Privacy policy

This data protection declaration informs you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) in the context of the provision of our services as well as within our online offer and the websites, functions and content associated with it as well as external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
Responsible

Andreas Sobing
Schliemannstr. 9
27749 Delmenhorst

E-Mail: admin@andreassobing.de
Link to imprint: https://andreassobing.de/ueber-mich/

Types of data processed

– Inventory data (e.g., personal master data, names or addresses).
– Contact data (e.g., e-mail, telephone numbers).
– Content data (e.g., text input, photographs, videos).
– Usage data (e.g., web pages visited, interest in content, access times).
– Meta/communication data (e.g., device information, IP addresses).
Categories of data subjects

Visitors and users of the online offer (hereinafter, we also refer to the data subjects collectively as “users”).
Purpose of the processing

– Making available the online offer, its functions and content.
– Responding to contact requests and communicating with users.
– Security measures.
– Reach measurement/marketing

Terminology used

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data.

“Pseudonymization” means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures which ensure that the personal data are not attributed to an identified or identifiable natural person.

“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 analyze 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.

“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.

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.
Relevant legal basis

In accordance with Art. 13 DSGVO, we inform you of the legal basis for our data processing activities. For users from the area of application of the General Data Protection Regulation (DSGVO), i.e. the EU and the EEC, the following applies, unless the legal basis is stated in the privacy policy:
The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 DSGVO;
The legal basis for processing for the fulfillment of our services and implementation of contractual measures as well as answering inquiries is Art. 6 (1) lit. b DSGVO;
The legal basis for processing to fulfill our legal obligations is Art. 6 (1) lit. c DSGVO;
In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) lit. d DSGVO serves as the legal basis.
The legal basis for the processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Art. 6 (1) lit. e DSGVO.
The legal basis for processing to protect our legitimate interests is Art. 6 (1) lit. f DSGVO.
The processing of data for purposes other than those for which they were collected is determined by the requirements of Art. 6 (4) DSGVO.
The processing of special categories of data (according to Art. 9 (1) DSGVO) is determined according to the requirements of Art. 9 (2) DSGVO.

Security measures

We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk, in accordance with the legal requirements, taking into account the state of the art, the cost of implementation and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, entry into, disclosure of, assurance of availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, deletion of data, and response to data compromise. 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 through data protection-friendly default settings.
Cooperation with processors, joint controllers and third parties

If, in the course of our processing, we disclose data to other persons and companies (order processors, jointly responsible persons or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers, is necessary for the performance of the contract), users 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 disclose or transfer data to other companies in our group of companies or otherwise grant them access, this is done in particular for administrative purposes as a legitimate interest and beyond that on a basis that complies with the legal requirements.
Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this occurs in the context of the use of third-party services or disclosure, or transfer of data to other persons or companies, this will only occur if it is done for the fulfillment of our (pre)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or leave the data in a third country only if the legal requirements are met. This means, for example, that the processing takes place on the basis of special guarantees, such as the officially recognized determination of a level of data protection that corresponds to the EU (e.g. for the USA by the “Privacy Shield”) or compliance with officially recognized special contractual obligations.

Rights of the data subjects

You have the right to obtain confirmation as to whether or not data concerning you is being processed and to obtain information about such data, as well as further information and a copy of the data in accordance with the law.

You have the right, in accordance with. the legal requirements, to request that the data concerning you be completed or that incorrect data concerning you be corrected.

You have the right, in accordance. with the legal requirements, to demand that data concerning you be deleted without delay, or alternatively, in accordance with the legal requirements, to demand restriction of the processing of the data.

You have the right to demand that the data concerning you that you have provided to us be received in accordance with the legal requirements and to demand that it be transferred to other persons responsible.

You also have the right, in accordance with the law, to lodge a complaint with the competent supervisory authority.
Right of withdrawal

You have the right to revoke any consent you have given with effect for the future.
Right of objection

You may object to the future processing of data relating to you at any time in accordance with the statutory provisions. The objection can be made in particular against the processing for purposes of direct advertising

Cookies and right to object to direct advertising

Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. The primary purpose of a cookie is to store information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. Such a cookie may store, for example, the contents of a shopping cart in an online store or a login status. Cookies that remain stored even after the browser is closed are referred to as “permanent” or “persistent”. For example, the login status can be stored if users visit them after several days. Likewise, the interests of users can be stored in such a cookie, which is used for range measurement or marketing purposes. Third-party cookies” are cookies that are offered by providers other than the responsible party that operates the online offer (otherwise, if they are only its cookies, they are referred to as “first-party cookies”).

We may use temporary and permanent cookies and provide information about this in our privacy policy.

If users do not want 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 the 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 declared for a large number of the services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by disabling them in the browser settings. Please note that in this case not all functions of this online offer can be used.
Deletion of data

The data processed by us will be deleted or restricted in its processing in accordance with the legal requirements. Unless expressly stated within the scope of 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 the deletion does not conflict with any statutory retention obligations.

If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.

Changes and updates to the privacy policy

We ask you to regularly check the content of our privacy policy. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
Business-related processing

In addition, we process
– Contract data (e.g., subject matter of the contract, term, customer category).
– Payment data (e.g., bank details, payment history)
of our customers, interested parties and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
Order processing in the online store and customer account

We process the data of our customers in the context of ordering processes in our online store to enable them to select and order the selected products and services, as well as their payment and delivery, or execution.

The processed data includes inventory data, communication data, contract data, payment data and the data subjects of the processing include our customers, prospective customers and other business partners. The processing is carried out for the purpose of providing contractual services in the context of operating an online store, billing, delivery and customer services. In this context, we use session cookies for storing the shopping cart content and permanent cookies for storing the login status.

The processing is carried out for the fulfillment of our services and the implementation of contractual measures (e.g. implementation of order transactions) and as far as it is required by law (e.g., legally required archiving of business transactions for trading and tax purposes). In this context, the information marked as required is necessary for the justification and fulfillment of the contract. We disclose the data to third parties only in the context of delivery, payment or in the context of legal permissions and obligations, as well as when this is based on our legitimate interests, about which we inform you in the context of this privacy policy (eg, to legal and tax advisors, financial institutions, freight companies and authorities).

Users can optionally create a user account, in which they can view their orders in particular. During the registration process, the required mandatory information is provided to the users. User accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data with regard to the user account will be deleted, subject to their retention is necessary for commercial or tax reasons. Information in the customer account will remain until its deletion with subsequent archiving in the event of a legal obligation or our legitimate interests (e.g., in the event of litigation). It is the responsibility of the users to save their data in the event of termination before the end of the contract.

In the context of registration and renewed registrations as well as use of our online services, 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 users in protection against abuse and other unauthorized use. In principle, this data is not passed on to third parties, unless it is necessary for the pursuit of our legal claims as a legitimate interest or there is a legal obligation to do so.

The deletion takes place after the expiry of legal warranty and other contractual rights or obligations (e.g., payment claims or performance obligations from contracts with customers), whereby the necessity of the storage of the data is reviewed every three years; in the case of storage due to legal archiving obligations, the deletion takes place after their expiry.

Agency services

We process our customers’ data 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.

