Privacy policy

Introduction

With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as "data" for short) that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part 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 the "Online Offer").

The terms used are not gender-specific.

Status: July 18, 2022

Introduction
Person responsible
Contact Data Protection Officer
Overview of processing operations
Relevant legal basis
Security measures
Transfer of personal data
Data processing in third countries
Deletion of data
Use of cookies
Business services
Provision of the online offer and web hosting
Special information on applications (apps)
Registration, login and user account
Blogs and publication media
Contact and inquiry management
Newsletter and electronic notifications
Sweepstakes and contests
Surveys and polls
Modification and updating of the privacy policy
Rights of data subjects
Definitions of terms

Responsible

Divodo International GmbH
Wilhelm-Bergner-Str. 11a

21509 Glinde - Germany

Authorized representatives:

Anja Pehmöller, Remko Tiecken

E-mail address:

info@divodo.asia

Phone:

040 23936690

Imprint:

https://www.divodo.asia/impressum

Contact Data Protection Officer

datenschutzbeauftragter@divodo.asia

Overview of processing operations

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

Inventory data.
Payment data.
Contact data.
Content data.
Contract data.
Usage data.
Meta/communication data.

Categories of data subjects

Customers.
Interested parties.
Communication partners.
Users.
Sweepstakes and contest participants.
Business and contractual partners.
Participants.

Purposes of processing

Provision of contractual services and customer service.
Contact requests and communication.
Security measures.
Direct marketing.
Office and organizational procedures.
Management and response to inquiries.
Conducting sweepstakes and contests.
Feedback.
Provision of our online services and user experience.
Information technology infrastructure.

Relevant legal bases

The following is an overview of the legal basis 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. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.

Consent (Art. 6 (1) p. 1 lit. a) DSGVO) - The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
Performance of a contract and pre-contractual requests (Art. 6 (1) p. 1 lit. b) DSGVO) - Processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures carried out at the data subject's request.
Legal obligation (Art. 6 (1) p. 1 lit. c) DSGVO) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
Legitimate interests (Art. 6 (1) p. 1 lit. f) DSGVO) - Processing is necessary for the purposes of the legitimate interests of the controller or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in 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 to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for employment purposes (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

Security 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 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, in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, the deletion of data, and responses to data compromise. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software as well as procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

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

Transmission of personal data

In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. 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 comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

Data transfer within the group of companies: We may transfer personal data to other companies within our group of companies or grant them access to this data. Insofar as this transfer is for administrative purposes, the transfer of the data is based on our legitimate corporate and business interests or takes place insofar as it is necessary for the fulfillment of our contract-related obligations or if the consent of the data subjects or a legal permission exists.

Data processing in third countries

If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of using third-party services or disclosing or transferring data to other persons, entities or companies, this will only be done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, 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, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission:

https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it 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. That is, the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defense of legal claims or to protect the rights of another natural or legal person.

Within the scope of our data protection notices, we may provide users with further information on the deletion as well as on the retention of data that specifically applies to the respective processing operations.

Use of cookies

Cookies are small text files, or other memory notes, which store information on end devices and read information from the end devices. E.g. to store the login status in a user account, a shopping cart content in an e-shop, the content accessed or functions used of an online offer. Cookies can further be used for various purposes, e.g. for purposes of functionality, security and comfort of online offers as well as the creation of analyses of visitor flows.

Notes on consent: We use cookies in accordance with legal requirements. Therefore, we obtain prior consent from users except where it is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary to provide the user with a telemedia service (i.e., our online offering) that they have expressly requested. The revocable consent is clearly communicated to the users and contains the information about the respective cookie use.

Notes on legal bases under data protection law: The legal basis under data protection law on which we process users' personal data using 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 a business operation of our online offer and improvement of its usability) or, if this is done in the context of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. For what purposes the cookies are processed by us, we clarify in the course of this privacy policy or in the context of our consent and processing procedures.

Storage duration: With regard to the storage duration, 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 offer and closed his end device (e.g. browser or mobile app).
Permanent cookies: Permanent cookies remain stored even after the end 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. Likewise, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration 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 consents they have given at any time and also file an objection to processing in accordance with the legal requirements in Art. 21 DSGVO. Users can also declare their objection via their browser settings, e.g. by deactivating the use of cookies (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.

