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”) we process, for what purposes and to what extent. The Privacy Policy applies to all processing of personal data carried out by us, both in the context 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 the “Online Offer”).
The terms used are not gender-specific.
Last updated: 26. June 2025
Outline
- Preamble
- Person in charge
- Overview of processing
- Relevant legal bases
- Safety measures
- Transfer of personal data
- International data transfers
- Rights of data subjects
- Use of cookies
- Business services
- Use of online platforms for quotation and sales purposes
- Payment
- Provision of the online offer and web hosting
- Registration, Login and User Account
- Contact and Enquiry Management
- Communication via Messenger
- Newsletters and electronic notifications
- Advertising communication via e-mail, post, fax or telephone
- Web analysis, monitoring and optimization
- Presence in social networks (social media)
- Plugins and embedded functions and content
- Definitions
Person in charge
Barbara Sinkovic
Römerstraße 70
4600 Wels
E-mail address: info@fame-nails.at
Imprint: Legal notice – Fame Nails
Overview of processing
The following overview summarises the types of data processed and the purposes of their processing, and refers to the data subjects.
Types of data processed
- Inventory data.
- Payment.
- Contact details.
- Content Data.
- Contract.
- Usage.
- Meta, communication and procedural data.
Categories of data subjects
- Customers.
- Interested parties.
- Communication.
- User.
- Business and contractual partners.
Purposes of processing
- Provision of contractual services and fulfilment of contractual obligations.
- Contact requests and communication.
- Security Measures.
- Direct marketing.
- Range measurement.
- Office and organizational procedures.
- Conversion measurement.
- Managing and responding to requests.
- Feedback.
- Marketing.
- User-related information profiles.
- Provision of our online offer and user-friendliness.
- Information technology infrastructure.
Relevant legal bases
Relevant legal bases according to the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the regulations of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Furthermore, if more specific legal bases are relevant in individual cases, we will inform you of these in the privacy policy.
- Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) – The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or purposes.
- Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) – 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 prior to entering into a contract.
- Legal obligation (Art. 6 para. 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 para. 1 sentence 1 lit. f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by 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.
National data protection regulations in Austria: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Austria. These include, in particular, the Federal Act on the Protection of Natural Persons with regard to the Processing of Personal Data (Data Protection Act – FADP). In particular, the Data Protection Act contains special provisions on the right of access, the right to rectification or erasure, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases.
Note on the applicability of the GDPR and the Swiss FADP: This data protection notice serves both to provide information in accordance with the Swiss Federal Act on Data Protection (Swiss FADP) and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that due to the broader spatial application and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms “processing” of “personal data”, “overriding interest” and “particularly sensitive personal data” used in the Swiss FADP, the terms “processing” of “personal data” as well as “legitimate interest” and “special categories of data” used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss FADP within the scope of the Swiss FADP.
Safety measures
In accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, 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, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.
Measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, availability and separation. We have also put in place procedures to ensure that the rights of data subjects are exercised, that data is deleted and that data is compromised. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes in accordance with the principle of data protection, through technical design and through data protection-friendly default settings.
TLS/SSL encryption (https): To protect the data of users transmitted through our online services, we use TLS/SSL encryption. Secure Sockets Layer (SSL) is the standard technology used to secure internet connections by encrypting the data transmitted between a website or app and a browser (or between two servers). Transport Layer Security (TLS) is an updated and more secure version of SSL. Hyper Text Transfer Protocol Secure (HTTPS) appears in the URL when a website is secured by an SSL/TLS certificate.
Transfer of personal data
As part of our processing of personal data, the data may be transmitted 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 with the recipients of your data that 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, bodies or companies, this will only take place in accordance with the legal requirements. If the level of data protection in the third country has been recognised by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers only take place if the level of data protection is otherwise ensured, in particular by means of standard contractual clauses (Art. 46 para. 2 lit. c) GDPR), explicit consent or in the case of contractual or legally required transfer (Art. 49 para. 1 GDPR). In addition, we will inform you of the basis of the third-country transfer for the individual providers from the third country, with the adequacy decisions taking precedence as the basis. Information on third-country transfers and existing adequacy decisions can be found in the EU Commission’s information service: 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 as secure for certain companies from the USA as part of the adequacy decision of 10.07.2023. The list of certified companies as well as further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/. As part of the data protection notice, we will inform you which service providers we use are certified under the Data Privacy Framework.