In this context, we process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter of contract, term), payment data (e.g., bank details, payment history), usage data and metadata (e.g., in the context of evaluating and measuring the success of marketing measures). As a matter of principle, we do not process special categories of personal data, unless these are components of commissioned processing. Data subjects include our customers, prospective customers as well as their customers, users, website visitors or employees as well as third parties. The purpose of the processing is the provision of contractual services, billing and our customer service. The legal basis for the processing results from Art. 6 para. 1 lit. b DSGVO (contractual services), Art. 6 para. 1 lit. f DSGVO (analysis, statistics, optimization, security measures). We process data that is necessary for the justification and fulfillment of contractual services and point out the necessity of their indication. Disclosure to external parties only takes place if it is necessary in the context of an order. When processing the data provided to us as part of an order, we act in accordance with the instructions of the client as well as the legal requirements of a contract processing pursuant to Art. 28 DSGVO and do not process the data for any other purposes than those specified in the order.

We delete the data after the expiry of legal warranty and comparable obligations. The necessity of keeping the data is reviewed every three years; in the case of legal archiving obligations, the deletion takes place after their expiry (6 years, according to § 257 para. 1 HGB, 10 years, according to § 147 para. 1 AO). In the case of data disclosed to us by the client as part of an order, we delete the data in accordance with the specifications of the order, generally after the end of the order.
External payment service providers

We use external payment service providers through whose platforms users and we can make payment transactions (e.g., each with a link to the privacy policy, Paypal (https://www.paypal.com/de/webapps/mpp/ua/privacy-full), Klarna (https://www.klarna.com/de/datenschutz/), Skrill (https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/), Giropay (https://www.giropay.de/rechtliches/datenschutz-agb/), Visa (https://www.visa.de/datenschutz), Mastercard (https://www.mastercard.de/de-de/datenschutz.html), American Express (https://www.americanexpress.com/de/content/privacy-policy-statement.html).

In the context of the performance of contracts, we use the payment service providers on the basis of Art. 6 para. 1 lit. b. DSGVO. Furthermore, we use external payment service providers on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. DSGVO in order to offer our users effective and secure payment options.

The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e. we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the payment service providers transmit the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the terms and conditions and data protection information of the payment service providers.

For the payment transactions, the terms and conditions and data protection information of the respective payment service providers apply, which can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and assertion of revocation, information and other data subject rights.

Administration, financial accounting, office organization, contact management.

We process data in the context of administrative tasks as well as organization of our operations, financial accounting and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c. DSGVO, Art. 6 para. 1 lit. f. DSGVO. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e. tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information mentioned in these processing activities.

In this context, we disclose or transfer data to the tax authorities, consultants, such as tax advisors or auditors, as well as other fee offices and payment service providers.

Furthermore, based on our business interests, we store information on suppliers, event organizers and other business partners, e.g. for the purpose of contacting them at a later date. This data, most of which is company-related, is generally stored permanently.
Business analyses and market research

In order to operate our business economically and to be able to recognize market trends and the wishes of contractual partners and users, we analyze the data we have on business transactions, contracts, inquiries, etc.. In doing so, we process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. DSGVO, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offer.

The analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we may take into account the profiles of registered users with details, for example, of the services they have used. The analyses serve us to increase the user-friendliness, the optimization of our offer and the business management. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with aggregated values.

If these analyses or profiles are personal, they will be deleted or anonymized upon termination of the user, otherwise after two years from the conclusion of the contract. In other respects, the overall business analyses and general trend analyses are prepared anonymously wherever possible.

Participation in affiliate partner programs

Within our online offer, we use industry-standard tracking measures based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer) pursuant to Art. 6 (1) lit. f DSGVO, insofar as these are necessary for the operation of the affiliate system. In the following, we explain the technical background to users.

The services offered by our contractual partners may also be advertised and linked on other websites (so-called affiliate links or after-buy systems, if, for example, links or third-party services are offered after a contract has been concluded). The operators of the respective websites receive a commission if users follow the affiliate links and subsequently take advantage of the offers.

In summary, it is necessary for our online offer that we can track whether users who are interested in affiliate links and/or the offers available on our website subsequently take up the offers at the instigation of the affiliate links or our online platform. For this purpose, the affiliate links and our offers are supplemented by certain values, which may be part of the link or otherwise set, e.g. in a cookie. The values include in particular the source website (referrer), time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as tracking-specific values such as advertising material ID, affiliate ID and categorizations.

The online identifiers of the users used by us are pseudonymous values. That is, the online identifiers themselves do not contain any personal data such as names or email addresses. They only help us to determine whether the same user who clicked on an affiliate link or became interested in an offer via our online offer has taken advantage of the offer, i.e. has concluded a contract with the provider, for example. However, the online identifier is personal to the extent that the partner company and also us, the online identifier together with other user data. Only in this way can the partner company tell us whether the user has taken advantage of the offer and we can, for example, pay out the bonus.
Amazon affiliate program

We are based on our legitimate interests (i.e. interest in the economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f. DSGVO) participants in the affiliate program of Amazon EU, which was designed to provide a medium for websites, by means of which through the placement of advertisements and links to Amazon.de advertising fees can be earned (so-called affiliate system). I.e. as an Amazon partner we earn on qualified purchases.

Amazon uses cookies to track the origin of orders. Among other things, Amazon can recognize that you have clicked the affiliate link on this website and subsequently purchased a product from Amazon.

For more information about Amazon’s use of data and ways to object, please see the company’s privacy policy: https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010.

Note: Amazon and the Amazon logo are trademarks of Amazon.com, Inc. or one of its affiliates.

AWIN Partner Program

Based on our legitimate interests (i.e. interest in the economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO), we are participants in the affiliate program of AWIN AG, Eichhornstraße 3, 10785 Berlin, Germany, which is designed to provide a means for websites to earn advertising fees by placing advertisements and links to AWIN (so-called affiliate system). AWIN uses cookies in order to be able to trace the origin of the conclusion of the contract. Among other things, AWIN can recognize that you have clicked the affiliate link on this website and subsequently concluded a contract with or through AWIN.

For further information on the use of data by Awin and the possibility to object, please refer to the company’s privacy policy: https://www.awin.com/de/rechtliches.
Affilinet affiliate program

We are participants in the Affilinet partner program on the basis of our legitimate interests (i.e. interest in the economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO), we are participants in the affiliate program of affilinet GmbH, Sapporobogen 6-8, 80637 Munich, Germany, which is designed to provide a means for websites to earn advertising fees by placing advertisements and links to Affilinet (so-called affiliate system). Affilinet uses cookies to track the origin of the conclusion of the contract. Among other things, Affilinet can recognize that you have clicked the affiliate link on this website and subsequently concluded a contract with or through Affilinet.

For more information about Affilinet’s use of data and ways to object, please see the company’s privacy policy: https://www.affili.net/de/footeritem/datenschutz.
Registration function

Users can create a user account. As part of the registration process, the required mandatory information is provided to users and processed on the basis of Art. 6 (1) lit. b DSGVO for purposes of providing the user account. The processed data includes in particular the login information (name, password as well as an email address). The data entered during registration is used for the purposes of using the user account and its purpose.

Users may be informed about information relevant to their user account, such as technical changes, by e-mail. If users have terminated their user account, their data relating to the user account will be deleted, subject to any legal obligation to retain it. It is the responsibility of users to back up their data upon termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract.

