Data Privacy Declaration
We at CoachHub are committed to the highest level of confidentiality and the protection of the personal data entrusted to us, some of which is very personal. We only process personal data of our users (i.e. customers, coaches, coachees and visitors of the website/app and other users) as far as this is necessary to provide a functional website or application as well as our contents and services. The processing of personal data of our users takes place regularly only after consent of the user. An exception applies in those cases in which it is not possible to obtain prior consent for actual reasons and the processing of the data is permitted by statutory regulations.
This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as “data") in the context of the provision of our services and within our online offering and the associated websites, functions, applications and content as well as external online presences, such as our Social Media Profile on (hereinafter jointly referred to as “platform"). With regard to the terms used, such as “processing" or “person responsible", we refer you to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Person in charge
Leipziger Strasse 119
10117 Berlin, Germany
Managing Director: Yannis Niebelschuetz, Matti Niebelschuetz
Link to imprint: https://www.coachhub.io/en/imprint
Contact Data Protection Officer: email@example.com
Types of data processed
– General data (e.g., person data, names or addresses).
– Contact data (e.g., e-mail, telephone numbers).
– Content data (e.g., text entries, photographs, videos).
– Usage data (e.g., websites visited, interest in content, access times).
– Meta/communication data (e.g., device information, IP addresses).
Categories of persons concerned
Visitors and users of the platform (hereinafter referred to collectively as “users").
Purpose of processing
– Provision of the platform, its functions and contents.
– Answering contact requests and communicating with users.
– Security measures.
“Personal data" means any information relating to an identified or identifiable natural person (hereinafter “data subject"); a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier (e.g. a cookie) or to one or more specific characteristics which express the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, is regarded as identifiable.
“Processing’ means any operation or set of operations which is carried out with or without the aid of automated processes and which involves personal data. The term is broad and covers practically every handling of data.
“Pseudonymisation’ means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the provision of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures ensuring that the personal data are not attributed to an identified or identifiable natural person.
“Profiling" means any automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to the work performance, economic situation, health, personal preferences, interests, reliability, conduct, whereabouts or movements of that natural person.
“Controller" means any natural or legal person, public authority, agency or body which alone or jointly with others determines the purposes and means of the processing of personal data.
“Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
In accordance with Art. 13 GDPR we inform you about the legal basis of our data processing. For users from the area of application of the General Data Protection Regulation (GDPR), i.e. the EU and the EEC, the following applies, if the legal basis is not mentioned in the data protection explanation:
The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR;
The legal basis for the processing for the fulfilment of our services and the implementation of contractual measures as well as the answering of inquiries is Art. 6 para. 1 lit. b GDPR;
The legal basis for the processing for the fulfilment of our legal obligations is Art. 6 para. 1 lit. c GDPR;
Art. 6 para. 1 lit. d GDPR serves as the legal basis in the event that vital interests of the data subject or another natural person necessitate the processing of personal data.
The legal basis for the processing necessary to perform a task which is in the public interest or in the exercise of official authority entrusted to the data controller is Art. 6 para. 1 lit. e GDPR.
The legal basis for the processing to safeguard our legitimate interests is Art. 6 para. 1 lit. f GDPR.
The processing of data for purposes other than those for which they were collected is governed by the provisions of Art. 6 (4) GDPR.
The processing of special categories of data (pursuant to Art. 9 (1) GDPR) is governed by the provisions of Art. 9 (2) GDPR.
We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, extent, circumstances and purposes of the processing, as well as the different probability of occurrence and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
Measures shall include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to, access to, inputting, disclosure, securing and separation of data. In addition, we have established procedures to ensure the exercise of data subjects’ rights, deletion of data and reaction to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and data protection-friendly default settings.