Rights of data subjects
Rights of data subjects under the GDPR: As data subjects, you have various rights under the GDPR, which result in particular from Art. 15 to 21 GDPR:
- Right to object: You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you that is carried out on the basis of Art. 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is related to such direct advertising.
- Right of revocation in the case of consent: You have the right to revoke any consent you have given at any time.
- Right: You have the right to request confirmation as to whether the data in question is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
- Right to rectification: In accordance with the legal requirements, you have the right to request the completion of the data concerning you or the correction of the incorrect data concerning you.
- Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be deleted immediately, or alternatively to demand a restriction of the processing of the data in accordance with the legal requirements.
- Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request its transmission to another controller.
- 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 in which you habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you believe that the processing of the data relating to your person personal data violates the GDPR.
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 cart in an e-shop, the content accessed or the functions used in an online offer. Cookies can also be used for various purposes, e.g. for the purposes of functionality, security and convenience of online offers as well as for the creation of analyses of visitor flows.
Notes on consent: We use cookies in accordance with the legal regulations. Therefore, we obtain prior consent from users, unless this is not required by law. In particular, consent is not necessary if the storage and reading of the information, i.e. also of cookies, is absolutely necessary in order to provide the users with a telemedia service (i.e. our online offer) that they expressly request. Strictly necessary cookies usually include cookies with functions that serve the display and functionality of the Online Offering, load balancing, security, the storage of Users’ preferences and choices, or similar purposes related to the provision of the main and ancillary functions of the Online Offering requested by the Users. The revocable consent is clearly communicated to the users and contains the information on the respective use of cookies.
Information on data protection legal bases: The legal basis on which we process users’ personal data with the help of cookies depends on whether we ask users for consent. If the users consent, the legal basis for the processing of their data is the declared consent. Otherwise, the data processed with the help of cookies will be 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 fulfilment of our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. We will explain the purposes for which we process cookies in the course of this privacy policy or as part of our consent and processing processes.
Storage period: With regard to the storage period, the following types of cookies are distinguished:
- Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their device (e.g. browser or mobile application).
- Persistent 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, the 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 period of cookies (e.g. as part of obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.
General information on revocation and objection (so-called “opt-out”): Users can revoke the consent they have given at any time and object to the processing in accordance with the legal requirements. To this end, users can, among other things, restrict the use of cookies in the settings of their browser (although this may also limit the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing processes, procedures and services:
- Processing of cookie data on the basis of consent: We use a procedure for consent management: Procedures for obtaining, logging, managing and revoking consent, in particular for the use of cookies and similar technologies for storing, reading and processing information on users’ end devices as well as their processing, within the framework of which the users’ consent to the use of cookies, or the consent of the users to the use of cookies, or to the use of cookies. Procedures for obtaining, logging, managing and revoking consent, in particular for the use of cookies and similar technologies for storing, reading and processing information on users’ end devices as well as their processing methods and providers, as well as for the use of cookies. In this case, the declaration of consent is stored in order not to have to repeat its query again and to be able to prove 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 his 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. In this case, a pseudonymous user identifier is formed and stored at the time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and device used; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with the contractual partners (or pre-contractually), e.g. to answer inquiries.
We process this data in order to fulfil our contractual obligations. This includes, in particular, the obligations to provide the agreed services, any updating obligations and remedy in the event of warranty and other service disruptions. In addition, we process the data to protect our rights and for the purpose of the administrative tasks associated with these obligations as well as the company organization. In addition, we process the data on the basis of our legitimate interests in proper and business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the scope of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or for the fulfilment of legal obligations. The contractual partners are informed about other forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.
We inform the contractual partners of which data is required for the aforementioned purposes before or in the context of data collection, e.g. in online forms, by means of special marking (e.g. colours) or symbols (e.g. asterisks or similar), or in person.
We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal reasons of archiving. The statutory retention period is ten years for documents relevant to tax law as well as for commercial books, inventories, opening balance sheets, annual financial statements, the work instructions and other organisational documents and accounting documents required to understand these documents, and six years for received commercial and business letters and reproductions of the commercial and business letters sent. The period begins at the end of the calendar year in which the last entry in the book was made, the inventory, the opening balance sheet, the annual financial statements or the management report were drawn up, the commercial or business letter was received or sent or the accounting document was created, the record was also made or the other documents were created.
Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.
- Types of data processed: Inventory data (e.g. names, addresses); Payment data (e.g. bank details, invoices, payment history); Contact details (e.g., email, phone numbers); Contract data (e.g. subject matter of the contract, term, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta-, communication and procedural data (e.g. . IP addresses, times, identification numbers, consent status).