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 users in protection against abuse and other unauthorized use. In principle, this data is not passed on to third parties, unless it is necessary for the pursuit of our claims or there is a legal obligation to do so pursuant to Art. 6 para. 1 lit. c. DSGVO. The IP addresses are anonymized or deleted after 7 days at the latest.

Comments and contributions

When users leave comments or other contributions, their IP addresses may be stored for 7 days on the basis of our legitimate interests as defined in Art. 6 (1) lit. f. DSGVO are stored for 7 days. This is done for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore 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. DSGVO, to process the information of the users for the purpose of spam detection.

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

The personal information provided in the context of comments and contributions, any contact and website information as well as the content-related information will be stored permanently by us until the user objects.
Comment subscriptions

Follow-up comments can be subscribed to by users with their consent pursuant to Art. 6 para. 1 lit. a DSGVO. Users will receive a confirmation email to verify that they are the owner of the email address entered. Users can unsubscribe from ongoing comment subscriptions at any time. The confirmation email will include instructions on how to unsubscribe. For the purposes of proving user consent, we store the time of subscription along with users’ IP address and delete this information when users unsubscribe.

You can unsubscribe from receiving our subscription at any time, i.e. revoke your consents. We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to prove consent formerly given. The processing of this data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.

Retrieval of profile pictures from Gravatar

We use the service Gravatar of Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA, within our online offer and especially in the blog.

Gravatar is a service where users can register and store profile pictures and their e-mail addresses. If users leave posts or comments on other online presences (especially blogs) with the respective email address, their profile pictures can thus be displayed next to the posts or comments. For this purpose, the email address provided by the users is transmitted to Gravatar in encrypted form for the purpose of checking whether a profile is stored for it. This is the sole purpose of transmitting the email address and it will not be used for any other purpose, but will be deleted afterwards.

Gravatar is used on the basis of our legitimate interests within the meaning of Art. 6 (1) (f) DSGVO, as we use Gravatar to offer post and comment authors the opportunity to personalize their posts with a profile picture.

By displaying the images, Gravatar obtains the IP address of the users, as this is necessary for a communication between a browser and an online service. More information on the collection and use of data by Gravatar can be found in Automattic’s privacy policy: https://automattic.com/privacy/.

If users do not want a user image associated with their email address on Gravatar to appear in the comments, they should use an email address that is not on file with Gravatar to comment. We also point out that it is also possible to use an anonymous email address or no email address at all if users do not want their email address to be sent to Gravatar. Users can completely prevent the transmission of data by not using our commenting system.
Soundcloud

Our podcasts are stored on the platform “Soundcloud”, offered by SoundCloud Limited, Rheinsberger Str. 76/77, 10115 Berlin, Germany and are played from this platform.

For this purpose, we integrate so-called Soundcloud widgets into our website. These are playback software with which users can play the podcasts. Here Soundcloud can measure which podcasts are listened to and to what extent and process this information pseudonymously for statistical and business management purposes. For this purpose, cookies may be stored in the browsers of the nuzers and processed for the purpose of forming user profiles, e.g. for the purpose of issuing ads that correspond to the potential interests of the users. In the case of users who are registered with Soundcloud, Soundcloud may associate the listening information with their profiles.

The use is based on our legitimate interests, i.e. interest in a safe and efficient provision, analysis as well as optimization of our audio offer pursuant to Art. 6 para. 1 lit. f. DSGVO.

Further information and objection options can be found in the privacy policy of Soundcloud: https://soundcloud.com/pages/privacy.

Blubrry Podcasting Services

We use the podcast hosting and statistics service Blubrry from the provider Rawvoice, Inc, 5000 Arlington Centre Blvd, Suite 2115 Upper Arlington, OH 43220, USA. The podcasts are loaded by Blubrry or transmitted via Blubrry.

Blubrry processes IP addresses and device information to enable podcast downloads/playbacks and to determine statistical data, such as view counts. This data is anonymized or pseudonymized before being stored in Blubrry’s database.

The use is based on our legitimate interests, i.e. interest in a safe and efficient provision, analysis as well as optimization of our podcast offer according to Art. 6 para. 1 lit. f. DSGVO.

Blubrry is (currently according to its own information) certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://create.blubrry.com/resources/about-blubrry/privacy-shield/).

Further information and opt-out options can be found in Blubrry’s privacy policy: https://create.blubrry.com/resources/about-blubrry/privacy-policy/.
Podigee Podcast Hosting

We use the podcast hosting service Podigee of the provider Podigee UG, Am Walde 2, 56249 Herschbach, Germany. The podcasts are thereby loaded by Podigee or transmitted via Podigee.

The use is based on our legitimate interests, i.e. interest in a secure and efficient provision, analysis and optimization of our podcast offer pursuant to Art. 6 para. 1 lit. f. DSGVO.

Podigee processes IP addresses and device information to enable podcast downloads/playbacks and to determine statistical data, such as call-up figures. This data is anonymized or pseudonymized before being stored in Podigee’s database, unless it is necessary for the provision of the podcasts.

Further information and objection options can be found in Podigee’s privacy policy: https://www.podigee.com/de/about/privacy/ .
Contacting

When contacting us (e.g. via contact form, email, telephone or via social media), the user’s details are used to process the contact request and its handling pursuant to Art. 6 para. 1 lit. b. (in the context of contractual/pre-contractual relations), Art. 6 para. 1 lit. f. (other requests) DSGVO processed… The user’s details may be stored in a customer relationship management system (“CRM system”) or comparable inquiry organization.

We delete the requests if they are no longer necessary. We review the necessity every two years; Furthermore, the legal archiving obligations apply.

Newsletter

With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.

Content of the newsletter: We send newsletters, e-mails and other electronic notifications with promotional information (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. If the contents of the Newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. Otherwise, our newsletters contain information about our services and us.

Double opt-in and logging: Registration for our newsletter is carried out in a so-called double opt-in process. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The registrations for 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 to your data stored with the dispatch service provider are logged.

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

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

The logging of the registration process is based on our legitimate interests pursuant to Art. 6 para. 1 lit. f DSGVO. Our interest is directed towards the use of a user-friendly as well as secure newsletter system that serves our business interests as well as meets the expectations of the users and furthermore allows us to prove consent.

Cancellation/Revocation – You can cancel the receipt of our newsletter at any time, i.e. revoke your consents. You will find a link to cancel the newsletter at the end of each newsletter. We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to be able to prove consent formerly given. The processing of this data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.
Newsletter – Mailchimp

The newsletter is sent using the dispatch service provider “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, thereby providing a guarantee of compliance with the European level of data protection (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. DSGVO and an order processing agreement pursuant to Art. 28 para. 3 p. 1 DSGVO.

The dispatch service provider may use the data of the recipients in pseudonymous form, i.e. without assignment to a user, to optimize or improve its own services, e.g. to technically optimize the 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.

Newsletter – performance measurement

The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened, or if we use a shipping service provider, from their server. In the course of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the retrieval are collected.

This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. The statistical surveys also include the determination of whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention 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 our content to them or to send different content according to the interests of our users.

Unfortunately, a separate revocation of the performance measurement is not possible, in which case the entire newsletter subscription must be cancelled.
Hosting and e-mail dispatch

The hosting services used by us serve to provide 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 offer.

