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Privacy Policy

Table of Contents

Preamble

Lytt GmbH, based in Münster, Germany (hereinafter referred to as "Lytt" or "we") offers a cloud-based information and communication system that enables companies to manage internal communications with their employees, including the handling of complaints, feedback and other reports, and to include additional consultants in communications (hereinafter referred to as "Services").

User is the company, e.g. an employer, which has concluded an agreement with Lytt (hereinafter referred to as "Client"), or the persons employed or otherwise engaged by the Client, e.g. employees, freelancers, case managers (hereinafter referred to as "Employees"), or visitors of our online presences (hereinafter referred to as "Client", "Employees" and "Visitors" collectively as "Users" or "You").

In the following, we will inform you which personal data we collect from you when you use our services or visit or use our online presences, such as our websites and social media profiles. Personal data are individual details about personal or factual circumstances of a specific or identifiable natural person (hereinafter referred to as "data").

1. Responsible party for data processing

We process personal data of employees of our Clients as contract processors within the meaning of Art. 4 No. 8 GDPR, i.e. on behalf of our Clients within the meaning of Art. 28 GDPR. For this data processing, the Client is the responsible body within the meaning of Art. 4 No. 7 GDPR, which makes the use of our services available or permitted to its employees. Further information on order data processing can be found in our information sheet for registrants.

For personal data which we receive from our Clients or from employees whose employer is not a Client of ours, or for personal data which we receive and process via our online presences, we, Lytt, are responsible within the meaning of Art. 4 No. 7 GDPR:

Lytt GmbH
Represented by the managing directors

Marvin Homburg and Lara von Petersdorff-Campen

Alter Fischmarkt 12
48143 Münster
Germany

Phone: +49 251 1410 3560
Mail: hey@lytt.co

You can reach our data protection officer at: legal@lytt.co

2. Categories of data processed

We process personal data in accordance with the applicable laws, in particular the General Data Protection Regulation (DSGVO) and the Federal Data Protection Act (BDSG). We process personal data of the following data categories:

3. Data processing on contact

When contacting us (e.g. via contact form, e-mail, telephone or via social media), we will process data of you, such as name, e-mail address, telephone number, for the processing of the contact request and their settlement pursuant to Art. 6 Para 1 lit. b)) GDPR. (within the framework of contractual/pre-contractual relationships), Art. 6 Para 1 lit. f)) GDPR (other requests). The data of the user can be stored in a Client Relationship Management System ("CRM System") or a comParable system.

We will delete this data if it is no longer required. We review the necessity every two years; furthermore, the statutory archiving obligations apply.

4. Data processing for the provision of our services

4.1 General contract execution

We process the data of our Clients on the basis of Art. 6 Para 1 lit. b) GDPR in order to provide our contractual or pre-contractual services to the Client. The data processed, the type, scope and purpose and the necessity of their processing are determined by the underlying contractual relationship.

The processed data include contact and inventory data of our Clients (e.g. name, address, e-mail and telephone number), as well as contract data (e.g. services used, contract contents, contractual communication, names of contact persons) and payment data (e.g. bank details, payment history).

We do not process any special categories of personal data, unless these are components of a commissioned or contractual processing.

We process data which are necessary for the justification and fulfilment of the contractual services and point out the necessity of their indication, if this is not evident for the contracting parties. Disclosure to external persons or companies will only take place if it is necessary within the framework of the contract. When processing the data provided to us within the framework of an order, we act in accordance with the instructions of the Client and the legal requirements.

Data will be deleted when it is no longer required for the fulfilment of contractual or statutory welfare obligations and for the handling of any warranty and comParable obligations, whereby the necessity of data retention is reviewed every three years; otherwise the statutory retention obligations apply.

4.2 Agency services

We process data of our Clients and other users as part of our contractual services which include conceptual and strategic consulting, campaign planning, software and design development / consulting or maintenance, implementation of campaigns and processes / handling, server administration, data analysis / consulting services and training services.