- Data subjects: Customers; Interested parties. Business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; Security measures; Contact requests and communication; Office and organizational procedures; Managing and responding to requests; Conversion measurement (measuring the effectiveness of marketing measures). Profiles with user-related information (creating user profiles).
- Legal bases: Performance of the contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Account: Customers can create an account within our online offer (e.g. customer or user account, or “customer account” for short). If the registration of a customer account is required, customers will be informed of this as well as the information required for registration. The customer accounts are not public and cannot be indexed by search engines. As part of the registration as well as subsequent logins and use of the customer account, we store the IP addresses of the customers along with the access times in order to be able to prove registration and prevent any misuse of the customer account. If the customer account has been terminated, the customer account data will be deleted after the date of termination, unless it is retained for purposes other than making it available in the customer account or must be retained for legal reasons (e.g. internal storage of customer data, order processes or invoices). It is the responsibility of the customers to secure their data when the customer account is terminated; Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- Wish list: Customers can create a product/wish list. In this case, the products will be stored as part of the fulfilment of our contractual obligations until the account is deleted, unless the product list entries are removed by the customer or we expressly inform the customer of different storage periods; Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- Economic analysis and market research: For business reasons and in order to be able to identify market trends, wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., whereby contractual partners, interested parties, customers, visitors and users of our online offer may fall into the group of data subjects. The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). If available, we may take into account the profiles of registered users together with their information, e.g. on services used. The analyses are for our sole purpose and are not disclosed externally, unless they are anonymous analyses with summarized, i.e. anonymised values. Furthermore, we take into account the privacy of the users and process the data for analysis purposes as pseudonymously as possible and, if possible, anonymously (e.g. as aggregated data); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Online shop, order forms, e-commerce and delivery: We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and related services, as well as to pay for them and deliver them. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution for our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such in the context of the ordering or comparable purchase process and includes the information required for delivery, provision and invoicing, as well as contact information in order to be able to consult with us if necessary; Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Use of online platforms for quotation and sales purposes
We offer our services on online platforms operated by other service providers. In this context, in addition to our data protection information, the data protection information of the respective platforms applies. This applies in particular with regard to the execution of the payment process and the procedures used on the platforms for reach measurement and interest-based marketing.
- Types of data processed: Inventory data (e.g. names, addresses); Payment data (e.g. bank details, invoices, payment history); Contact details (e.g., email, phone numbers); Contract data (e.g. subject matter of the contract, term, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta-, communication and procedural data (e.g. . IP addresses, times, identification numbers, consent status).
- Data subjects: Customers.
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations. Marketing.
- Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing processes, procedures and services:
- WeAppU – Shop: Hosting and software for the creation, provision and operation of websites and online stores; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Service provider: Lightspeed Commerce Inc., 700 Saint-Antoine St. E., Suite 300 Montréal (Québec) H2Y 1A6, Canada; Website: https://www.weappu.net/. Privacy Policy: https://www.lightspeedhq.com/legal/privacy-policy/.
Payment
In the context of contractual and other legal relationships, on the basis of legal obligations or otherwise on the basis of our legitimate interests, we offer the data subjects efficient and secure payment options and use other service providers in addition to banks and credit institutions (collectively “payment service providers”).
The data processed by the payment service providers includes inventory data, such as name and address, bank data such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient-related information. The information is required to carry out the transactions. However, the data entered will only be processed by and stored by the payment service providers. This means that we do not receive any account or credit card-related information, but only information confirming or negative information about the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transfer is to check identity and creditworthiness. For this purpose, we refer to the terms and conditions and the data protection information of the payment service providers.
The terms and conditions and data protection notices of the respective payment service providers, which can be accessed within the respective websites or transaction applications, apply to the payment transactions. We also refer to them for the purpose of further information and assertion of rights of revocation, information and other data subjects.
- Types of data processed: Inventory data (e.g. names, addresses); Payment data (e.g. bank details, invoices, payment history); Contract data (e.g. subject matter of the contract, term, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta-, communication and procedural data (e.g. . IP addresses, times, identification numbers, consent status).
- Data subjects: Customers. Interested parties.
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations.
- Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing processes, procedures and services:
- PayPal: Payment services (technical connection of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.paypal.com/de. Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
- Stripe: Payment services (technical connection of online payment methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://stripe.com; Privacy Policy: https://stripe.com/de/privacy. Basis for third-country transfer: EU-US Data Privacy Framework (DPF).