In doing so, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer pursuant to Art. 6 (1) lit. f DSGVO in conjunction with Art. 28 DSGVO. Art. 28 DSGVO (conclusion of order processing contract).

Collection of access data and log files

We, or our hosting provider, collects on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO, we collect data about each access to the server on which this service is located (so-called server log files). 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) for a maximum of 7 days and then deleted. Data whose further storage is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.
Content delivery network from StackPath

We use a so-called “Content Delivery Network” (CDN), offered by StackPath, LLC, 2021 McKinney Avenue, Suite 1100 Dallas, Texas 75201, USA. StackPath is certified under the Privacy Shield agreement, thereby providing a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000CbahAAC&status=Active).

A CDN is a service with the help of which content of our online offer, in particular large media files such as graphics or scripts are delivered more quickly with the help of regionally distributed servers connected via the Internet. User data is processed solely for the aforementioned purposes and to maintain the security and functionality of the CDN.

The use is based on our legitimate interests, i.e. interest in a secure and efficient provision, analysis as well as optimization of our online offer.

For more information, please see StackPath’s privacy policy: https://www.stackpath.com/legal/privacy-statement.
Google Tag Manager

Google Tag Manager is a solution with which we can manage so-called website tags via an interface (and thus, for example, integrate Google Analytics as well as other Google marketing services into our online offer). The Tag Manager itself (which implements the tags) does not process any personal data of the users. With regard to the processing of users’ personal data, please refer to the following information on Google services. Usage guidelines: https://www.google.com/intl/de/tagmanager/use-policy.html.

Google Analytics

We use Google Analytics, a web analytics service provided by Google LLC (“Google”), on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f. DSGVO) Google Analytics, a web analytics service provided by Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by the users is usually transmitted to a Google server in the USA and stored there.

Google is certified under the Privacy Shield agreement and thereby 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 for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. In doing so, pseudonymous usage profiles of the users can be created from the processed data.

We only use Google Analytics with IP anonymization activated. 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 will the full IP address be 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 data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offer to Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

For more information on data usage by Google, setting and objection options, please refer to Google’s privacy policy (https://policies.google.com/privacy) as well as the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

The users’ personal data is deleted or anonymized after 14 months.
Google Universal Analytics

We use Google Analytics in the form of “Universal Analytics”. “Universal Analytics” refers to a method of Google Analytics in which user analysis is based on a pseudonymous user ID and thus a pseudonymous profile of the user is created with information from the use of different devices (so-called “cross-device tracking”).
Target group formation with Google Analytics

We use Google Analytics to display the ads placed by within advertising services of Google and its partners, only to those users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited), which we transmit to Google (so-called “Remarketing Audiences”, or “Google Analytics Audiences”). With the help of Remarketing Audiences, we also want to ensure that our ads correspond to the potential interest of users.

Google Adsense with personalized ads

We use the service AdSense, with the help of which ads are displayed on our website and we receive payment for their display or other use. For these purposes, usage data, such as the click on an ad and the IP address of the user are processed, whereby the IP address is shortened by the last two digits. Therefore, the processing of the users’ data is pseudonymized.

We use Adsense with personalized ads. In doing so, Google draws conclusions about users’ interests based on the websites they visit or apps they use and the user profiles thus created. Advertisers use this information to tailor their campaigns to these interests, which benefits users and advertisers alike. For Google, ads are personalized when captured or known data determines or influences ad selection. This includes past search queries, activities, website visits, app usage, demographic and location information, among others. Specifically, this includes: demographic targeting, targeting on interest categories, remarketing, and targeting on customer match lists and audience lists uploaded to DoubleClick Bid Manager or Campaign Manager.

For more information on Google’s use of data, settings and opt-out options, please refer to Google’s privacy policy (https://policies.google.com/technologies/ads) as well as Google’s advertising display settings (https://adssettings.google.com/authenticated).
Google Adsense with non-personalized ads

We use the services of Google Adsense on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).

We use Adsense with non-personalized ads. In this case, 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 broad (e.g., location-level) geographic targeting based on current location, content on the current website or app, and current search terms. Google prevents any personalized targeting, including demographic targeting and targeting based on user lists.

For more information about Google’s use of data, settings and opt-out options, please refer to Google’s privacy policy (https://policies.google.com/technologies/ads) and the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

Google AdWords and conversion measurement

We use the online marketing method Google “AdWords” to place ads in the Google advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. This allows us to display ads for and within our Online Offerings 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 he or she has been interested in on other online offers, this is referred to as “remarketing”. For these purposes, when our website and other websites on which the Google advertising network is active are called up, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also referred to as “web beacons”) are integrated 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 web pages the user has visited, which content the user is interested in and which offers the user has clicked on, as well as technical information about the browser and operating system, referring web pages, time of visit and other information about the use of the online offer.

Furthermore, we receive an individual “conversion cookie”. The information obtained with the help of the cookie is used by Google to create conversion statistics for us. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page tagged with a conversion tracking tag. However, we do not receive any information that personally identifies users.

The users’ data is processed pseudonymously within the Google advertising network. I.e. Google does not store and process e.g. the name or email address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. I.e. from Google’s perspective, the ads are not managed 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 explicitly allowed Google to process the data without this pseudonymization. The information collected about users is transmitted to Google and stored on Google’s servers in the USA.

Google Doubleclick

We use the services of Google LLC, 1600 Amphitheatre Park Park, Mountain View, CA 9.0.2008 (“Google”) on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).

We use the online marketing method Google “Doubleclick” to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.). Double Click is characterized by the fact that ads are displayed in real time based on presumed user interests. This allows us to display ads for and within our online offering 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 he or she was interested in on other online offers, this is referred to as “remarketing”. For these purposes, when our website and other websites on which the Google advertising network is active are called up, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also referred to as “web beacons”) are integrated 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 web pages the user has visited, which content the user is interested in and which offers the user has clicked on, as well as technical information about the browser and operating system, referring web pages, time of visit and other information about the use of the online offer.

The IP address of the user is also recorded, whereby this is shortened within member states of the European Union or in other contracting states of the Agreement on the European Economic Area and only in exceptional cases is transferred in full to a Google server in the USA and shortened there. The aforementioned information may also be combined on the part of Google with such information from other sources. If the user subsequently visits other websites, he may be shown ads tailored to his interests based on his user profile.

User data is processed pseudonymously within the Google advertising network. This means that Google does not store and process the name or e-mail address of the user, for example, but processes the relevant data on a cookie basis within pseudonymous user profiles. I.e. from Google’s perspective, the ads are not managed 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 allowed Google to process the data without this pseudonymization. The information collected by Google marketing services about users is transmitted to Google and stored on Google’s servers in the USA.

For more information about Google’s data use, settings and opt-out options, please refer to Google’s privacy policy (https://policies.google.com/technologies/ads) as well as Google’s advertising display settings (https://adssettings.google.com/authenticated).
Jetpack (WordPress Stats)

We use on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) the plugin Jetpack (here the sub-function “WordPress Stats”), which embeds a tool for statistical analysis of visitor traffic and is provided by Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA. Jetpack uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site.

