Privacy Policy
Privacy Policy
Table of Contents
– Introduction and overview
– Scope of application
– Legal basis
– Contact details of the person responsible
– Storage period
– Rights under the General Data Protection Regulation
– Data transfer to third countries
– Order processing agreement (AVV)
– Cookies
– Web hosting introduction
– Website Building Blocks Introduction
– Web Analytics Introduction
– Social Media Introduction
– Explanation of terms used
Introduction and Overview
We have written this privacy statement (version 05.02.2023-112401595) in order to explain to you, in accordance with the requirements of the General Data Protection Regulation (EU) 2016/679 and applicable national laws, which personal data (data for short) we as the controller – and the processors (e.g. providers) commissioned by us – process, will process in the future and what lawful options you have. The terms used are to be understood as gender-neutral. In short, we inform you comprehensively about the data we process about you.Data protection statements usually sound very technical and use legal terminology. This privacy statement, on the other hand, is intended to describe the most important things to you as simply and transparently as possible. As far as transparency is concerned, technical terms are explained in a reader-friendly way, links to further information are provided and graphics are used. In this way, we inform you in clear and simple language that we only process personal data in the course of our business activities if there is a corresponding legal basis. This is certainly not possible by providing the most concise, unclear and legalistic explanations possible, as is often standard practice on the Internet when it comes to data protection. I hope you find the following explanations interesting and informative and perhaps there is one or two pieces of information you did not know.If you still have questions, we would like to ask you to contact the responsible office mentioned below or in the imprint, to follow the links provided and to look at further information on third-party sites. Our contact details can of course also be found in the imprint.
Scope of Application
This data protection declaration applies to all personal data processed by us in the company and to all personal data processed by companies commissioned by us (order processors). By personal data, we mean information within the meaning of Art. 4 No. 1 DSGVO, such as a person’s name, email address and postal address. The processing of personal data ensures that we can offer and invoice our services and products, whether online or offline. The scope of this privacy policy includes:
– all online presences (websites, online shops) that we operate
– social media sites and email communications
– mobile apps for smartphones and other devices
In short, the data protection declaration applies to all areas in which personal data is processed in the company via the aforementioned channels in a structured manner. If we enter into legal relationships with you outside of these channels, we will inform you separately where applicable.
Legal Basis
In the following privacy statement, we provide you with transparent information on the legal principles and regulations, i.e. the legal bases of the General Data Protection Regulation, which enable us to process personal data.
As far as EU law is concerned, we refer to REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016, which you can of course read online on EUR-Lex, the gateway to EU law, at https://eur-lex.europa.eu/legal-content/DE/ALL/?uri=celex%3A32016R0679.
We only process your data if at least one of the following conditions applies:
1. consent (Article 6(1)(a) DSGVO): You have given us your consent to process data for a specific purpose. An example would be the storage of your entered data of a contact form.
2. contract (Article 6(1)(b) DSGVO): In order to fulfil a contract or pre-contractual obligations with you, we process your data. For example, if we conclude a sales contract with you, we need personal information in advance.
3. legal obligation (Article 6(1)(c) DSGVO): If we are subject to a legal obligation, we process your data. For example, we are legally obliged to keep invoices for accounting purposes. These usually contain personal data.
4. legitimate interests (Article 6(1)(f) DSGVO): In the case of legitimate interests that do not restrict your fundamental rights, we reserve the right to process personal data. For example, we need to process certain data in order to operate our website in a secure and economically efficient manner. This processing is therefore a legitimate interest.
Other conditions, such as the performance of recordings in the public interest and the exercise of official authority as well as the protection of vital interests, do not usually arise for us. If such a legal basis should be relevant, it will be indicated at the appropriate place.
In addition to the EU Regulation, national laws also apply:
– In Austria, this is the Federal Act on the Protection of Individuals with regard to the Processing of Personal Data (Data Protection Act), or DSG for short.
– In Germany, the Federal Data Protection Act, or BDSG for short, applies.
If other regional or national laws apply, we will inform you about them in the following sections.
Contact details of the responsible person
If you have any questions about data protection or the processing of personal data, you will find the contact details of the responsible person or body below:
SLEADE e.U.
Roman Mitterlehner
Puchberg 12, 4324 Rechberg, Austria
Authorised to represent: Roman Mitterlehner
e-mail: For security reasons, please use the contact form.
Phone: +436644150837
Imprint: https://www.sleade.com/imprint/
Storage period
It is our general policy to store personal data only for as long as is absolutely necessary for the provision of our services and products. This means that we delete personal data as soon as the reason for processing the data no longer exists. In some cases, we are legally obliged to store certain data even after the original purpose has ceased to exist, for example for accounting purposes.