Further guidance on processing operations, procedures and services: Processing of Cookie Data Based on Consent: We use a cookie consent management procedure, in the context of which the consent of users to the use of cookies, or the processing and providers mentioned in the cookie consent management procedure can be obtained and managed and revoked by users. Here, the declaration of consent is stored in order not to have to repeat its query 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 their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of 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 consent (e.g., which categories of cookies and/or service providers), as well as the browser, system and end device used.

Business services

We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as "contractual partners") in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer inquiries.

We process this data in order to fulfill our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. In addition, we process the data to safeguard our rights and for the purpose of administrative tasks associated with these obligations and company organization. Furthermore, we process the data on the basis of our legitimate interests in proper and business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for 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 disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.

We inform the contractual partners which data is required for the aforementioned purposes before or in the course of 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 legal warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons. The statutory retention period is ten years for documents relevant under tax law as well as for commercial books, inventories, opening balances, annual financial statements, the work instructions required to understand these documents and other organizational documents and accounting records, and six years for received commercial and business letters and reproductions of sent commercial and business letters. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was prepared, the commercial or business letter was received or sent, or the accounting document was created, furthermore the recording was made or the other documents were created.

Insofar as 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 in the relationship between the users and the providers.

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., subject matter of contract, term, customer category); usage data (e.g., websites visited, interest in content, access times); meta/communication data (e.g., device information, IP addresses).
Data subjects: Customers; prospective customers; business and contractual partners.
Purposes of processing: provision of contractual services and customer service; security measures; contact requests and communication; office and organizational procedures; administration and response to requests.
Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legal obligation (Art. 6 para. 1 p. 1 lit. c) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

Customer account: Contractual partners can create an account within our online offer (e.g. customer or user account, "customer account" for short). If registration of a customer account is required, contractual partners will be informed of this as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. In the context of registration and subsequent logins and uses of the customer account, we store the IP addresses of the customers along with the access times, in order to prove the registration and to prevent any misuse of the customer account.If customers have terminated their customer account, the data relating to the customer account will be deleted, unless their retention is required for legal reasons. It is the responsibility of the customers to secure their data when the customer account is terminated; legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Wishlist/ wish list: Customers may create a product/wish list. In this case, the products are stored as part of the fulfillment of our contractual obligations until the account is deleted, unless the product list entries are removed by the customer or we expressly inform the customer of different storage periods; legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Store and e-commerce: We process the data of our customers to enable them to select, purchase or order the selected products, goods and associated services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery, or execution to our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is identified as such in the context of the order or comparable purchase process and includes the information needed for delivery, or provision and billing, as well as contact information in order to be able to consult; legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Provision of the online offer and web hosting

In order to provide our online offer securely 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 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 as part of the provision of the hosting offer may include all information relating to the users of our online offer, which is generated as part of the use and communication. This regularly includes the IP address, which is necessary to deliver the content of online offers to browsers, and all entries made within our online offer or from websites.

Types of data processed: Content data (e.g. entries in online forms); Usage data (e.g. web pages visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.).).
Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further information on processing, procedures and services:

E-mail sending and hosting: The web hosting services we use also include the sending, receiving and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for SPAM detection purposes. Please note that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted in transit, but (unless a 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 reception on our server; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Collection of access data and log files: We ourselves (or our web hosting provider) collect data on each access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume 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 may be used for security purposes, for example, to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data whose further storage is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.
Wix: Hosting and software for the creation, provision and operation of websites, blogs and other online offerings; Service provider: Wix.com Ltd, Nemal St. 40, 6350671 Tel Aviv, Israel; Legal Grounds: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://de.wix.com/; Privacy Policy: https://de.wix.com/about/privacy; Order Processing Agreement: https://www.wix.com/about/privacy-dpa-users; Further Information: As part of the aforementioned services provided by Wix, data may also be transferred to Wix Inc, 500 Terry A. Francois Boulevard, San Francisco, California 94158, USA on the basis of standard contractual clauses or an equivalent data protection guarantee as part of further processing on behalf of Wix.

