 (1) (f) GDPR also lies in the above purposes.
If you purchase goods or services on our website and provide your e-mail address, we can then use it to send you a newsletter. In such a case, only direct advertising for your own similar goods or services will be sent via the newsletter. There is no transfer of data to third parties in connection with data processing for sending newsletters. The data will only be used to send the newsletter. The legal basis for processing the data after you have registered for the newsletter is Article 6(1)(a) GDPR if you have given your consent.
Your data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. Your e-mail address will therefore only be stored for as long as the subscription to the newsletter is active unless you have expressly consented to further use of your data. You can unsubscribe from the newsletter at any time. For this purpose, there is a corresponding link in every newsletter. This also enables revocation of the consent to the storage of the personal data collected during the registration process.
Mailchimp
We use the “MailChimp” service from the provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA to send the newsletter. With "MailChimp", the data of the recipients are used in pseudonymous form, ie without assignment to a user, to optimize or improve our own services, e.g. for the technical optimization of the dispatch and the presentation of the newsletter or for statistical purposes. The data of our newsletter recipients will only be used by us and not by the Rocket Science Group LLC, for example, to write to you or to pass the data on to third parties.
There is no adequacy decision by the European Commission for the MailChimp service for the USA. We base our cooperation with them on standard data protection clauses of the European Commission. If your IP address is collected via the technologies, it will be shortened before it is stored on the provider's servers by activating IP anonymization. The full IP address is only transmitted to the provider's server and shortened there in exceptional cases. Unless otherwise specified for the individual technologies, data processing takes place on the basis of an agreement concluded between jointly responsible persons for the respective technology in accordance with Art. 26 DSGVO. We have concluded an order processing contract with the provider in accordance with Article 28 (3) Sentence 1 GDPR.
The legal basis for data processing is Art. 6 (1) (a) GDPR (consent). You can revoke your consent at any time by unsubscribing from the newsletter. This also applies in the event that you do not want an analysis by MailChimp. We provide a link or an e-mail address at the end of each newsletter for the revocation. You can also unsubscribe from the newsletter directly on the website.
Your data stored with us for the receipt of the newsletter will be stored by us until you unsubscribe from the newsletter and deleted both from our servers and from the servers of MailChimp after you unsubscribe from the newsletter. Data stored by us for other purposes (e.g. e-mail addresses for the members' area) remain unaffected.
12. Customer registration
If you have the opportunity to set up a customer account on our website and to register by providing your personal data, the following applies: The data is entered in an input mask and transmitted to us, and stored. A transfer of data to third parties does not take place. Which data collected can be seen from the respective input forms. Your consent to the processing of this data is expressly obtained as part of the registration process. At the time of registration, the following data is also stored for security reasons: the IP address of the calling computer, and the date and time of registration. Our legitimate interest in data processing in accordance with Article 6 (1) (f) GDPR also lies in the above purposes. Your registration is necessary to fulfill a contract with you or to carry out pre-contractual measures. By registering, we can quickly and easily provide you with the data you have entered once again, without you having to re-enter them. If you have given your consent, the legal basis for processing the data is Article 6 (1) (a) GDPR. If the registration serves to fulfill a contract between you and us or to carry out pre-contractual measures, the additional legal basis for the processing of the data is Art. 6 Paragraph 1 lit. b GDPR.
Your data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. This is the case during the registration process to fulfill a contract or to carry out pre-contractual measures if the data is no longer required for the execution of the contract. Even after the conclusion of the contract, it may be necessary to store the personal data of the contractual partner in order to comply with contractual or legal obligations.
As a user, you have the option to cancel the registration at any time. You can have the data stored about you changed at any time. To change or delete your data, simply contact us using the contact details given in the imprint. Ideally, send us an email. If the data is required to fulfill a contract or to carry out pre-contractual measures, the data can only be deleted prematurely if there are no contractual or legal obligations to the contrary.
13. Contact form and email contact
If there is a contact form on our website that you can use to contact us electronically, the following applies: If you use this option, the data entered in the input mask will be transmitted to us and stored. Data collected in the case of a contact form can be found on the respective contact form. At the time the message is sent, the IP address of the calling computer; Date and time of registration are saved to prevent misuse of the contact form and to ensure the security of our information technology systems. Our legitimate interest in data processing in accordance with Article 6 (1) (f) GDPR also lies in the above purposes.