Should you wish your data to be deleted or revoke your consent to data processing, the data will be deleted as soon as possible and insofar as there is no obligation to store it.
We will inform you about the specific duration of the respective data processing below, provided we have further information on this.
Rights according to the General Data Protection Regulation
Pursuant to Articles 13, 14 DSGVO, we inform you about the following rights you are entitled to in order to ensure fair and transparent processing of data:
– According to Article 15 DSGVO, you have the right to information about whether we process data about you. If this is the case, you have the right to receive a copy of the data and to know the following information:
o the purpose for which we are processing it;
o the categories, or types, of data being processed;
o who receives this data and, if the data is transferred to third countries, how security can be guaranteed;
o how long the data will be stored;
o the existence of the right to rectification, erasure or restriction of processing and the right to object to processing;
o that you can lodge a complaint with a supervisory authority (links to these authorities can be found below);
o the origin of the data if we have not collected it from you;
o whether profiling is carried out, i.e. whether data is automatically analysed to arrive at a personal profile of you.
– You have a right to rectification of data under Article 16 of the GDPR, which means that we must rectify data if you find errors.
– You have the right to erasure (“right to be forgotten”) under Article 17 of the GDPR, which specifically means that you may request the deletion of your data.
– According to Article 18 of the GDPR, you have the right to restriction of processing, which means that we may only store the data but not use it any further.
– According to Article 20 of the GDPR, you have the right to data portability, which means that we will provide you with your data in a standard format upon request.
– You have a right to object under Article 21 of the GDPR, which entails a change in processing after enforcement.
o If the processing of your data is based on Article 6(1)(e) (public interest, exercise of official authority) or Article 6(1)(f) (legitimate interest), you may object to the processing. We will then check as soon as possible whether we can legally comply with this objection.
o If data is used to carry out direct advertising, you can object to this type of data processing at any time. We may then no longer use your data for direct marketing.
o If data is used for profiling, you can object to this type of data processing at any time. We may no longer use your data for profiling thereafter.
– You may have the right under Article 22 of the GDPR not to be subject to a decision based solely on automated processing (for example profiling).
– You have the right to complain under Article 77 of the GDPR. This means that you can complain to the data protection authority at any time if you believe that the data processing of personal data violates the GDPR.
In short, you have rights – do not hesitate to contact the controller listed above at our office!
If you believe that the processing of your data violates data protection law or your data protection rights have been violated in any other way, you can complain to the supervisory authority. For Austria, this is the data protection authority, whose website can be found at https://www.dsb.gv.at/. In Germany, there is a data protection commissioner for each federal state. For more information, you can contact the Federal Commissioner for Data Protection and Freedom of Information (BfDI). The following local data protection authority is responsible for our company:
Austria Data Protection Authority
Head: Mag. Dr. Andrea Jelinek
Address: Barichgasse 40-42, 1030 Vienna
Telephone number: +43 1 52 152-0
E-mail address: dsb@dsb.gv.at
Website: https://www.dsb.gv.at/
Data transfer to third countries
We only transfer or process data to countries outside the EU (third countries) if you consent to this processing, if this is required by law or contractually necessary and in any case only to the extent that this is generally permitted. Your consent is in most cases the most important reason for us to have data processed in third countries. Processing personal data in third countries such as the US, where many software vendors provide services and have their server locations, may mean that personal data is processed and stored in unexpected ways.
We explicitly point out that according to the opinion of the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. Data processing by US services (such as Google Analytics) may result in data not being processed and stored anonymously. Furthermore, US government authorities may be able to access individual data. In addition, it is possible that collected data may be linked to data from other services of the same provider, provided you have a corresponding user account. Where possible, we try to use server locations within the EU if this is offered.
We will inform you in more detail about data transfer to third countries, where applicable, at the appropriate points in this privacy policy.
Order processing agreement (AVV)
In this section, we would like to explain to you what a processing order is and why it is needed. Because the word “order processing agreement” is quite a mouthful, we will also use the acronym AVV more often here in the text. Like most companies, we do not work alone, but also use the services of other companies or individuals ourselves. Through the involvement of various companies or service providers, it may be that we pass on personal data for processing. These partners then act as processors with whom we conclude a contract, the so-called order processing agreement (AVV). The most important thing for you to know is that the processing of your personal data is carried out exclusively according to our instructions and must be regulated by the GCU.
Who are processors?
As a company and website owner, we are responsible for all the data we process from you. In addition to data controllers, there may also be so-called processors. This includes any company or person who processes personal data on our behalf. More precisely and according to the GDPR definition: any natural or legal person, authority, institution or other body that processes personal data on our behalf is considered a processor. Processors can therefore be service providers such as hosting or cloud providers, payment or newsletter providers or large companies such as Google or Microsoft.
