Privacy Policy
Preamble
With the following privacy policy we would like to inform you which types of
your personal data (hereinafter also abbreviated as "data") we process for
which purposes and in which scope. The privacy statement applies to all
processing of personal data carried out by us, both in the context of
providing our services and in particular on our websites, in mobile
applications and within external online presences, such as our social media
profiles (hereinafter collectively referred to as "online services").
The terms used are not gender-specific.
Last Update: 19. May 2023
Table of contents
Controller
Ralf Wirtz
Roemerstrasse 19
50321 Bruehl, Germany
E-Mail Address:
info@ralfwirtz.com
Overview of processing operations
The following table summarises the types of data processed, the purposes for
which they are processed and the concerned data subjects.
Categories of Processed Data
- Contact data.
- Content data.
- Usage data.
- Meta, communication and process data.
Categories of Data Subjects
Purposes of Processing
- Provision of contractual services and customer support.
- Contact requests and communication.
- Security measures.
- Web Analytics.
- Targeting.
- Conversion tracking.
- Affiliate Tracking.
- Content Delivery Network (CDN).
- Feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online services and usability.
- Information technology infrastructure.
Legal Bases for the Processing
Below you will find an overview of the legal basis 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. If, in addition, more specific legal bases
are applicable in individual cases, we will inform you of these in the data
protection declaration.
-
Consent (Article 6 (1) (a) GDPR) - The data subject has
given consent to the processing of his or her personal data for one or more
specific purposes.
-
Legitimate Interests (Article 6 (1) (f) GDPR) - Processing
is necessary for the purposes of the legitimate interests pursued by the
controller or by a third party, except where such interests are overridden
by the interests or fundamental rights and freedoms of the data subject
which require protection of personal data.
In addition to the data protection regulations of the GDPR, national
regulations apply to data protection in Germany. This includes in particular
the Law on Protection against Misuse of Personal Data in Data Processing
(Federal Data Protection Act - BDSG). In particular, the BDSG contains special
provisions on the right to access, the right to erase, the right to object,
the processing of special categories of personal data, processing for other
purposes and transmission as well as automated individual decision-making,
including profiling. Furthermore, it regulates data processing for the
purposes of the employment relationship (§ 26 BDSG), in particular with regard
to the establishment, execution or termination of employment relationships as
well as the consent of employees. Furthermore, data protection laws of the
individual federal states may apply.
Security Precautions
We take appropriate technical and organisational measures in accordance with
the legal requirements, taking into account the state of the art, the costs of
implementation and the nature, scope, context and purposes of processing as
well as the risk of varying likelihood and severity for the rights and
freedoms of natural persons, in order to ensure a level of security
appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality,
integrity and availability of data by controlling physical and electronic
access to the data as well as access to, input, transmission, securing and
separation of the data. In addition, we have established procedures to ensure
that data subjects' rights are respected, that data is erased, and that we are
prepared to respond to data threats rapidly. Furthermore, we take the
protection of personal data into account as early as the development or
selection of hardware, software and service providers, in accordance with the
principle of privacy by design and privacy by default.
Transmission of Personal Data
In the context of our processing of personal data, it may happen that the data
is transferred to other places, companies or persons or that it is 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
embedded in a website. In such cases, the legal requirements will be respected
and in particular corresponding contracts or agreements, which serve the
protection of your data, will be concluded with the recipients of your data.
Data Processing in Third Countries
If we process data in a third country (i.e. outside the European Union (EU),
the European Economic Area (EEA)) or the processing takes place in the context
of the use of third party services or disclosure or transfer of data to other
persons, bodies or companies, this will only take place in accordance with the
legal requirements.
Subject to express consent or transfer required by contract or law, we process
or have processed the data only in third countries with a recognised level of
data protection, on the basis of special guarantees, such as a contractual
obligation through so-called standard protection clauses of the EU Commission
or if certifications or binding internal data protection regulations justify
the processing (Article 44 to 49 GDPR, information page of the EU Commission:
https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).
Erasure of data
The data processed by us will be erased in accordance with the statutory
provisions as soon as their processing is revoked or other permissions no
longer apply (e.g. if the purpose of processing this data no longer applies or
they are not required for the purpose). If the data is not deleted because
they are required for other and legally permissible purposes, their processing
is limited to these purposes. This means that the data will be restricted and
not processed for other purposes. This applies, for example, to data that must
be stored for commercial or tax reasons or for which storage is necessary to
assert, exercise or defend legal claims or to protect the rights of another
natural or legal person. Our further information on individual processing
operations may also contain additional and specific information on data
retention and erasure applicable to the respective processing operations.