Provision of the online offer and web hosting
We process users’ data in order 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 device.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times); Meta-, communication and procedural data (e.g. . IP addresses, times, identification numbers, consent status).
- 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.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- 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 can include the address and name of the websites and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the load on the servers and their stability; Legal basis: Legitimate interests (Art. 6 para. 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 whose further retention is necessary for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified.
Registration, Login and User Account
Users can create a user account. As part of the registration process, users will be provided with the required mandatory information and processed for the purpose of providing the user account on the basis of contractual fulfilment of obligations. The processed data includes, in particular, login information (username, password and an e-mail address).
As part of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorized use. As a matter of principle, this data will not be passed on to third parties, unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users may be informed by e-mail about processes relevant to their user account, such as technical changes.
- Types of data processed: Inventory data (e.g. names, addresses); Contact details (e.g., email, phone numbers); Content data (e.g. entries in online forms); Meta-, communication and procedural data (e.g. . IP addresses, times, identification numbers, consent status).
- Data subjects: Users (e.g. . website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; Security measures; Managing and responding to requests. Provision of our online offer and user-friendliness.
- Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Registration with real names: Due to the nature of our community, we ask users to use our offer only using real names. This means that the use of pseudonyms is not permitted; Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- Users’ profiles are not public: Users’ profiles are not publicly visible and inaccessible.
- Deletion of data after termination: If users have terminated their user account, their data with regard to the user account will be deleted, subject to a legal permission, obligation or consent of the users; Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- No obligation to retain data: It is the responsibility of the users to back up their data in the event of termination before the end of the contract. We are entitled to irretrievably delete all data of the user stored during the term of the contract; Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Contact and Enquiry Management
When contacting us (e.g. by post, contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the enquiring persons will be processed insofar as this is necessary to answer the contact enquiries and any requested measures.
- Types of data processed: Contact details (e.g., email, phone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta-, communication and procedural data (e.g. . IP addresses, times, identification numbers, consent status).
- Data subjects: Communication.
- Purposes of processing: Contact requests and communication; Managing and responding to requests; Feedback (e.g. collecting feedback via online form). Provision of our online offer and user-friendliness.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing processes, procedures and services:
- Contact: If users contact us via our contact form, e-mail or other communication channels, we process the data provided to us in this context to process the request communicated; Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Communication via Messenger
We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, encryption, the use of the metadata of the communication and your objection options.
You can also contact us by alternative means, e.g. by phone or e-mail. Please use the contact options provided to you or the contact options provided within our online offer.
In the case of end-to-end encryption of content (i.e., the content of your message and attachments), please note that the communication content (i.e., the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use an up-to-date version of Messenger with encryption enabled to ensure that message content is encrypted.
However, we would also like to point out to our communication partners that although the providers of the messengers do not view the content, they can find out that and when communication partners communicate with us and that technical information about the device used by the communication partners and, depending on the settings of their device, location information (so-called metadata) is processed.
Notes on legal bases: If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. In addition, if we do not ask for consent and you contact us on your own initiative, for example, we use Messenger as a contractual measure in relation to our contractual partners as well as in the context of the initiation of a contract and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and fulfilment of the needs of our communication partners in communication via Messenger. Furthermore, we would like to point out that we will not transmit the contact details provided to us to the messengers for the first time without your consent.
Revocation, objection and deletion: You can revoke your consent at any time and object to communication with us via Messenger at any time. In the case of communication via messenger, we delete the messages in accordance with our general deletion guidelines (e.g., as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise, as soon as we can assume that we have answered any information from the communication partners, if no reference to a previous conversation is to be expected and the deletion is not precluded by any statutory retention obligations.
Reservation of reference to other means of communication: Finally, we would like to point out that for reasons of your security, we reserve the right not to answer inquiries via Messenger. This is the case, for example, if internal contractual matters require special secrecy or a response via messenger does not meet the formal requirements. In such cases, we refer you to more adequate communication channels.
- Types of data processed: Contact details (e.g., email, phone numbers); Usage data (e.g. websites visited, interest in content, access times); Meta-, communication and procedural data (e.g. . IP addresses, times, identification numbers, consent status).
- Data subjects: Communication.
- Purposes of processing: Contact requests and communication; Direct marketing (e.g. by e-mail or post).