We will obtain your consent to the processing of the data before sending it and at the same time refer to this data protection declaration. Alternatively, you can also contact us by email. In this case, only the personal data you sent in the e-mail will be stored to process the contact. Under no circumstances will your data be passed on to third parties. Your data will only be used for the intended communication. The legal basis for processing the data if you have given your consent is Article 6 (1) (a) GDPR. The legal basis for the processing of personal data that you have sent to us by e-mail is Article 6 (1) (f) GDPR. If the e-mail contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6 (1) (b) GDPR.
The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. For the personal data from the input mask of the contact form and those sent by e-mail, this is the case when the respective communication with you has ended. The conversation is over when it can be inferred from the circumstances that the facts in question have been finally clarified.
You have the option to revoke your consent to the processing of personal data at any time. If you have contacted us by email, you can object to the storage of your personal data at any time. The revocation can be made, for example, by sending a revocation e-mail or by letter to our contact addresses given in the imprint. All personal data stored in the course of making contact will then be deleted.
14. Usercentrics consent management platform for managing consent
We use the Usercentrics Consent Management Platform ("Usercentrics") on our website to inform you about the cookies and other technologies that we use on our website. As well as obtaining, managing, and documenting your consent, if required by law, to the processing of your personal data through these technologies. According to Article 6 Paragraph 1 S. 1 lit. c GDPR, this is necessary to fulfill our legal obligation according to Article 7 Paragraph 1 GDPR to be able to prove your consent to the processing of your personal data to which we are subject.
Usercentrics is an offer from Usercentrics GmbH, Rosental 4, 80331 Munich, Germany, which processes your data on our behalf. When you visit our website, the Usersentrics web server stores a so-called server log file, which also contains your anonymized IP address, date and time of the visit, device, and browser information, and information on your consent behavior. Your data will be deleted after three years unless you have expressly consented to further use of your data in accordance with Article 6 Paragraph 1 Sentence 1 lit we will inform you in this statement.
15. Data transfer to service partners for order processing
We only pass on your personal data to service partners who are involved in the processing of the contract, such as the shipping company commissioned with the delivery, and the bank commissioned with payment matters. The extent of data transfer to third parties is limited to the necessary minimum, namely your first and last name, your address, and, if applicable, your delivery address. The legal basis is Article 6 (1) (b) GDPR.
In the event that you have expressly given us or, at your request, the service partner your consent to do so, we will also give your e-mail address, your telephone number, or your date of birth for the purpose of coordinating a delivery date with the shipping company or a necessary identity and credit check of the payment service provider. If you do not give us your consent in this respect, prior coordination of a delivery date or a delivery notification or a "purchase on account" "purchase by direct debit" or "hire purchase" is not possible. The legal basis for this is Article 6 (1) (a) GDPR.
You can of course revoke your consent at any time with effect for the future to us or to the respective service partner. However, the respective service partner may still be entitled to process your personal data if this is necessary for the contractual execution of the contract.
In particular, we work with the following service providers:
a) Service Provider
Online Marketing via AdRoll Retargeting
We advertise this website in search results and on third-party websites through our advertising partner AdRoll Advertising Ltd., Level 6, 1, Burlington Plaza, Burlington Road, Dublin 4, Ireland (“AdRoll”). When you visit our website, a retargeting cookie is automatically set by AdRoll or its partners, which enables interest-based advertising using a pseudonymous cookie ID based on the pages you visit. Data processing takes place on the basis of an agreement between jointly responsible parties in accordance with Art. 26 GDPR. We determine the parameters of the respective advertising campaign. AdRoll is responsible for the precise implementation (e.g. deciding on the placement of the individual ads). The data automatically collected by AdRoll (IP address, time of visit, device and browser information as well as information on your use of our website) may be combined by AdRoll with information from other sources and transmitted to AdRoll advertising partners. In addition, they are usually transferred to a server of NextRoll, Inc., 2300 Harrison St, Fl 2, San Francisco CA, 94110, USA, and stored there. The European Commission has not issued an adequacy decision for the USA. Our cooperation with them is based on standard data protection clauses of the European Commission. In order to set the cookies, we need your informed consent in accordance with Article 6 Paragraph 1 lit. a) GDPR, which you can give before activation via a consent window (cookie consent tool).