For a better understanding of the terminology, here is an overview of the three roles in the GDPR:
Data subject (you as a customer or interested party) → controller (we as a company and client) → processor (service provider such as a web hoster or cloud provider).
Content of a processing contract
As mentioned above, we have concluded an AVV with our partners who act as processors. This states first and foremost that the processor will process the data to be processed exclusively in accordance with the GDPR. The contract must be concluded in writing, although in this context, the electronic conclusion of the contract is also deemed to be “in writing”. Only on the basis of the contract will the processing of personal data take place. The contract must contain the following:
– Binding us as the controller
– Obligations and rights of the data controller
– Categories of data subjects
– Nature of the personal data
– Nature and purpose of the data processing
– Subject and duration of data processing
– Place of performance of the data processing
Furthermore, the contract contains all obligations of the processor. The most important obligations are:
– to ensure data security measures
– to take possible technical and organisational measures to protect the rights of the data subject
– to keep a data processing register
– cooperate with the data protection supervisory authority at its request
– carry out a risk analysis in relation to the personal data received.
– Sub-processors may only be engaged with the written consent of the data controller.
You can see what such an AVV looks like in concrete terms at https://www.wko.at/service/wirtschaftsrecht-gewerberecht/eu-dsgvo-mustervertrag-auftragsverarbeitung.html, for example. A sample contract is presented here.
Cookies
Cookies Summary
Data subjects: Visitors to the website
Purpose: depends on the cookie. More details can be found below or from the manufacturer of the software that sets the cookie.
Data processed: Depending on the particular cookie used. More details can be found below or from the manufacturer of the software that sets the cookie.
Storage period: depends on the cookie, can vary from hours to years.
Legal basis: Art. 6 para. 1 lit. a DSGVO (consent), Art. 6 para. 1 lit.f DSGVO (legitimate interests).
What are cookies?
Our website uses HTTP cookies to store user-specific data.
In the following, we explain what cookies are and why they are used so that you can better understand the following privacy policy.
Whenever you browse the internet, you use a browser. Popular browsers include Chrome, Safari, Firefox, Internet Explorer and Microsoft Edge. Most websites store small text files in your browser. These files are called cookies.
One thing cannot be denied: Cookies are really useful little helpers. Almost all websites use cookies. More precisely, they are HTTP cookies, as there are also other cookies for other applications. HTTP cookies are small files that are stored on your computer by our website. These cookie files are automatically placed in the cookie folder, effectively the “brain” of your browser. A cookie consists of a name and a value. When defining a cookie, one or more attributes must also be specified.
Cookies store certain user data about you, such as language or personal page settings. When you return to our site, your browser transmits the “user-related” information back to our site. Thanks to cookies, our site knows who you are and offers you the setting you are used to. In some browsers each cookie has its own file, in others, such as Firefox, all cookies are stored in a single file.
The following graphic shows a possible interaction between a web browser such as Chrome and the web server. Here, the web browser requests a website and receives a cookie back from the server, which the browser uses again as soon as another page is requested.
There are both first-party cookies and third-party cookies. First-party cookies are created directly by our site, third-party cookies are created by partner websites (e.g. Google Analytics). Each cookie is to be evaluated individually, as each cookie stores different data. The expiry time of a cookie also varies from a few minutes to a few years. Cookies are not software programmes and do not contain viruses, Trojans or other “pests”. Cookies also cannot access information on your PC.
For example, cookie data may look like this
Name: _ga
Wert: GA1.2.1326744211.152112401595-9
Purpose: to distinguish website visitors
Expiry date: after 2 years
A browser should be able to support these minimum sizes
– At least 4096 bytes per cookie
– At least 50 cookies per domain
– At least 3000 cookies in total
What types of cookies are there?
The question of which cookies we use in particular depends on the services used and is clarified in the following sections of the privacy policy. At this point we would like to briefly discuss the different types of HTTP cookies.
We can distinguish between 4 types of cookies:
Essential cookies
These cookies are necessary to ensure basic functions of the website. For example, these cookies are needed when a user places a product in the shopping basket, then continues surfing on other pages and only later goes to the checkout. These cookies do not delete the shopping cart even if the user closes his browser window.
Purpose cookies
These cookies collect information about user behaviour and whether the user receives any error messages. In addition, these cookies are also used to measure the loading time and the behaviour of the website with different browsers.
Goal-oriented cookies
These cookies provide a better user experience. For example, locations entered, font sizes or form data are saved.
Advertising cookies
These cookies are also called targeting cookies. They are used to provide the user with individually adapted advertising. This can be very practical, but also very annoying.
Usually, when you visit a website for the first time, you are asked which of these types of cookies you would like to allow. And of course, this decision is also stored in a cookie.
