Data privacy

Data privacy

Introduction

With the following data protection declaration, we would like to explain to you which types of your personal data (hereinafter also referred to as "data") we process, for which purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both 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 offer") ).

The terms used are not gender specific.

As of August 21, 2021

Table of contents

Responsible person

Andreas Friedrich
Emmentaler Str.76d
D-13407 Berlin

Telephone: 030 - 40363409
Email address: info@friedrich.re

Imprint: friedrich.re/en/impressum .

Overview of the processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

Categories of data subjects

Purposes of processing

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 requirements may apply in your or our country of residence or domicile. Furthermore, if more specific legal bases are relevant in individual cases, we will inform you of this in the data protection declaration.

National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national data protection regulations apply in Germany. This includes in particular the law on the protection against misuse of personal data during data processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases, including profiling. 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.Furthermore, state data protection laws of the individual federal states can be applied.

Safety measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons to ensure a level of protection appropriate to the risk.

The measures include, in particular, securing the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, transfer, securing of availability and their separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to the threat to the data. Furthermore, we consider the protection of personal data already in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and data protection-friendly default settings.

Shortening of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a full IP address is not required, the IP address will be shortened (also referred to as "IP masking"). The last two digits or the last part of the IP address after a point are removed or replaced by placeholders. The shortening of the IP address is intended to prevent or make it much more difficult to identify a person using their IP address.

SSL encryption (https): We use SSL encryption to protect your data transmitted via our online offer. You can recognize such encrypted connections by the prefix https: // in the address line of your browser.

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as the consents allowed for processing are revoked or other permissions are no longer applicable (e.g. if the purpose of processing this data is no longer applicable or is not required for the purpose).

If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. In other words, the data is blocked and not processed for other purposes. This applies, for example, to data that must be stored 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.

Our data protection information may also contain further information on the storage and deletion of data, which have priority for the respective processing.

Use of cookies

Cookies are text files that contain data from visited websites or domains and are stored on the user's computer by a browser. A cookie is primarily used to store information about a user during or after their visit to an online offer. The stored information can include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was viewed. The term cookies also includes other technologies that fulfill the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also known as "user IDs")

A distinction is made between the following types of cookies and functions:

Notes on legal bases: The legal basis on which we process your personal data with the help of cookies depends on whether we ask for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offer and its improvement) or, if the use of cookies is necessary, to fulfill our contractual obligations.

Storage duration: If we do not provide you with any explicit information on the storage duration of permanent cookies (e.g. as part of a so-called cookie opt-in), please assume that the storage duration can be up to two years.

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke your consent or to object to the processing of your data using cookie technologies ( collectively referred to as "opt-out"). You can first explain your objection using the settings of your browser, e.g. by deactivating the use of cookies (which can also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be made using a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further objection notices in the context of the information on the service providers and cookies used.

Processing of cookie data on the basis of consent: We use a procedure for cookie consent management, in the context of which the consent of the user to the use of cookies or the processing and provider mentioned in the context of the cookie consent management procedure is obtained and managed and revoked by the users can be. The declaration of consent is saved in order not to have to repeat the query again and to be able to prove the consent in accordance with the legal obligation. The 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 the consent to a user or his device. Subject to individual information on the providers of cookie management services, the following information applies:The duration of the storage of the consent can be 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 end device used.

Provision of the online offer and web hosting

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

The data processed as part of the provision of the hosting offer can include all information relating to the users of our online offer that is generated in the context of use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or from websites.

Email sending and hosting: The web hosting services we use also include sending, receiving and storing emails. For these purposes, the addresses of the recipients and senders as well as other information relating to the sending of e-mails (e.g. the providers involved) and the content of the respective e-mails are processed. The aforementioned data can also be processed for the purpose of detecting SPAM. Please note that emails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted while they are being transported, but (if no so-called end-to-end encryption method is used) not on the servers from which they are sent and received.We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the receipt on our server.

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 web pages 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 belong.

