Data protection

With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as „data“) that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part of the provision of our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as „online offer“).

The terms used are not gender-specific.

Status: 17 May 2022

Table of contents

  • Person in charge
  • Overview of processing operations
  • Applicable legal basis
  • Security measures
  • Transfer of personal data
  • Data processing in third countries
  • Deletion of data
  • Use of cookies
  • Provision of the online offer and web hosting
  • Contact and inquiry management
  • Chatbots and chat functions
  • Web analysis, monitoring and optimization
  • Online marketing
  • Plugins and embedded functions and content
  • Modification and updating of the privacy policy
  • Rights of data subjects
  • Definitions

Responsible person

Heat Transfer Technology AG
Gotthardstrasse 27
6302 Zug
Schweiz

E-mail address:
office@htt-ag.com

Imprint:
https://www.htt-ag.com/data-protection/

Processing overview

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.
  • Contact data.
  • Content data.
  • Usage data.
  • Meta/communication data.

Categories of persons concerned

  • Communication partner.
  • Users.

Purposes of the processing

  • Provision of contractual services and customer service.
  • Contact requests and communication.
  • Direct marketing.
  • Reach measurement.
  • Tracking.
  • Conversion measurement.
  • Click tracking.
  • A/B tests.
  • Heatmaps.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online services and user experience.

Applicable legal bases

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. Should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 para. 1 p. 1 lit. a. GDPR) – The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
  • Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. GDPR) – 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 data subject's request.
  • Legal obligation (Art. 6 (1) p. 1 lit. c. GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR) – 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.

In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Switzerland. These include in particular the Federal Data Protection Act (FADP). The FADP applies in particular if no EU/EEC citizens are affected and e.g. only data of Swiss citizens are processed.

Security measures

We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. We also have procedures in place to ensure the exercise of data subjects' rights, the deletion of data and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

SSL encryption (https): In order to protect your data transmitted via our online offer, we use SSL encryption. You can recognise such encrypted connections by the prefix https:// in the address line of your browser.

Transmission of personal data

In the course of our processing of personal data, the data may be transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

Data transfer within the group of companies: We may transfer personal data to other companies within our group of companies or grant them access to this data. Where this transfer is for administrative purposes, the transfer of data is based on our legitimate business and commercial interests or is made where it is necessary for the performance of our contract-related obligations or where we have the consent of the data subjects or legal permission.

Data transfer within the organisation: We may transfer personal data to other bodies within our organisation or grant them access to this data. Where this transfer is for administrative purposes, the transfer of the data is based on our legitimate business and operational interests or is made where it is necessary to fulfill our contractual obligations or where there is consent from the data subjects or legal permission.

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 the disclosure or transfer of data to other persons, bodies or companies, this is only done in accordance with the statutory requirements.

Subject to express consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognised level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).

Data erasure

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose).

If the data are not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.

Within the framework of our data protection notices, we may provide users with further information on the deletion as well as on the retention of data that applies specifically to the respective processing operations.

Use of cookies

Cookies are small text files or other memory notes that store information on end devices and read information from the end devices. For example, to save the login status in a user account, the contents of a shopping basket in an e-shop, the contents called up or the functions used in 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 legal requirements. We therefore obtain prior consent from users, except where this is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary to provide a telemedia service (i.e. our online offer) expressly requested by the user. The revocable consent is clearly communicated to the users and contains the information on the respective cookie use.

Notes on legal bases under data protection law: The legal basis under data protection law on which we process users' personal data using 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 using cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and improvement of its usability) or, if this is done in the context of the performance of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. The purposes for which the cookies are processed by us are explained in the course of this privacy policy or as part of our consent and processing procedures.

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 their end device (e.g. browser or mobile app).
  • Permanent cookies: Permanent cookies remain stored even after the end 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 to measure reach. Unless we provide users with explicit information about the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that they can be stored for 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 object to the processing in accordance with the legal requirements in Art. 21 GDPR (further information on the objection is provided within the scope of this privacy policy). Users can also declare their objection using the settings of their browser.