Online marketing via Criteo
We advertise this website in search results and on third-party websites through our advertising partner Criteo SA, 32 Rue Blanche, 75009 Paris, France (“Criteo”). When you visit our website, a retargeting cookie is automatically set by Criteo or its partners, which enables interest-based advertising using a pseudonymous cookie ID based on the pages you visit. Data processing takes place on the basis of an agreement between jointly responsible parties in accordance with Art. 26 GDPR. We determine the parameters of the respective advertising campaign. Criteo is responsible for the precise implementation (e.g. deciding on the placement of the individual ads). The data automatically collected by Criteo (IP address, time of visit, device and browser information as well as information on your use of our website) may be merged by Criteo with information from other sources and transmitted to Criteo advertising partners.
In order to set the cookies, we need your informed consent in accordance with Article 6 Paragraph 1 lit. a) GDPR, which you can give before activation via a consent window (cookie consent tool).
Online marketing via AWIN
Through our advertising partner AWIN AG, Landsberger Allee 104 BC, 10249 Berlin, Germany ("AWIN"), we market space for third-party advertisements. These advertisements will be shown to you in various places on this website. AWIN can use cookies to track the course of the respective order and, in particular, to understand that you clicked on the respective ad and then ordered the product. For this purpose, data (IP address, time of visit, device and browser information as well as information on your use of our website) are collected, transmitted to AWIN , and processed by AWIN. We have no influence on this data processing. Data processing takes place on the basis of an agreement between jointly responsible parties in accordance with Art. 26 GDPR.
In order to set the cookies, we need your informed consent in accordance with Article 6 Paragraph 1 lit. a) GDPR, which you can give before activation via a consent window (cookie consent tool).
b) Shipping service provider:
Royal Mail
In the event that the shipment is made via Royal Mail, we will give your respective data to Royal Mail.
YODEL
In the event that the shipment is made via YODEL, we will pass on your respective data to YODEL Yodel Delivery Network Limited, 2nd Floor, Skyways Hub, Speke Road, Speke, Liverpool L70 1AB.
Evri
In the event that the shipment is made via Evri, we will pass on your respective data to Evri. Evri is the trading name of Hermes Parcelnet Limited.
Capitol House, 1 Capitol Close, Morley, Leeds, LS27 0WH
c) Payment service provider
PayPal
When paying via PayPal, credit card via PayPal, direct debit via PayPal, or "purchase on account" via PayPal, we pass on your payment data to PayPal (Europe) S.à rl et Cie, SCA, 22-24 Boulevard Royal, L -2449 Luxembourg (hereinafter "PayPal"), continue. PayPal reserves the right to carry out a credit check for the payment methods credit card via PayPal, direct debit via PayPal, or "purchase on account" via PayPal. PayPal uses the result of the credit check in relation to the statistical probability of non-payment for the purpose of deciding whether to provide the respective payment method. The credit report can contain probability values (so-called score values). As far as score values are included in the result of the credit report, they are based on a scientifically recognized mathematical-statistical process. Address data, among other things, is included in the calculation of the score values.
Shopify Payment
We use Shopify, a service of Shopify Inc., 150 Elgin St., 8th Fl, Ottawa, ON K2P 1L4, Canada, as our e-commerce platform. Shopify stores the personal data generated as part of a purchase on foreign servers and in the USA, for data from the EEA and Switzerland primarily in Ireland by Shopify International Limited, 2nd Floor 1-2 Victoria Buildings, Haddington Road, Dublin 4, D04 XN32 Ireland.
In order to set the cookies, we need your informed consent in accordance with Article 6 Paragraph 1 lit. a) GDPR, which you can give before activation via a consent window (cookie consent tool). Alternatively, we ask for your consent in accordance with Article 49 (1) (a) GDPR to transfer your personal data to a third country.
If we offer Shopify payment options and you use them to complete your purchase, Shopify may store your credit card information. Your personal data is encrypted during the ordering process using PCI-DSS (Payment Card Industry Data Security Standard) and transmitted over the Internet. Your purchase processing data will only be stored for as long as is necessary for the complete processing of the transaction. After that, your purchase transaction data will be deleted.
16. Third-party tools and plugins
We use third-party tools on our website, e.g. to analyze usage data, in order to be able to optimally design our online offers and our website in terms of user-friendliness and optimization. The tools generally use “cookies” (for definition see “Cookies” above). For the data processed in this way, we may need your prior informed consent in accordance with Article 6 Paragraph 1 lit. a GDPR, which you can give before activation via a consent window (cookie consent tool).