The server log files can be used on the one hand for security purposes, e.g. to avoid overloading the server (especially in the case of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the load on the server and its stability.

Used services and service providers:

Community functions

The community functions we provide allow users to enter into conversations or other exchanges with one another. Please note that the use of the community functions is only permitted in compliance with the applicable legal situation, our conditions and guidelines and the rights of other users and third parties.

Storage of data for security purposes: The contributions and other inputs of the users are processed for the purposes of the community and conversation functions and, subject to legal obligations or legal permission, are not disclosed to third parties. An obligation to surrender may arise in particular in the case of illegal contributions for the purposes of legal prosecution. We point out that in addition to the content of the posts, their time and the IP address of the user are saved. This is done in order to be able to take appropriate measures to protect other users and the community.

Protection of their own data: The users decide for themselves which data they disclose about themselves within our online offer. For example, when users provide information about themselves or take part in conversations. We ask users to protect their data and to publish personal data only with care and only to the extent necessary. In particular, we ask the users to note that they have to protect their access data in a very special way and use secure passwords (ie above all long and random combinations of characters).

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). The data of the readers are only processed for the purposes of the publication medium to the extent that it is necessary for its presentation and communication between authors and readers or for reasons of security. In addition, we refer to the information on the processing of visitors to our publication medium in the context of this data protection notice.

Comments and contributions: If users leave comments or other contributions, their IP addresses can be saved on the basis of our legitimate interests. This is done for our safety if someone leaves illegal content in comments and contributions (insults, prohibited political propaganda, etc.). In this case we can be prosecuted for the comment or contribution and are therefore interested in the identity of the author.

Furthermore, we reserve the right to process user information for the purpose of spam detection on the basis of our legitimate interests.

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

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

Profile pictures of Gravatar: We use the Gravatar service within our online offer and in particular in the blog.

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

Gravatar is used on the basis of our legitimate interests, since with the help of Gravatar we offer authors of posts and comments the opportunity to personalize their posts with a profile picture.

By displaying the images, Gravatar learns the IP address of the user, as this is necessary for communication between a browser and an online service.

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

Used services and service providers:

Establishing contact and managing inquiries

When contacting us (e.g. via the contact form, email, telephone or via social media), the details of the inquiring person are processed, insofar as this is necessary to answer the contact inquiries and any requested measures.

The answering of contact inquiries in the context of contractual or pre-contractual relationships takes place to fulfill our contractual obligations or to answer (pre) contractual inquiries and otherwise on the basis of the legitimate interests in answering the inquiries.

Newsletters and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter “newsletter”) only 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 consent of the user. Incidentally, our newsletters contain information about our services and us.

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

Double opt-in procedure: The registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registration you will receive an email in which you will be asked to confirm your registration. This confirmation is necessary so that nobody can register with someone else's e-mail address. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the 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 e-mail addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time. In the event of obligations to permanently observe contradictions, we reserve the right to store the e-mail address in a blacklist for this purpose alone (so-called "blocklist").

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving that it has proceeded properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure mailing system.

Notes on legal bases: The newsletter is sent on the basis of the recipient's consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, 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 e-mails, this is done on the basis of our legitimate interests. The registration process is recorded based on our legitimate interests to demonstrate that it was carried out in accordance with the law.

Contents: Information about us, new articles, our services, promotions and offers.

Measurement of opening and click rates:

The newsletters may contain a so-called "web beacon", ie a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from its 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 for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our aim nor, if used, that of the shipping service provider to observe individual users. Rather, the evaluations serve 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 evaluation of the newsletter and the measurement of success take place, subject to the express consent of the user, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves both our business interests and the expectations of the users.

A separate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be canceled or contradicted.

Web analysis, monitoring and optimization

The web analysis (also known as "range measurement") is used to evaluate the flow of visitors to our online offer and can include behavior, interests or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of the range analysis, we can, for example, recognize at what time our online offer or its functions or content are used most often or invite you to reuse. We can also understand which areas need optimization.