The information generated by the cookie about your use of this website is stored on a server in the USA. In the process, user profiles can be created from the processed data, although these are only used for analysis purposes and not for advertising purposes. For more information, please refer to the privacy statements of Automattic: https://automattic.com/privacy/ and notes on Jetpack cookies: https://jetpack.com/support/cookies/.

Facebook Pixel, Custom Audiences and Facebook Conversion

Within our online offer, the so-called “Facebook pixel” of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are a resident of the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), is used due to our legitimate interests in the analysis, optimization and economic operation of our online offer and for these purposes.

Facebook is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

With the help of the Facebook pixel, it is possible for Facebook, on the one hand, to determine the visitors to our online offer as a target group for the display of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our online offer 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 Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of users and do not have a harassing effect. With the help of the Facebook pixel, we can also track the effectiveness of the Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion”).

The processing of the data by Facebook takes place within the framework of Facebook’s data usage policy. Accordingly, general information on the display of Facebook ads, in Facebook’s data usage policy: https://www.facebook.com/policy. Specific information and details about the Facebook Pixel and how it works can be found in Facebook’s help section: https://www.facebook.com/business/help/651294705016616.

You can opt-out of the Facebook Pixel’s collection and use of your data to display Facebook Ads. To set which types of ads are displayed to you within Facebook, you can visit the page set up by Facebook and follow the instructions there on the settings for usage-based advertising: https://www.facebook.com/settings?tab=ads. The settings are done in a platform-independent manner, which means that they are applied to all devices, such as desktop computers or mobile devices.

You can further object to the use of cookies that are used for reach measurement and advertising purposes via the Network Advertising Initiative deactivation page (http://optout.networkadvertising.org/) and additionally the U.S. website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).

Bing Ads

We use within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) we use the conversion and tracking tool “Bing Ads” of Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. In doing so, Microsoft stores cookies on the users’ devices in order to enable an analysis of the use of our online offer by the users, provided that users have reached our online offer via a Microsoft Bing ad (so-called “conversion measurement”). In this way, Microsoft and we can recognize that someone has clicked on an ad, been redirected to our online offer and reached a previously determined target page (so-called “conversion page”). We only learn the total number of users who clicked on a Bing ad and were then redirected to the conversion page. No IP addresses are stored. No personal information about the identity of users is shared.

Microsoft is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active).

If users do not wish to participate in the tracking process of Bing Ads, they can also deactivate the setting of a cookie required for this purpose via browser settings or use the opt-out page of Microsoft: http://choice.microsoft.com/de-DE/opt-out.

Users can find further information on data protection and the cookies used by Microsoft Bing Ads in Microsoft’s data protection declaration: https://privacy.microsoft.com/de-de/privacystatement.

Visual Website Optimizer

Within our online offer, based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) the service Visual Website Optimizer (an offer of Wingify Software Private Limited, 404, Gopal Heights, Netaji Subhash Place, Pitam Pura, Delhi 110034, India) is used.

Visual Website Optimizer allows to track the effect of different changes on a website (e.g. changes in input fields, design, etc.) within the framework of so-called “A/B testing”, “click tracking” and “heat maps”. A/B tests are used to improve the usability and performance of online offerings. For example, users are presented with different versions of a website or its elements, such as input forms, on which the placement of content or labels of navigation elements may differ. Then, based on the behavior of users, e.g., staying on the website longer or interacting with the elements more frequently, it can be determined which of these websites or elements are more likely to meet users’ needs. “Click tracking” allows to overview users’ movements within an entire online offer. Since the results of these tests are more accurate when users’ interactions can be tracked over time (e.g., being able to see if a user likes to return), cookies are usually stored on users’ computers for these testing purposes. “Heatmaps” are mouse movements of users that are combined to form an overall picture, which can be used, for example, to identify which website elements are preferred and which website elements users prefer less.

Cookies are stored on users’ devices only for these test purposes. Only pseudonymous user data is processed. For more information, please refer to Visual Website Optimizer’s privacy policy: https://vwo.com/privacy-policy/.

If you do not want Visual Website Optimizer to collect your usage behavior, you can object to the data collection using this link: https://[PLEASE INSERT YOUR DOMAIN]/?vwo_opt_out=1.

Online presence in social media

We maintain online presences within social networks and platforms in order to be able to communicate with customers, interested parties and users active there and to inform them about our services there.

We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users’ rights. With regard to U.S. providers that are certified under the Privacy Shield, we point out that they thereby undertake to comply with the data protection standards of the EU.

Furthermore, user data is usually processed for market research and advertising purposes. For example, usage profiles can be created from the usage behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behavior and interests of the users are stored. Furthermore, data may also be stored in the usage profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).

The processing of the users’ personal data is based on our legitimate interests in effectively informing users and communicating with users pursuant to Art. 6 para. 1 lit. f. DSGVO. If the users are asked by the respective providers of the platforms for consent to the aforementioned data processing, the legal basis of the processing is Art. 6 para. 1 lit. a., Art. 7 DSGVO.

For a detailed description of the respective processing and the opt-out options, please refer to the information of the providers linked below.

Also in the case of requests for information and the assertion of user rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

– Facebook, -pages, -groups, (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) on the basis of an agreement on joint processing of personal data – Privacy Policy: https://www.facebook.com/about/privacy/, specifically for pages: https://www.facebook.com/legal/terms/information_about_page_insights_data , Opt-Out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.

– Google/ YouTube (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – Privacy Policy: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.

– Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – Privacy Policy/ Opt-Out: http://instagram.com/about/legal/privacy/.

– Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) – Privacy Policy: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.

– Pinterest (Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA) – Privacy Policy/ Opt-Out: https://about.pinterest.com/de/privacy-policy.

– LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland) – Privacy Policy https://www.linkedin.com/legal/privacy-policy , Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active.

– Xing (XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany) – Privacy Policy/ Opt-Out: https://privacy.xing.com/de/datenschutzerklaerung.

– Wakalet (Wakelet Limited, 76 Quay Street, Manchester, M3 4PR, United Kingdom) – Privacy Policy/ Opt-Out: https://wakelet.com/privacy.html.

– Soundcloud (SoundCloud Limited, Rheinsberger Str. 76/77, 10115 Berlin, Germany) – Privacy Policy/ Opt-Out: https://soundcloud.com/pages/privacy.

Integration of third-party services and content

Within our online offer, we use content or service offers of third parties on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) to integrate content or services offered by third-party providers, such as videos or fonts (hereinafter uniformly referred to as “content”).

This always requires that the third-party providers of this content are aware of the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content. We endeavor to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.
Vimeo

We can embed the videos of the platform “Vimeo” of the provider Vimeo Inc, Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA. Privacy policy: https://vimeo.com/privacy. We point out that Vimeo may use Google Analytics and refer to the privacy policy (https://policies.google.com/privacy) as well as opt-out options for Google Analytics (http://tools.google.com/dlpage/gaoptout?hl=de) or Google’s settings for data use for marketing purposes (https://adssettings.google.com/).
Youtube

We integrate the videos of the platform “YouTube” 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.
Google Fonts

We integrate 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.