If you want to know more about cookies and are not afraid of technical documentation, we recommend https://datatracker.ietf.org/doc/html/rfc6265, the Request for Comments of the Internet Engineering Task Force (IETF) called “HTTP State Management Mechanism”.
Purpose of processing via cookies
The purpose ultimately depends on the cookie in question. More details can be found below or from the manufacturer of the software that sets the cookie.
What data is processed?
Cookies are small helpers for many different tasks. Unfortunately, it is not possible to generalise about what data is stored in cookies, but we will inform you about the data processed or stored in the following privacy policy.
Storage duration of cookies
The storage period depends on the respective cookie and is specified further below. Some cookies are deleted after less than an hour, others can remain stored on a computer for several years.
You can also influence the storage period yourself. You can delete all cookies manually at any time via your browser (see also “Right to object” below). Furthermore, cookies that are based on consent will be deleted at the latest after revocation of your consent, whereby the legality of the storage remains unaffected until then.
Right of objection – how can I delete cookies?
You decide how and whether you want to use cookies. Regardless of which service or website the cookies originate from, you always have the option of deleting, deactivating or only partially permitting cookies. For example, you can block third-party cookies but allow all other cookies.
If you want to find out which cookies have been stored in your browser, if you want to change or delete cookie settings, you can find this in your browser settings:
Chrome: Delete, activate and manage cookies in Chrome.
Safari: Manage cookies and website data with Safari
Firefox: Delete cookies to remove data that websites have placed on your computer
Internet Explorer: Delete and manage cookies
Microsoft Edge: Delete and manage cookies
If you generally do not want cookies, you can set up your browser so that it always informs you when a cookie is to be set. In this way, you can decide for each individual cookie whether you allow the cookie or not. The procedure varies depending on the browser. The best way is to search for the instructions in Google with the search term “Delete Cookies Chrome” or “Deactivate Cookies Chrome” in the case of a Chrome browser.
Legal basis
The so-called “Cookie Guidelines” have been in place since 2009. These state that the storage of cookies requires your consent (Article 6 para. 1 lit. a DSGVO). Within the EU countries, however, there are still very different reactions to these directives. In Austria, however, this directive was implemented in § 96 para. 3 of the Telecommunications Act (TKG). In Germany, the Cookie Directive has not been implemented as national law. Instead, this directive was largely implemented in § 15 para.3 of the Telemedia Act (TMG).
For cookies that are absolutely necessary, even if there is no consent, there are legitimate interests (Article 6 para. 1 lit. f DSGVO), which in most cases are of an economic nature. We want to provide visitors to the website with a pleasant user experience and for this purpose certain cookies are often absolutely necessary.
Where cookies are used that are not strictly necessary, this is only done with your consent. The legal basis in this respect is Art. 6 para. 1 lit. a DSGVO.
In the following sections, you will be informed in more detail about the use of cookies, insofar as the software used uses cookies.
Web hosting introduction
Web hosting summary
Data subjects: visitors to the website
Purpose: professional hosting of the website and safeguarding of its operation
Data processed: IP address, time of website visit, browser used and other data. More details can be found below or with the respective web hosting provider used.
Storage period: depends on the respective provider, but usually 2 weeks Legal basis: Art. 6 para. 1 lit.f DSGVO (Legitimate Interests)
What is web hosting?
When you visit websites nowadays, certain information – including personal data – is automatically created and stored, including on this website. This data should be processed as sparingly as possible and only with justification. By website, by the way, we mean the totality of all web pages on a domain, i.e. everything from the home page (homepage) to the very last sub-page (like this one). By domain, we mean, for example, example.de or sampleexample.com.
If you want to view a website on a computer, tablet or smartphone, you use a programme called a web browser to do so. You probably know some web browsers by name: Google Chrome, Microsoft Edge, Mozilla Firefox and Apple Safari. We call them browsers or web browsers for short.
To display the website, the browser must connect to another computer where the website’s code is stored: the web server. Running a web server is a complicated and time-consuming task, which is why it is usually done by professional providers. These offer web hosting and thus ensure reliable and error-free storage of website data. A whole lot of technical terms, but please stay tuned, it gets better!
When the browser on your computer (desktop, laptop, tablet or smartphone) connects and during data transfer to and from the web server, personal data may be processed. On the one hand, your computer stores data, on the other hand, the web server also has to store data for a while to ensure proper operation.
A picture is worth a thousand words, so the following graphic illustrates the interaction between the browser, the internet and the hosting provider.
Why do we process personal data?
The purposes of data processing are:
1. to professionally host the website and secure its operation
2. to maintain operational and IT security
3. anonymous evaluation of access behaviour to improve our offer and, if necessary, to prosecute or pursue claims.
What data is processed?