We process contact and inventory data of our Clients (e.g. name, address, e-mail and telephone number), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter of contract, duration), payment data (e.g., bank details, payment history), usage and metadata (e.g. within the scope of evaluating and measuring the success of marketing measures).

The purpose of the processing is the provision of contractual services, billing and our Client service. The legal basis of the processing results from Art. 6 Para 1 lit. b) GDPR (contractual services), Art. 6 Para 1 lit. f) GDPR (analysis, statistics, optimisation, security measures). Disclosure to external parties only takes place if it is necessary within the framework of a contract. When processing the data provided to us within the framework of an order, we shall act in accordance with the instructions of the Client and the legal requirements for order processing pursuant to Art. 28 GDPR and shall not process the data for any purposes other than those specified in the order.

We delete the data after the expiry of statutory warranty and comParable obligations. The necessity of keeping the data is reviewed every three years; in case of legal requirements. After their expiration (e.g. after 3 years) the deletion takes place according to archiving obligations according to § 195 ff. BGB, § 78 StGB, 6 J, pursuant to § 257 (1) HGB, 10 J, pursuant to § 147 Para 1 AO). In case of data which is transmitted to us within the framework of an order disclosed by the Client, we delete the data according to the specifications of the order, in principle after the end of the order.

4.3 Administration, financial accounting, office organisation, contact management

We process data in the context of administrative tasks as well as the organisation of our business, financial accounting and compliance with legal obligations, such as archiving. Here we process the same data that we process within the scope of providing our contractual services. The processing bases are Art. 6 Para 1 lit. c) GDPR, Art. 6 Para 1 lit. f) GDPR. Clients and other users are affected by the processing.

The deletion of data with regard to contractual services and contractual communication corresponds to the data specified in these processing activities.

We disclose or transmit data to the tax authorities, consultants, such as tax consultants or auditors, as well as other fee offices and payment service providers.

Furthermore, on the basis of our business interests, we store information on suppliers, organisers and other business partners, e.g. for the purpose of establishing contact at a later date. This data, which is mainly company-related, is stored permanently.

4.4 Business analyses and market research

In order to operate our business economically, to recognize market trends, Client wishes and other users, we analyse the data available to us on business transactions, contracts, enquiries, etc., in order to identify the most suitable and appropriate solutions. We process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 Para 1 lit. f) GDPR, whereby the persons concerned include Clients, interested parties and other users of our online presence.

The analyses are carried out for the purpose of business management evaluations, marketing and Market Research. In doing so, we can provide the profiles of the registered users with information, e.g. about the services taken advantage of. The analyses serve us for the increase of the user-friendliness, the optimisation of our range of products and services and business efficiency. The analyses are solely for our benefit and will not be disclosed externally, unless they are anonymous analyses with of the combined values.

If these analyses or profiles are person-related, they will be deleted or anonymised upon termination by the user, otherwise after two years from the conclusion of the contract. In all other respects, the macroeconomic analyses and general trend determinations shall be prepared anonymously wherever possible.

5. Data processing when using and visiting our online presence

5.1 Visiting our website

If you only use our website for information purposes, i.e. if you do not register or if you do not provide information elsewhere, we only collect the personal data that your browser sends to us. If you would like to view our web pages, we collect data on the basis of Art. 6 Para 1 lit. f) GDPR the usage and metadata (e.g. access times, contents of the pages, browsers), IP addresses that are technically necessary for us to display our website to you and to ensure its stability and safety.

5.2 Online Presence in Social Media

We maintain online presences within social networks and platforms in order to communicate with Clients and other users to inform them about our services. When calling up the respective networks and platforms, the terms and conditions and the data processing guidelines of their respective operators apply.

Unless otherwise stated in our data protection declaration, we process the data of users who communicate with us within social networks and platforms, e.g. post articles on our online presence or send us messages.

5.3 Comments and contributions

When users leave comments or other contributions, their IP addresses may be changed based on our legitimate interests within the meaning of Art. 6 Para 1 lit. f) GDPR for 7 days. This shall take place for our safety, if someone leaves illegal contents in comments and contributions (insults, forbidden political propaganda, etc.). In this case, we are interested in the identity of the author.

