Privacy Policy

PRIVACY POLICY
(Privacy Policy) / Data protection declaration
Who we are
The address of our website is: https://www.zeilen.consulting

This privacy policy informs you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) 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).

Person responsible
Rows Ltd.
Turmstrasse 4
D- 78467 Constance
Germany
Tel: +49 (7531) 9369888
E-mail address: hello@pepperandpartner.com
Link to imprint: https://www.zeilen.consulting/impressum

Types of data processed:
– Inventory data (e.g., names, 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, behavior, 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 Article 13 of the GDPR, we inform you of the legal basis for our data processing activities. If the legal basis is not mentioned in the privacy statement, the following applies: The legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 DSGVO, the legal basis for processing to fulfill our services and carry out contractual measures and respond to inquiries is Art. 6(1)(b) DSGVO, the legal basis for processing to fulfill our legal obligations is Art. 6(1)(c) DSGVO, and the legal basis for processing to protect our legitimate interests is Art. 6(1)(f) 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.

Security measures
We take appropriate technical and organizational measures in accordance with Art. 32 DSGVO, taking into account the state of the art, the implementation costs 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, in order to ensure a level of protection appropriate to the risk.

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 already take the protection of personal data into account during 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 (Article 25 of the GDPR).

Cooperation with processors and third parties
If, in the course of our processing, we disclose data to other persons and companies (order processors or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a 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 pursuant to Art. 6 (1) lit. b DSGVO), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we commission third parties to process data on the basis of a so-called “order processing agreement”, this is done on the basis of Art. 28 DSGVO.

Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this happens in the context of using third-party services or disclosing, or transferring data to third parties, this will only happen if it is done to fulfill 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 allow the processing of data in a third country only if the special requirements of Art. 44 et seq. DSGVO are met. I.e. the processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to that of the EU (e.g. for the USA by the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).

Rights of the data subjects
You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with Art. 15 DSGVO.

You have according to. Art. 16 DSGVO the right to request the completion of the data concerning you or the correction of incorrect data concerning you.

You have the right, in accordance with Art. 17 DSGVO, to request that data concerning you be deleted without delay, or alternatively, in accordance with Art. 18 DSGVO, to request restriction of the processing of the data.

You have the right to request that the data concerning you that you have provided to us be received in accordance with Art. 20 DSGVO and to request that it be transferred to other data controllers.

You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 DSGVO.

Right of withdrawal
You have the right to revoke any consent given in accordance with Art. 7 (3) DSGVO with effect for the future.

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

Cookies and right to object in the case of direct advertising
Cookies” are small files that are stored on users’ computers. Various data 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 or her 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 U.S. 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 not all functions of this online offer can then be used.

Deletion of data
The data processed by us will be deleted or restricted in its processing in accordance with Articles 17 and 18 DSGVO. 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.

According to legal requirements in Germany, data is stored for 10 years in accordance with §§ 147 para. 1 AO, 257 para. 1 nos. 1 and 4, para. 4 HGB (books, records, management reports, accounting vouchers, commercial books, documents relevant for taxation, etc.) and 6 years according to § 257 para. 1 nos. 2 and 3, para. 4 HGB (commercial letters).

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

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 on the basis of Art. 6 para. 1 lit. b (execution of order transactions) and c (legally required archiving) DSGVO. 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 to legal advisors and authorities. The data is only processed in third countries if this is necessary for the fulfillment of the contract (e.g. at the request of the customer for delivery or payment).

Users can optionally create a user account, in which they can view their orders in particular. As part of the registration process, the required mandatory information will be provided to users. User accounts are not public and cannot be indexed by search engines. If users have cancelled 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 in accordance with Art. 6 para. 1 lit. c DSGVO. Information in the customer account remains until its deletion with subsequent archiving in the event of a legal obligation. It is the responsibility of the users to save their data in the event of termination before the end of the contract.

Within the scope of registration and renewed registrations as well as the 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 claims or there is a legal obligation to do so pursuant to Art. 6 Para. 1 lit. c DSGVO.

Deletion takes place after the expiry of legal warranty and comparable obligations, the necessity of storing the data is reviewed every three years; in the case of legal archiving obligations, deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) storage obligation).

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 are necessary for the justification and fulfillment of the 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.

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. 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 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 provided by 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 data provided in the context of comments and contributions, will be stored by us permanently until the objection of the users.

Comment subscriptions
Follow-up comments can be subscribed to by users with their consent pursuant to Art. 6 (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.

Akismet anti-spam check
Our online offer uses the service “Akismet”, which is offered by Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA. The use is based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f) DSGVO. With the help of this service, comments from real people are distinguished from spam comments. For this purpose, all comment details are sent to a server in the USA, where they are analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data is stored beyond this time. This information includes the name entered, the email address, the IP address, the comment content, the referrer, information on the browser used as well as the computer system and the time of the entry.

More information on the collection and use of data by Akismet can be found in Automattic’s privacy policy: https://automattic.com/privacy/.

Users are welcome to use pseudonyms, or to refrain from entering their name or email address. You can completely prevent the transfer of data by not using our commenting system. That would be a shame, but unfortunately we don’t see any other alternatives that work just as effectively.

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 the transmission of 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.

Retrieval of emojis and smilies
Within our WordPress blog, graphical emojis (or smilies), i.e. small graphical files expressing emotions, are used that are retrieved from external servers. Here, the providers of the servers, collect the IP addresses of the users. This is necessary so that the emoji files can be transmitted to the users’ browsers. The Emojie service is provided by Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA. Privacy policy of Automattic: https://automattic.com/privacy/. The server domains used are s.w.org and twemoji.maxcdn.com. As far as we know, these are so-called content delivery networks, i.e. servers that only serve to transmit files quickly and securely, and the users’ personal data is deleted after transmission.

The use of emojis is based on our legitimate interests, i.e. interest in an attractive design of our online offer according to Art. 6 para. 1 lit. f. DSGVO.

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

CRM system Zendesk
We use the CRM system “Zendesk”, of the provider Zendesk, Inc., 989 Market Street #300, San Francisco, CA 94102, USA, in order to be able to process user inquiries faster and more efficiently (legitimate interest pursuant to Art. 6 para. 1 lit. f. DSGVO ).

Zendesk is certified under the Privacy Shield agreement and thereby offers an additional guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000TOjeAAG&status=Active).

Zendesk uses the data of the users only for the technical processing of the requests and does not pass them on to third parties. To use Zendesk, at least a correct e-mail address is required. Pseudonymous use is possible. In the course of processing service requests, it may be necessary to collect further data (name, address).

If users do not agree to data collection via and data storage in Zendesk’s external system, we offer them alternative contact options for submitting service requests by e-mail, telephone, fax or mail.

For more information, users should refer to Zendesk’s privacy policy: https://www.zendesk.de/company/customers-partners/privacy-policy/.

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 described procedures.

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 request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time.

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. In addition, our newsletters contain information about our products and accompanying information (e.g. safety instructions), offers, promotions and our company.

Double-Opt-In and logging: The registration for our newsletter takes place 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 § 107 para. 2 TKG 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 107 (2) and (3) TKG.

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.

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 offering.

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, respectively our hosting provider, collect 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.

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 Policy: https://www.google.com/intl/de/tagmanager/use-policy.html.

Google Analytics
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) 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 users 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/technologies/ads) 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 match the potential interest of users.

Google Adsense with personalized ads
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 services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).

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 services of Google AdWords and conversion measurement 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 “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 in which he or she has expressed interest 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 Doubleclick 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 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 on Google’s use of data, settings and objection options, please refer to Google’s privacy policy (https://policies.google.com/technologies/ads) and the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).

Integration of third-party services and content
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) 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 combined with such information from other sources.

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.

Instagram
Within our online offer, functions and contents 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/.

Comments

When visitors post comments on the website, we collect the data displayed in the comment form, as well as the visitor’s IP address and the user agent string (this identifies the browser) to help detect spam.

An anonymized string may be created from your email address (also called a hash) and passed to the Gravatar service to check if you are using it. The privacy policy of the Gravatar service can be found here: https://automattic.com/privacy/. After your comment is approved, your profile picture will be publicly visible in the context of your comment.

Media
If you are a registered user and upload photos to this website, you should avoid uploading photos with an EXIF GPS location. Visitors to this website could download photos stored on this website and extract their location information.

Cookies
When you post a comment on our website, it may be a consent to store your name, email address and website in cookies. This is a convenience feature so that when you post another comment, you don’t have to re-enter all this information. These cookies are stored for one year.

If you have an account and log in to this website, we will set a temporary cookie to determine if your browser accepts cookies. This cookie does not contain any personally identifiable information and is discarded when you close your browser.

When you sign in, we will set some cookies to store your login information and viewing options. Login cookies expire after two days and display option cookies expire after one year. If you select “Stay signed in” when you sign up, your sign-in will be maintained for two weeks. When you log out of your account, the login cookies are deleted.

When you edit or publish an article, an additional cookie is stored in your browser. This cookie does not contain any personal data and only refers to the post ID of the article you just edited. The cookie expires after one day.

Embedded content from other websites
Posts on this website may contain embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves exactly as if the visitor had visited the other website.

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

How long we store your data
When you post a comment, it is stored indefinitely, including metadata. This allows us to automatically detect and approve follow-up comments instead of holding them in a moderation queue.

For users who register on our site, we also store the personal information they provide in their user profiles. All users can view, change, or delete their personal information at any time (the username cannot be changed). Administrators of the website can also view and modify this information.

What rights you have to your information
If you have an account on this website or have posted comments, you may request an export of your personal information from us, including any information you have provided to us. In addition, you can request the deletion of all personal data we have stored about you. This does not include data that we are required to retain due to administrative, legal or security needs.

Where we send your data
Visitor comments may be examined by an automated service for spam detection.PRIVACY POLICY
(Privacy Policy) / Data protection declaration
Who we are
The address of our website is: https://www.zeilen.gmbh

Person responsible
Rows Ltd.
Turmstrasse 4
D- 78467 Constance
Germany
Tel: +49 (7531) 9369888
E-mail address: hello@zeilen.org
Link to imprint: https://www.zeilen.org/impressum