Even while you are visiting our website right now, our web server, which is the computer on which this website is stored, usually automatically saves data such as
– the complete internet address (URL) of the website you are visiting
– Browser and browser version (e.g. Chrome 87)
– the operating system used (e.g. Windows 10)
– the address (URL) of the previously visited page (referrer URL) (e.g. https://www.beispielquellsite.de/vondabinichgekommen/)
– the host name and IP address of the device being accessed (e.g. COMPUTERNAME and 194.23.43.121)
– the date and time
– in files, the so-called web server log files
How long is data stored?
As a rule, the above data is stored for a fortnight and then automatically deleted. We do not pass on this data, but we cannot rule out the possibility that this data may be viewed by the authorities in the event of unlawful behaviour.
In short, your visit is logged by our provider (the company that runs our website on special computers (servers)), but we do not pass on your data without your consent!
Legal basis
The lawfulness of the processing of personal data in the context of web hosting results from Art. 6 para. 1 lit. f DSGVO (protection of legitimate interests), because the use of professional hosting with a provider is necessary in order to present the company on the internet in a secure and user-friendly way and to be able to pursue attacks and claims from this if necessary.
Between us and the hosting provider there is usually a contract on commissioned processing in accordance with Art. 28 f. DSGVO, which ensures compliance with data protection and guarantees data security.
World4You privacy policy
We use World4You, a web hosting provider among others, for our website. The service provider is the Austrian company World4You Internet Services GmbH, Hafenstraße 35, 4020 Linz, Austria.
You can find out more about the data processed by using World4You in the data protection declaration at https://www.world4you.com/de/unternehmen/datenschutzerklaerung.html.
World4You order processing agreement (AVV)
We have concluded an order processing agreement (AVV) with World4You (World4You Internet Services GmbH, Hafenstraße 35 , 4020 Linz, Austria) in accordance with Article 28 of the General Data Protection Regulation (DSGVO). What exactly a GCU is and, above all, what must be included in a GCU, you can read in our general section “Order processing agreement (GCU)”.
This contract is required by law because World4You processes personal data on our behalf. It clarifies that World4You may only process data they receive from us according to our instructions and must comply with the GDPR. You can find the link to the order processing agreement (AVV) at
https://www.world4you.com/faq/de/dsgvo/faq.stellt-world4you-eine-vereinbarung-zur-auftragsverarbeitung-zur-verfuegung.html.
Website Building Block Systems Introduction
Website building block system Privacy Policy Summary
Data subjects: Visitors to the website
Purpose: Optimisation of our service performance
Data processed: Data such as technical usage information such as browser activity, clickstream activity, session heatmaps as well as contact details, IP address or your geographical location. More details can be found below in this privacy policy and in the privacy policy of the providers.
Storage period: depends on the provider
Legal basis: Art. 6 para. 1 lit. f DSGVO (Legitimate Interests), Art. 6 para. 1 lit. a DSGVO (Consent).
What are website building systems?
We use a website construction kit system for our website. Modular systems are special forms of a content management system (CMS). With a modular system, website operators can create a website very easily and without programming knowledge. In many cases, web hosts also offer building block systems. By using a modular system, personal data of you may also be collected, stored and processed. In this data protection text, we provide you with general information about data processing by modular systems. You can find more detailed information in the provider’s data protection declarations.
Why do we use website construction kit systems for our website?
The biggest advantage of a modular system is that it is easy to use. We want to offer you a clear, simple and concise website that we can easily operate and maintain ourselves – without external support. A modular system now offers many helpful functions that we can use even without programming knowledge. This enables us to design our web presence according to our wishes and to offer you an informative and pleasant time on our website.
What data is stored by a modular system?
Exactly what data is stored depends, of course, on the website construction kit system used. Each provider processes and collects different data from the website visitor. However, as a rule, technical usage information such as operating system, browser, screen resolution, language and keyboard settings, hosting provider and the date of your website visit are collected. Tracking data (e.g. browser activity, clickstream activity, session heatmaps, etc.) may also be processed. In addition, personal data may also be collected and stored. This is mostly contact data such as email address, telephone number (if you have provided it), IP address and geographical location data. You can find out exactly what data is stored in the provider’s privacy policy.
How long and where is the data stored?
We will inform you about the duration of the data processing below in connection with the website construction kit system used, provided we have further information on this. You will find detailed information about this in the provider’s privacy policy. In general, we only process personal data for as long as is absolutely necessary for the provision of our services and products. It may be that the provider stores data about you according to its own specifications, over which we have no control.
Right of objection
You always have the right to information, correction and deletion of your personal data. If you have any questions, you can also contact the person responsible for the website construction system used at any time. You can find contact details either in our privacy policy or on the website of the relevant provider.
You can delete, deactivate or manage cookies that providers use for their functions in your browser. Depending on which browser you use, this works in different ways. Please note, however, that all functions may then no longer work as usual.