In addition to web analysis, we can also use test procedures, for example to test and optimize different versions of our online offer or its components.

For these purposes, so-called user profiles can be created and saved in a file (so-called "cookie") or similar processes can be used for the same purpose. This information can include, for example, the content viewed, the websites visited and the elements and technical information used there, such as the browser used, the computer system used and information on times of use. If users have consented to their location data being collected, this can also be processed, depending on the provider.

The IP addresses of the users are also saved. However, we use an IP masking process (ie pseudonymization by shortening the IP address) to protect users. In general, in the context of web analysis, A / B testing and optimization, no clear user data (such as e-mail addresses or names) are saved, but pseudonyms. This means that we and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

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

Used services and service providers:

Online marketing

We process personal data for online marketing purposes, which can 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 processes are used, by means of which the user information relevant to the presentation of the aforementioned content is saved. This information can include content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, these can also be processed.

The IP addresses of the users are also saved. However, we use available IP masking procedures (ie, pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) are stored in the context of the online marketing process, but pseudonyms. This means that we, as well as the providers of online marketing processes, do not know the actual identity of the users, but only the information stored in their profiles.

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

As an exception, clear data can be assigned to the profiles. This is the case if the users are, for example, members of a social network whose online marketing process we use and the network connects the profiles of the users with the aforementioned information. We ask you to note that users can make additional agreements with the providers, e.g. by giving their consent during registration.

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

Unless otherwise stated, we ask you to assume that the cookies used will be stored for a period of two years.

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

Used services and service providers:

Affiliate Programs and Affiliate Links

In our online offer, we include so-called affiliate links or other references (which may include search masks, widgets or discount codes) to the offers and services of third-party providers (collectively referred to as "affiliate links"). If users follow the affiliate links or then take advantage of the offers, we can receive a commission or other benefits from these third-party providers (collectively referred to as "commission").

In order to be able to track whether the users have taken advantage of the offers of an affiliate link used by us, it is necessary for the respective third party provider to find out that the users have followed an affiliate link used within our online offer. The assignment of the affiliate links to the respective business deals or to other promotions (e.g. purchases) serves the sole purpose of accounting for commission and is canceled as soon as it is no longer required for the purpose.

For the purposes of the aforementioned assignment of the affiliate links, the affiliate links can be supplemented with certain values ​​that are part of the link or that can be stored in some other way, e.g. in a cookie. In addition to the values, the starting website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer and an online identifier of the user.

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

Used services and service providers:

Presence in social networks (social media)

We maintain an online presence 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 can be processed outside of the European Union. This can result in risks for the user because it could make it more difficult to enforce the users' rights, for example.

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

For a detailed description of the respective forms of processing and the possibilities of objection (opt-out), we 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 point out that these can be most effectively asserted with the providers. Only the providers have access to the data of the users and can take appropriate measures and provide information directly. If you still need help, you can contact us.

Facebook: We are together with Facebook Ireland Ltd. responsible for the collection (but not the further processing) of 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 the users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under "Device information" in the Facebook data policy declaration: 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 analysis services, so-called “page insights”, for website operators so that they can obtain information about how people use their pages and interact with 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 the data subject (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent 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).

Used services and service providers:

Plugins and embedded functions as well as content

We include functional and content elements in our online offer that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). This can be, for example, graphics, videos or city maps (hereinafter uniformly referred to as “content”).

The integration always presupposes 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 for the display of this content or functions. We strive 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 contain, among other things, technical information about the browser and operating system, the websites to be referred to, the time of visit and other information about the use of our online offer, as well as being linked to such information from other sources.

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

Used services and service providers:

Change and update of the data protection declaration

We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as the changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this data protection declaration, please note that the addresses may change over time and ask you to check the information before contacting us.

Definitions of terms

This section gives you an overview of the terms used in this data protection declaration. Many of the terms are taken from the law and primarily defined in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are sorted alphabetically.