Furthermore, we reserve the right, on the basis of our legitimate interests pursuant to Art. 6 Para 1 lit. f) GDPR, to process user data for the purpose of spam detection.

On the same legal basis, in the case of surveys, we reserve the right to store the IP addresses of users for the duration of the surveys and to use cookies in order to avoid multiple votes.

The data provided in the context of comments and contributions will be stored permanently by us until the user rejects them.

5.4 Comment subscriptions

Subsequent comments may be subscribed to by users with their consent pursuant to Art. 6 Para 1 lit. a) GDPR. Users receive a confirmation email to check whether they are the owner of the email address entered. Users can unsubscribe from ongoing comment subscriptions at any time. The confirmation email will contain information on the cancellation options. For the purposes of proving the users' consent, we store the registration time and the IP address of the users and delete this information when users unsubscribe from the subscription.

You can cancel the receipt of our subscription at any time, i.e. revoke your consent. We can store the e-mail addresses for up to three years on the basis of our legitimate interests before we delete it, in order to be able to prove a previously given consent. The processing of these data is limited to the purpose of a possible defence against claims. An individual request for cancellation is possible at any time, provided that at the same time the former existence of a consent is confirmed.

5.5 Collection of access data and log files

We, or our hosting provider, collect data on each access to the server on which this service is located (so-called server log files) on the basis of our legitimate interests within the meaning of Art. 6 Para 1 lit. f) GDPR. The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for security reasons (e.g. for the clarification of abuse or fraud actions) for the duration of maximally 7 days and deleted afterwards. Data whose further storage is necessary for evidence purposes are excluded from deletion until the respective incident has been finally clarified.

5.6. Cookies und Widerspruchsrecht bei Direktwerbung​

Cookies" are small files that are stored on the user's computer. Different data can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after the user's visit to an online service. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online offer and closes his browser. The content of a shopping cart in an online shop or a login status, for example, can be stored in such a cookie. Cookies are referred to as "permanent" or "persistent" and remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. The interests of the user can also be stored in such a cookie and used for range measurement or marketing purposes. Third party cookies" are cookies that are offered by providers other than the person responsible for operating the online service (otherwise, if they are only the latter's cookies, they are referred to as "first party cookies"). We may use temporary and permanent cookies and explain this in our privacy policy. If users do not wish cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of your browser. The exclusion of cookies can lead to functional restrictions of this online offer. A general objection to the use of cookies used for online marketing purposes can be raised for a large number of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices or the EU website http://www.youronlinechoices.com. In addition, cookies can be saved by deactivating them in the browser settings. Please note that in this case not all functions of this online offer can be used.

6. Newsletter​

With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures and your rights of objection. By subscribing to our newsletter, you declare your agreement with the receipt and the described procedures.

Content of the newsletter:
We send newsletters, e-mails and other electronic notifications containing advertising information (hereinafter "newsletter") only with the consent of the recipient or a legal permission. If the contents of the newsletter are specifically described within the scope of registration, they are decisive for the consent of the user. In addition, our newsletters contain information about our services and us.

Double-Opt-In and logging:
The registration to our newsletter takes place in a so-called Double-Opt-In procedure, i.e. you receive an e-mail after the registration, in which you are asked for the confirmation of your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. The registrations to the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address. Likewise changes of your data stored with the shipping service provider are logged.

Registration data:
To subscribe to the newsletter, it is sufficient to enter your e-mail address. Optionally, we ask you to enter a name in the newsletter for the purpose of a personal address.

The dispatch of the newsletter and the performance measurement associated with it are based on the consent of the recipients pursuant to Art. 6 Para 1 lit. a), Art. 7 GDPR in conjunction with § 7 Para 2 no. 3 UWG or, if consent is not required, on our legitimate interests in direct marketing pursuant to Art. 6 Para 1 lt. f) GDPR in conjunction with Art. 6 Para 1 lit. a), Art. 7 GDPR in conjunction with § 7 Para 2 no. 3 UWG. § 7 Para 3 UWG.

