Privacy statementWould you rather read this in German? Lieber auf Deutsch lesen?
With the following data protection declaration we would like to inform you which types of your personal data (hereinafter also referred to as "data") we process for which purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both within the framework of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer").
The terms used are not gender-specific.
Status: December 19, 2019
Table of contents
- Introductory remarks
- Person in charge
- Overview of processing operations
- Applicable legal bases
- Safety precautions
- Transmission and disclosure of personal data
- Data processing in third countries
- Provision of online services and web hosting
- Newsletter and broad communication
- Deletion of data
- Modification and updating of the data protection declaration
- Rights of data subjects
- Definitions of terms
Person in charge
Legal entity in charge: Inviado Ltd & Co KG as stated in the imprint: https://inviado.com/impressum
Authorised representatives (person in charge): Jan Prill, Babendiekstr. 60b, 22587 Hamburg
E-mail address: email@example.com
Legal notice: https://janprill.com/impressum
Overview of processing operations
The following table summarises the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
Inventory data (for example, names, addresses).
Content data (e.g. text entries, photographs, videos).
Contact data (e.g. e-mail, telephone numbers).
Meta/communication data (e.g. device information, IP addresses).
Usage data (e.g. websites visited, interest in content, access times).
Categories of data subjects
Users (e.g. website visitors, users of online services).
Purposes of processing
Content Delivery Network (CDN).
Direct marketing (e.g. by e-mail or post).
Contractual services and service.
Applicable legal bases
In the following we inform you about the legal basis of the Data Protection Ordinance (DSGVO), on the basis of which we process personal data. Please note that, in addition to the provisions of the DSGVO, the national data protection regulations in your or our country of residence and domicile may also apply.
Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO) - The data subject has given his/her consent to the processing of his/her personal data for one or more specific purposes.
Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO) - Processing is necessary to safeguard the legitimate interests of the data controller or of a third party, unless the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, prevail.
National data protection regulations in Germany: In addition to the data protection regulations of the Basic Data Protection Regulation, national regulations apply to data protection in Germany. In particular, this includes the Act on Protection against Misuse of Personal Data in Data Processing (Bundesdatenschutzgesetz - BDSG). In particular, the BDSG contains special provisions on the right of information, the right of deletion, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (§ 26 BDSG), in particular with regard to the establishment, execution or termination of employment relationships as well as the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.
We shall take appropriate technical and organisational measures in accordance with the statutory requirements, taking into account the state of the art, the implementation costs and the nature, extent, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
Such measures shall include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to, and access to, input, transmission, securing and separation of data. In addition, we have established procedures to ensure the exercise of data subjects' rights, the deletion of data and responses to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
SSL encryption (https): We use SSL encryption to protect your data transmitted via our online service. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.
Transmission and disclosure of personal data
As part of our processing of personal data, it may happen that the data is transferred to other offices, companies, legally independent organisational units or persons or that it is disclosed to them. Recipients of this data may include, for example, payment institutions within the framework of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and in particular conclude corresponding contracts or agreements with the recipients of your data which serve to protect your data.
Data processing in third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of services of third parties or the disclosure or transfer of data to other persons, bodies or companies, this is only done in accordance with the legal requirements.
Subject to express consent or transfer required by contract or law, we will only process or have the data processed in third countries with a recognised level of data protection, which includes US processors certified under the "Privacy Shield", or on the basis of special guarantees, such as a contractual obligation through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).
Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user's computer. A cookie is primarily used to store information about a user during or after his visit within an online offer. The information stored can include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was viewed. The term "cookies" also includes other technologies that fulfil the same functions as cookies (e.g. if user information is stored using pseudonymous online identifiers, also referred to as "user IDs").
The following cookie types and functions are distinguished:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
- Permanent Cookies: Permanent cookies remain stored even after the browser has been closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The interests of users who are used for range measurement or marketing purposes can also be stored in such a cookie.
- First-Party-Cookies: First-Party-Cookies are set by ourselves.
- Third-Party-Cookies:: Third-Party-Cookies are mainly used by advertisers (so-called third parties) to process user information.
- Necessary (also: essential or absolutely necessary) cookies: Cookies may be absolutely necessary for the operation of a website (e.g. to save logins or other user inputs or for security reasons).
Processed types of data: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Persons concerned: Users (e.g. website visitors, users of online services).
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Provision of online services and web hosting
In order to provide our online services securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers they manage) the online services can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security and technical maintenance services.
The data processed within the framework of the provision of the hosting service may include all information relating to the users of our online service that is collected within the scope of use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.
Collection of access data and log files: We (or our web hosting provider) collect data on each access to the server (so-called server log files). Server log files can include the address and name of the websites and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.
The server log files can be used for security purposes, e.g. to avoid overloading the server (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure server utilization and stability.
Content-Delivery-Network: We use a "Content-Delivery-Network" (CDN). A CDN is a service with the help of which the contents of an online offer, in particular large media files such as graphics or program scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet.
Processed data types: Inhaltsdaten (z.B. Texteingaben, Fotografien, Videos), Nutzungsdaten (z.B. besuchte Webseiten, Interesse an Inhalten, Zugriffszeiten), Meta-/Kommunikationsdaten (z.B. Geräte-Informationen, IP-Adressen).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of Processing: Content Delivery Network (CDN), Contractual Services and Service.
Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. DSGVO).