Cooperation with contract processors, joint managers and third parties
Insofar as we disclose data to other persons and companies (contract processors, jointly responsible persons or third parties) within the scope of our processing, transfer them to them or otherwise grant them access to the data, this shall only take place on the basis of legal permission (e.g. if a transfer of the data to third parties, such as payment service providers, is necessary for the fulfilment of the contract), users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
Insofar as we disclose, transmit or otherwise grant access to data to other companies of our group of companies, this is done in particular for administrative purposes as a legitimate interest and beyond that on a basis corresponding to the legal requirements.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this is done in the context of the use of third party services or disclosure or transfer of data to other persons or companies, this only occurs if it is done to fulfil our (pre)contractual obligations, on the basis of your consent, a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or leave the data in a third country only if the legal requirements are met. I.e. the processing takes place e.g. on basis of special guarantees, like the officially recognized statement of a data protection level corresponding to the EU (e.g. for the USA by the “Privacy Shield") or observance of officially recognized special contractual obligations.
Rights of persons concerned
You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law.
You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the incorrect data concerning you.
In accordance with the statutory provisions, you have the right to demand that the relevant data be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
You have the right to demand that we receive the data concerning you that you have provided to us in accordance with the statutory provisions and to demand that it be passed on to other persons responsible.
They also have the right to file a complaint with the competent supervisory authority in accordance with the statutory provisions.
Right of withdrawal
You have the right to revoke any consent you have given with effect for the future.
Right of objection
You may object at any time to the future processing of the data concerning you in accordance with the statutory provisions. In particular, you may object to the processing of your data for the purposes of direct marketing.
Cookies and right to object to direct advertising
“Cookies" are small files that are stored on the user’s computer. Different data can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) on the platform during or after the user’s visit. Temporary cookies, or “session cookies" or “transient cookies", are cookies that are deleted after a user leaves the platform and closes his browser. The content of a shopping basket in an online shop or a login status, for example, can be stored in such a cookie. Cookies are referred to as “permanent" or “persistent" and remain stored even after the browser has been closed. For example, the login status can be saved if users visit it after several days. The interests of the users who are used for range measurement or marketing purposes can also be stored in such a cookie. Third party cookies" are cookies that are offered by providers other than the person responsible for operating the platform (otherwise, if they are only the latter’s cookies, they are referred to as “first party cookies").
If users do not wish cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional limitations of this platform.
Deletion of data
The data processed by us will be deleted in accordance with the statutory provisions or their processing will be restricted. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and there are no legal obligations to retain them.
If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons.
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.
We process the data of our clients and interested parties and other clients or contractual partners (uniformly referred to as “clients") in accordance with Art. 6 para. 1 lit. b) GDPR in order to provide them with our contractual or pre-contractual services. The data processed, the type, scope and purpose and the necessity of their processing are determined by the underlying contractual relationship. The processed data basically includes inventory and master data of the clients (e.g., name, address, etc.), as well as contact data (e.g., e-mail address, telephone, etc.), contract data (e.g., services used, fees, names of contact persons, etc.) and payment data (e.g., bank details, payment history, etc.).
If required by law or for the performance of the contract, we disclose or transmit the client’s data within the scope of communication with other specialists, as necessary for the performance of the contract or typically involved third parties, insofar as this is necessary for the provision of our services pursuant to Art. 6 para. 1 lit b. GDPR serves, legally according to Art. 6 para. 1 lit c. GDPR or within the framework of a consent pursuant to Art. 6 para. 1 lit. a., Art. 7 GDPR.
The data will be deleted when the data is no longer required for the fulfilment of contractual or statutory duties of care and for the handling of any warranty and comparable obligations, whereby the necessity of storing the data is reviewed every three years; otherwise the statutory duties of storage apply.
Administration, financial accounting, office organisation, contact management
We process data in the context of administrative tasks as well as the organisation of our business, financial accounting and compliance with legal obligations, such as archiving. Here we process the same data that we process within the scope of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e. tasks which serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of the data with regard to contractual services and contractual communication corresponds to the data specified in these processing activities.
We disclose or transmit data to the tax authorities, consultants, such as tax consultants or auditors, as well as other fee offices and payment service providers.
Furthermore, on the basis of our business interests, we store information on suppliers, organisers and other business partners, e.g. for the purpose of establishing contact at a later date. This data, which is mainly company-related, is stored permanently.
Business analyses and market research
In order to run our business economically, to be able to recognise market trends, wishes of our contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., in order to identify the most suitable and appropriate solutions for your needs. We process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. GDPR, whereby the persons concerned include contractual partners, interested parties, customers, visitors and users of our platform.