- Legal bases: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Facebook Messenger: Facebook Messenger with end-to-end encryption (Facebook Messenger end-to-end encryption requires activation, unless it is enabled by default); Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Data Processing Agreement: https://www.facebook.com/legal/terms/dataprocessing. Basis for third-country transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
- WhatsApp: WhatsApp Messenger with end-to-end encryption; Service provider: WhatsApp Ireland Limited, 4 Grand Canal Quay, Dublin 2, D02 KH28, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.whatsapp.com/; Privacy Policy: https://www.whatsapp.com/legal. Basis for third-country transfer: EU-US Data Privacy Framework (DPF).
Newsletters and electronic notifications
We send newsletters, e-mails and other electronic notifications (hereinafter referred to as “newsletters”) only with the consent of the recipients or legal permission. If its contents are specifically described in the context of a registration for the newsletter, they are decisive for the consent of the users. In addition, our newsletters contain information about our services and us.
To subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name for the purpose of personal address in the newsletter, or other information if this is necessary for the purposes of the newsletter.
Double opt-in procedure: Registration for our newsletter is generally carried out in a so-called double opt-in procedure. This means that after registering, you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can log in with someone else’s e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the login and confirmation time as well as the IP address. Changes to your data stored by the shipping service provider will also be logged.
Deletion and restriction of processing: We may retain the unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe contradictions, we reserve the right to store the e-mail address in a blacklist (so-called “blocklist”) for this purpose alone.
The registration process is recorded on the basis of our legitimate interests for the purpose of proving that it is running properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure mailing system.
Contents:
Information about us, our services, promotions and offers.
- Types of data processed: Inventory data (e.g. names, addresses); Contact details (e.g., email, phone numbers); Meta, communication and procedural data (e.g. IP addresses, time, identification numbers, consent status); Usage Data (e.g. websites visited, interest in content, access times).
- Data subjects: Communication.
- Purposes of processing: Direct marketing (e.g. by e-mail or post).
- Legal bases: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Opt-out: You can unsubscribe from receiving our newsletter at any time, i.e. . h. Withdraw your consent or object to further receipt. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably e-mail.
Further information on processing processes, procedures and services:
- Measurement of open and click-through rates: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server or, if we use a shipping service provider, from its server when the newsletter is opened. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of access, are first collected.
This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behaviour on the basis of their access locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. The evaluations serve us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
The measurement of the opening rates and the click rates as well as the storage of the measurement results in the profiles of the users as well as their further processing are carried out on the basis of the consent of the users.
Unfortunately, it is not possible to revoke the performance measurement separately, in which case the entire newsletter subscription must be cancelled or objected to. In this case, the stored profile information will be deleted; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Advertising communication via e-mail, post, fax or telephone
We process personal data for the purposes of advertising communication, which can be carried out via various channels, such as e-mail, telephone, post or fax, in accordance with the legal requirements.
Recipients have the right to revoke their consent at any time or to object to advertising communications at any time.
After revocation or objection, we store the data required to prove the previous authorisation for contacting or sending you data for up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. On the basis of the legitimate interest in permanently observing the revocation or objection of the users, we also store the data necessary to avoid renewed contact (e.g. e-mail address, telephone number, name, depending on the communication channel).
- Types of data processed: Inventory data (e.g. names, addresses); Contact details (e.g. e-mail, telephone numbers).
- Data subjects: Communication.
- Purposes of processing: Direct marketing (e.g. by e-mail or post).
- Legal bases: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Web analysis, monitoring and optimization
Web analysis (also referred to as “reach measurement”) serves to evaluate the flow of visitors to our online offer 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 identify, for example, at what time our online offer or its functions or content are used most frequently or invite reuse. We can also understand which areas need to be optimized.
In addition to web analysis, we may also use test procedures, e.g. to test and optimize different versions of our online offer or its components.
Unless otherwise stated below, profiles, i.e. data combined into 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 times of use. If users have consented to the collection of their location data vis-à-vis us or 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 process (i.e., pseudonymization by shortening the IP address) to protect users. In general, in the context of web analysis, A/B testing and optimization, no clear data of the users (such as e-mail addresses or names) is stored, but pseudonyms. This means that we as well as the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times); Meta-, communication and procedural data (e.g. . IP addresses, times, identification numbers, consent status).
- 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).
- Safety Measures: IP masking (pseudonymization of the IP address).
Presence in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the area of the European Union. This can result in risks for users, for example, because it could make it more difficult to enforce users’ rights.
Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on user behavior and the resulting interests of users. The user profiles can in turn be used, for example, to place advertisements inside and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the user’s usage behaviour and interests are stored. Furthermore, data may also be stored in the user profiles regardless of the devices used by the users (in particular if the users are members of the respective platforms and are logged in to them).
