Privacy policy

Introduction

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

The terms used are not gender-specific.

Status: July 3, 2020

Table of contents

Responsible

WiederHolz (not yet officially registered)
Duburger Str. 59
24939 Flensburg

Authorized representatives: ASM Mominul Hasan

E-Mail-Address: contact@wiederholz.org

Imprint: www.wiederholz.org

Overview of the processing operations

The following table summarises the types of data processed and the purposes of their processing, and refers to the data subjects.

Types of data processed
  • Inventory data (e.g. names, addresses).
  • Content data (e.g. text entries, photographs, videos).
  • Contact data (e.g. e-mail, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
Categories of data subjects
  • Interested parties.
  • Communication partners.
  • Users (e.g. website visitors, users of online services).
  • Lottery and competition participants.
Purposes of processing
  • Visit action evaluation.
  • Direct marketing (e.g. by e-mail or post).
  • Conducting prize draws and competitions.
  • Feedback (e.g. collecting feedback via online form).
  • Interest-based and behaviour-based marketing.
  • Contact requests and communication.
  • Profiling (creation of user profiles).
  • Remarketing.
  • Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures.
  • Tracking (e.g. interest/behavioural profiling, use of cookies).
  • Contractual performance and service.
  • Management and response to inquiries.

Applicable legal basis

In the following, we provide the legal basis of the basic data protection regulation (DSGVO), on the basis of which we process personal data. Please note that in addition to the regulations of the DSGVO, national data protection regulations may apply in your or our country of residence and domicile. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 para. 1 sentence 1 letter a DSGVO) – The data subject has given his or her consent to the processing of personal data relating to him or her for one or more specific purposes.
  • Fulfilment of a contract and pre-contractual requests (Art. 6 para. 1 sentence 1 letter b. FADP) – Processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the request of the data subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. FADP) – The processing is necessary to safeguard the legitimate interests of the controller or of a third party, unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data outweigh those of the controller.
National data protection regulations in Germany:

In addition to the data protection regulations of the basic data protection regulation, national regulations on data protection apply in Germany. These include in particular the law on protection against misuse of personal data in data processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to deletion, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision making in individual cases including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

Registration, login and user account

Users can create a user account. Within the scope of registration, users are provided with the required mandatory data and processed for the purpose of providing the user account on the basis of contractual obligation fulfilment. The processed data includes in particular the login information (name, password and an e-mail address). The data entered during registration is used for the purpose of using the user account and its purpose.

Users can be informed by e-mail about processes relevant to their user account, such as technical changes. If users have cancelled their user account, their data with regard to the user account will be deleted, subject to a legal obligation to keep records. It is the responsibility of users to save their data before the end of the contract if they have terminated their user account. We are entitled to irretrievably delete all user data stored during the contract period.

Within the scope 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 user in protection against misuse and other unauthorized use. As a matter of principle, this data is not passed on to third parties, unless it is necessary to pursue our claims or there is a legal obligation to do so.

Online forum: Participation in the forum requires a registration, in which, subject to other details in the registration form, you must provide a name or your name, a password and the e-mail address to which the access data will be sent. For security reasons, the password should be state-of-the-art, i.e. complicated (users will be advised of this during registration if necessary) and not used elsewhere. Posts in the forum are visible to the public, unless their visibility is limited to certain members or groups of members. The contributions of the authors are stored with their names, if registered or indicated, the time and the content of the entry. When registering and writing entries, the IP addresses of users are also stored, in case the entries contain illegal content and the IP addresses could be used for legal prosecution. The responsible person reserves the right to delete registrations and entries on the basis of proper consideration.

  • Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Contractual services and service, security measures, administration and answering of inquiries.
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Contact

When contacting us (e.g. via contact form, e-mail, telephone or via social media), the data of the inquiring persons will be processed to the extent necessary to answer the contact inquiries and any requested measures.

The answering of contact inquiries within the scope of contractual or pre-contractual relations is carried out in order to fulfil our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of the legitimate interest in answering the inquiries.

  • Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: communication partners.
  • Purposes of processing: contact requests and communication.
  • Legal basis: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Sweepstakes and competitions

We process personal data of participants in competitions and contests only in compliance with the relevant data protection regulations, insofar as the processing is contractually required for the provision, implementation and handling of the competition, the participants have consented to the processing or the processing serves our legitimate interests (e.g. in the security of the competition or the protection of our interests from misuse through the possible recording of IP addresses when submitting competition entries).

If contributions of the participants are published in the context of the competition (e.g. in the context of a vote or presentation of the competition contributions or the winners or the reporting on the competition), we point out that the names of the participants can also be published in this context. The participants can object to this at any time.

If the competition takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as “online platform”), the terms of use and data protection regulations of the respective platforms shall also apply. In these cases, we would like to point out that we are responsible for the information provided by the participants in the course of the competition and that enquiries regarding the competition should be addressed to us.