The analyses are carried out for the purpose of economic evaluations, marketing and market research. We can consider the profiles of the registered users with information, e.g. about their used services. The analyses serve us to increase user friendliness, to optimise our range of services and to improve business efficiency. The analyses serve us alone and are not disclosed externally unless they are anonymous analyses with summarized values.
If these analyses or profiles are person-related, they will be deleted or anonymised upon termination by the user, otherwise after two years from the conclusion of the contract. In all other respects, the macroeconomic analyses and general trend determinations shall be prepared anonymously wherever possible.
Data protection information in the application process
We process the applicant data only for the purpose and within the framework of the application procedure in accordance with the legal requirements. The processing of the applicant data is carried out to fulfil our (pre)contractual obligations within the scope of the application procedure in the sense of Art. 6 Para. 1 lit. b. GDPR Art. 6 para. 1 lit. f. GDPR insofar as data processing becomes necessary for us, e.g. within the framework of legal proceedings (in Germany, § 26 BDSG additionally applies).
The application procedure requires that applicants provide us with the applicant data. If we offer an online form, the necessary applicant data is marked, otherwise it results from the job descriptions and basically includes the personal details, postal and contact addresses and the documents belonging to the application, such as cover letter, curriculum vitae and certificates. In addition, applicants may voluntarily provide us with additional information.
Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are voluntarily disclosed in the application process, their processing is also carried out in accordance with Art. 9 para. 2 lit. b GDPR (e.g. health data, such as severely disabled status or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are requested from applicants as part of the application procedure, their processing is also carried out in accordance with Art. 9 para. 2 lit. a GDPR (e.g. health data if these are necessary for the exercise of a profession).
Where made available, applicants may submit their applications via an online form on our website. The data will be transmitted to us encrypted according to the state of the art.
Applicants can also send us their applications by e-mail. Please note, however, that e-mails are generally not sent in encrypted form and that the applicants themselves must ensure that they are encrypted. We therefore cannot assume any responsibility for the transmission path of the application between the sender and the reception on our server and therefore recommend using an online form or postal dispatch. Instead of applying using the online form and e-mail, applicants still have the option of sending their application by post.
In the event of a successful application, the data provided by the 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 applicant’s data will be deleted. Applicant 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 after a period of six months so that we can answer any follow-up questions regarding the application and meet our obligations to provide evidence under the Equal Treatment Act. Invoices for any reimbursement of travel expenses will be archived in accordance with the provisions of tax law.
As part of the application process, we offer applicants the opportunity to be included in our “talent pool" for a period of two years on the basis of consent as defined in Art. 6 Para. 1 lit. a. and Art. 7 GDPR.
The application documents in the talent pool will be processed solely within the framework of future job advertisements and the employee search and will be destroyed at the latest after the deadline. Applicants are informed that their consent to inclusion in the Talent Pool is voluntary, has no influence on the current application procedure and that they can revoke this consent at any time for the future and declare objections within the meaning of Art. 21 DSGVO.
Users can create a user account. Within the scope of registration, the required mandatory data will be communicated to the users and processed on the basis of Art. 6 Para. 1 lit. b GDPR for the purpose of providing the user account. The processed data includes in particular the login information (name, password and an e-mail address). The data entered during registration will be used for the purposes of using the user account and its purpose.
Users may be informed by e-mail of information relevant to their user account, such as technical changes. If users have terminated their user account, their data will be deleted with regard to the user account, subject to a statutory retention obligation. It is the responsibility of the users to secure their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract.
Within the scope of using 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 the user’s protection against misuse and other unauthorized use. A passing on of these data to third parties does not take place in principle, unless it is necessary for the pursuit of our claims or there is a legal obligation according to Art. 6 para. 1 lit. c. GDPR. The IP addresses will be anonymized or deleted after 7 days at the latest.
User profile and account
In the individual coaching account on our platform, data is stored that is necessary for the implementation of a smooth coaching process. This data is transmitted to us and stored by the user. These data are:
(1) User profile data (including name, email address, profile picture, language selection and time zone)
(2) Name of the selected coach, including profile data of the coaches (in text, picture and introduction video)
(3) Message history from chat communication with coach or service
(4) Information on planned and taken place coaching sessions, log files, as well as on follow-up tasks
(5) Objectives for coaching, selected development areas and progress, as well as further information on intercation and the coaching program.
