Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process for which purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and especially 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: June 6, 2024

Table of Contents

Responsible Party

Martin Milewski
Konradstr. 11
83233 Bernau am Chiemsee

Email Address: milewski@gedankenspiel-mm.de

Overview of Processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of Data Processed

  • Inventory data.
  • Payment data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication, and procedural data.
  • Image and/or video recordings.
  • Audio recordings.
  • Log data.

Categories of Data Subjects

  • Service recipients and clients.
  • Interested parties.
  • Communication partners.
  • Users.
  • Business and contract partners.
  • Depicted persons.

Purposes of Processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Security measures.
  • Reach measurement.
  • Office and organizational procedures.
  • Organizational and administrative procedures.
  • Feedback.
  • Profiles with user-related information.
  • Provision of our online offer and user-friendliness.
  • Information technology infrastructure.
  • Business processes and economic procedures.

Relevant Legal Bases

Relevant legal bases under the GDPR: The following provides an overview of the legal bases of the GDPR on which we base the processing of personal data. Please note that in addition to the regulations of the GDPR, national data protection regulations may apply in your or our country of residence or establishment. If more specific legal bases are relevant in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6(1) sentence 1 lit. a) GDPR) – The data subject has given their consent to the processing of personal data concerning them for one or more specific purposes.
  • Contract performance and pre-contractual inquiries (Art. 6(1) sentence 1 lit. b) GDPR) – The processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject before entering into a contract.
  • Legal obligation (Art. 6(1) sentence 1 lit. c) GDPR) – The processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR) – the 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.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. This includes, in particular, the Federal Data Protection Act (BDSG). The BDSG contains special regulations on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and the transmission and automated decision-making in individual cases, including profiling. Furthermore, the data protection laws of the individual federal states may apply.

Note on the applicability of the GDPR and Swiss DSG: These data protection notices serve both to provide information under the Swiss DSG and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that due to broader spatial application and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms used in the Swiss DSG “processing” of “personal data”, “overriding interest”, and “particularly sensitive personal data”, the terms used in the GDPR “processing” of “personal data” as well as “legitimate interest” and “special categories of data” are used. However, the legal meaning of the terms will continue to be determined under the Swiss DSG within the scope of the applicability of the Swiss DSG.

Security Measures

We take appropriate technical and organizational measures to ensure a level of security appropriate to the risk, considering the state of the art, the implementation costs, and the nature, scope, context, and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, in accordance with the legal requirements.

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, input, transfer, ensuring availability, and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to data threats. Additionally, we consider the protection of personal data already during the development or selection of hardware, software, and procedures according to the principle of data protection by design and by default.

Shortening of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a full IP address is not required, the IP address is shortened (also referred to as “IP masking”). In this process, the last two digits or the last part of the IP address after a dot are removed or replaced by placeholders. The shortening of the IP address is intended to prevent or significantly complicate the identification of a person based on their IP address.

Securing online connections using TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted through our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator for users that their data is securely and encrypted transmitted.

Transfer of Personal Data

In the course of our processing of personal data, it may happen that these are transferred to other entities, companies, legally independent organizational units, or persons or disclosed to them. Recipients of this data may include, for example, service providers tasked with IT tasks or providers of services and content embedded in a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data, which serve to protect your data.

International Data Transfers

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 if the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities, or companies, this will only be done in accordance with legal requirements. If the level of data protection in the third country has been recognized by an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers will only take place if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46(2)(c) GDPR), explicit consent, or in the case of contractual or legally required transfer (Art. 49(1) GDPR). Otherwise, we will inform you of the basis of the third-country transfer for the individual providers from the third country, with adequacy decisions taking precedence. Information on third-country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

EU-US Trans-Atlantic Data Privacy Framework: As part of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the level of data protection for certain companies from the USA as safe within the framework of the adequacy decision of 10.07.2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). We inform you within the framework of the data protection notices which service providers used by us are certified under the Data Privacy Framework.

General Information on Data Storage and Deletion

We delete personal data that we process in accordance with legal requirements as soon as the underlying consents are revoked or there are no further legal bases for processing. This applies to cases where the original purpose of processing ceases to apply or the data is no longer needed. Exceptions to this rule exist if legal obligations or special interests require longer retention or archiving of the data.

In particular, data that must be retained for commercial or tax reasons or whose storage is necessary for legal prosecution or the protection of the rights of other natural or legal persons must be archived accordingly.