Use of Cookies
Cookies are small text files or other data records that store information on
end devices and read information from the end devices. For example, to store
the login status in a user account, the contents of a shopping cart in an
e-shop, the contents accessed or the functions used. Cookies can also be used
for various purposes, e.g. for purposes of functionality, security and
convenience of online offers as well as the creation of analyses of visitor
flows.
Information on consent: We use cookies in accordance with the
statutory provisions. Therefore, we obtain prior consent from users, except
when it is not required by law. In particular, consent is not required if the
storage and reading of information, including cookies, is strictly necessary
in order to provide an information society service explicitly requested by the
subscriber or user. Essential cookies usually include cookies with functions
related to the display and operability of the onlineservice, load balancing,
security, storage of users' preferences and choices or similar purposes
related to the provision of the main and secondary functions of the
onlineservice requested by users. The revocable consent will be clearly
communicated to the user and will contain the information on the respective
cookie use.
Information on legal bases under data protection law: The
legal basis under data protection law on which we process users' personal data
with the use of cookies depends on whether we ask users for consent. If users
consent, the legal basis for processing their data is their 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
services 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 which purposes the
cookies are processed by us, we do clarify in the course of this privacy
policy or in the context of our consent and processing procedures.
Retention period: With regard to the retention period, a
distinction is drawn between the following types of cookies:
-
Temporary cookies (also known as "session cookies"):
Temporary cookies are deleted at the latest after a user has left an online
service and closed his or her end device (i.e. browser or mobile
application).
-
Permanent cookies: Permanent cookies remain stored even
after the terminal device is closed. 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 that
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 Article
21 GDPR. Users can also declare their objection by means of the settings
of their browser, e.g. by deactivating the use of cookies (whereby this may
also limit the functionality of our online services). An objection to the use
of cookies for online marketing purposes, can also be declared via the
websites
https://optout.aboutads.info
and
https://www.youronlinechoices.com/.
-
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
Consent (Article 6 (1) (a) GDPR).
Further information on processing methods, procedures and services
used:
-
Processing Cookie Data on the Basis of Consent: We use a
cookie management solution in which users' consent to the use of cookies, or
the procedures and providers mentioned in the cookie management solution,
can be obtained, managed and revoked by the users. The declaration of
consent is stored so that it does not have to be retrieved again and the
consent can be proven in accordance with the legal obligation. Storage can
take place server-sided and/or in a cookie (so-called opt-out cookie or with
the aid of comparable technologies) in order to be able to assign the
consent to a user or and/or his/her device. Subject to individual details of
the providers of cookie management services, the following information
applies: The duration of the storage of the consent can be up to two years.
In this case, a pseudonymous user identifier is formed and stored with the
date/time of consent, information on the scope of the consent (e.g. which
categories of cookies and/or service providers) as well as the browser,
system and used end device; Legal Basis: Consent (Article 6
(1) (a) GDPR).
-
Cookiebot: Cookie-Consent Manager;
Service provider: Cybot A/S, Havnegade 39, 1058 Copenhagen,
Denmark; Website:
https://www.cookiebot.com; Privacy Policy:
https://www.cookiebot.com/en/privacy-policy/; Further Information: Stored data (on the server of the
service provider): The IP number of the user in anonymous form (the last
three digits are set to 0), date and time of the consent, user agent of the
user's browser, the URL from which the consent was sent, An anonymous,
random and encrypted key value; the consent status of the user.
Provision of online services and web hosting
We process user data in order to be able to provide them with our online
services. For this purpose, we process the IP address of the user, which is
necessary to transmit the content and functions of our online services to the
user's browser or terminal device.
-
Processed data types: Usage data (e.g. websites visited,
interest in content, access times); Meta, communication and process data
(e.g. IP addresses, time information, identification numbers, consent
status); Content data (e.g. text input, photographs, videos).
-
Data subjects: Users (e.g. website visitors, users of
online services).
-
Purposes of Processing: Provision of our online services
and usability; Information technology infrastructure (Operation and
provision of information systems and technical devices, such as computers,
servers, etc.).); Security measures; Content Delivery Network (CDN);
Provision of contractual services and customer support.