Legal basis
We have a legitimate interest in using a website construction kit in order to optimise our online service and present it to you in an efficient and user-friendly manner. The corresponding legal basis for this is Art. 6 para. 1 lit. f DSGVO (Legitimate Interests). Nevertheless, we only use the construction kit if you have given your consent.
Insofar as the processing of data is not absolutely necessary for the operation of the website, the data will only be processed on the basis of your consent. This applies in particular to tracking activities. The legal basis in this respect is Art. 6 para. 1 lit. a DSGVO.
With this data protection declaration, we have provided you with the most important general information about data processing. If you would like more detailed information, you will find further information – if available – in the following section or in the provider’s privacy policy.
WordPress.com privacy policy
We use WordPress.com, a website construction kit, for our website. The service provider is the American company Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA.
WordPress also processes data from you in the USA, among other places. We would like to point out that according to the opinion of the European Court of Justice, there is currently no adequate level of protection for the transfer of data to the USA. This may entail various risks for the legality and security of data processing.
WordPress uses so-called standard contractual clauses (= Art. 46. para. 2 and 3 DSGVO) as the basis for data processing with recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway, i.e. in particular the USA) or a data transfer there. Standard Contractual Clauses (SCC) are templates provided by the EU Commission and are intended to ensure that your data comply with European data protection standards even if they are transferred to third countries (such as the USA) and stored there. Through these clauses, WordPress undertakes to comply with the European level of data protection when processing your relevant data, even if the data is stored, processed and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding standard contractual clauses here, among other places: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de
The Data Processing Agreements, which correspond to the standard contractual clauses, can be found at https://wordpress.com/support/data-processing-agreements/.
You can find out more about the data processed through the use of WordPress.com in the privacy policy at https://automattic.com/de/privacy/.
WordPress.com order processing agreement (AVV)
We have concluded an order processing agreement (AVV) with WordPress.com within the meaning of Article 28 of the General Data Protection Regulation (GDPR). You can read more about what exactly an AVV is and, in particular, what must be included in an AVV in our general section “Order processing agreement (AVV)”.
This contract is required by law because WordPress.com processes personal data on our behalf. It clarifies that WordPress.com may only process data they receive from us according to our instructions and must comply with the GDPR. You can find the link to the order processing agreement (AVV) at https://wordpress.com/support/data-processing-agreements/.
Web Analytics Introduction
Web Analytics Privacy Policy Summary
Data subjects: Visitors to the website
Purpose: To analyse visitor information in order to optimise the web offer.
Data processed: Access statistics, which include data such as locations of accesses, device data, access duration and time, navigation behaviour, click behaviour and IP addresses. More details can be found in the respective web analytics tool used.
Storage period: depends on the web analytics tool used.
Legal basis: Art. 6 para. 1 lit. a DSGVO (consent), Art. 6 para. 1 lit. f DSGVO (legitimate interests).
What is Web Analytics?
We use software on our website to evaluate the behaviour of website visitors, known as web analytics for short. This involves collecting data that the respective analytic tool provider (also called tracking tool) stores, manages and processes. With the help of the data, analyses of user behaviour on our website are created and made available to us as the website operator. In addition, most tools offer various test options. For example, we can test which offers or contents are best received by our visitors. For this purpose, we show you two different offers for a limited period of time. After the test (so-called A/B test), we know which product or content our website visitors find more interesting. For such test procedures, as for other analytics procedures, user profiles can also be created and the data stored in cookies.
Why do we use web analytics?
We have a clear goal with our website: we want to deliver the best web offer on the market for our industry. In order to achieve this goal, we want to offer the best and most interesting offer on the one hand, and on the other hand we want to make sure that you feel completely comfortable on our website. With the help of web analysis tools, we can take a closer look at the behaviour of our website visitors and then improve our website accordingly for you and for us. For example, we can see how old our visitors are on average, where they come from, when our website is visited the most or which content or products are particularly popular. All this information helps us to optimise the website and thus best adapt it to your needs, interests and wishes.
What data is processed?
Exactly what data is stored depends, of course, on the analysis tools used. But as a rule, for example, which content you view on our website, which buttons or links you click on, when you call up a page, which browser you use, which device (PC, tablet, smartphone, etc.) you use to visit the website or which computer system you use are stored. If you agreed that location data may also be collected, these may also be processed by the web analysis tool provider.
In addition, your IP address is also stored. According to the General Data Protection Regulation (DSGVO), IP addresses are personal data. However, your IP address is usually stored pseudonymised (i.e. in an unrecognisable and shortened form). For the purpose of testing, web analysis and web optimisation, no direct data, such as your name, age, address or e-mail address, is stored as a matter of principle. All this data, if collected, is stored pseudonymously. This means that you cannot be identified as a person.