In order to respect your privacy, the data that may allow a reference to your person, such as IP address, registration, or device identifiers, will be anonymized or pseudonymized as soon as possible. Specifically, these are the following tools:
a) Google Analytics 4 (with cookies) ：
We use Google Analytics 4, a service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"), to analyze how our websites are used.
As a result, so-called "cookies" are used by Google Analytics 4 by default. Cookies are text files that are stored on your end device and that enable an analysis of your use of the website. The information generated by the cookie about your use of this website (including the IP address transmitted by your device, shortened by the last digits, see below) is usually transmitted to a Google server, where it is stored and processed. This can also result in information being transmitted to the servers of Google LLC, a company based in the USA, where the information is further processed.
When using Google Analytics 4, the IP address transmitted by your end device when using the website is automatically and automatically collected and processed in an anonymous form. Thus, a direct personal reference of the collected information is excluded. This automatic anonymization is carried out by shortening the last digits of the IP address transmitted by your end device by Google within member states of the European Union (EU) or in other contracting states of the Agreement on the European Economic Area (EEA).
On our behalf, Google will use this and other information to evaluate your use of the website, to compile reports (reports) on your website activities or your usage behavior and to provide us with other services related to website activity and internet usage. The shortened IP address transmitted by your end device as part of Google Analytics 4 in this context will not be merged with other Google data. The data collected as part of the use of Google Analytics 4 is stored for 2 months and then deleted.
Google Analytics 4 also enables the creation of statistics with statements about the age, gender and interests of website users based on an evaluation of interest-related advertising and including third-party information via a special function, the so-called "demographic characteristics". This enables the determination and differentiation of user groups on the website for the purpose of targeted marketing measures. However, the data collected via the "demographic characteristics" cannot be assigned to a specific person and therefore not to you personally. Data collected via the "Demographic characteristics" function is stored for two months and then deleted.
All of the processing described above, in particular the setting of Google Analytics cookies to store and read information on the end device you use to use the website, will only take place if you have given us your express consent via the cookie content tool in accordance with Art. 6 Paragraph 1 lit. a GDPR. Google Analytics 4 will not be used when you use the website without your consent. You can revoke the consent you have given at any time with effect for the future. In order to make use of your revocation, please deactivate this service via the "Cookie Consent Tool" provided on the website.
The "Google Signals" service can also be used on our website as an extension of Google Analytics 4. Google Signals can be used to create cross-device reports from Google (so-called "cross-device tracking"). If you have activated "personalized ads" in the settings of your Google account and linked your internet-enabled devices to your Google account, Google can analyze user behavior across devices and create database models based on this, provided that you have given your consent to the use of Google Analytics in accordance with Art 6 (1) (a) GDPR via our cookie consent tool. The logins and device types of all site visitors who were logged into a Google account and carried out a conversion are taken into account. The data shows, among other things, on which device you first clicked on an ad and on which device the associated conversion took place. As far as Google Signals is used, we do not receive any personal data from Google, only statistics that are created on the basis of Google Signals. You have the option of deactivating the "Personalized ads" function in the settings of your Google account and thus switching off cross-device analysis.
Google Analytics 4 can also use the "UserIDs" function as an extension on this website. By assigning individual UserIDs, we can have Google create cross-device reports (so-called "cross-device tracking"). This means that your usage behavior can also be analyzed across devices if you have given your consent to the use of Google Analytics in accordance with Article 6(1)(a) GDPR when you set up a personal account by registering on this website and are logged into your personal account on different end devices with your respective access data. The data collected in this way shows, among other things, on which end device you clicked on an ad for the first time and on which end device the corresponding conversion took place.
Because of the use of Google Analytics 4, we have concluded a so-called data processing agreement with Google. As a result, Google is obliged to protect the data of our website users and not to pass it on to third parties.
In order to ensure compliance with the European level of data protection even if data is transferred from the EU or the EEA to the USA and possible further processing there, Google refers to the so-called standard contractual clauses of the European Commission. We have contractually agreed this with Google.
b) Facebook custom audience (Facebook Pixel)
We use the "Custom Audiences" remarketing function of Facebook Inc., 1 6011 Hacker Way, Menlo Park, CA 94025, USA ("Facebook"). This enables us to show you interest-based advertisements (“Facebook Ads”) when you visit our website as part of a visit to the social network Facebook or other websites that also use the process. A cookie must be stored on your computer for these purposes. You can activate and deactivate the use of cookies on your computer via our cookie consent tool.