-
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services
used:
-
Provision of online offer on rented hosting space: For the
provision of our online services, we use storage space, computing capacity
and software that we rent or otherwise obtain from a corresponding server
provider (also referred to as a "web hoster");
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
-
Collection of Access Data and Log Files: The access to our
online services is logged in the form of so-called "server log files".
Server log files may include the address and name of the web pages and files
accessed, the date and time of access, data volumes transferred,
notification of successful access, browser type and version, the user's
operating system, referrer URL (the previously visited page) and, as a
general rule, IP addresses and the requesting provider. The server log files
can be used for security purposes, e.g. to avoid overloading the servers
(especially in the case of abusive attacks, so-called DDoS attacks) and to
ensure the stability and optimal load balancing of the servers;
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
Retention period: Log file information is stored for a
maximum period of 30 days and then deleted or anonymized. Data, the further
storage of which is necessary for evidence purposes, are excluded from
deletion until the respective incident has been finally clarified.
-
E-mail Sending and Hosting: The web hosting services we use
also include sending, receiving and storing e-mails. For these purposes, the
addresses of the recipients and senders, as well as other information
relating to the sending of e-mails (e.g. the providers involved) and the
contents of the respective e-mails are processed. The above data may also be
processed for SPAM detection purposes. Please note that e-mails on the
Internet are generally not sent in encrypted form. As a rule, e-mails are
encrypted during transport, but not on the servers from which they are sent
and received (unless a so-called end-to-end encryption method is used). We
can therefore accept no responsibility for the transmission path of e-mails
between the sender and reception on our server;
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
-
Content-Delivery-Network: We use a so-called "Content
Delivery Network" (CDN). A CDN is a service with whose help contents of our
online services, in particular large media files, such as graphics or
scripts, can be delivered faster and more securely with the help of
regionally distributed servers connected via the Internet;
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
-
1&1 IONOS: Services in the field of the provision of
information technology infrastructure and related services (e.g. storage
space and/or computing capacities); Service provider:
1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany;
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
Website:
https://www.ionos.com;
Privacy Policy:
https://www.ionos.com/terms-gtc/terms-privacy/; Data Processing Agreement:
https://www.ionos.de/hilfe/datenschutz/allgemeine-informationen-zur-datenschutz-grundverordnung-dsgvo/auftragsverarbeitung/.
-
Cloudflare: Content-Delivery-Network (CDN) - service with
whose help contents of our online services, in particular large media files,
such as graphics or scripts, can be delivered faster and more securely with
the help of regionally distributed servers connected via the Internet;
Service provider: Cloudflare, Inc., 101 Townsend St, San
Francisco, CA 94107, USA; Legal Basis: Legitimate Interests
(Article 6 (1) (f) GDPR); Website:
https://www.cloudflare.com; Privacy Policy:
https://www.cloudflare.com/privacypolicy/; Data Processing Agreement:
https://www.cloudflare.com/cloudflare-customer-dpa;
Standard Contractual Clauses (Safeguarding the level of data protection
when processing data in third countries):
https://www.cloudflare.com/cloudflare-customer-scc.
Web Analysis, Monitoring and Optimization
Web analysis is used to evaluate the visitor traffic on our website and may
include the behaviour, interests or demographic information of users, such as
age or gender, as pseudonymous values. With the help of web analysis we can
e.g. recognize, at which time our online services or their functions or
contents are most frequently used or requested for repeatedly, as well as
which areas require optimization.
In addition to web analysis, we can also use test procedures, e.g. to test and
optimize different versions of our online services or their components.
Unless otherwise stated below, profiles, i.e. data aggregated for a usage
process, can be created for these purposes and information can 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 from us or from the providers of the services we use, location
data may also be processed.
Unless otherwise stated below, profiles, that is data summarized for a usage
process or user, may be created for these purposes and stored in a browser or
terminal device (so-called "cookies") or similar processes may be used for the
same purpose. 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 consented to the collection of their location data or profiles to
us or to the providers of the services we use, these may also be processed,
depending on the provider.
The IP addresses of the users are also stored. However, we use any existing IP
masking procedure (i.e. pseudonymisation by shortening the IP address) to
protect the user. In general, within the framework of web analysis, A/B
testing and optimisation, no user data (such as e-mail addresses or names) is
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
processes.