The following example shows schematically how Google Analytics works as an example of client-based web tracking with Java Script code.
How long the respective data is stored always depends on the provider. Some cookies only store data for a few minutes or until you leave the website again, other cookies can store data for several years.
Duration of data processing
We will inform you about the duration of data processing below, provided we have further information on this. In general, we only process personal data for as long as is strictly necessary to provide our services and products. If, as in the case of accounting for example, it is required by law, this storage period may be exceeded.
Right to object
You also have the right and the possibility to revoke your consent to the use of cookies or third-party providers at any time. This works either via our cookie management tool or via other opt-out functions. For example, you can also prevent data collection through cookies by managing, deactivating or deleting cookies in your browser.
Legal basis
The use of web analytics requires your consent, which we have obtained with our cookie pop-up. According to Art. 6 para. 1 lit. a DSGVO (consent), this consent constitutes the legal basis for the processing of personal data, as may occur during the collection by web analytics tools.
In addition to consent, there is a legitimate interest on our part in analysing the behaviour of website visitors and thus improving our offer technically and economically. With the help of web analytics, we detect website errors, can identify attacks and improve economic efficiency. The legal basis for this is Art. 6 para. 1 lit. f DSGVO (Legitimate Interests). Nevertheless, we only use the tools if you have given your consent.
Since web analytics tools use cookies, we also recommend that you read our general data protection declaration on cookies. To find out exactly which of your data is stored and processed, you should read the data protection statements of the respective tools.
Information on specific web analytics tools, where available, can be found in the following sections.
Social Media Introduction
Social Media Privacy Policy Summary
Data subjects: Visitors to the website
Purpose: Presentation and optimisation of our service performance, contact with visitors, interested parties, etc., advertising.
Data processed: Data such as telephone numbers, email addresses, contact details, user behaviour data, information about your device and your IP address.
More details can be found with the respective social media tool used.
Storage period: depending on the social media platforms used.
Legal basis: Art. 6 para. 1 lit. a DSGVO (consent), Art. 6 para. 1 lit. f DSGVO (legitimate interests).
What is social media?
In addition to our website, we are also active on various social media platforms. In this context, user data may be processed so that we can target users who are interested in us via the social networks. In addition, elements of a social media platform may also be embedded directly in our website. This is the case, for example, when you click on a so-called social button on our website and are directly redirected to our social media presence. So-called social media are websites and apps through which registered members can produce content, share content openly or in specific groups and network with other members.
Why do we use social media?
For years, social media platforms have been the place where people communicate and connect online. Our social media presences allow us to bring our products and services closer to prospective customers. The social media elements integrated on our website help you to be able to switch to our social media content quickly and without complications.
The data that is stored and processed through your use of a social media channel is primarily for the purpose of conducting web analyses. The aim of these analyses is to be able to develop more precise and personalised marketing and advertising strategies. Depending on your behaviour on a social media platform, appropriate conclusions can be drawn about your interests with the help of the evaluated data and so-called user profiles can be created. This also enables the platforms to present you with customised advertisements. Cookies are usually set in your browser for this purpose, which store data on your usage behaviour.
We generally assume that we remain responsible under data protection law, even if we use services of a social media platform. However, the European Court of Justice has ruled that in certain cases the operator of the social media platform may be jointly responsible with us within the meaning of Art. 26 DSGVO. Insofar as this is the case, we point this out separately and work on the basis of an agreement to this effect. The essence of the agreement is then reproduced below for the platform concerned.
Please note that when using the social media platforms or our built-in elements, data may also be processed from you outside the European Union, as many social media channels, for example Facebook or Twitter, are American companies. This may make it less easy for you to claim or enforce your rights in relation to your personal data.
What data is processed?
Exactly what data is stored and processed depends on the provider of the social media platform. But usually it is data such as phone numbers, email addresses, data you enter in a contact form, user data such as which buttons you click, who you like or follow, when you visited which pages, information about your device and your IP address. Most of this data is stored in cookies. Especially if you yourself have a profile on the social media channel you are visiting and are logged in, data can be linked to your profile.
All data collected via a social media platform is also stored on the servers of the providers. This means that only the providers have access to the data and can give you the appropriate information or make changes.
If you want to know exactly what data is stored and processed by the social media providers and how you can object to the data processing, you should carefully read the respective privacy policy of the company. We also recommend that you contact the provider directly if you have any questions about data storage and data processing or if you wish to assert corresponding rights.
Duration of data processing
We will inform you about the duration of data processing below, provided we have further information on this. For example, the social media platform Facebook stores data until it is no longer needed for its own purpose. However, customer data that is matched with our own user data is deleted within two days. In general, we only process personal data for as long as is absolutely necessary for the provision of our services and products. If it is required by law, for example in the case of accounting, this storage period may be exceeded.