Our data protection notices contain additional information on the retention and deletion of data that apply specifically to certain processing processes.

In the case of multiple indications of the retention period or deletion deadlines of a date, the longest period is always decisive.

If a period does not explicitly begin on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships, within the framework of which data is stored, the event triggering the period is the time the termination or other termination of the legal relationship becomes effective.

Data that is no longer needed for the originally intended purpose but is retained due to legal requirements or other reasons is processed exclusively for the reasons that justify its retention.

Further information on processing procedures, procedures, and services:

  • Retention and deletion of data: The following general periods apply to retention and archiving under German law:
    • 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, and the work instructions and other organizational documents necessary for their understanding, booking receipts, and invoices (§ 147(3) in conjunction with (1) No. 1, 4, and 4a AO, § 14b(1) UStG, § 257(1) No. 1 and 4, (4) HGB).
    • 6 years – Other business documents: received commercial or business letters, copies of sent commercial or business letters, other documents relevant for taxation, such as hourly wage slips, operating accounting sheets, calculation documents, price labels, but also payroll documents, as far as they are not already booking receipts, and cash register strips (§ 147(3) in conjunction with (1) No. 2, 3, 5 AO, § 257(1) No. 2 and 3, (4) HGB).
    • 3 years – Data necessary to consider potential warranty and damage claims or similar contractual claims and rights and associated inquiries, based on previous business experiences and usual industry practices, are stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Rights of Data Subjects

Rights of data subjects under the GDPR: As a data subject, you have 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 based on Art. 6(1) lit. e or f GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw consents at any time.
  • Right of access: You have the right to request confirmation as to whether data concerning you is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: You have the right, in accordance with legal requirements, to request the completion or correction of data concerning you.
  • Right to erasure and restriction of processing: You have the right, in accordance with legal requirements, to request that data concerning you be deleted immediately, or alternatively, to request a restriction of the processing of the data in accordance with legal requirements.
  • Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format in accordance with legal requirements, or to request that it be transferred to another controller.
  • Right to lodge a complaint with a supervisory authority: In accordance with legal requirements 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 in the member state of your habitual residence, workplace, or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Business Services

We process data from our contractual and business partners, such as customers and interested parties (collectively referred to as “contractual partners”), in the context of contractual and similar legal relationships as well as related measures and in terms of communication with the contractual partners (or pre-contractually), for example, to respond to inquiries.

We use this data to fulfill our contractual obligations. This includes, in particular, the obligations to provide the agreed services, any update obligations, and remedies for warranty and other performance disruptions. Furthermore, we use the data to protect our rights and for the purposes of the administrative tasks associated with these obligations and corporate organization. We also process the data based on our legitimate interests in proper and economic business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information, and rights (e.g., involving telecommunications, transport, and other support services, subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). In accordance with applicable law, we only disclose the data of contractual partners to third parties to the extent necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners are informed about further forms of processing, such as for marketing purposes, within the framework of this privacy policy.

We inform the contractual partners before or during the data collection, e.g., in online forms, through special markings (e.g., colors) or symbols (e.g., asterisks or similar), or personally, which data is required for the aforementioned purposes.

We delete the data after the expiration of statutory warranty and comparable obligations, i.e., generally after four years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal reasons (e.g., for tax purposes, generally ten years). Data that has been disclosed to us as part of an order by the contracting partner will be deleted in accordance with the specifications and generally after the end of the order.

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers). Contract data (e.g. contract subject, duration, customer category).
  • Data subjects: Service recipients and clients; Interested parties. Business and contractual partners.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Communication; Office and organizational procedures; Organizational and administrative procedures. Business processes and economic procedures.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Contract performance and pre-contractual inquiries (Art. 6(1) sentence 1 lit. b) GDPR); Legal obligation (Art. 6(1) sentence 1 lit. c) GDPR). Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR).