Google ReCaptcha

We integrate the function for the recognition of bots, e.g. for entries in online forms (“ReCaptcha”) 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.
Google Maps

We integrate 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, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually executed in the context 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.
Typekit fonts from Adobe

We use external “Typekit fonts” on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. f. DSGVO), we use external “Typekit” fonts from the provider Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Republic of Ireland. Adobe is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000TNo9AAG&status=Active).
Use of Facebook social plugins

We use social plugins based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. f. DSGVO) social plugins (“plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”).
This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within Facebook. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.

When a user calls up a function of this online offer that contains such a plugin, his or her device establishes a direct connection with Facebook’s servers. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated into the online offer by the latter. In the process, usage profiles of the users can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects with the help of this plugin and therefore inform users according to our level of knowledge.

By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user is logged into Facebook, Facebook can assign the visit to his Facebook account. If users interact with the plugins, for example by clicking the Like button or posting a comment, the corresponding information is transmitted from your device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will learn and store his or her IP address. According to Facebook, only an anonymized IP address is stored in Germany.

The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the related rights and settings options for protecting the privacy of users, can be found in Facebook’s privacy policy: https://www.facebook.com/about/privacy/.

If a user is a Facebook member and does not want Facebook to collect data about him or her via this online offer and link it to his or her membership data stored with Facebook, he or she must log out of Facebook and delete his or her cookies before using our online offer. Further settings and objections to the use of data for advertising purposes, are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.

Twitter

Within our online offer, functions and contents of the service Twitter, offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, may be integrated. This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within Twitter.
If the users are members of the Twitter platform, Twitter can assign the call of the above-mentioned content and functions to the profiles of the users there. Twitter is certified under the Privacy Shield agreement and thereby 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.
Instagram

Within our online offer, functions and content of the service Instagram, offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA, may be integrated. This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within Instagram. If the users are members of the Instagram platform, Instagram can assign the call of the above-mentioned content and functions to the profiles of the users there. Privacy policy of Instagram: http://instagram.com/about/legal/privacy/.
Pinterest

Within our online offer, functions and contents of the service Pinterest, offered by Pinterest Inc, 635 High Street, Palo Alto, CA, 94301, USA, can be integrated. This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within Pinterest. If the users are members of the Pinterest platform, Pinterest can assign the call of the above-mentioned content and functions to the profiles of the users there. Pinterest privacy policy: https://about.pinterest.com/de/privacy-policy.
Xing

Within our online offer, functions and contents of the service Xing, offered by XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany, may be integrated. This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offering within Xing. If the users are members of the Xing platform, Xing can assign the call-up of the above-mentioned content and functions to the users’ profiles there. Privacy policy of Xing: https://privacy.xing.com/de/datenschutzerklaerung.
LinkedIn

Within our online offer, functions and contents of the service LinkedIn, offered by LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland, may be integrated. This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within LinkedIn. If the users are members of the LinkedIn platform, LinkedIn can assign the call of the above-mentioned content and functions to the profiles of the users there. Privacy policy of LinkedIn: https://www.linkedin.com/legal/privacy-policy.. LinkedIn is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active). Privacy policy: https://www.linkedin.com/legal/privacy-policy, Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Sharing functions of AddThis

Within our online offer, the service “AddThis” (1595 Spring Hill Rd Suite 300 Vienna, VA 22182, USA) is used to share content of this online offer within social networks (so-called sharing).

The use is based on our legitimate interests, i.e. interest in disseminating our online offer pursuant to Art. 6 para. 1 lit. f. DSGVO.

AddThis uses the personal information of the users for the provision and execution of the sharing functions. In addition, AddThis may use pseudonymous information of the users for marketing purposes. This data is stored on the user’s computer using so-called “cookie” text files. Privacy policy: http://www.addthis.com/privacy, Opt-Out: http://www.addthis.com/privacy/opt-out.

Shariff sharing functions

We use the privacy-safe “Shariff” buttons. “Shariff” was developed to allow more privacy on the net and to replace the usual “share” buttons of social networks. In this case, it is not the user’s browser, but the server on which this online offer is located, that establishes a connection with the server of the respective social media platforms and queries, for example, the number of likes, etc. The user remains anonymous in this process. The user remains anonymous. More information about the Shariff project can be found at the developers of the magazine c’t: www.ct.de.

Created with Datenschutz-Generator.de from RA Dr. Thomas Schwenke

Cookies and reports on access figures

We use “session cookies” from VG Wort, Munich, to measure access to texts in order to record the probability of copying. Session cookies are small units of information that a provider stores in the RAM of the visitor’s computer. A randomly generated unique identification number, a so-called session ID, is stored in a session cookie. In addition, a cookie contains information about its origin and the storage period. Session cookies cannot store any other data. These measurements are carried out by Kantar Germany GmbH using the Scalable Central Measurement Method (SZM). They help to determine the copy probability of individual texts for the remuneration of legal claims of authors and publishers. We do not collect any personal data via cookies.

Many of our pages are provided with JavaScript calls, through which we report the accesses to the Verwertungsgesellschaft Wort (VG Wort). [PLEASE CHECK whether this is the case for your publisher!] We thus enable our authors to participate in the distributions of the VG Wort, which ensure the statutory remuneration for the uses of copyrighted works in accordance with § 53 UrhG.

It is also possible to use our offers without cookies. Most browsers are set to automatically accept cookies. However, you can deactivate the storage of cookies or set your browser to notify you as soon as cookies are sent.

Our website and our mobile website use the “Scalable Central Measurement Method” (SZM) of Kantar Germany GmbH to determine statistical parameters for determining the copy probability of texts.

Anonymous measurement values are collected in the process. The access count measurement alternatively uses a session cookie or a signature, which is created from various automatically transmitted information of your browser, for the recognition of computer systems. IP addresses are only processed in anonymized form.

The procedure was developed in compliance with data protection. The sole aim of the procedure is to determine the copying probability of individual texts.

At no time are individual users identified. Your identity always remains protected. You will not receive any advertising via the system.

The terms used in the following are, among others, those from Art. 4 of the General Data Protection Regulation (DSGVO).
Name and address of the controller

The responsible party within the meaning of the General Data Protection Regulation (DSGVO) and other national data protection laws of the member states as well as other data protection regulations is the manufacturer of this plugin indicated in the imprint.
General information on data processing
Scope of the processing of personal data

As a matter of principle, we process personal data of our users only to the extent necessary to provide a functional plugin. The processing of personal data of our users is regularly carried out only with the consent of the user. An exception applies in cases where obtaining prior consent is not possible for actual reasons and the processing of the data is permitted by legal regulations.
Legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for processing operations involving personal data, Article 6 (1) (a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis.

When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 (1) lit. b DSGVO serves as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures.

Insofar as processing of personal data is necessary for compliance with a legal obligation to which our company is subject, Art. 6 (1) lit. c DSGVO serves as the legal basis.

In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) lit. d DSGVO serves as the legal basis.

If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the first-mentioned interest, Art. 6 (1) f DSGVO serves as the legal basis for the processing.