-
Processed data types: Usage data (e.g. websites visited,
interest in content, access times); Meta, communication and process data
(e.g. IP addresses, time information, identification numbers, consent
status).
-
Data subjects: Users (e.g. website visitors, users of
online services).
-
Purposes of Processing: Web Analytics (e.g. access
statistics, recognition of returning visitors); Profiles with user-related
information (Creating user profiles); Targeting (e.g. profiling based on
interests and behaviour, use of cookies); Provision of our online services
and usability; Conversion tracking (Measurement of the effectiveness of
marketing activities); Affiliate Tracking; Marketing.
-
Security measures: IP Masking (Pseudonymization of the IP
address).
- Legal Basis: Consent (Article 6 (1) (a) GDPR).
Further information on processing methods, procedures and services
used:
-
1&1 IONOS WebAnalytics: Webanalytics;
Service provider: 1&1 IONOS SE, Elgendorfer Str. 57,
56410 Montabaur, Germany; Legal Basis: Consent (Article 6
(1) (a) GDPR); Website:
https://www.ionos.com;
Privacy Policy:
https://www.ionos.com/terms-gtc/terms-privacy/; Data Processing Agreement:
https://www.ionos.de/hilfe/datenschutz/allgemeine-informationen-zur-datenschutz-grundverordnung-dsgvo/auftragsverarbeitung/; Further Information: The data is collected either by a
pixel or by a log file, without the use of cookies; the IP address of the
visitors is transmitted when a page request is sent, anonymized directly
after transmission and processed further without reference to a person; the
data is processed on the basis of an data processing agreement.
-
Google Analytics: Web analytics, reach measurement and
measurement of user traffic; Service provider: Google
Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
Legal Basis: Consent (Article 6 (1) (a) GDPR);
Website:
https://marketingplatform.google.com/intl/en/about/analytics/; Privacy Policy:
https://policies.google.com/privacy; Data Processing Agreement:
https://business.safety.google/adsprocessorterms/;
Standard Contractual Clauses (Safeguarding the level of data protection
when processing data in third countries):
https://business.safety.google/adsprocessorterms; Opt-Out: Opt-Out-Plugin:
https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the Display of Advertisements:
https://adssettings.google.com/authenticated; Further Information:
https://privacy.google.com/businesses/adsservices
(Types of processing and data processed).
Profiles in Social Networks (Social Media)
We maintain online presences within social networks and process user data in
this context in order to communicate with the users active there or to offer
information about us.
We would like to point out that user data may be processed outside the
European Union. This may entail risks for users, e.g. by making it more
difficult to enforce users' rights.
In addition, user data is usually processed within social networks for market
research and advertising purposes. For example, user profiles can be created
on the basis of user behaviour and the associated interests of users. The user
profiles can then be used, for example, to place advertisements within and
outside the networks which are presumed to correspond to the interests of the
users. For these purposes, cookies are usually stored on the user's computer,
in which the user's usage behaviour and interests are stored. Furthermore,
data can be stored in the user profiles independently of the devices used by
the users (especially if the users are members of the respective networks or
will become members later on).
For a detailed description of the respective processing operations and the
opt-out options, please refer to the respective data protection declarations
and information provided by the providers of the respective networks.
Also in the case of requests for information and the exercise of rights of
data subjects, we point out that these can be most effectively pursued with
the providers. Only the providers have access to the data of the users and can
directly take appropriate measures and provide information. If you still need
help, please do not hesitate to contact us.
-
Processed data types: Contact data (e.g. e-mail, telephone
numbers); Content data (e.g. text input, photographs, videos); Usage data
(e.g. websites visited, interest in content, access times); Meta,
communication and process data (e.g. IP addresses, time information,
identification numbers, consent status).
-
Data subjects: 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 (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services
used:
-
LinkedIn: Social network;
Service provider: LinkedIn Ireland Unlimited Company,
Wilton Plaza Wilton Place, Dublin 2, Ireland;
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
Website:
https://www.linkedin.com; Privacy Policy:
https://www.linkedin.com/legal/privacy-policy; Data Processing Agreement:
https://legal.linkedin.com/dpa;
Standard Contractual Clauses (Safeguarding the level of data protection
when processing data in third countries):
https://legal.linkedin.com/dpa; Opt-Out:
https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
-
Twitter: Social network; Service provider:
Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2
D02 AX07, Ireland, parent company: Twitter Inc., 1355 Market Street, Suite
900, San Francisco, CA 94103, USA; Legal Basis: Legitimate
Interests (Article 6 (1) (f) GDPR); Privacy Policy:
https://twitter.com/privacy, (Settings:
https://twitter.com/personalization).