Special notes on applications (apps)

We process the data of the users of our application insofar as this is necessary to provide the application and its functionalities to the users, to monitor its security and to further develop it. We may also contact users in compliance with legal requirements, provided that the communication is necessary for purposes of administration or use of the application. In all other respects, we refer to the data protection information in this privacy policy with regard to the processing of users' data.

Legal basis: the processing of data required for the provision of the functionalities of the application serves the fulfillment of contractual obligations. This also applies if the provision of the functionalities requires authorization of the users (e.g. releases of device functions). If the processing of data is not necessary for the provision of the functionalities of the application, but serves the security of the application or our business interests (e.g. collection of data for purposes of optimizing the application or security purposes), it is based on our legitimate interests. If users are explicitly asked for their consent to the processing of their data, the processing of the data covered by the consent is based on the consent.

Types of data processed: inventory data (e.g., names, addresses); meta/communication data (e.g., device information, IP addresses); payment data (e.g., bank details, invoices, payment history); contract data (e.g., subject matter of contract, term, customer category).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: provision of contractual services and customer service.
Legal grounds: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further notes on processing processes, procedures and services:

Commercial use: We process the data of the users of our application, registered and any test users (hereinafter uniformly referred to as "users") in order to be able to provide our contractual services to them as well as on the basis of legitimate interests in order to be able to ensure the security of our application and to develop it further. The required information is identified as such in the context of the conclusion of the use, order, purchase order or comparable contract and may include the information required for the provision of services and for any billing, as well as contact information in order to be able to hold any consultations; legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) DSGVO).
No location history and no movement profiles: Location data is only used selectively and is not processed to create a location history or a movement profile of the devices used or their users.

Registration, login and user account

Users can create a user account. In the course of registration, users are provided with the required mandatory data and processed for the purpose of providing the user account on the basis of contractual obligation fulfillment. The processed data includes in particular the login information (username, password and an e-mail address).

In the context of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorized use. As a matter of principle, this data is not passed on to third parties unless it is necessary for the prosecution of our claims or there is a legal obligation to do so.

Users may be informed by e-mail about processes relevant to their user account, such as technical changes.

Types of data processed: inventory data (e.g., names, addresses); contact data (e.g., email, phone numbers); content data (e.g., input in online forms); meta/communication data (e.g., device information, IP addresses).
Data subjects: Users (e.g., website visitors, users of online services).
Purposes of processing: providing contractual services and customer service; security measures; managing and responding to requests; providing our online offer and user experience.
Legal bases: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further notes on processing processes, procedures and services:

Registration with clear name: Due to the nature of our community, we ask users to use our services only by using clear names. I.e. the use of pseudonyms is not permitted; Legal basis: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Deletion of data after termination: If users have terminated their user account, their data with regard to the user account will be deleted, subject to any legal permission, obligation or consent of the users; legal basis: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
No obligation to retain data: It is the responsibility of the users to save their data upon termination before the end of the contract. We are entitled to irretrievably delete all of the user's data stored during the term of the contract; legal basis:contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data are processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.

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).
Data subjects: Users (e.g., website visitors, users of online services).
Purposes of processing: Provision of contractual services and customer service; feedback (e.g. collecting feedback via online form); provision of our online offer and user-friendliness.
Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Contact and inquiry management

When contacting us (e.g. via contact form, email, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

The response to the contact inquiries as well as the management of contact and inquiry data in the context of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to respond to (pre)contractual inquiries and otherwise on the basis of legitimate interests in responding to the inquiries and maintaining user or business relationships.

Types of data processed: contact data (e.g., email, phone numbers); content data (e.g., input in online forms); usage data (e.g., websites visited, interest in content, access times); meta/communication data (e.g., device information, IP addresses).
Data subjects: Communication partners.
Purposes of processing: provision of contractual services and customer service; contact requests and communication; managing and responding to requests; feedback (e.g. collecting feedback via online form); providing our online offer and user experience.
Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context for the purpose of processing the communicated request. For this purpose, we process personal data in the context of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfillment and otherwise on the basis of our legitimate interests as well as the interests of the communication partners in responding to the concerns and our statutory retention obligations; Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Newsletter and electronic notifications

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

In order to subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name, for the purpose of personal address in the newsletter, or further information, if this is necessary for the purposes of the newsletter.