(6) Results of satisfaction and coaching experience surveys and other surveys and assessments and evaluations
Your consent will be obtained for the processing of your data during the registration process and reference will be made to this data protection declaration. The data will not be passed on to third parties in this context. The data will be used exclusively for the processing of the coaching program.
The legal basis for the processing of the data is Art. 6 para. 1 lit. a GDPR if the user has given his consent. The processing of personal data from the individual coaching area serves us solely to enable a functioning coaching platform and to process the coaching program. The registration for the coaching program also includes the necessary justified interest in the processing of the data.
The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. For the personal data from the individual coaching area, this is the case when the coaching program with the user has ended. The coaching program is terminated when it can be inferred from the circumstances that the coaching has been completed and a new start or continuation will not take place.
The user has the possibility to revoke his consent to the processing of personal data at any time. In such a case, the coaching program cannot be continued. You have to send an email to us. All personal data stored in the course of the coaching programme will be deleted in this case.
When contacting us (e.g. via contact form, e-mail, telephone or via social media), the user’s details are used to process the contact enquiry and to process it in accordance with Art. 6 Para. 1 lit. b. of the German Data Protection Act. (within the framework of contractual/pre-contractual relationships), Art. 6 Para. 1 lit. f. (other inquiries) GDPR processed. The user data can be stored in a customer relationship management system (“CRM system") or comparable inquiry organization.
We will delete the requests if they are no longer necessary. We review the necessity every two years; furthermore, the statutory archiving obligations apply.
We use the CRM system of the provider HubSpot , Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141 USA in order to be able to process user requests faster and more efficiently (justified interest according to Art. 6 Para. 1 lit. f. GDPR).
HubSpot is certified under the Privacy Shield Agreement and thus offers an additional guarantee to comply with European data protection law if data is processed in the USA (https://www.privacyshield.gov/participant?id=a2zt0000000TN8pAAG).
HubSpot uses user data only for the technical processing of inquiries and does not pass them on to third parties. In order to use HubSpot, at least a correct e-mail address must be provided. A pseudonymous use is possible. In the course of processing service requests, it may be necessary to collect further data (name, address).
If users do not agree with data collection and data storage in HubSpot’s external system, we offer them alternative contact options for submitting service requests by e-mail, telephone, fax or post, but cannot guarantee the usability of our platform.
Further information can be found in the hubspot data protection declaration: https://legal.hubspot.com/data-privacy
With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures and your rights of objection. By subscribing to our newsletter, you declare your agreement with the receipt and the described procedures.
Content of the newsletter: We send newsletters, e-mails and other electronic notifications containing advertising information (hereinafter “newsletter") only with the consent of the recipient or a legal permission. If the contents of the newsletter are specifically described within the scope of registration, they are decisive for the consent of the user. In addition, our newsletters contain information about our services and us.
Double-Opt-In and logging: The registration to our newsletter takes place in a so-called Double-Opt-In procedure. This means that you will receive an e-mail after your registration in which you will be asked to confirm your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address. Likewise the changes of your data stored with the Versanddienstleister are logged.
Registration data: To subscribe to the newsletter, it is sufficient to enter your e-mail address. Optionally, we ask you to enter a name in the newsletter for the purpose of addressing you personally.
The dispatch of the newsletter and the performance measurement associated with it are based on the consent of the recipients pursuant to Art. 6 para. 1 lit. a, Art. 7 GDPR in conjunction with § 7 para. 2 no. 3 UWG or, if consent is not required, on our legitimate interests in direct marketing pursuant to Art. 6 para. 1 as per f. GDPR in connection with § 7 Abs. 3 UWG.
The registration procedure is recorded on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR. Our interest is directed towards the use of a user-friendly and secure newsletter system that serves our business interests as well as the expectations of the users and furthermore allows us to provide evidence of consent.
Cancellation/revocation – You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to provide evidence of a previously given consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time.