In the event of your express consent in accordance with Article 6 (1) (a) GDPR, your visitor behavior can also be tracked via so-called tracking pixels after you have seen or clicked on a Facebook advertisement. This process is used to evaluate the effectiveness of Facebook ads for statistical and market research purposes and can help to optimize future advertising.
The data collected is anonymous to us and does not allow us to draw any conclusions about the identity of the visitor. However, the data is stored and processed by Facebook so that a connection to your respective user profile is possible. In addition, Facebook can use the data obtained for its own advertising purposes. Alternatively, we ask for your consent in accordance with Article 49 (1) (a) GDPR to transfer your personal data to a third country.
c) Google Ads
We use Google Ads, and Google Conversion Tracking from Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA ("Google"). Google Ads sets a "cookie" on your computer if you have reached our website via a Google ad.
These cookies lose their validity after 30 days and are not used for personal identification. If you visit certain pages of our website while the cookie has not yet expired, Google and we can recognize via our Google Ads account that you clicked on a Google ad placed by us and were forwarded to this page.
Each Google Ads customer receives a different cookie. This means that cookies cannot be tracked via the websites of Google Ads customers. The information obtained using the conversion cookie is used to create conversion statistics for Google Ads customers who have opted for conversion tracking. Google Ads customers find out the total number of users who clicked on your ad and were redirected to a page with a conversion tracking tag. However, we do not receive any information with which users can be personally identified.
In order to set the cookies, we need your informed consent in accordance with Article 6 Paragraph 1 lit. a) GDPR, which you can give before activation via a consent window (cookie consent tool).
Alternatively, we ask for your consent in accordance with Article 49 (1) (a) GDPR to transfer your personal data to a third country.
d) Google reCAPTCHA
We use the reCAPTCHA function from Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA ("Google"). This function is primarily used to distinguish whether an entry is made by a natural person or whether it is misused by machine and automated processing. The service includes sending your IP address and any other data required by Google for the reCAPTCHA service to Google.
In order to use Google reCAPTCHA, we need your informed consent in accordance with Article 6 (1) (a) GDPR, which you can give before activation via a consent window (cookie consent tool). Alternatively, we ask for your consent in accordance with Article 49 (1) (a) GDPR to transfer your personal data to a third country.
e) Google web fonts
This site uses so-called web fonts provided by Google LLC., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA ("Google") for the uniform display of fonts. When you call up a page, your browser loads the required web fonts into your browser cache in order to display text and fonts correctly. For this purpose, the browser you are using must connect to the Google servers. This gives Google knowledge that our website was accessed via your IP address.
In order to use Google web fonts, we need your informed consent in accordance with Article 6 (1) (a) GDPR, which you can give prior to activation via a consent window (cookie consent tool). Alternatively, we ask for your consent in accordance with Article 49 (1) (a) GDPR to transfer your personal data to a third country.
f) YouTube
We use functions of the "YouTube" service to embed our own videos on our website as part of the so-called "framing". YouTube is operated by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 ESW5, Ireland ("Google").
We only embed YouTube videos in the “extended data protection mode”, which YouTube itself makes available. This initially prevents YouTube from storing cookies on your device. However, when you call up the relevant pages, your IP address and other data are already being transmitted. This tells Google which of our websites you have visited. However, this information cannot be assigned to you unless you are logged in to YouTube or another Google service before accessing the page.
In order to use YouTube, we require your informed consent in accordance with Article 6 Paragraph 1 Letter a GDPR, which you can give prior to activation via a consent window (cookie consent tool). Alternatively, we ask for your consent in accordance with Article 49 (1) (a) GDPR to transfer your personal data to a third country. If you have not given your consent, the YouTube videos are also blocked by so-called content blockers. If you still want to watch the video, you must first agree to Google's privacy policy when you click on the video; only then can you start the video.
When the playback of an embedded YouTube video is started, "YouTube" only sets cookies as part of the extended data protection mode that does not contain any personally identifiable information that would be traceable to you, unless you are logged into any Google service at the same time. If you want to avoid personal references, you can prevent this by logging out of your YouTube account. The cookies are integrated in accordance with Art. 6 (1) (f) GDPR for the purpose of collecting information about user behavior and creating video statistics as well as improving the user-friendliness of the YouTube offer.
You have the right to object to the creation of these user profiles, although you must contact Google to exercise this right. Regardless of whether the embedded video is played, a connection to the Google "double-click" network is established when you visit this website.