Double opt-in procedure: The registration for our newsletter is always carried out in a so-called double opt-in process. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise, changes to your data stored with the shipping service provider are logged.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove consent formerly given. The processing of this data will be limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list (so-called "block list") for this purpose alone.

The logging of the registration process takes place on the basis of our legitimate interests for the purposes of proving its proper course. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

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, phone numbers); meta/communication data (e.g. device information, IP addresses).
Data subjects: Communication partners.
Purposes of processing: direct marketing (e.g., via e-mail or postal mail).
Legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
Option to object (opt-out): You can cancel receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the above contact options, preferably e-mail, for this purpose

Sweepstakes and contests

We process personal data of participants in sweepstakes and contests only in compliance with the relevant data protection provisions, insofar as the processing is contractually necessary for the provision, implementation and execution of the sweepstakes, the participants have consented to the processing or the processing serves our legitimate interests (e.g., in the security of the sweepstakes or the protection of our interests against misuse through possible collection of IP addresses when submitting sweepstakes entries).

If contributions from participants are published as part of the sweepstakes (e.g. as part of a vote or presentation of the sweepstakes entries or the winners or reporting on the sweepstakes), we point out that the names of the participants may also be published in this context. Participants may object to this at any time.

If the sweepstakes takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as "online platform"), the usage and data protection provisions of the respective platforms shall also apply. In these cases, we would like to point out that we are responsible for the information provided by the participants as part of the sweepstakes and that inquiries with regard to the sweepstakes should be directed to us.

The participants' data will be deleted as soon as the competition or contest has ended and the data is no longer required to inform the winners or because queries about the competition are to be expected. In principle, the participants' data will be deleted no later than 6 months after the end of the sweepstakes. Winners' data may be retained for longer in order, for example, to answer queries about the prizes or to be able to fulfill the prize services; in this case, the retention period depends on the type of prize and is up to three years for items or services, for example, in order to be able to process warranty claims. Furthermore, the participants' data may be stored for longer, e.g. in the form of reporting on the sweepstakes in online and offline media.

If data was also collected for other purposes as part of the sweepstakes, its processing and the retention period will be governed by the data protection information on this use (e.g. in the case of registration for the newsletter as part of a sweepstakes).

Types of data processed: inventory data (e.g., names, addresses); content data (e.g., input in online forms); meta/communication data (e.g., device information, IP addresses).
Data subjects: Sweepstakes and contest participants.
Purposes of processing: implementation of sweepstakes and contests.
Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Surveys and polls

We conduct surveys and interviews in order to collect information for the respective communicated survey or interview purpose. The surveys and questionnaires we conduct (hereinafter "surveys") are evaluated anonymously. Personal data is only processed insofar as this is necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address in order to display the survey in the user's browser or to enable the survey to be resumed with the aid of a cookie).

Types of data processed: 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).
Data subjects: Communication partners; participants.
Purposes of processing: feedback (e.g. collecting feedback via online form).
Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Change and update of the privacy policy

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

If we provide addresses and contact information of companies and organizations in this privacy statement, 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 Art. 15 to 21 GDPR:

Right to object: you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
Right to withdraw consent: You have the right to revoke any consent given at any time.
Right to information: You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with legal requirements.
Right to rectification: In accordance with the legal requirements, you have the right to demand that the data concerning you be completed or that the incorrect data concerning you be rectified.
Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be erased without delay or, alternatively, to demand restriction of the processing of the data in accordance with the legal requirements.
Right to data portability: you have the right to receive data relating to you that you have provided to us in a structured, common and machine-readable format, or to request that it be transferred to another controller, in accordance with the law.
Complaint to supervisory authority: In accordance with the law 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 where you usually 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 of terms

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

Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Controller: "Controller" means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
Processing: "Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data, be it collection, analysis, storage, transmission or deletion.