Data deletion and storage period

The personal data of the data subject will be deleted or blocked as soon as the purpose of storage ceases to apply. Storage may also take place if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. Data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.
Data transmission

The data transmission on the Internet to our server takes place via HTTPS and TLS protocol in an encrypted manner. An unencrypted transmission is not possible on the part of our server. The data is encrypted by our plugin or your web browser, then transmitted and finally decrypted by our server.
Provision of the plugin
Description and scope of data processing

The plugin does not send any data to the manufacturer without the consent of the user. Data that may be sent to the manufacturer is listed below. The plugin does not create or collect usage data.
Check function for counters
Description and scope of data processing

You have the option to have us check the counters embedded by the plugin on your website. This is done via the “Check” link, which can be found in several places in the plugin. If you click on this check link, the following data will be sent to our server:

By your access with a web browser:
Information about the web browser type and version used,
the user’s operating system,
the user’s IP address,
the date and time of access,
the website from which the user’s system accesses our server,
data contained in the verification link:
the public counter,
the link to the web page (WordPress page) where the counter should be located.

The data sent by your access with a web browser to will only be stored in the log files of our system if an error occurs during the corresponding page request. Not affected by this is the IP address of the user or other data that allows the assignment of data to a user.

The data contained in the check link is used by our server to test whether the public counter is located on the web page (WordPress page) contained in the check link.

We temporarily store the user’s IP address solely for the purpose of determining how often the user uses the check function within a time interval.

This data is not stored together with other personal data of the user.

Legal basis for data processing

The legal basis for the temporary storage of data is Art. 6 para. 1 lit. f or a DSGVO.
Purpose of the data processing

The temporary storage of the IP address by the server is necessary to enable delivery of the accessed website to the user’s computer. For this purpose, the user’s IP address must remain stored for the duration of the session.

The temporary storage of the data in the check link is necessary to perform the check.

We temporarily store the user’s IP address exclusively to protect our check function from misuse (excessive use).
Duration of storage

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the check function for counters, this is the case when the respective session has ended. No permanent storage takes place.

We store the user’s IP address for a maximum of one day to protect our system.
Possibility of objection and removal

The storage of data in log files in the event of an error is absolutely necessary for the operation of the check function for counters. Consequently, there is no possibility of objection on the part of the user.

The storage of the user’s IP address is mandatory for the protection of our system. Consequently, there is no possibility for the user to object.

The user can activate the use of the check function for counters via a checkbox in the “Privacy” area/menu in order to be able to use it, or deactivate it in order to object to its use. By default, this check box is disabled.
Rights of the data subject

If personal data is processed by you, you are a data subject within the meaning of the GDPR and you are entitled to the following rights vis-à-vis the controller:
Right of access

You may request confirmation from the controller as to whether personal data concerning you is being processed by us. If such processing is taking place, you may request information from the controller about the following:

The purposes for which the personal data are processed,
the categories of personal data which are processed,
the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed,
the planned duration of the storage of the personal data concerning you or, if concrete information on this is not possible, criteria for determining the storage period,
the existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing,
the existence of a right of appeal to a supervisory authority,
any available information about the origin of the data, if the personal data are not collected from the data subject,
the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.

You have the right to request information about whether personal data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed about the appropriate safeguards pursuant to Art. 46 DSGVO in connection with the transfer.

Right to rectification

You have a right to rectification and/or completion vis-à-vis the controller if the personal data processed concerning you is inaccurate or incomplete. The controller shall carry out the rectification without undue delay.
Right to restriction of processing

Under the following conditions, you may request the restriction of the processing of personal data concerning you:

if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data,
the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data,
the controller no longer needs the personal data for the purposes of processing, but you need them for the establishment, exercise or defense of legal claims, or
if you have objected to the processing pursuant to Article 21 (1) DSGVO and it is not yet clear whether the legitimate grounds of the controller outweigh your grounds.

If the processing of personal data concerning you has been restricted, such data may – apart from being stored – only be processed with your consent or for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State.

If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
Right to erasure

Obligation to erase:

You may request the controller to erase the personal data concerning you without undue delay, and the controller is obliged to erase such data without undue delay, if one of the following reasons applies:

the personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed,
you withdraw your consent on which the processing was based pursuant to Art. 6 (1) a or Art. 9 (2) a DSGVO and there is no other legal basis for the processing,
you object to the processing pursuant to Art. 21 (1) DSGVO and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) DSGVO,
the personal data concerning you have been processed unlawfully,
the erasure of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject,
the personal data concerning you has been collected in relation to information society services offered pursuant to Article 8(1) of the GDPR.

Information to third parties:

If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17(1) of the GDPR, it shall take reasonable measures, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers that process the personal data that you, as the data subject, have requested them to erase all links to, or copies or replications of, that personal data.

Exceptions:

The right to erasure does not exist to the extent that the processing is necessary:

For the exercise of the right to freedom of expression and information,
for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller,
for reasons of public interest in the area of public health pursuant to Art. 9(2)(h) and (i) and Art. 9(3) DSGVO,
for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Article 89(1) DSGVO, insofar as the right referred to in section a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing, or
for the assertion, exercise or defense of legal claims.

Right to information

If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.

You have the right vis-à-vis the controller to be informed about these recipients.
Right to data portability

You have the right to receive the personal data concerning you that you have provided to the controller in a structured, common and machine-readable format. You also have the right to transfer this data to another controller without hindrance from the controller to whom the personal data was provided, provided that

the processing is based on consent pursuant to Art. 6 (1) a DSGVO or Art. 9 (2) a DSGVO or on a contract pursuant to Art. 6 (1) b DSGVO and
the processing is carried out with the help of automated procedures.

In exercising this right, you also have the right to obtain that the personal data concerning you be transferred directly from one controller to another controller, insofar as this is technically feasible. Freedoms and rights of other persons must not be affected by this.

The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Right to object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions.

The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims.

If the personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to processing of the personal data concerning you for the purposes of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.

If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.

You have the possibility, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise your right to object by means of automated procedures using technical specifications.

Right to revoke the declaration of consent under data protection law

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
Automated decision in individual cases including profiling

You have the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

is necessary for the conclusion or performance of a contract between you and the controller,
is permitted by legal provisions of the Union or the Member States to which the controller is subject and these legal provisions contain appropriate measures to protect your rights and freedoms as well as your legitimate interests, or
is carried out with your explicit consent.

However, these decisions may not be based on special categories of personal data pursuant to Article 9(1) of the GDPR, unless Article 9(2)(a) or (g) of the GDPR applies and appropriate measures have been taken to protect the rights and freedoms as well as your legitimate interests.

With regard to the aforementioned cases, the controller shall take reasonable steps to safeguard the rights and freedoms as well as your legitimate interests, which include, at a minimum, the right to obtain the intervention of a person on the part of the controller, to express his or her point of view and to contest the decision.

Right to complain to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, workplace or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.

Who we are

We are the OnTheGoSystems Ltd. company, makers of the WPML plugin and owners of the wpml.org website.

You can find more information about us, including our full address, on our company website.

What personal data we collect and why we collect it

Comments

When you leave comments on the site we collect the data shown in the comments form, and also your IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Contact forms

Information submitted through the contact forms on our site are sent to our company email, hosted by Gmail. Google adheres to the EU “Privacy Shield” policy and you can find more information about this here.

While we keep these submissions for customer service purposes they are never used for marketing purposes or shared with third parties.