Plugins and embedded functions and content
Within our online services, we integrate functional and content elements that
are obtained from the servers of their respective providers (hereinafter
referred to as "third-party providers"). These may, for example, be graphics,
videos or city maps (hereinafter uniformly referred to as "Content").
The integration always presupposes that the third-party providers of this
content process the IP address of the user, since they could not send the
content to their browser without the IP address. The IP address is therefore
required for the presentation of these contents or functions. We strive to use
only those contents, whose respective offerers use the IP address only for the
distribution of the contents. Third parties 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 evaluate 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 include technical information
about the browser and operating system, referring websites, visit times and
other information about the use of our website, as well as may be linked to
such information from other sources.
-
Processed data types: Usage data (e.g. websites visited,
interest in content, access times); Meta, communication and process data
(e.g. IP addresses, time information, identification numbers, consent
status).
-
Data subjects: Users (e.g. website visitors, users of
online services).
-
Purposes of Processing: Provision of our online services
and usability.
-
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services
used:
-
Integration of third-party software, scripts or frameworks: We incorporate into our online services software which we retrieve from
servers of other providers (e.g. function libraries which we use for the
purpose of displaying or user-friendliness of our online services). The
respective providers collect the user's IP address and can process it for
the purposes of transferring the software to the user's browser as well as
for security purposes and for the evaluation and optimisation of their
services; Legal Basis: Legitimate Interests (Article 6 (1)
(f) GDPR).
-
Google Fonts (Provision on own server): Provision of font
files for the purpose of a user-friendly presentation of our online
services; Service provider: The Google Fonts are hosted on
our server, no data is transmitted to Google;
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
-
Font Awesome (Provision on own server): Display of fonts
and symbols; Service provider: The Font Awesome icons are
hosted on our server, no data is transmitted to the provider of Font
Awesome; Legal Basis: Legitimate Interests (Article 6 (1)
(f) GDPR).
Changes and Updates to the Privacy Policy
We kindly ask you to inform yourself regularly about the contents of our data
protection declaration. We will adjust the privacy policy as changes in our
data processing practices make this necessary. We will inform you as soon as
the changes require your cooperation (e.g. consent) or other individual
notification.
If we provide addresses and contact information of companies and organizations
in this privacy policy, we ask you to note that addresses may change over time
and to verify the information before contacting us.
Rights of Data Subjects
As data subject, you are entitled to various rights under the GDPR, which
arise in particular from Articles 15 to 21 of the GDPR:
-
Right to Object: You have the right, on grounds arising from your
particular situation, to object at any time to the processing of your
personal data which is based on letter (e) or (f) of Article 6(1) GDPR,
including profiling based on those provisions. Where personal data are
processed for direct marketing purposes, you have the right to object at
any time to the processing of the personal data concerning you for the
purpose of such marketing, which includes profiling to the extent that it
is related to such direct marketing.
-
Right of withdrawal for consents: You have the right to
revoke consents at any time.
-
Right of access: You have the right to request confirmation
as to whether the data in question will be processed and to be informed of
this data and to receive further information and a copy of the data in
accordance with the provisions of the law.
-
Right to rectification: You have the right, in accordance
with the law, to request the completion of the data concerning you or the
rectification of the incorrect data concerning you.
-
Right to Erasure and Right to Restriction of Processing: In
accordance with the statutory provisions, you have the right to demand that
the relevant data be erased immediately or, alternatively, to demand that
the processing of the data be restricted in accordance with the statutory
provisions.
-
Right to data portability: You have the right to receive
data concerning you which you have provided to us in a structured, common
and machine-readable format in accordance with the legal requirements, or to
request its transmission to another controller.
-
Complaint to the supervisory authority: Without prejudice
to any other administrative or judicial remedy, you shall have the right to
lodge a complaint with a supervisory authority, in particular in the Member
State of his or her habitual residence, place of work or place of the
alleged infringement if you consider that the processing of personal data
relating to you infringes the GDPR.