The registration procedure is recorded on the basis of our legitimate interests pursuant to Art. 6 Para 1 lit. f) GDPR. Our interest is directed towards the use of a user-friendly and secure newsletter system that serves our business interests as well as the expectations of the users and furthermore allows us to provide evidence of consent.

Cancellation/revocation:
You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to provide evidence of 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 a consent is confirmed at the same time.

6.1. Newsletter – Mailchimp​

The newsletters are sent by the mail service "MailChimp", a newsletter dispatch platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view the privacy policy of the shipping service provider here: https://mailchimp.com/legal/privacy. The Rocket Science Group LLC d/b/a MailChimp is certified under the Privacy Shield Agreement and thereby provides a guarantee of compliance with the European Privacy Level (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active). The shipping service provider is used on the basis of our legitimate interests pursuant to Art. 6 Para 1 lit. f) GDPR and an order processing contract pursuant to Art. 28 Para 3 S. 1 DSGVO

. The dispatch service provider can use the recipient's data in pseudonymous form, i.e. without allocation to a user, to optimise or improve its own services, e.g. for technical optimisation of dispatch and presentation of the newsletter or for statistical purposes. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.

6.2. Newsletter – Performance measurement

The newsletters contain a so-called "web-beacon", i.e. a file the size of a pixel, which is retrieved from our server when the newsletter is opened, or from the server of a dispatch service provider if we use one. Within the scope of this retrieval, technical information such as information about the browser and your system, as well as your IP address and time of retrieval are first collected.

This information is used for the technical improvement of the services on the basis of technical data or target groups and their reading behaviour on the basis of their retrieval points (which can be determined with the help of the IP address) or access times. Statistical surveys also include determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. It is, however, neither our endeavour nor, if used, that of the dispatch service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt contents to them or to adapt different contents according to the interests of our users.

A seParate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled.

6.3. Hosting and e-mail delivery

The hosting services used by us serve the provision of the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services which we use for the purpose of operating this online service.

In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of Clients and other users of our online presences on the basis of our legitimate interests in the efficient and secure provision of these online presences pursuant to Art. 6 Para 1 lit. f) GDPR in connection with Art. 28 GDPR (conclusion of contract processing agreement).

7. Integration of third-party services and content

On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online presences within the meaning of Art. 6 Para 1 lit. f) GDPR), we use content or service offers from third parties on our online presences in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as "content").

This always presupposes that the third-party providers of this content perceive the IP address of the user, since they would not be able to send the content to their browser without the IP address. The IP address is required to display this content. We make every effort to use only those contents whose respective providers only use the IP address to deliver the contents. Third party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. "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 operating system, referring websites, visiting times and other information about the use of our online presence, as well as may be linked to such information from other sources.

7.1. Google Fonts​

We bind the fonts ("Google Fonts") of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy, Opt-Out: https://adssettings.google.com/authenticated.

7.2. Google Maps​

We bind the maps of the service "Google Maps" of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The processed data may include IP addresses and location data of the users, which, however, cannot be accessed without their consent (as a rule, within the framework of the settings of their mobile devices). The data may be processed in the USA. Privacy policy: https://www.google.com/policies/privacy, Opt-Out: https://adssettings.google.com/authenticated.

7.3. Twitter

Within our online presence, functions and contents of the Twitter service, offered by Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, can be integrated. This may include, for example, content such as images, videos or text and buttons with which users can share content from this online presence within Twitter. If the users are members of the Twitter platform, Twitter can assign the call of the above contents and functions to the profiles of the users there. Twitter is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active). Privacy policy: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization.

7.4. Google Tag Manager​

Google Tag Manager is a solution that allows us to manage so-called website tags via a single interface (and thus integrate Google Analytics and other Google marketing services into our online presence). The Tag Manager itself (which implements the tags) does not process any personal user data. With regard to the processing of users' personal data, reference is made to the following information on Google services. Terms of use: https://www.google.com/intl/de/tagmanager/use-policy.html.