The participants’ data will be deleted as soon as the competition or contest has ended and the data is no longer required to inform the winners or because further inquiries regarding the competition can be expected. In principle, the participants’ data will be deleted at the latest 6 months after the end of the competition. Winners’ data may be retained for longer, e.g. in order to be able to answer questions about the prizes or to fulfil the prize services; in this case the retention period depends on the type of prize and is up to three years in the case of items or services, for example, in order to be able to process warranty claims. Furthermore, the participants’ data may be stored for longer, e.g. in the form of reports on the competition in online and offline media.

If data has been collected for other purposes as part of the competition, its processing and the duration of storage are governed by the data protection information for this use (e.g. in the case of registration for the newsletter as part of a competition).

  • Processed data types: inventory data (e.g. names, addresses), content data (e.g. text entries, photographs, videos).
  • Data subjects: Competition and contest participants.
  • Purposes of processing: organisation of competitions and contests.
  • Legal basis: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO).

Surveys and questionnaires

The surveys and questionnaires we conduct (hereinafter referred to as “surveys”) are evaluated anonymously. Personal data will only be processed to the extent necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address to display the survey in the user’s browser or to enable a resumption of the survey by means of a temporary cookie (session cookie)) or users have consented to this.

Information on legal basis: If we ask the participants for their consent to the processing of their data, this is the legal basis for the processing, otherwise the processing of the participants’ data is based on our legitimate interest in conducting an objective survey.

  • Data types processed: Contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Communication partners, users (e.g. website visitors, users of online services).
  • Purposes of processing: contact requests and communication, direct marketing (e.g. by e-mail or postal mail), tracking (e.g. interest/behavioural profiling, use of cookies), feedback (e.g. collection of feedback via online form)
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Services used and service providers:

Web analysis and optimization

Web analysis (also known as “reach measurement”) is used to evaluate the streams of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the range analysis we can, for example, identify at what time our online offer or its functions or contents are most frequently used or invite reuse. We can also understand which areas require optimization.

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

For these purposes, so-called user profiles can be created and stored in a file (so-called “cookie”) or similar procedures with the same purpose can be used. This information may include, for example, content viewed, web pages visited and elements used on those pages, and technical details such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this data may also be processed, depending on the provider.

The IP addresses of users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect the users. In general, in the context of web analysis, A/B testing and optimization, no clear user data (such as e-mail addresses or names) are 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.

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

  • Processed types of data: Usage data (e.g. websites visited, interest in content, access times).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of recurring visitors), tracking (e.g. interest/behavioural profiling, use of cookies), visitor action evaluation, profiling (creation of user profiles), interest-based and behaviour-based marketing.
  • Security measures: IP-Masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Services used and service providers:

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.

Please note that user data may be processed outside the European Union. This can result in risks for the users, because the enforcement of the users’ rights could be made more difficult. With regard to US providers that are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we would like to point out that they thereby undertake to comply with the data protection standards of the EU.

Furthermore, user data within social networks is generally processed for market research and advertising purposes. Thus, for example, user profiles can be created on the basis of user behaviour and the resulting interests of the users. The user profiles can in turn be used, for example, to place advertisements within 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 usage behaviour and interests of the users are stored. Furthermore, data may also be stored in the user profiles independently of the devices used by the users (especially 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 possibilities of objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.

Also in the case of requests for information and the assertion of data subject rights, we point out that these can be most effectively asserted with the providers. Only the providers have access to the data of the users in each case and can directly take appropriate measures and provide information. Should you nevertheless require assistance, you can contact us.

  • Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Purposes of processing: contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
  • Legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Used services and service providers:

Amendment and update of the privacy policy

We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes make it necessary for you to take action to cooperate (e.g. to give your consent) or to receive other individual notification.

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

Definitions of terms

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

  • Conversion tracking: “Conversion tracking” refers to a procedure that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user’s devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, we can use this to track whether the ads we have placed on other websites have been successful).
  • IP-Masking: “IP-Masking” is a method in which the last octet, i.e. the last two numbers of an IP address, are deleted so that the IP address can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymising processing methods, especially in online marketing
  • Interest-based and behavioural marketing: We speak of interest-based and/or behavioural marketing when the potential interests of users in ads and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behaviour (e.g. visiting and staying on certain websites, buying behaviour or interaction with other users), which is stored in a so-called profile. As a rule, cookies are used for these purposes.
  • Personal data: “Personal data” shall mean any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable 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 one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Person responsible: The term “person responsible” refers to the natural or legal person, public authority, institution or other body which, alone or jointly with others, decides on the purposes and means of processing personal data.
  • Processing: “processing” shall mean any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually all processing of data, whether it be collection, analysis, storage, communication or deletion.
  • Profiling: “Profiling” is any automated processing of personal data which consists of using personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information about age, gender, location and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behaviour or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, identify at what time visitors visit their website and what content they are interested in. This enables them to better adapt the contents of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for the purpose of range analysis in order to recognise returning visitors and thus obtain more precise analyses of the use of an online offering.
  • Remarketing: We speak of “remarketing” or “retargeting” when, for example, it is noted for advertising purposes which products a user has been interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Tracking: We speak of “tracking” when the behaviour of users can be traced across several online offers. As a rule, behavioural and interest information regarding the online offers used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.

Created with free data protection generator.de by Dr. Thomas Schwenke and translated from German with help of DeepL translator.