Further information on processing procedures, procedures, and services:

  • Coaching: We process the data of our clients as well as interested parties and other clients or contractual partners (collectively referred to as “clients”) in order to provide our services to them. The procedures carried out within the framework and for the purposes of coaching include: Contacting and communicating with clients, needs analysis to determine suitable coaching measures, planning and conducting coaching sessions, documenting coaching progress, recording and managing client-specific information and data, scheduling and organizing appointments, providing coaching materials and resources, billing and payment management, follow-up and review of coaching sessions, quality assurance, and feedback processes.
    The processed data, the type, scope, purpose, and necessity of their processing are determined by the underlying contractual and client relationship.
    If it is necessary for our contract fulfillment, to protect vital interests, or legally required, or if there is consent from the clients, we disclose or transmit the data of the clients in compliance with professional regulations to third parties or agents, such as authorities, billing offices, as well as in the field of IT, office or similar services; Legal bases: Contract performance and pre-contractual inquiries (Art. 6(1) sentence 1 lit. b) GDPR).

Provision of the Online Offer and Web Hosting

We process the data of users to be able to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or end device.

  • Types of data processed: Usage data (e.g., page views and duration of visits, click paths, usage intensity and frequency, used device types and operating systems, interactions with content and functions); Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved persons). Log data (e.g., log files concerning logins or the retrieval of data or access times).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR).

Further information on processing procedures, procedures, and services:

  • Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding server provider (also called “web hoster”); Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR).
  • Collection of access data and log files: Access to our online offer is logged in the form of so-called “server log files”. The server log files may include the address and name of the retrieved web pages and files, date and time of the retrieval, transmitted data volumes, message about successful retrieval, 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 avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and on the other hand, to ensure the utilization of the servers and their stability; Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data that needs to be retained for evidence purposes is excluded from deletion until the respective incident is finally clarified.
  • STRATO: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacities); Service provider: STRATO AG, Pascalstraße 10, 10587 Berlin, Germany; Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR); Website: https://www.strato.de; Privacy policy: https://www.strato.de/datenschutz/. Order processing contract: Provided by the service provider.

Use of Cookies

Cookies are small text files or other memory notes that store and retrieve information on end devices. For example, to store the login status in a user account, a shopping cart content in an e-shop, the accessed content, or used functions of an online offer. Cookies can also be used for different purposes, such as for the functionality, security, and comfort of online offers and the creation of analyses of visitor flows.

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

Notes on data protection legal bases: The data protection legal basis on which we process the personal data of users using cookies depends on whether we ask users for their consent. If the users agree, the legal basis for processing their data is the declared consent. Otherwise, the data processed using cookies is based on our legitimate interests (e.g., in a business operation of our online offer and the improvement of its usability) or, if this is done within the framework of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We clarify the purposes for which the cookies are used in the course of this privacy policy or within the framework of our consent and processing procedures.

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

  • Temporary cookies (also: session or 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 application).
  • Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved, and preferred content can be displayed directly when the user visits a website again. Likewise, the user data collected using 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), they should assume that these are permanent and that the storage duration can be up to two years.

    • General notes on revocation and objection (opt-out): Users can revoke their given consents at any time and also object to processing in accordance with the legal requirements, also by means of the privacy settings of their browser.

    • Types of data processed: Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved persons).
    • Data subjects: Users (e.g., website visitors, users of online services).
    • Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR). Consent (Art. 6(1) sentence 1 lit. a) GDPR).

    Further information on processing procedures, procedures, and services:

    • Processing of cookie data based on consent: We use a consent management solution in which the consent of users for the use of cookies or for the procedures and providers mentioned within the framework of the consent management solution is obtained. This procedure serves to obtain, document, manage, and revoke consents, particularly with regard to the use of cookies and similar technologies used to store, read, and process information on the users’ end devices. In this context, the consents of the users for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure, are obtained. Users also have the opportunity to manage and revoke their consents. The consent declarations are stored to avoid a repeated query and to be able to provide proof of the consent in accordance with the legal requirements. The storage takes place server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies to be able to assign the consent to a specific user or their device. Unless specific information about the providers of consent management services is available, the following general notes apply: The storage duration of the consent is up to two years. A pseudonymous user identifier is created, which is stored together with the time of the consent, the information on the scope of the consent (e.g., concerning categories of cookies and/or service providers), as well as information about the browser, system, and the used end device; Legal bases: Consent (Art. 6(1) sentence 1 lit. a) GDPR).
    • Cookiebot: Consent management: procedure for obtaining, documenting, managing, and revoking consents, particularly for the use of cookies and similar technologies for storing, reading, and processing information on the users’ end devices and their processing; Service provider: Usercentrics A/S, Havnegade 39, 1058 Copenhagen, Denmark; Website: https://www.cookiebot.com/en; Privacy policy: https://www.cookiebot.com/en/privacy-policy/; Order processing contract: Provided by the service provider; Further information: Stored data (on the server of the service provider): The user’s IP number in anonymized form (the last three digits are set to 0), date and time of consent, browser details, the URL from which the consent was sent, an anonymous, random, and encrypted key value. the user’s consent status.