7.5. Google Analytics

We use Google Analytics, a web analysis service of Google LLC ("Google"), on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online presence in the sense of Art. 6 Para 1 lit. f) GDPR). Google uses cookies. The information generated by the cookie about users' use of our online presence is generally transmitted to and stored by Google on servers in the United States. Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). Google will use this information on our behalf to evaluate users' use of our online presence, to compile reports on activities within our online presence and to provide us with other services relating to the use of our online presence and the Internet. Pseudonymous user profiles can be created from the processed data. We use Google Analytics only with activated IP anonymization. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases the full IP address is transmitted to a Google server in the USA and shortened there. The IP address transmitted by the user's browser is not merged with other Google data. Users may refuse the use of cookies by selecting the appropriate settings on their browser, they may also refuse the use of cookies by selecting the appropriate settings on their browser, and they may refuse the collection of data by Google that are related to the use of cookies on our website and the processing of such data by Google by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de. Further information on the use of data by Google, settings and objection options, can be found in Google's privacy policy (https://policies.google.com/technologies/ads) and in the settings for the display of advertising by Google (https://adssettings.google.com/authenticated). Users' personal data will be deleted or anonymised after 14 months.

7.6. Target group formation with Google Analytics

We use Google Analytics to display ads placed by Google and its partners within our advertising services only to users who have shown an interest in our online presence or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Google (so-called "remarketing" or "Google Analytics Audiences"). We also use remarketing audiences to ensure that our ads match users' potential interests.

7.7. Google Adsense with personalized ads

We use the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, ("Google") on our online presences on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online presences in the sense of Art. 6 Par. 1 lit. f) GDPR). Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). We use the AdSense service to display ads on our website and receive a reward for displaying or otherwise using them. For these purposes, usage data such as the click on an advertisement and the IP address of the user is processed, whereby the IP address is shortened by the last two digits. For this reason, the processing of user data is pseudonymised. We use Adsense with personalized ads. Google draws conclusions about the interests of users based on the websites or apps they visit and the user profiles they create. Advertisers use this information to tailor their campaigns to these interests, which is beneficial to both users and advertisers. For Google, ads are personalized when collected or known data determines or influences ad selection. This includes, but is not limited to past searches, activities, site visits, app usage, demographics, and location information. Specifically, this includes demographic targeting, targeting to interest categories, remarketing, targeting to match lists, and targeting lists uploaded to DoubleClick Bid Manager or Campaign Manager. For more information about Google's use of data, preferences, and opt-outs, please see Google's Privacy Statement (https://policies.google.com/technologies/ads) and Google's Advertising Display Settings (https://adssettings.google.com/authenticated).

7.8. Google Adsense with non-personalized ads

We use the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, ("Google") on our online presences on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online presences in the sense of Art. 6 Par. 1 lit. f) GDPR). Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). We use the AdSense service to display ads on our website and receive a reward for displaying or otherwise using them. For these purposes, usage data such as the click on an advertisement and the IP address of the user is processed, whereby the IP address is shortened by the last two digits. For this reason, the processing of user data is pseudonymised. We use Adsense with non-personalized ads. The ads are not displayed on the basis of user profiles. Non-personalized ads are not based on previous user behavior. Targeting uses contextual information, including rough (e.g. local) geographic targeting based on current location, content on the current website or app, and current keywords. Google prohibits any personalized targeting, including demographic targeting and targeting based on user lists. Further information on Google's use of data, setting and objection options can be found in Google's privacy policy (https://policies.google.com/technologies/ads) and in the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).