Cookie settings/options:

https://www.htt-ag.com/imprint//#cookie-consent

Further guidance on processing operations, procedures and services:

Processing of cookie data on the basis of consent: We use a cookie consent management procedure in 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. A pseudonymous user identifier is created and stored with the time of consent, information about the scope of consent (e.g., which categories of cookies and/or service providers), as well as the browser, system and end device used.

Provision of the online offer and web hosting

In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.

The data processed in the course of providing the hosting service may include all information relating to the users of our online service that is generated in the course of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

  • Types of data processed: 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).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Purposes of the processing: Provision of our online offer and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Further guidance on processing operations, procedures and services:

  • Email sending and hosting: The web hosting services we use also include the sending, receiving and storing of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of recognising SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption procedure is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.
  • Collection of access data and log files:  We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to prevent server overload (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the utilisation of the servers and their stability; Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further storage is required for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified.
  • Amazon Web Services (AWS): Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: Amazon Web Services, Inc., 410 Terry Avenue North, Seattle WA 98109, USA; Website: https://aws.amazon.com/?nc1=h_ls; Privacy statement: https://aws.amazon.com/privacy/?nc1=h_ls; Order processing agreement: https://d1.awsstatic.com/legal/aws-gdpr/AWS_GDPR_DPA.pdf; Standard contractual clauses (guaranteeing the level of data protection in the case of processing in third countries): https://aws.amazon.com/service-terms/?nc1=h_ls.

Contact and request management

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

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

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

Further guidance on processing operations, procedures and services:

Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context for the purpose of processing 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 concerns and our statutory retention obligations.

Chatbots and chat functions

We offer online chats and chatbot functions (collectively referred to as "chat services") as a communication option. 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 also be stored within the relevant 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 these in accordance with 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 on the device used by the users and, depending on the settings of their device, also location information (so-called metadata) for the purpose of optimising the respective services and for security purposes. Likewise, the metadata of the communication via chat services (i.e. e.g. information on who communicated with whom) could be used by the respective platform providers in accordance with their regulations, to which we refer for further information, for marketing purposes or to display advertising tailored to users.

If users agree with 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 informs users how and with which terms they can unsubscribe from the messages. When users unsubscribe from chatbot messages, their data is deleted from the list of message recipients.

We use the aforementioned information to operate our chat services, e.g. to address users personally, to answer their queries, 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 queries).

Notes on legal bases: We use chat services on the basis of consent if we have previously obtained users' permission to process their data within the scope of our chat services (this applies to cases where users are asked for consent, e.g. for a chatbot to send them messages on a regular basis). If we use chat services to answer users' enquiries about our services or our company, this is done for contractual and pre-contractual communication. Furthermore, we use chat services on the basis of our legitimate interests in optimising the chat services, their operational efficiency and increasing the positive user experience.

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

  • Data types processed: 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).
  • Persons concerned:  Communication partner.
  • Purposes of the processing:  Contact requests and communication; direct marketing (e.g. by e-mail or post).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR); Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. GDPR); Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Further guidance on processing operations, procedures and services:

Web analysis, monitoring and optimisation

Web analytics (also referred to as "reach measurement") is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the reach analysis, we can, for example, recognise at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimisation.

In addition to web analysis, we may also use test procedures, e.g. to test and optimise different versions of our online offer or its components.

Unless otherwise stated below, profiles, i.e. data summarised 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 from us or from the providers of the services we use, location data may also be processed.

The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimisation, but pseudonyms. This means that we as well as the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.

Notes on legal bases: Where we ask users to consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Data types processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Persons affected: Users (e.g. website visitors, users of online services).
  • Purposes of the processing: Remarketing; reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles); tracking (e.g. interest/behaviour-related profiling, use of cookies); click tracking; A/B tests; heatmaps (mouse movements on the part of users that are combined to form an overall picture.); provision of our online offer and user friendliness.
  • Security measures: IP masking (pseudonymisation of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR); Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Further guidance on processing operations, procedures and services:

  • Google Analytics: web analytics, reach measurement and measurement of user flows; 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://marketingplatform.google.com/intl/en_uk/about/analytics/; Privacy policy: https://policies.google.com/privacy?hl=en; Order processing agreement: https://business.safety.google/intl/en/adsprocessorterms/; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://business.safety.google/intl/en/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://business.safety.google/intl/en/adsservices/ (Types of processing as well as data processed).
  • Google Analytics 4: We use Google Analytics to perform user analysis based on a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to an end device in order to recognise which content users have accessed within one or various usage processes, which search terms they have used, have accessed again or have interacted with our online offer. The time of use and its duration are also stored, as well as the sources of the users referring to our online offer and technical aspects of their end devices and browsers. In the process, pseudonymous profiles of users are created with information from the use of various devices, whereby cookies may be used. In Analytics, higher level geographic location data is provided by collecting the following metadata based on IP search: "city" (and the derived latitude and longitude of the city), "continent", "country", "region", "subcontinent" (and the ID-based equivalents). To ensure the protection of user data in the EU, Google receives and processes all user data via domains and servers within the EU. Users' IP addresses are not logged and are truncated by the last two digits by default. The shortening of the IP address takes place on EU servers for EU users. In addition, all sensitive data collected from users in the EU is deleted before it is collected via EU domains and servers; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland, Mutterunternehmen: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/en_uk/about/analytics/; Privacy Policy: https://policies.google.com/privacy?hl=en; Order processing contract: https://business.safety.google/intl/en/adsprocessorterms/; Standard contractual clauses (guaranteeing the level of data protection in the case of processing in third countries): https://business.safety.google/intl/en/adsprocessorterms/; Possibility of objection (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://business.safety.google/intl/en/adsservices/ (Types of processing and data processed).
  • Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offer (please refer to further information in this data protection declaration). The Tag Manager itself (which implements the tags) does not create user profiles or store cookies. Google only learns the user's IP address, which is necessary to run the Google Tag Manager; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland, Parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/en_uk/about/; Privacy Policy: https://policies.google.com/privacy?hl=en; Order processing agreement: https://business.safety.google/intl/en/adsprocessorterms/; Standard contractual clauses (guaranteeing the level of data protection in the case of processing in third countries): https://business.safety.google/intl/en/adsprocessorterms/; Further information: https://business.safety.google/intl/en/adsservices/ (Types of processing and data processed).
  • Hotjar Observe: Software for analyzing and optimizing online offers on the basis of pseudonymously performed measurements and analyses of user behavior, which may include in particular A/B tests (measurement of popularity and user-friendliness of different content and functions), measurement of click paths and interaction with content and functions of the online offer (so-called heat maps and recordings); Service provider: Hotjar Ltd, 3 Lyons Range, 20 Bisazza Street, Sliema SLM 1640, Malta ; Legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: www.hotjar.com; Privacy policy: www.hotjar.com/legal/policies/privacy; Deletion of data: The cookies that Hotjar uses have different "lifetimes"; some remain valid for up to 365 days, some only during the current visit; Cookie policy: www.hotjar.com/legal/policies/cookie-information; Opt-out: https://www.hotjar.com/legal/compliance/opt-out.
  • Matomo: Matomo is software that is used for web analysis and reach measurement purposes. When Matomo is used, cookies are generated and stored on the user's terminal device. The user data collected as part of the use of Matomo is only processed by us and is not shared with third parties. The cookies are stored for a maximum period of 13 months: matomo.org/faq/general/faq_146/; Legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Deletion of data: The cookies have a maximum storage period of 13 months.

Online marketing

We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or presentation of promotional and other content (collectively, „Content“) based on potential user interests and the measurement of its effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called „cookie“) or similar procedures are used, by means of which the information about the user relevant to the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information, such as the browser used, the computer system used and information on usage times and functions used. If users have consented to the collection of their location data, this may also be processed.

The IP addresses of users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of the users (such as e-mail addresses or names) are stored in the context of the online marketing process, but pseudonyms. This means that we, as well as the providers of the online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can later generally be read on other websites that use the same online marketing procedure and analyzed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.

Exceptionally, clear data can be assigned to the profiles. This is the case if, for example, the users are members of a social network whose online marketing procedure we use and the network links the profiles of the users with the aforementioned data. We ask to note that users may make additional arrangements with the providers, e.g., by giving consent as part of the registration process.