Newsletter – Success Measurement
The newsletters contain a so-called “web-beacon", i.e. a file the size of a pixel, which is retrieved from our server when the newsletter is opened or, if we use a dispatch service provider, from its server. Within the scope of this retrieval, technical information such as information about the browser and your system, as well as your IP address and time of retrieval are first collected.
This information is used for the technical improvement of the services on the basis of technical data or target groups and their reading behaviour on the basis of their retrieval points (which can be determined with the help of the IP address) or access times. Statistical surveys also include determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. It is, however, neither our endeavour nor, if used, that of the dispatch service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our contents to them or to send different contents according to the interests of our users.
A separate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled.
Hosting and e-mailing
The hosting services used by us serve the provision of the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services which we use for the purpose of operating this platform.
Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this platform on the basis of our legitimate interests in the efficient and secure provision of this platform pursuant to Art. 6 Para. 1 lit. f GDPR in connection with Art. 28 GDPR (conclusion of an order processing contract).
Collection of access data and log files
We, and/or our Hostinganbieter, raise on basis of our entitled interests in the sense of the art. 6 Abs. 1 lit. f. GDPR collects data on each access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Log file information is stored for security reasons (e.g. for the clarification of abuse or fraud actions) for the duration of maximally 7 days and deleted afterwards. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.
Google Tag Manager
Google is certified under the Privacy Shield Agreement and thereby offers a guarantee of compliance with European privacy laws (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf in order to evaluate the use of our platform by users, to compile reports on activities within this platform and to provide us with other services associated with the use of this platform and the Internet. Pseudonymous user profiles can be created from the processed data.
We only use Google Analytics with IP anonymization enabled. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.
Further information on the use of data by Google, setting and objection options can be found in Google’s data protection declaration (https://policies.google.com/privacy) and in the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).
The personal data of the users will be deleted or anonymized after 14 months.
Google AdWords and Conversion Measurement
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our platform within the meaning of Art. 6 Para. 1 lit. f. of the German Civil Code), we make use of the following services GDPR) the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google").
Google is certified under the Privacy Shield Agreement and thereby offers a guarantee of compliance with European privacy laws (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
We use the Google “AdWords" online marketing method to place ads on the Google advertising network (e.g., in search results, videos, websites, etc.) so that they are displayed to users who have an alleged interest in the ads. This allows us to display ads for and within our platform in a more targeted manner in order to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products in which he or she is interested on other online offers, this is referred to as “remarketing". For these purposes, when you visit our and other websites on which the Google Advertising Network is active, Google directly executes a code from Google and integrates so-called (re)marketing tags (invisible graphics or code, also known as “web beacons") into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). This file records which websites the user visits, what content he is interested in and what offers the user has clicked on, as well as technical information on the browser and operating system, referring websites, visit times and other information on the use of the platform.
Furthermore we receive an individual “Conversion-Cookie". The information collected with the help of the cookie is used by Google to compile conversion statistics for us. However, we only know the anonymous total number of users who clicked on our ad and were directed to a page with a conversion tracking tag. However, we do not receive any personally identifiable information.
User data is processed pseudonymously within the Google advertising network. This means, for example, that Google does not store and process the user’s name or e-mail address, but processes the relevant data cookie-related within pseudonymous user profiles. This means that, from Google’s point of view, the ads are not administered and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymisation. The information collected about users is transmitted to Google and stored on Google’s servers in the United States.
Further information on the use of data by Google, setting and objection options can be found in Google’s data protection declaration (https://policies.google.com/technologies/ads) and in the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).
Facebook-Pixel, Custom Audiences und Facebook-Conversion
Within our platform the so-called “Facebook pixel" of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are resident in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook"), is used due to our legitimate interests in the analysis, optimisation and economic operation of our platform and for these purposes.
Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
With the help of the Facebook pixel, Facebook is on the one hand able to determine the visitors of our platform as the target group for the presentation of ads (so-called “Facebook ads"). Accordingly, we use Facebook pixels to display Facebook ads placed by us only to Facebook users who have shown an interest in our platform or who have certain characteristics (e.g. interests in certain topics or products that are determined on the basis of the websites visited) that we transmit to Facebook (so-called “custom audiences"). Using Facebook pixels, we also want to ensure that our Facebook ads correspond to the potential interest of users and are not annoying. Using Facebook pixels, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing if users were referred to our website after clicking on a Facebook ad (known as “conversion").