7.9. Google AdWords and Conversion Measurement

We use the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, ("Google") on our online presences on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online presences in the sense of Art. 6 Par. 1 lit. f) GDPR). Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). We use the Google "AdWords" online marketing process to place ads on the Google advertising network (e.g. in search results, videos, websites, etc.) so that they are displayed to users who have a suspected interest in the ads. This allows us to display ads for and within our online presences in a more targeted manner so that we only present users with ads that potentially match their interests. If, for example, a user is shown ads for products in which he or she is interested on other online presences, this is referred to as "remarketing". For these purposes, when you visit our and other websites on which the Google Advertising Network is active, Google directly executes a code from Google and integrates so-called (re)marketing tags (invisible graphics or code, also known as "web beacons") into the website. With their help, an individual cookie, i.e. a small file, is stored on the user's device (comParable technologies can also be used instead of cookies). This file records which websites the user visits, what content he is interested in and what offers the user has clicked on, as well as technical information on the browser and operating system, referring websites, visiting times and other information on the use of the online presence. Furthermore, we receive an individual "conversion cookie". The information obtained with the help of the cookie is used by Google to compile conversion statistics for us. However, we only know the anonymous total number of users who clicked on our ad and were directed to a page with a conversion tracking tag. However, we do not receive any personally identifiable information. User information is processed pseudonymously within the Google Advertising Network. This means, for example, that Google does not store and process the user's name or e-mail address, but processes the relevant data cookie-related within pseudonymous user profiles. This means that, from Google's point of view, the ads are not administered and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymisation. The information collected about users is transmitted to Google and stored on Google's servers in the United States. Further information on the use of data by Google, setting and objection options, can be found in Google's privacy policy (https://policies.google.com/technologies/ads) and in the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).

7.10. Google Doubleclick​

We use the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, ("Google") on our online presences on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online presences in the sense of Art. 6 Para 1 lit. f) GDPR). Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). We use the Google "Doubleclick" online marketing process to place ads on the Google advertising network (e.g., in search results, videos, websites, etc.). Double Click is characterized by the fact that ads are displayed in real time based on users' suspected interests. This allows us to display ads for and within our online presences in a more targeted manner to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products in which he or she is interested on other online presences, this is referred to as "remarketing". For these purposes, when you visit our and other websites on which the Google Advertising Network is active, Google directly executes a code from Google and integrates so-called (re)marketing tags (invisible graphics or code, also known as "web beacons") into the website. With their help, an individual cookie, i.e. a small file, is stored on the user's device (comParable technologies can also be used instead of cookies). This file records which websites the user visits, what content he is interested in and what offers the user has clicked on, as well as technical information on the browser and operating system, referring websites, visiting times and other information on the use of the online presence. The IP address of the user is also recorded, whereby this is shortened within member states of the European Union or in other signatory states to the Agreement on the European Economic Area and only in exceptional cases is it completely transmitted to a Google server in the USA and shortened there. Google may also link the above information to such information from other sources. If the user subsequently visits other websites, ads tailored to the user's profile may be displayed according to the user's presumed interests. User data is processed pseudonymously within the Google advertising network. This means, for example, that Google does not store and process the user's name or e-mail address, but processes the relevant data cookie-related within pseudonymous user profiles. This means that, from Google's point of view, the ads are not administered and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymisation. The information Google Marketing Services collects about users is transmitted to Google and stored on Google's servers in the United States. Further information on the use of data by Google, setting and objection options can be found in Google's privacy policy (https://policies.google.com/technologies/ads) and in the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).

7.11. Akismet Anti-Spam Testing

Our online presences use the "Akismet" service offered by Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA. The use is based on our legitimate interests in the sense of Art. 6 Para 1 lit. f) GDPR. With the help of this service, comments of real people are distinguished from spam comments. All comments are sent to a server in the USA, where they are analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data is stored beyond this time. This information includes the name entered, the email address, the IP address, the comment content, the referrer, information about the browser used, the computer system and the time of the entry. Further information on the collection and use of data by Akismet can be found in Automattic's privacy policy: https://automattic.com/privacy. Users are welcome to use pseudonyms or to refrain from entering their name or email address. You can completely prevent the transmission of data by not using our comment system.