In principle, we only receive access to summarized information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e., for example, to a conclusion of a contract with us. The conversion measurement is used solely to analyze the success of our marketing measures.

Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.

Notes on legal bases: If we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, users‘ data is processed on the basis of our legitimate interests (i.e. interest in efficient, 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).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: marketing; profiling with user-related information (creating user profiles); conversion measurement (measuring the effectiveness of marketing activities).
  • 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).
  • Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the objection options given to the providers (so-called „opt-out“). If no explicit opt-out option has been specified, you have the option of disabling cookies in your browser settings. However, this may restrict functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for the respective areas: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices.  c) USA: https://www.aboutads.info/choices. d) Cross-territory: https://optout.aboutads.info.

Further information on processing, procedures and services:

Google Ads and conversion measurement: we use the online marketing procedure „Google Ads“ to place ads in the Google advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads (so-called „conversion“). Furthermore, we measure the conversion of the ads. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page marked with a so-called „conversion tracking tag“. However, we ourselves do not receive any information with which users can be identified; 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://marketingplatform.google.com/intl/en_uk/about/analytics/; Privacy policy: https://policies.google.com/privacy?hl=en; Further information: Types of processing as well as data processed: https://business.safety.google/intl/en/adsservices/; Google Advertising Products Data Processing Terms: Information on services Data processing terms between data controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/intl/en/adscontrollerterms/.

Plugins and embedded functions and content

We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These can be, for example, graphics, videos or 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, as without the IP address they would not be able to send the content to their browser. The IP address is thus required for the presentation of these contents or functions. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to analyse information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offering, as well as being linked to such information from other sources.

Notes on the legal basis: Where we ask users to consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Data types 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. entries in online forms).
  • Persons concerned:  Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness.
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR); Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. GDPR); Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Further guidance on processing operations, procedures and services:

Amendment and update of the privacy policy

We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organisations in this data protection declaration, please note that the addresses may change over time and please check the information before contacting us.

Rights of the data subject

As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to revoke any consent you have given at any time.
  • Right to information: You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectify: In accordance with the legal requirements, you have the right to request that the data concerning you be completed or that the incorrect data concerning you be corrected.
  • Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that data relating to you be deleted immediately or, alternatively, to demand restriction of the processing of the data in accordance with the statutory provisions.
  • Right to data portability: You have the right to receive data relating to you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transferred to another person responsible.
  • Complaint to supervisory authority: In accordance with the law and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you usually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Definitions of terms

This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined above all in Art. 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.

  • A/B tests: A/B tests are used to improve the usability and performance of online offerings. For example, users are presented with different versions of a website or its elements, such as input forms, on which the placement of the content or the labels of the navigation elements may differ. Then, based on the users‘ behavior, e.g., staying on the web page longer or interacting with the elements more frequently, it can be determined which of these web pages or elements are more likely to meet the users‘ needs.
  • Heatmaps: „Heatmaps“ are users‘ mouse movements that are summarized to form an overall image that can be used, for example, to identify which web page elements are preferred and which web page elements users prefer less.
  • Click tracking: Click tracking allows to overview the movements of users within an entire online offer. Since the results of these tests are more accurate if user interaction can be tracked over a period of time (e.g., so that we can find out whether a user likes to return), cookies are usually stored on users‘ computers for these testing purposes.
  • Conversion measurement: Conversion measurement (also referred to as „visit action evaluation“) is a procedure that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users‘ devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we have placed on other websites have been 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 (e.g. cookie) or to one or more factors specific to 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 analyze, evaluate or to predict 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 interaction with websites and their content, etc.) (e.g., interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include visitors‘ behavior or interests in certain information, such as website content. 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 reach analysis purposes, 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.
  • Tracking: We speak of „tracking“ when the behavior of users can be traced across several online offerings. As a rule, behavioral and interest information is stored in cookies or on servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can subsequently be used, for example, to display advertisements to users that are likely to correspond to their interests.
  • Controller: a „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, be it collection, analysis, storage, transmission or deletion.