Right to object
You also have the right and the option to revoke your consent to the use of cookies or third-party services such as embedded social media elements at any time. This works either via our cookie management tool or via other opt-out functions. For example, you can also prevent data collection through cookies by managing, deactivating or deleting cookies in your browser.
Since cookies may be used with social media tools, we also recommend that you read our general data protection declaration on cookies. To find out exactly what data is stored and processed by you, you should read the privacy statements of the respective tools.
Legal basis
If you have consented that data from you can be processed and stored by integrated social media elements, this consent is considered the legal basis of the data processing (Art. 6 para. 1 lit. a DSGVO). In principle, if consent is given, your data will also be stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f DSGVO) in fast and good communication with you or other customers and business partners. Nevertheless, we only use the tools if you have given your consent. Most social media platforms also set cookies in your browser to store data. That is why we recommend that you read our privacy text on cookies carefully and look at the privacy policy or cookie policy of the respective service provider.
You will find information on specific social media platforms – if available – in the following sections.
Explanation of terms used
We always try to write our data protection declaration as clearly and understandably as possible. However, this is not always easy, especially when it comes to technical and legal topics. It often makes sense to use legal terms (such as personal data) or certain technical terms (such as cookies, IP address). However, we do not want to use these without explanation. Below you will now find an alphabetical list of important terms used that we may not have sufficiently addressed in the previous privacy statement. If these terms have been taken from the GDPR and are definitions, we will also quote the GDPR texts here and add our own explanations where necessary.
Processor
Definition according to Article 4 of the GDPR
For the purposes of this Regulation, the term:
“processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
Explanation: As a company and website owner, we are responsible for all data we process from you. In addition to data controllers, there may also be so-called processors. This includes any company or person that processes personal data on our behalf. Processors can therefore be, in addition to service providers such as tax advisors, hosting or cloud providers, payment or newsletter providers or large companies such as Google or Microsoft.
Consent
Definition according to Article 4 of the GDPR
For the purposes of this Regulation, the term:
“consent” of the data subject means any freely given specific, informed and unambiguous indication of his or her wishes in the form of a statement or other unambiguous affirmative act by which the data subject signifies his or her agreement to personal data relating to him or her being processed;
Explanation: As a rule, such consent is given on websites via a cookie consent tool. You are probably familiar with this. Whenever you visit a website for the first time, you are usually asked via a banner whether you agree or consent to the data processing. In most cases, you can also make individual settings and thus decide for yourself which data processing you allow and which you do not. If you do not consent, no personal data of yours may be processed. In principle, consent can of course also be given in writing, i.e. not via a tool.
Personal data
Definition according to Article 4 of the GDPR
For the purposes of this Regulation, the term:
“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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
Explanation: Personal data is therefore all data that can identify you as a person. This is usually data such as:
– Name
– address
– email address
– Postal address
– telephone number
– Date of birth
– Identification numbers such as national insurance number, tax identification number, identity card number or matriculation number
– Bank data such as account number, credit information, account balances, etc.
According to the European Court of Justice (ECJ), your IP address is also personal data. IT experts can use your IP address to determine at least the approximate location of your device and subsequently you as the connection owner. Therefore, the storage of an IP address also requires a legal basis within the meaning of the GDPR. There are also so-called “special categories” of personal data that also require special protection. These include:
– racial and ethnic origin
– political opinions
– religious or ideological convictions
– trade union membership
– genetic data, such as data taken from blood or saliva samples
– biometric data (which is information on mental, physical or behavioural characteristics that can identify an individual).
health data
– data on sexual orientation or sexual life
Profiling
Definition under Article 4 of the GDPR.
For the purposes of this Regulation, the term:
“profiling” means any automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or change of location;
Explanation: Profiling involves gathering various pieces of information about an individual in order to learn more about that individual. In the web sector, profiling is often used for advertising purposes or for credit checks. Web or advertising analysis programmes, for example, collect data about your behaviour and interests on a website. This results in a specific user profile which can be used to target advertising to a specific group.
Responsible
Definition according to Article 4 of the GDPR
For the purposes of this Regulation, the term:
“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; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its designation may be provided for under Union or Member State law;
Explanation: In our case, we are responsible for the processing of your personal data and therefore the “controller”. If we pass on collected data to other service providers for processing, they are “processors”. This requires the signing of a “contract for processing (GCP)”.
Processing
Definition according to Article 4 of the GDPR.
For the purposes of this Regulation, the term:
“processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organisation, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
Note: When we talk about processing in our privacy policy, we mean any kind of data processing. This includes, as mentioned above in the original GDPR statement, not only the collection but also the storage and processing of data.
All texts are protected by copyright.
Source: Created with the data protection generator from AdSimple