7.12. Emojis and smilies retrieval

Within our WordPress blog, graphic emojis (or smilies), i.e. small graphic files that express feelings, are used that are obtained from external servers. The server providers collect the IP addresses of the users. This is necessary so that the emoji files can be transmitted to the users' browsers. The Emojie service is offered by Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA. Automattic Privacy Policy: https://automattic.com/privacy. The server domains used are s.w.org and twemoji.maxcdn.com, which to the best of our knowledge are so-called content-delivery networks, i.e. servers which only serve to transmit files quickly and securely and which delete users' personal data after transmission. The use of emojis is based on our legitimate interests, i.e. interest in an attractive design of our online presence according to Art. 6 Para 1 lit. f) GDPR.

8. Security measures

In accordance with Art 32 GDPR and taking into account the state of the art, the implementation costs and the nature, extent, circumstances and purposes of the processing as well as the different probability of occurrence and severity of the risk to the rights and freedoms of natural persons, we shall take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.

Measures shall include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to, access to, inputting, disclosure, securing and seParation of data. In addition, we have established procedures to ensure the exercise of data subjects' rights, the deletion of data and the response to data threats. 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 technology design and data protection-friendly default settings (Art 25 GDPR).

9. Cooperation with contract processors and third parties

If we disclose data to other persons and companies (contract processors or third parties) in the context of our processing, transfer them to them or otherwise grant them access to the data, this will only take place on the basis of a legal permit (e.g. if the data is transferred to third parties, such as payment service providers, according to Art. 6 Para 1 lit b) DSGVO is necessary for the fulfilment of the contract), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we commission third parties with the processing of data on the basis of a so-called "order processing contract", this is done on the basis of Art. 28 GDPR.

10. Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of the use of third-party services or disclosure or transfer of data to third parties, this will only occur if it is done to fulfil our (pre)contractual obligations, on the basis of your consent, a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special requirements of Art. 44 et seq GDPR are met. I.e. processing takes place at present.B. on the basis of special guarantees, such as the officially recognised determination of a data protection level corresponding to that of the EU (e.g. for the USA by the "Privacy Shield") or observance of officially recognised special contractual obligations (so-called "standard contractual clauses").

11. Rights of data subjects

11.1. Rights of data subjects

You have the right to request confirmation as to whether the data in question will be processed and to request access to this data and further information and a copy of the data in accordance with Art. 15 GDPR.

According to Art. 16 GDPR you have the right to request the completion of data concerning you or the correction of incorrect data concerning you.

In accordance with Art. 17 GDPR you have the right to demand that the data in question be deleted immediately or, alternatively, in accordance with Art. 18 GDPR to demand that the processing of the data be restricted.

You have the right to request that the data concerning you which you have provided to us be preserved in accordance with Art. 20 GDPR and that it be transferred to other responsible parties.

You also have the right, pursuant to Art. 77 GDPR, to file a complaint with the competent supervisory authority.

11.2. Right of withdrawal

You have the right to revoke any consent granted in accordance with Art. 7 Para 3 GDPR with effect for the future.

11.3. Right of objection

You may object at any time to the future processing of the data concerning you in accordance with Art. 21 GDPR. The objection can be made in particular against the processing for purposes of direct marketing.

12. Deletion of data

The data processed by us will be deleted or their processing restricted in accordance with Art. 17 and 18 GDPR . Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and there are no legal obligations to retain them. If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons.

According to legal requirements in Germany, the storage takes place in particular for 10 years according to §§§ 147 Para 1 AO, § 257 Para 1 No. 1 and 4, Para 4 HGB (books, records, management reports, accounting vouchers, (e.g., trading books, documents relevant for taxation, etc.) and 6 years according to § 257 Para 1 Nos. 2 and 3, Para 4 HGB (commercial letters).

According to legal requirements in Austria, the storage is carried out in particular for 7 years in accordance with § 132 Para 1 BAO (accounting documents, receipts/invoices, accounts, receipts, business papers, list of income and expenses, etc.), for 22 years in connection with real estate and for 10 years for documents in connection with electronically provided services, telecommunications, radio and television services provided to non-entrepreneurs in EU member states and for which the Mini One Stop Shop (MOSS) is claimed.

Last modified: August 2019