17. Information on transfers to third countries (data transfer to third countries)
We use technologies from service providers on our website whose server locations may be in third countries outside the EU or EEA. This also includes the USA. If, as in the case of the USA, there is no adequacy decision by the EU Commission, an appropriate level of data protection must be ensured by means of other suitable guarantees. On July 16, 2020, the ECJ ruled that the Privacy Shield Agreement between the EU and the USA may no longer be used to transfer personal data to the USA. This means that the sectoral adequacy decision is rescinded.
Suitable guarantees in the form of contractually agreed standard contractual clauses of the EU Commission or binding internal data protection regulations (binding corporate rules) are possible in principle, but require the contracting parties to check in advance whether an appropriate level of protection can be guaranteed. According to the judgment of the ECJ, it may be necessary to take additional protective measures.
In principle, we have agreed to the standard data protection clauses issued by the EU Commission and which continue to apply to the third-party technologies we use that process personal data in a third country such as the USA. If possible, we also agree on additional guarantees that are intended to ensure that adequate data protection is guaranteed in the USA or other third countries.
Irrespective of this, it may happen that, despite all contractual and technical measures, the level of data protection in the third country does not correspond to that of the EU. In these cases, we ask you, if necessary, within the framework of the cookie consent, for your consent in accordance with Article 49 (1) (a) GDPR for the transfer of your personal data to a third country. This relates in particular to data transmission to the USA.
In particular, there is a risk that US authorities may not be granted sufficiently restricted access rights to your personal data from an EU perspective, without us as the data exporter or you as the data subject being aware of this and you may not have any legal remedies available to prevent this or to take action against such access.
18. Rights of the data subject
If personal data is processed by you, you are the data subject within the meaning of the GDPR and you have the following rights vis-à-vis the person responsible:
Right of providing information(Art. 15 GDPR) - You can request confirmation from us as the person responsible as to whether personal data relating to you will be processed by us.
In the case of processing, you can request the following information from us: the purposes for which the personal data are processed; the categories of personal data being processed; the recipients or categories of recipients to whom your personal data has been or will be disclosed; the planned duration of the storage of the personal data concerning you or, if specific information on this is not possible, criteria for determining the storage duration; the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the person responsible or a right to object to this processing; the existence of a right of appeal to a supervisory authority; all available information about the origin of the data if the personal data are not collected from the data subject; the existence of automated decision-making including profiling in accordance with Art. 22 Para. 1 and 4 GDPR and - at least in these cases - meaningful information about the logic involved as well as the scope and intended effects of such processing for the data subject. You also have the right to request information as to whether your personal data is being transmitted to a third country or to an international organization. In this context, you can request to be informed of the appropriate guarantees pursuant to Art. 46 GDPR in connection with the transmission.
Right to Rectification(Art. 16 GDPR) - You have the right to immediate correction and/or completion from the person responsible if the processed personal data concerning you is incorrect or incomplete. Right to Erasure(Art. 17 GDPR) - You can demand from us as the person responsible that the personal data concerning you be deleted immediately. In this case, we are obliged to delete this data immediately if one of the following reasons applies:
(1) The personal data relating to you are no longer necessary for the purposes for which they were collected or otherwise processed.
(2 ) You revoke your consent on which the processing was based pursuant to Article 6 Paragraph 1 Letter a or Article 9 Paragraph 2 Letter a GDPR and there is no other legal basis for the processing.
(3) You object to the processing in accordance with Article 21 (1) GDPR and there are no overriding legitimate reasons for the processing, or you object to the processing in accordance with Article 21 (2) GDPR.
(4) The personal data concerning you was processed unlawfully.
(5) The deletion of personal data concerning you is necessary to fulfill a legal obligation under Union law or the law of the Member States to which the person responsible is subject.
(6) The personal data concerning you was collected in relation to information society services offered pursuant to Article 8 (1) GDPR.
If we have made the personal data relating to you public and we are obliged to delete it in accordance with Art. 17 (1) GDPR, we shall take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform those responsible for data processing, who process the personal data that you, as the data subject, have requested us to delete all links to this personal data or copies or replications of this personal data.