For a detailed description of the respective forms of processing and the options for objection (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, you can contact us.
- Types of data processed: Contact details (e.g., email, phone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta-, communication and procedural data (e.g. . IP addresses, times, identification numbers, consent status).
- Data subjects: Users (e.g. . website visitors, users of online services).
- Purposes of processing: Contact requests and communication; Feedback (e.g. collecting feedback via online form). Marketing.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Instagram: Social network; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com. Privacy Policy: https://instagram.com/about/legal/privacy.
- Facebook pages: profiles within the Facebook social network; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Basis for third-country transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum); Further information: Together with Meta Platforms Ireland Limited, we are responsible for the collection (but not the further processing) of data of visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content users view or interact with, or the actions they take (see “Things You and Others Do and Provide” in Facebook’s Data Policy: https://www.facebook.com/policy), as well as information about the devices users use (e.g., IP addresses, operating system, browser type, language preferences, cookie data; see “Device Information” in Facebook Data Policy: https://www.facebook.com/policy). As explained in Facebook’s Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services called “Page Insights” to Page operators to provide them with insights into how people interact with their Pages and with the content associated with them. We have entered into a special agreement with Facebook (“Page Insights Information”, https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to comply with the rights of data subjects (i.e. users can e.g. information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “About Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data). Joint responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular with regard to the transmission of the data to the parent company Meta Platforms, Inc. in the USA.
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”). This 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 users, since without the IP address they would not be able to send the content to their browser. The IP address is therefore required for the display of these contents or functions. We make every effort to only use content whose respective providers use the IP address only for the delivery of the content. Third-party vendors may also use pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and the operating system, referring websites, the time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times); Meta-, communication and procedural data (e.g. . IP addresses, times, identification numbers, consent status).
- Data subjects: Users (e.g. . website visitors, users of online services).
- Purposes of processing: Provision of our online offer and user-friendliness.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Google Fonts (obtained from Google Server): Procurement of fonts (and symbols) for the purpose of a technically safe, maintenance-free and efficient use of fonts and symbols with regard to topicality and loading times, their uniform presentation and consideration of possible licensing restrictions. The provider of the fonts is informed of the user’s IP address so that the fonts can be made available in the user’s browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) are transmitted that are necessary for the provision of the fonts depending on the devices used and the technical environment. This data may be processed on a server of the font provider in the USA – When visiting our online offer, the users’ browsers send their browsers HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving the fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) of Google Fonts and then the fonts specified in the CCS. These HTTP requests include (1) the IP address used by the user to access the Internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user-agent that describes the browser and operating system versions of the website visitors, and the referral URL (i.e., the web page on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and they are not analyzed. The Google Fonts Web API logs details of the HTTP requests (requested URL, user-agent, and referral URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user-agent has to customize the font that is generated for the respective browser type. The user-agent is logged primarily for debugging and is used to generate aggregated usage statistics that are used to measure the popularity of font families. These aggregated usage statistics are published on the Google Fonts Analytics page. Finally, the referral URL is logged so that the data can be used for production maintenance and an aggregated report on the top integrations can be generated based on the number of font requests. Google says it does not use any of the information collected by Google Fonts to profile end users or serve targeted ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfer: EU-US Data Privacy Framework (DPF). Further information: https://developers.google.com/fonts/faq/privacy?hl=de.
Definitions
This section provides an overview of the terminology used in this Privacy Policy. Insofar as the terms are defined by law, their legal definitions shall apply. The following explanations, on the other hand, are primarily intended to serve understanding.
- Conversion measurement: Conversion measurement (also known as “visit action evaluation”) is a method 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 are carried out and then retrieved again on the target website. For example, it allows us to understand 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. a 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 “user-related information profiles”, or “profiles” for short, includes any form of automated processing of personal data consisting of the use of such personal data in order to obtain certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information relating to demographics, behaviour and interests, such as interaction with websites and their content, etc.) Analyze, evaluate, or predict them (e.g., interests in certain content or products, click behavior on a web page, or location). Cookies and web beacons are often used for profiling purposes.
- Range 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 content of websites. With the help of the reach analysis, operators of online services can identify, for example, at what time users visit their websites and what content they are interested in. This allows them to better adapt the content of the websites to the needs of their visitors, for example. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
- Person in charge: “Controller” means 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 far-reaching and encompasses practically any handling of data, be it collection, evaluation, storage, transmission or deletion.