    Contact and Inquiry Management

    When contacting us (e.g., by post, contact form, e-mail, phone, or via social media) and within the framework of existing user and business relationships, the information of the requesting persons is processed to the extent necessary to answer the contact inquiries and any requested measures.

    • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and e-mail addresses or phone numbers); Content data (e.g., textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation); Usage data (e.g., page views and duration of visits, click paths, usage intensity and frequency, used device types and operating systems, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved persons).
    • Data subjects: Communication partners.
    • Purposes of processing: Communication; Organizational and administrative procedures; Feedback (e.g., collecting feedback via online form). Provision of our online offer and user-friendliness.
    • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
    • Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR). Contract performance and pre-contractual inquiries (Art. 6(1) sentence 1 lit. b) GDPR).

    Further information on processing procedures, procedures, and services:

    • Contact form: When contacting us via our contact form, by e-mail, or other communication channels, we process the personal data transmitted to us to respond to and handle the respective request. This usually includes information such as name, contact details, and possibly other information provided to us and necessary for appropriate processing. We use this data exclusively for the stated purpose of contacting and communicating; Legal bases: Contract performance and pre-contractual inquiries (Art. 6(1) sentence 1 lit. b) GDPR), Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR).
    • Contact Form 7: Management of contact inquiries and communication; Service provider: Rock Lobster, LLC; Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR); Website: https://contactform7.com/. Further information: Operation within its own hosting environment.

    Video Conferences, Online Meetings, Webinars, and Screen Sharing

    We use platforms and applications of other providers (hereinafter referred to as “conference platforms”) for the purpose of conducting video and audio conferences, webinars, and other types of video and audio meetings (hereinafter collectively referred to as “conference”). When selecting the conference platforms and their services, we observe the legal requirements.

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

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

    Data protection measures of the participants: Please refer to the privacy notices of the conference platforms for details on how your data is processed by the conference platforms and choose the optimal security and privacy settings for you within the settings of the conference platforms. Please also ensure data and privacy protection in the background of your recording for the duration of a video conference (e.g., by informing roommates, locking doors, and using, if technically possible, the function to obscure the background). Links to the conference rooms and access data must not be shared with unauthorized third parties.

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

    • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and e-mail addresses or phone numbers); Content data (e.g., textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation); Usage data (e.g., page views and duration of visits, click paths, usage intensity and frequency, used device types and operating systems, interactions with content and functions); Image and/or video recordings (e.g., photographs or video recordings of a person); Audio recordings. Log data (e.g., log files concerning logins or the retrieval of data or access times.).
    • Data subjects: Communication partners; Users (e.g., website visitors, users of online services). Depicted persons.
    • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Communication. Office and organizational procedures.
    • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
    • Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR).

    Further information on processing procedures, procedures, and services:

    Web Analysis, Monitoring, and Optimization

    Web analysis (also referred to as “reach measurement”) is used to evaluate the visitor flows of our online offer and can include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online offer or its functions or contents are most frequently used or invite reuse. Likewise, we can understand which areas need optimization.

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

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

    In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no clear data of the users (such as e-mail addresses or names) are stored within the framework of web analysis, A/B testing, and optimization, but pseudonyms. This means that we and the providers of the used software do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

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

    • Types of data processed: Usage data (e.g., page views and duration of visits, click paths, usage intensity and frequency, used device types and operating systems, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved persons).
    • Data subjects: Users (e.g., website visitors, users of online services).
    • Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors). Profiles with user-related information (creating user profiles).
    • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods can be stored on users’ devices for a period of up to two years.).
    • Security measures: IP masking (pseudonymization of the IP address).
    • Legal bases: Consent (Art. 6(1) sentence 1 lit. a) GDPR). Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR).

    Further information on processing procedures, procedures, and services:

    • Matomo: Matomo is a software used for web analysis and reach measurement. In the context of using Matomo, cookies are generated and stored on the users’ devices. The data collected through the use of Matomo is only processed by us and not shared with third parties. The cookies are stored for a maximum period of 13 months: https://matomo.org/faq/general/faq_146/; Legal bases: Consent (Art. 6(1) sentence 1 lit. a) GDPR). Deletion of data: The cookies have a storage duration of a maximum of 13 months.