Facebook processes the data in accordance with the Facebook Data Usage Policy. Accordingly, general information on the presentation of Facebook ads in the Facebook Data Usage Policy: https://www.facebook.com/policy. Specific information and details about Facebook pixels and how they work can be found in the Facebook help section: https://www.facebook.com/business/help/651294705016616.
You may opt out of Facebook pixel collection and use of your information to display Facebook ads. To set what types of ads you see within Facebook, you can go to the page set up by Facebook and follow the instructions on the settings for usage-based ads: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
Within our platform, we act on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our platform within the meaning of Art. 6 Para. 1 lit. f. of the German Civil Code). DSGVO) the conversion and tracking tool “Bing Ads" of Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. Microsoft stores cookies on the user’s devices in order to enable an analysis of the use of our platform by users if users have reached our platform via a Microsoft Bing display (so-called “conversion measurement"). In this way, Microsoft and we can recognize that someone clicked on an advertisement, was redirected to our platform and reached a previously determined target page (“conversion page"). We only know the total number of users who clicked on a Bing ad and were redirected to the Conversion page. No IP addresses are stored. No personal information about the identity of users will be shared.
Microsoft is certified under the Privacy Shield Agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active).
If users do not wish to participate in the tracking process of Bing Ads, they can also deactivate the setting of a cookie required for this via the browser setting or use the opt-out page of Microsoft: http://choice.microsoft.com/opt-out.
Users can find further information on data protection and the cookies used by Microsoft Bing Ads in Microsoft’s data protection declaration: https://privacy.microsoft.com/privacystatement.
Online presences in social media
We maintain online presences within social networks and platforms in order to be able to communicate with customers, interested parties and users active there and to inform them about our services.
We would like to point out that user data may be processed outside the European Union. This could result in risks for users, e.g. because it could make it more difficult to enforce users’ rights. With regard to US providers that are certified under the Privacy Shield, we would like to point out that by doing so they commit themselves to comply with EU data protection standards.
Furthermore, user data is usually processed for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the resulting interests of users. The user profiles can in turn be used, for example, to place advertisements inside and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer in which the user’s usage behaviour and interests are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (in particular if the users are members of the respective platforms and are logged in to them).
The processing of users’ personal data is carried out on the basis of our legitimate interests in effective information for users and communication with users pursuant to Art. 6 Para. 1 lit. f. DGDPR. If the users are requested by the respective providers of the platforms to consent to the aforementioned data processing, the legal basis for the processing is Art. 6 Para. 1 lit. a., Art. 7 GDPR.
For a detailed representation of the respective processing and the possibilities of objection (Opt-Out), we refer to the following linked information of the providers.
Also in the case of requests for information and the assertion of user rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and give information. Should you nevertheless need help, you can contact us.
– Facebook, Pages, Groups, (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) on the basis of a Joint Processing Agreement – Privacy Statement: https://www.facebook.com/about/privacy/, specifically for Pages: https://www.facebook.com/legal/terms/information_about_page_insights_data , Opt-Out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.
– Google/ YouTube (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – Datenschutzerklärung: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt00000000001L5AAI&status=Active.
– Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – Privacy Statement / Opt-Out: http://instagram.com/about/legal/privacy/.
– Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) – Privacy Statement: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.
– Pinterest (Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA) – Privacy Statement/ Opt-Out: https://about.pinterest.com/de/privacy-policy.
– LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Irland) – Privacy Statement https://www.linkedin.com/legal/privacy-policy , Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active.
Integration of third-party services and content
Within our platform, we act on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our platform within the meaning of Art. 6 Para. 1 lit. f. of the German Civil Code). GDPR) content or service offers from third parties in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content").
This always presupposes that the third-party providers of this content perceive the IP address of the user, since they would not be able to send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We make every effort to use only those contents whose respective providers only use the IP address to deliver the contents. Third party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons") for statistical or marketing purposes. Pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, visit times and other information about the use of our platform, as well as may be linked to such information from other sources.
Last update: 12/17/2018