Cookies

Our site uses the following cookies:

Google Analytics cookies – these are set for monitoring and tracking visitors behavior on the site.
WordPress logged-in cookies – these are used by WordPress to authenticate logged-in visitors, password authentication, and user verification.
WPML cookies – these are used by our WPML plugin to identify the preferred user’s language as our site is multilingual. You can find detailed information about this on our page about browser cookies stored by WPML.
WooCommerce cookies – these are used by the WooCommerce plugin to track visitors and their purchased items in the cart.
W3 Total Cache cookies – these are used by W3 Total Cache plugin to monitor referrer and user identification for caching purposes.
WP Polls cookies – these are used by WP Polls plugin to provide proper polls functionality based on user identification.
ICL-MPP Affiliate cookies – this is used by our system to monitor and identify affiliates for the purpose of performance monitoring and payments.
bbPress cookies – this used by the bbPress plugin to provide proper forum functionality based on user status and profile.
Toolset plugin cookies – this is used by our Toolset plugin (Toolset Types, Module Manager, and Toolset Forms) to properly provide functionality based on user status.
2checkout WooCommerce cookies – this is used by the WooCommerce extension 2checkout for verifying user payment and checkout status.
WP Postratings cookies – this is used by the WP Post rating plugin to provide proper rating functionality based on user status.
Limit Login Attempts cookies – this is used by the Limit login attempts plugin to provide brute force security in logins by monitoring user cookies.
CMS Tree Page View cookies – this is used by the CMS Tree Page View to provide correct functionality based on user behavior.

Embedded content from other websites

Articles on this site may include embedded content, like YouTube videos, for example. Embedded content from other websites behaves in the exact same way as if you visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged-in to that website.

Analytics

In addition to Google Analytics, we are using the following statistics on our site for performance and monitoring:

Affiliate performance statistics – statistics regarding our affiliates
Installer statistics – statistics regarding the number of plugin installations of our products in clients, also includes the site info like PHP version, WordPress version used, etc.
Support statistics – statistics regarding our supporters and clients about how many tickets created, resolved, pending, etc.
WooCommerce statistics – statistics regarding our sales, conversion rates, refunds, etc.
Reference sites statistics – statistics regarding our clients reference sites installation.
Compatibility plugin statistics – statistics regarding our clients compatible/incompatible themes/plugins with our products.

Professional Translation Services

WPML allows you to send the content of your site for translation to third-party translation services of your own choice. This involves sending the content data, calculating the commissions for translations, and communication between the involved systems.

Only data that is required to send and receive site contents for the translation is shared with the selected translation services. In short, it is not possible to use professional translation through WPML without sharing the information needed for the translation to happen.

All communication between WPML and translation services is encrypted.

Data shared with our support

Sometimes, to help our support debug a WPML-related issue on your site, we might ask you to share a copy of your site with us. Since this is your site, you are the one responsible for its data and we strongly encourage you to remove any personal information from the database before sharing it with us.

That being said, here are some important points about what happens with the site duplicates and data that is shared with our support:

When a debug or setting check is needed, we ask for access to the site or even a full copy of the site.
We use that access/duplicates strictly for debugging.
We do not share that data with anyone outside of the company.
We might need to share the duplicates with OnTheGoSystems supporters and developers when the case requires it.
We destroy this information after we finish debugging and resolve your issue.
Our forum is public but any outside URL is automatically masked and any private information is shared only in private comment seen only by the supporters and the client that reported the issue.
Again, we strongly encourage you to remove any personal/sensitive information they might hold before sharing access/duplication if they are concerned about it.
We cannot be held responsible for any loss of private information from databases if that should occur. In other words, you should have a fully working backup of whatever site you share with us.

Data collected by the WPML plugin and add-ons you use

The WPML plugin is fully compliant with GDPR.

If you give it explicit consent, the only data it can collect is which theme and plugins your site is using. This information is used only for providing you with faster and better support. WPML will prompt you and require explicit action, asking you if you want to share with us this information. If you decline, it will not collect any data whatsoever.

WPML add-on plugins that we provide, like Gravity Forms Multilingual, for example, allow WPML to work with certain plugins. However, they do not perform any explicit duties of these plugins. They will not even work without the main plugin activated on the site. So, for example, Gravity Forms Multilingual does not in any way send or receive data – this is still done through the main Gravity Forms plugin.

You will have to contact the authors of these third-party plugins and themes for information about who they deal with GDPR and similar regulations.

WPML Translation Management add-on plugin

WPML provides a separate add-on plugin called Translation Management. It helps you manage your content’s translation better and offers you multiple tools for sending content for translation.

Because of the service this plugin provides, it has to send your contents off-site. Specifically, Translation Management add-on plugin can:

Send to wpml.org the names and emails of the site’s admin, Translation Managers, and translators.
Send to wpml.org and its sub-domains content of the site, for the purpose of translating that content.
Send to translation services, which the users select themselves, the content for translation.

It goes without saying that the data sent by Translation Management is sent in an automatic and secure manner and used exclusively for providing you the translation services. None of it is shared or used for any other purposes or shared with any third-party besides the translators.

If you decide to use the Translation Management add-on, the sending of this information is not optional, it is simply part of the service. Therefore, if you do not wish to share this information for translation purposes, you should not use WPML Translation Management add-on.

We don’t share your data with third-parties in a way as to reveal any of your personal information like email, name, etc. However, some data is transferred and/or stored with third-party services we use, like cloud-based services and payment processors. This is done as a way to provide you with a better overall service and user experience.

Here are the services we use to make our own service better for you:

Active Trail – we store our client contact details for newsletters, announcements, and usability testing invite purposes. They can opt-out of these at any time.
PayPal – we use Paypal as one of our payment processor. During checkout, a client will provide login information and credit card info. This information is processed directly within this gateway payment and we do not save it on our sites.
Stripe – we use Stripe as one of our payment processor. During checkout, a client will provide credit card info. These are all stored in the Stripe site.
2Checkout – we use this as one of our payment processor. During checkout, a client will provide credit card info. These are all stored in the 2checkout site. These are shared for future checkouts and account renewals.
Amazon SES – we use this services to manage mailing campaigns to our clients. What is shared are client contact details (name and client email).

Who can see my personal information

If you are not a registered client in our site, there is no personal information we have or can see about you.

If you are a client with a WPML account, your personal information can be accessed by:

Our System administrator
Our supporters when they need to (in order to provide support) get the information about the client accounts and access.

How long we retain your data

When you submit a support ticket or a comment, its metadata is retained until (if) you tell us to remove it. We use this data so that we can recognize you and approve your comments automatically instead of holding them for moderation.

If you register on our website, we also store the personal information you provide in your user profile. You can see, edit, or delete your personal information at any time (except changing your username). Website administrators can also see and edit that information.

How we protect your data and what data breach procedures we have in place

We protect customer data with the following site features:

We are entirely using SSL/HTTPS throughout all our sites. This encrypts our user communications with the servers so personal identifiable information is never captured by third parties without authorization.
Databases are sanitized (actual user personal details are removed) before deploying to development or testing environment.

In case of a data breach, System administrators will immediately go through affected users and will attempt to reset passwords if needed after informing the user.

What rights you have over your data

If you have an account on this site or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us.

You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes. In short, we cannot erase data that is vital to you being our customer (i.e. basic account information like an email address).

For these requests, please use this form.

Additional Information

You can find additional information about related topics on the following pages: