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Introduction

With the following data protection declaration, we would like to inform you about which types of your personal data (hereinafter also referred to as “data”) we process, for what purposes and to what extent. This data protection declaration applies to all processing of personal data carried out by us, both in the context 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 offering”).

The terms used are not gender specific.

As of: 21 December 2023

Responsible

Your Morocco Owner: Taoufiq Ouabi
Merzouga 52202 – Morocco
Authorized representative: Taoufiq Ouabi
Email address: contact@letsdiscovermorocco.com
Phone: +212 663 008 294
 Imprint: https://wordpress-649903-3750568.cloudwaysapps.com/impressum/

Overview of processing

The following overview summarises the types of data processed and the purposes of their processing and refers to the persons concerned.

Types of data processed

  • Inventory data.
  • Payment details.
  • Contact details.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta/communication data.
  • Applicant data.

Categories of data subjects

  • Customers.
  • Employees.
  • Interested parties.
  • communication partner.
  • users.
  • applicants.
  • Business and contractual partners.

Purposes of processing

  • Provision of contractual services and customer service.
  • Contact requests and communication.
  • direct marketing.
  • Office and organizational procedures.
  • Conversion measurement.
  • Managing and responding to inquiries.
  • Application process.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offering and user-friendliness.

Relevant legal bases

Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Article 6 (1) sentence 1 lit. a. GDPR) – The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
  • Contract performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b. GDPR) – The processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.
  • Legal obligation (Article 6 (1) sentence 1 lit. c. GDPR) – The processing is necessary to fulfill a legal obligation to which the controller is subject.
  • Legitimate interests (Article 6 (1) sentence 1 lit. f. GDPR) – Processing is necessary to safeguard the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject which require protection of personal data prevail.
  • Application process as a pre-contractual or contractual relationship (Art. 9 Para. 2 lit. b GDPR) – If, as part of the application process, special categories of personal data within the meaning of Art. 9 Para. 1 GDPR (e.g. health data, such as severe disability status or ethnic origin) are requested from applicants so that the controller or the data subject can exercise the rights arising from employment law and social security and social protection law and fulfill his or her obligations in this regard, their processing takes place in accordance with Art. 9 Para. 2 lit. b. GDPR, in the case of the protection of vital interests of the applicants or other persons in accordance with Art. 9 Para. 2 lit. c. GDPR or for the purposes of healthcare or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnostics, care or treatment in the health or social sector or for the administration of systems and services in the health or social sector in accordance with Art. 9 Para. 2 lit. h. GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 Para. 2 lit. a. GDPR.

In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. This includes in particular the law on protection against misuse of personal data in data processing (Federal Data Protection Act – BDSG). The BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission and automated decision-making in individual cases, including profiling. It also regulates data processing for the purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. In addition, state data protection laws of the individual federal states may apply.

Security measures

In accordance with the legal requirements, 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 different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

The measures include in particular ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to it, input, transfer, ensuring availability and separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to data threats. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

Transmission of personal data

As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons or that it is disclosed to them. The recipients of this data may include, for example, 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 appropriate contracts or agreements with the recipients of your data that 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 if the processing takes place in the context of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies, this will only be done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transmission, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, if certifications or binding internal data protection regulations exist (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

Deletion of data

The data we process will be deleted in accordance with legal requirements as soon as the consents permitted for processing are revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or it is no longer required for the purpose).

If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted 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 retained for commercial or tax law reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.

As part of our data protection information, we can provide users with further information on the deletion and storage of data that applies specifically to the respective processing operations.

Use of cookies

Cookies are small text files or other storage notes that store information on end devices and read information from the end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed or the functions used in an online service. Cookies can also be used for different purposes, e.g. to ensure the functionality, security and convenience of online services and to create analyses of visitor flows.

Notes on consent: We use cookies in accordance with legal regulations. We therefore obtain prior consent from users, unless this is not required by law. Consent is not necessary in particular if the storage and reading of information, including cookies, is absolutely necessary in order to provide users with a telemedia service that they have expressly requested (i.e. our online offering). The revocable consent is clearly communicated to users and contains information on the respective cookie usage.

Notes on data protection legal bases: The data protection legal basis on which we process users’ personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and improving its usability) or, if this is done as part of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We will explain the purposes for which we process cookies in the course of this data protection declaration or as part of our consent and processing processes.

Storage period:  With regard to the storage period, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies):  Temporary cookies are deleted at the latest after a user has left an online offering and closed his or her device (e.g. browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The user data collected using cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.

General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also object to processing in accordance with the legal requirements in Art. 21 GDPR (further information on objection can be found in this data protection declaration). Users can also declare their objection using the settings in their browser.

Cookie settings/opt-out option: https://www.webtoffee.com/product/gdpr-cookie-consent/

Further information on processing procedures, methods and services:

  • Processing of cookie data based on consent: We use a cookie consent management process within the framework of which the consent of users to the use of cookies or the processing and providers mentioned in the cookie consent management process can be obtained and managed and revoked by users. The declaration of consent is stored so that it does not have to be requested again and so that consent can be proven in accordance with the legal obligation. Storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies) in order to be able to assign consent to a user or their device. Subject to individual information about the providers of cookie management services, the following information applies: The consent can be stored for up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and device used.

Business Services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) within the framework of contractual and comparable legal relationships as well as related measures and within the framework of communication with the contractual partners (or pre-contractually), e.g. to answer inquiries.

We process this data in order to fulfil our contractual obligations. This includes in particular the obligations to provide the agreed services, any updating obligations and remedy in the event of warranty and other service disruptions. In addition, we process the data to protect our rights and for the purposes of the administrative tasks associated with these obligations and the company organization. In addition, we process the data on the basis of our legitimate interests in proper and economical business management and in security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. The contractual partners are informed about other forms of processing, e.g. for marketing purposes, in the context of this data protection declaration.

We inform our contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.

We delete the data after the expiry of statutory warranty and similar obligations, i.e., generally after 4 years, unless the data is stored in a customer account, e.g. for as long as it must be kept for legal archiving reasons (e.g. for tax purposes, usually 10 years). We delete data that was disclosed to us by the contractual partner as part of an order in accordance with the specifications of the order, generally after the end of the order.

To the extent that we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply to the relationship between the users and the providers.

Travel-related services

We process the data of our customers and prospective customers (collectively referred to as “customers”) in accordance with the underlying contractual relationship. We may also process information about the characteristics and circumstances of people or items belonging to them if this is necessary within the framework of the contractual relationship. This may include, for example, information about personal circumstances, mobile property and financial situation.

As part of our assignment, it may be necessary for us to process special categories of data within the meaning of Art. 9 Para. 1 GDPR, in particular information about a person’s health. The processing is carried out in order to protect the health interests of the customers and otherwise only with the consent of the customers.

If necessary for the performance of the contract or legally required, or with the customer’s consent or based on our legitimate interests, we disclose or transmit customer data, for example to the service providers involved in the performance of the travel services.

  • Types of data processed: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. e-mail, telephone numbers); contract data (e.g. contract subject, term, customer category).
  • Affected persons: interested parties; business and contractual partners.
  • Purposes of processing: Provision of contractual services and customer service; contact requests and communication; office and organizational procedures; administration and response to inquiries.
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b. GDPR); Legal obligation (Art. 6 Para. 1 Clause 1 Letter c. GDPR); Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f. GDPR).

Provision of the online offer and web hosting

In order to provide our online offering securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offering can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.

The data processed in the context of providing the hosting service may include all information concerning the users of our online service that arises in the context of use and communication. This usually includes the IP address, which is necessary in order to be able to deliver the content of online services to browsers, and all entries made within our online service or on websites.

  • Types of data processed: Content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Purpose of processing: Provision of our online offer and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Further information on processing procedures, methods and services:

  • Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The 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 servers (particularly in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability; Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that needs to be retained for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified.
  • dogado: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: dogado GmbH, Saarlandstr. 25, D-44139 Dortmund, Germany; Website: https://www.dogado.de/ ; Privacy policy: https://www.dogado.de/legal/datenschutz ; Contract processing agreement: https://www.dogado.de/faq/artikel/wie-kann-ich-einen-vertrag-zur-auftragsverarbeitung-av-gemaess-art-28-dsgvo-abschliessen/ .

Communication via Messenger

We use messengers for communication purposes and therefore ask you to note the following information on the functionality of the messengers, encryption, the use of communication metadata and your options for objection.

You can also contact us in alternative ways, e.g. by telephone or email. Please use the contact options provided to you or the contact options provided within our online offering.

In the case of end-to-end encryption of content (ie, the content of your message and attachments), we would like to point out that the communication content (ie, the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messenger with encryption activated to ensure that the message content is encrypted.

However, we would also like to point out to our communication partners that although the providers of the messengers cannot see the content, they can find out that and when communication partners communicate with us, as well as technical information about the device used by the communication partners and, depending on the settings of their device, location information (so-called metadata) are also processed.

Notes on legal bases:  If we ask communication partners for permission before communicating with them via messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and they contact us on their own initiative, for example, we use messenger in relation to our contractual partners and in the context of contract initiation as a contractual measure and in the case of other interested parties and communication partners on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners in communicating via messenger. We would also like to point out that we will not transmit the contact details provided to us to the messenger for the first time without your consent.

Revocation, objection and deletion: You can revoke your consent at any time and object to communication with us via messenger at any time. In the case of communication via messenger, we delete the messages in accordance with our general deletion guidelines (ie, for example, as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information from the communication partners, if no reference to a previous conversation is to be expected and there are no statutory retention periods that prevent deletion.

Reservation of reference to other communication channels: Finally, we would like to point out that for reasons of your security, we reserve the right not to answer inquiries via messenger. This is the case, for example, if internal contractual details require special confidentiality or if a response via messenger does not meet the formal requirements. In such cases, we will refer you to more appropriate communication channels.

  • Types of data processed: Contact data (e.g. email, telephone numbers); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Affected persons: communication partners.
  • Purposes of processing: contact requests and communication; direct marketing (e.g. by email or post).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Further information on processing procedures, methods and services:

Application process

The application process requires applicants to provide us with the data required for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the information provided there.

The information required generally includes personal information such as name, address, contact details and proof of the qualifications required for a position. We will be happy to provide additional information required upon request.

If provided, applicants can send us their applications using an online form. The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications via email. However, please note that emails are generally not sent encrypted over the Internet. Emails are usually encrypted during transport, but not on the servers from which they are sent and received. We cannot therefore accept any responsibility for the transmission path of the application between the sender and receipt on our server.

For the purposes of searching for applicants, submitting applications and selecting applicants, we may use applicant management or recruitment software and platforms and services from third parties in compliance with legal requirements.

Applicants are welcome to contact us about how to submit their application or send us their application by post.

Processing of special categories of data: If, as part of the application process, special categories of personal data within the meaning of Art. 9 (1) GDPR (e.g. health data, such as severe disability status or ethnic origin) are requested from applicants so that the controller or the data subject can exercise the rights arising from employment law and social security and social protection law and fulfil his or her obligations in this regard, their processing will be carried out in accordance with Art. 9 (2) lit. b. GDPR, in the case of protecting the vital interests of applicants or other persons in accordance with Art. 9 (2) lit. c. GDPR or for the purposes of healthcare or occupational medicine, for assessing the employee’s ability to work, for medical diagnostics, for care or treatment in the health or social sector or for the administration of systems and services in the health or social sector in accordance with Art. 9 (2) lit. h. GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 (2) (a) GDPR.

Deletion of data: In the event of a successful application, the data provided by applicants may be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicants’ data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Subject to a justified revocation by the applicant, deletion will take place no later than after a period of six months, so that we can answer any follow-up questions about the application and meet our obligations to provide evidence under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements.

Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the ongoing application process and that they can revoke their consent at any time for the future.

  • Types of data processed: Applicant data (e.g. personal details, postal and contact addresses, the documents relating to the application and the information contained therein, such as cover letters, CVs, references and other information about the person or qualifications provided voluntarily by applicants with regard to a specific position).
  • Persons concerned: applicants.
  • Purposes of processing: Application procedure (justification and possible subsequent implementation as well as possible subsequent termination of the employment relationship).
  • Legal basis: Application process as a pre-contractual or contractual relationship (Art. 9 Para. 2 lit. b GDPR).

Cloud services

We use software services accessible via the Internet and running on the servers of their providers (so-called “cloud services”, also referred to as “software as a service”) for the following purposes: document storage and management, calendar management, e-mail sending, spreadsheets and presentations, exchange of documents, content and information with specific recipients or publication of web pages, forms or other content and information as well as chats and participation in audio and video conferences.

In this context, personal data may be processed and stored on the providers’ servers if they are part of communication processes with us or are otherwise processed by us as set out in this data protection declaration. This data may include, in particular, master data and contact details of users, data on transactions, contracts, other processes and their contents. The providers of the cloud services also process usage data and metadata, which they use for security purposes and to optimize the service.

If we use cloud services to provide forms, documents and content to other users or publicly accessible websites, the providers may store cookies on users’ devices for the purposes of web analysis or to remember users’ settings (e.g. in the case of media control).

Notes on legal bases: If we ask for consent to use cloud services, the legal basis for processing is consent. Furthermore, their use can be part of our (pre)contractual services, provided that the use of cloud services was agreed within this framework. Otherwise, the user data is processed on the basis of our legitimate interests (ie, interest in efficient and secure administration and collaboration processes).

  • Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Affected persons: customers; employees (e.g. employees, applicants, former employees); interested parties; communication partners.
  • Purposes of processing: Office and organisational procedures.
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Further information on processing procedures, methods and services:

Newsletters and electronic notifications

We only send newsletters, emails and other electronic notifications (hereinafter “newsletters”) with the consent of the recipient or with legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user’s consent. Otherwise, our newsletters contain information about our services and us.

To subscribe to our newsletter, it is generally sufficient to provide your email address. However, we may ask you to provide a name for the purpose of addressing you personally in the newsletter or other information if this is necessary for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter is always carried out using a so-called double opt-in procedure. This means that after registration you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register using someone else’s email address. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider are also logged.

Deletion and restriction of processing:  We can store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove that consent was previously 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 previous existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address in a block list (so-called “block list”) for this purpose alone.

The registration process is logged on the basis of our legitimate interests for the purpose of proving that it was carried out correctly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure delivery system.

Notes on legal bases: The newsletter is sent based on the consent of the recipient or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of advertising to existing customers. If we commission a service provider to send emails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests in order to prove that it was carried out in accordance with the law.

Contents:

Information about us, our services, promotions and offers.

  • Types of data processed: 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).
  • Affected persons: communication partners.
  • Purposes of processing: direct marketing (e.g. by e-mail or post).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
  • Opt-out option: You can cancel your subscription to 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 use one of the contact options listed above, preferably email.

Further information on processing procedures, methods and services:

  • Measuring opening and click rates: 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. As part 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, is initially collected. This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. The evaluations help us 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. The measurement of the opening rates and click rates as well as the storage of the measurement results in the user profiles and their further processing are based on the consent of the users. A separate revocation of the success measurement is unfortunately not possible; in this case the entire newsletter subscription must be canceled or objected to. In this case, the stored profile information is deleted.
  • CleverReach: E-mail marketing platform; Service provider: CleverReach GmbH & Co. KG, //CRASH Building, Schafjückenweg 2, 26180 Rastede, Germany; Website: https://www.cleverreach.com/de ; Privacy policy: https://www.cleverreach.com/de/datenschutz/ ; Data processing agreement: concluded with provider.
  • Mailjet: email sending and email marketing platform; service provider: Mailjet SAS, 13-13 bis, rue de l’Aubrac, 75012 Paris, France; website: https://www.mailjet.de ; privacy policy: https://www.mailjet.de/privacy-policy .

Advertising communication via email, post, fax or telephone

We process personal data for the purposes of advertising communication, which can take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.

The recipients have the right to revoke their consent at any time or to object to promotional communications at any time.

After revocation or objection, we can store the data required to prove consent for up to three years on the basis of our legitimate interests before we delete it. 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 previous existence of consent is confirmed at the same time.

  • Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers).
  • Affected persons: communication partners.
  • Purposes of processing: direct marketing (e.g. by e-mail or post).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Online marketing

We process personal data for the purposes of online marketing, which may include in particular the marketing of advertising space or the presentation of advertising and other content (collectively referred to as “content”) based on the potential interests of users and the measurement of their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used by means of which the information about the user relevant to the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used as well as information on usage times and functions used. If users have consented to the collection of their location data, this can also be processed.

The IP addresses of the users are also stored. However, we use available IP masking procedures (ie pseudonymization by shortening the IP address) to protect the users. In general, no clear user data (such as email addresses or names) is stored as part of the online marketing process, but rather pseudonyms. This means that neither we nor the providers of the online marketing process know the actual identity of the users, only the information stored in their profiles.

The information in the profiles is usually stored in cookies or using similar processes. These cookies can generally also be read later on other websites that use the same online marketing process and analyzed for the purposes of displaying content, as well as supplemented with further data and stored on the server of the online marketing process provider.

In exceptional cases, clear data can be assigned to profiles. This is the case if, for example, the users are members of a social network whose online marketing processes we use and the network links the users’ profiles with the aforementioned information. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.

In principle, we only receive access to summarized information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, ie, for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyze the success of our marketing measures.

Unless otherwise stated, please assume that cookies used will be stored for a period of two years.

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

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Marketing; Profiles with user-related information (creation of user profiles); Conversion measurement (measurement of the effectiveness of marketing measures).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
  • Opt-out option: Please refer to the privacy policy of the respective provider and the opt-out options provided by the provider (so-called “opt-out”). If no explicit opt-out option has been provided, you have the option of deactivating cookies in your browser settings. However, this may restrict the functions of our online offering. We therefore also recommend the following opt-out options, which are offered in summary for each region: a) Europe: https://www.youronlinechoices.eu . b) Canada: https://www.youradchoices.ca/choices . c) USA: https://www.aboutads.info/choices . d) Cross-regional: https://optout.aboutads.info .

Further information on processing procedures, methods and services:

Customer reviews and rating processes

We participate in review and rating processes to evaluate, optimize and promote our services. If users rate us via the participating rating platforms or processes or otherwise provide feedback, the general terms and conditions or terms of use and the data protection notices of the providers also apply. As a rule, the rating also requires registration with the respective providers.

In order to ensure that the people giving the reviews have actually used our services, we transmit the necessary data regarding the customer and the service used to the respective review platform (including name, email address and order number or item number) with the customer’s consent. This data is used solely to verify the authenticity of the user.

  • Types of data processed: Contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Affected persons: customers; users (e.g. website visitors, users of online services).
  • Purposes of processing: Feedback (e.g. collecting feedback via online form).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Further information on processing procedures, methods and services:

Presences in social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.

We would like to point out that user data may be processed outside the European Union. This may result in risks for users because it could, for example, make it more difficult to enforce user rights.

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

For a detailed description of the respective processing methods and the options for objection (opt-out), please refer to the data protection declarations and information provided by the operators of the respective networks.

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

  • Types of data processed: Contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Purposes of processing: contact requests and communication; feedback (e.g. collecting feedback via online form); marketing.
  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Further information on processing procedures, methods and services:

  • Instagram: social network; service provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; website: https://www.instagram.com ; privacy policy: https://instagram.com/about/legal/privacy .
  • Facebook Pages: Profiles within the social network Facebook – We are jointly responsible with Facebook Ireland Ltd. for collecting (but not further processing) data from visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content users view or interact with, or the actions they take (see “Things you and others do and provide” in the Facebook Data Policy: https://www.facebook.com/policy ), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see “Device information” in the Facebook Data Policy: https://www.facebook.com/policy ). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services called “Page Insights” to page operators so that they can gain insights into how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook (“Information on Page Insights”, https://www.facebook.com/legal/terms/page_controller_addendum ), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of those affected (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular the right to information, deletion, objection and complaint to the responsible supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information on Page Insights” ( https://www.facebook.com/legal/terms/information_about_page_insights_data ); Service provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Standard contractual clauses (ensuring data protection levels when processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Further information: Agreement on joint responsibility: https://www.facebook.com/legal/terms/information_about_page_insights_data.

Plugins and embedded functions and content

We incorporate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may include, for example, graphics, videos or city maps (hereinafter referred to uniformly as “content”).

The integration always requires that the third-party providers of this content process the IP address of the user, since without the IP address they would not be able to send the content to their browser. The IP address is therefore required to display this content or functions. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers can 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 can also be stored in cookies on the user’s device and can contain, among other things, technical information about the browser and operating system, referring websites, the time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.

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

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses); inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness; provision of contractual services and customer service; profiles with user-related information (creation of user profiles).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Further information on processing procedures, methods and services:

Management, organization and tools

We use services, platforms and software from other providers (hereinafter referred to as “third-party providers”) for the purposes of organizing, managing, planning and providing our services. When selecting third-party providers and their services, we observe the legal requirements.

In this context, personal data may be processed and stored on the servers of third-party providers. This may affect various data that we process in accordance with this data protection declaration. This data may include, in particular, master data and contact details of users, data on transactions, contracts, other processes and their contents.

If users are referred to third-party providers or their software or platforms as part of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, to optimize the service or for marketing purposes. We therefore ask that you observe the data protection notices of the respective third-party providers.

Notes on legal bases: If we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Furthermore, their use can be a component of our (pre)contractual services, provided that the use of third-party providers was agreed within this framework. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.

  • Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Affected persons: communication partners; users (e.g. website visitors, users of online services).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Changes and updates to the privacy policy

We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing we carry out 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 organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.

Rights of the data subjects

As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:

  • Right to object: You have the right to object at any time to the processing of personal data concerning you which is carried out on the basis of Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you are processed in order to conduct direct advertising, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct advertising.
  • Right to withdraw consent: You have the right to withdraw consent at any time.
  • Right to information: You have the right to request confirmation as to whether or not data concerning you is being processed and to request information about this data as well as further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: You have the right, in accordance with the statutory provisions, to request that the data concerning you be completed or that inaccurate data concerning you be rectified.
  • Right to erasure and restriction of processing: You have the right, in accordance with the statutory provisions, to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
  • Right to data portability: You have the right to receive the data concerning you that you have made available to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transmitted to another controller.
  • Complaint to a supervisory authority: In accordance with the statutory provisions and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State in which you habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Definitions

This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined primarily in Art. 4 GDPR. The legal definitions are binding. The following explanations, however, are intended primarily to aid understanding. The terms are sorted alphabetically.

  • Conversion measurement: Conversion measurement (also known as “visit action evaluation”) is a process that can be used to determine the effectiveness of marketing measures. To do this, a cookie is usually stored on the user’s device within the websites on which the marketing measures take place and then retrieved again on the target website. For example, we can use this to see whether the ads we have placed on other websites were successful.
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “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. a cookie) or to one or more special characteristics that express the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any type of automated processing of personal data that consists in using this personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information relating to demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Controller: The “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of processing personal data.
  • Processing: “Processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it collection, evaluation, storage, transmission or deletion.

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