    Plug-ins 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 may include 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 users, as they could not send the content to their browser without the IP address. The IP address is therefore required for the display of these contents or functions. We strive to use only those contents whose respective providers use the IP address solely for the delivery of the contents. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to 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, among other things, technical information about the browser and operating system, referring websites, visit times, and other information about the use of our online offer, as well as being linked to such information from other sources.

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

    • Types of data processed: Usage data (e.g., page views and duration of visits, click paths, usage intensity and frequency, used device types and operating systems, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved persons).
    • Data subjects: Users (e.g., website visitors, users of online services).
    • Purposes of processing: Provision of our online offer and user-friendliness.
    • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods can be stored on users’ devices for a period of up to two years.).
    • Legal bases: Consent (Art. 6(1) sentence 1 lit. a) GDPR). Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR).

    Changes and Updates

    We ask you to regularly inform yourself about the content of our privacy policy. We adapt the privacy policy 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 organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting us.

    Definitions of Terms

    This section provides an overview of the terms used in this privacy policy. Insofar as the terms are legally defined, their legal definitions apply. The following explanations are intended to contribute to understanding.

    • Inventory data: Inventory data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar assignments. This data may include, among other things, personal and demographic information such as names, contact information (addresses, phone numbers, email addresses), birth dates, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, institutions, or systems by enabling unique assignment and communication.
    • Content data: Content data includes information generated in the course of creating, editing, and publishing content of all kinds. This category of data may include texts, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the actual content but also includes metadata that provides information about the content itself, such as tags, descriptions, author information, and publication dates.
    • Contact data: Contact data is essential information that enables communication with individuals or organizations. It includes, among other things, phone numbers, postal addresses, and email addresses, as well as communication means such as social media handles and instant messaging identifiers.
    • Meta, communication, and procedural data: Meta, communication, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Metadata, also known as data about data, includes information that describes the context, origin, and structure of other data. They may include details on file size, creation date, author of a document, and change histories. Communication data captures the exchange of information between users via various channels, such as email traffic, call logs, messages on social networks, and chat histories, including the people involved, timestamps, and transmission paths. Procedural data describes the processes and workflows within systems or organizations, including workflow documentation, transaction logs, and activity logs, as well as audit logs used to track and review operations.
    • Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data includes a wide range of information that shows how users use applications, which features they prefer, how long they stay on certain pages, and what paths they navigate through an application. Usage data can also include the frequency of use, timestamps of activities, IP addresses, device information, and location data. They are particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences, and potential problem areas within digital offerings.
    • 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 simply “profiles”, includes any type of automated processing of personal data that consists of using this personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this can include various information concerning demographics, behavior, and interests, such as interaction with websites and their content, etc.). Cookies and web beacons are often used for profiling purposes.
    • Log data: Log data is information about events or activities that have been logged in a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data is often used to analyze system problems, monitor security, or create performance reports.
    • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the visitor flows of an online offer and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online offers can, for example, recognize when users visit their websites and what content they are interested in. This allows them to better tailor the content of the websites to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis to recognize returning visitors and thus obtain more accurate analyses of the use of an online offer.
    • Controller: The “controller” is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
    • Processing: “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and encompasses practically any handling of data, whether it is collecting, evaluating, storing, transmitting, or deleting.
    • Contract data: Contract data is specific information that relates to the formalization of an agreement between two or more parties. They document the conditions under which services or products are provided, exchanged, or sold. This data category is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include the start and end dates of the contract, the type of agreed services or products, price agreements, payment terms, termination rights, renewal options, and special conditions or clauses. They serve as the legal basis for the relationship between the parties and are crucial for clarifying rights and obligations, enforcing claims, and resolving disputes.
    • Payment data: Payment data includes all information required for processing payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking, and any other form of financial transaction. They include details such as credit card numbers, bank account information, payment amounts, transaction data, verification numbers, and billing information. Payment data can also include information about payment status, chargebacks, authorizations, and fees.

    Footer EN

     

    ©2018 Gedankenspiel · Martin Milewski · Konradstrasse 11 · 83233 Bernau am Chiemsee · imprint · privacy policy