The right to erasure does not exist if the processing is necessary
(1) to exercise the right to freedom of expression and information;
(2) to fulfill a legal obligation that requires processing under Union or Member State law to which the controller is subject, or to perform a task that is in the public interest or in the exercise of official authority vested in the controller became;
(3) for reasons of public interest in the field of public health in accordance with Article 9 (2) lit. h and i and Article 9 (3) GDPR;
(4) for archiving purposes in the public interest, scientific or historical research purposes, or for statistical purposes pursuant to Art. 89 (1) GDPR, insofar as the law referred to under Section a) is likely to make it impossible or seriously impair the achievement of the objectives of this processing, or
(5) to assert, exercise or defend legal claims. Right to restriction of processing(Art. 18 GDPR) - Under the following conditions, you can request the restriction of the processing of your personal data: if you dispute the accuracy of the personal data concerning you for a period of time that enables the person responsible to check the accuracy of the personal data; the processing is unlawful and you refuse to delete the personal data and instead request that the use of the personal data be restricted; the person responsible no longer needs the personal data for the purposes of the processing, but you need them to assert, exercise or defend legal claims, or if you have lodged an objection to the processing pursuant to Art. 21 Para. 1 DSGVO and it is not yet certain whether the legitimate reasons of the person responsible outweigh your reasons.
If the processing of personal data concerning you has been restricted, this data - apart from its storage - may only be used with your consent or to assert, exercise or defend legal claims or to protect the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State are processed. If the restriction of processing has been restricted according to the above conditions, you will be informed by the person responsible before the restriction is lifted.
Right to information(Art. 19 GDPR) - If you have asserted the right to correction, deletion, or restriction of processing against the person responsible, he is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this correction or deletion of the data or restriction of the processing unless this proves impossible or involves a disproportionate effort. You have the right to be informed about these recipients by the person responsible.
Right to data portability(Art. 29 GDPR) - You have the right to receive the personal data concerning you that you have provided to the person responsible in a structured, common, and machine-readable format. In addition, you have the right to transmit this data to another person responsible without hindrance from the person responsible to whom the personal data was provided, provided that (1) the processing is based on consent pursuant to Article 6 (1) (a) GDPR or Article 9 (2) (a) GDPR or on a contract in accordance with Article 6 (1) (b) GDPR and (2) the processing is carried out using automated procedures.
In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one person responsible to another person responsible, insofar as this is technically feasible. The freedoms and rights of other people must not be impaired by this. The right to data portability does not apply to the processing of personal data that is required to perform a task that is in the public interest or in the exercise of official authority that has been assigned to the controller.
19. Right to object
You have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data, which is based on Article 6 Paragraph 1 lit. e or f GDPR; this also applies to profiling based on these provisions.
If you make use of your right to object, we will no longer process the personal data relating to you, unless we can demonstrate compelling legitimate grounds for the processing that outweigh your interests, rights, and freedoms, or the processing serves to assert, exercise or defend of legal claims.
If your personal data is processed in order to operate direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct advertising. If you object to the processing for direct marketing purposes, the personal data relating to you will no longer be processed for these purposes.
In connection with the use of information society services, you have the option – notwithstanding Directive 2002/58/EC – to exercise your right to object by means of automated procedures that use technical specifications.
20. Right to revoke the declaration of consent under the data protection law
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the legality of the processing carried out on the basis of the consent up to the point of revocation.
21. Automated individual decision-making including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply, (1) if the decision is necessary for the conclusion or performance of a contract between you and the person responsible, (2) due to legal regulations of the Union or the Member States to which the person responsible is subject, and these legal regulations take appropriate measures included to protect your rights and freedoms and your legitimate interests or (3) is done with your express consent.
However, these decisions must not be based on special categories of personal data pursuant to Article 9 Paragraph 1 GDPR unless Article 9 Paragraph 2 lit. a or g applies and appropriate measures have been taken to protect your rights and freedoms and your legitimate interests. With regard to the cases referred to in (1) and (3), the person responsible shall take appropriate measures to safeguard your rights and freedoms and your legitimate interests, including at least the right to obtain human intervention on the part of the person responsible, to express his or her point of view and to challenge the decision.
22. Right to lodge a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the member state of your place of residence, your place of work, or the place of the alleged infringement, if you believe that the processing of your personal data is contrary to violates the GDPR. The supervisory authority to which the complaint was lodged will inform the complainant about the status and the results of the complaint, including the possibility of a judicial remedy under Art. 78 GDPR.
23. Additional privacy information
If you have any further data protection questions, please feel free to contact us. Our contact details can be found above under the information on the person responsible for this data protection declaration or in our imprint.
This privacy policy is provided by
Attorney Kai Harzheim, Hamburg – www.harzheim.eu
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