Used services and service providers:
Netlify: hosting platform for websites; service provider: Netlify, Inc. jurisdiction of Incorporation/Organization DELAWARE, CIK (Filer ID Number): 0001672598; Netlify, Inc., 2325 3rd Street, Suite 215, 94107, San Francisco, California Website: https://www.netlify.com; Privacy Statement: https://www.netlify.com/privacy/ ; GDPR: https://www.netlify.com/gdpr/
Newsletter and broad communication
We send newsletters, e-mails and other electronic notifications (hereinafter referred to as "newsletters") only with the consent of the recipient or a legal permission. If the contents of the newsletter are specifically described within the scope of registration, they are decisive for the consent of the user. In addition, our newsletters contain information about our services and us.
In order to subscribe to our newsletters, it is generally sufficient for you to enter your e-mail address. However, we may ask you to provide a name for the purpose of addressing us personally in the newsletter, or other information, if this is required for the purposes of the newsletter.
Double opt-in procedure: The registration to our newsletter takes place in principle in a so-called Double-Opt-In procedure. This means that you will receive an e-mail after registration asking you to confirm your registration. This confirmation is necessary so that nobody can register with external 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 the changes of your data stored with the Versanddienstleister are logged.
Deletion and limitation of processing: Deletion and limitation of processing: We may store the deleted e-mail addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time. In the case of obligations to permanently observe contradictions, we reserve the right to store the e-mail address solely for this purpose in a blacklist.
The logging of the registration procedure takes place on the basis of our legitimate interests for the purposes of proving its proper course. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system..
Information on legal bases: The newsletter is sent on the basis of the recipient's consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, provided and to the extent that this is permitted by law, e.g. in the case of existing customer advertising. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to prove that it was conducted in accordance with the law.
Content: Information about us, our services, promotions and offers.
Performance measurement: The newsletters contain a so-called "web beacon", i.e. a file the size of a pixel, which is retrieved from our server or, if we use a dispatch service provider, from its server when the newsletter is opened. 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 retrieval, are first collected.
This information is used for the technical improvement of our newsletter on the basis of technical data or target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or access times. This analysis also includes determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our endeavour nor, if used, that of the dispatch service provider to observe individual users. Rather, the evaluations serve us to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
The evaluation of the newsletter and the performance measurement are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purposes of using a user-friendly and secure newsletter system, which serves both our business interests and the expectations of the users.
A separate revocation of the performance measurement is unfortunately not possible, in which case the entire newsletter subscription must be cancelled or contradicted.
Prerequisite for the use of free services: Consent to the sending of mailings can be made dependent on the use of free services (e.g. access to certain content or participation in certain campaigns) as a prerequisite. If users wish to make use of the free service without registering for the newsletter, please contact us.
Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
Persons concerned: Communication partners, users (e.g. website visitors, users of online services).
Purposes of processing: direct marketing (e.g. by e-mail or post), contractual services and service.
Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a DSGVO), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. DSGVO).
Opt-Out: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options listed above, preferably e-mail.
Used services and service providers:
Mailchimp: e-mail marketing platform; service provider: "Mailchimp" - Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; website: : https://mailchimp.com; privacy statement: https://mailchimp.com/legal/privacy/; Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active.
Deletion of data
The data processed by us will be deleted in accordance with the statutory provisions as soon as their consent permitted for processing is revoked or other permissions lapse (e.g. if the purpose of processing this data has lapsed or it is not necessary for the purpose).
If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.
Further information on the deletion of personal data can also be found in the individual data protection notices of this data protection declaration.
Modification and updating of the data protection declaration
We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as the changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organisations in this data protection declaration, please note that the addresses may change over time and please check this information before contacting us.
Rights of data subjects
Under the DSGVO, they are entitled to various rights as affected parties, which result in particular from Articles 15 to 18 and 21 DSGVO:
- Right of objection: You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you on the basis of Art. 6 para. 1 lit. e or f DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct advertising, you have the right at any time to object to the processing of the personal data concerning you for the purpose of such advertising; this also applies to profiling insofar as it is connected with such direct advertising.
- Right of withdrawal for consents: You have the right to revoke your consent at any time.
- Right to information: You have the right to request confirmation as to whether the data concerned will be processed and to request information about this data as well as further information and a copy of the data in accordance with the statutory provisions.
- Right of rectification: You have the right, in accordance with the provisions of the law, to request the completion of the data concerning you or the rectification of inaccurate data concerning you.
- Right to cancellation and limitation of processing: You have the right, in accordance with the statutory provisions, to demand that the data relating to you be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
- Right to data transfer: You have the right to receive data concerning you which you have made available to us in a structured, common and machine-readable format in accordance with the legal requirements or to demand its transfer to another responsible person.
- Complaint to supervisory authority: You also have the right, in accordance with the statutory provisions, to lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, your place of work or the place of the presumed infringement, if you are of the opinion that the processing of your personal data violates the DSGVO.
Definitions of terms
This section provides an overview of the terms used in this privacy statement. Many of the terms are taken from the law and defined above all in Art. 4 DSGVO. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.
- Content Delivery Network (CDN): A "Content Delivery Network" (CDN) is a service with the help of which the contents of an online offer, in particular large media files such as graphics or program scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet.
- Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or with one or more specific characteristics that express the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
- Data controller (also: person in charge): a "data controller" is a natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
- Processing: "processing" means any operation or set of operations which is carried out with or without the aid of automated processes and which is linked to personal data. The term is broad and covers practically all handling of data, be it collection, analysis, storage, transmission or erasure.