Privacy Policy
Status: 18.03.2025
Responsible party
Born2Pray
Enes Emirzeoglu
Schwarzwaldstraße 18
71139 Ehningen
Germany
Email address: support@born2pray.com
Phone: 017675890750
VAT ID: DE 339540977
Imprint: www.born2pray.com/pages/impressum
Overview of processing activities
The following overview summarizes the types of data processed and the purposes of their processing and refers to the affected persons.
Types of data processed
- Inventory data
- Payment data
- Contact details
- Content data
- Contract data
- Usage data
- Meta, communication, and procedural data
Categories of affected persons
- Customers
- Interested parties
- Communication partners
- Users
- Contest and competition participants
- Business and contract partners
Purposes of processing
- Provision of contractual services and fulfillment of contractual obligations
- Contact inquiries and communication
- Security measures
- Direct marketing
- Reach measurement
- Tracking
- Office and Organizational Procedures
- Conversion Measurement
- Management and Response to Inquiries
- Conducting Sweepstakes and Competitions
- Feedback
- Marketing
- Profiles with User-Related Information
- Provision of Our Online Offer and User-Friendliness
- Information Technology Infrastructure
Relevant Legal Bases
Relevant Legal Bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If more specific legal bases are relevant in individual cases, we will inform you of these in the privacy policy.
- Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given consent to the processing of their personal data for one or more specific purposes.
- Contract Performance and Pre-Contractual Requests (Art. 6 para. 1 sentence 1 lit. b) GDPR) - The processing is necessary for the performance of a contract to which the data subject is a party, or to take steps at the request of the data subject prior to entering into a contract.
- Legal Obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) - The processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, unless the interests or fundamental rights and freedoms of the data subject which require protection of personal data override those interests.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. This includes in particular the Act to Protect against the Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains special regulations on the right of access, the right to deletion, the right to object, the processing of special categories of personal data, processing for other purposes, transmission, and automated individual decision-making including profiling. Furthermore, state data protection laws of the individual federal states may apply.
Note on the applicability of the GDPR and Swiss DPA: These data protection notices serve both to provide information according to the Swiss Federal Act on Data Protection (Swiss DPA) and according to the General Data Protection Regulation (GDPR). For this reason, please note that due to the broader territorial application and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms used in the Swiss DPA "processing" of "personal data", "overriding interest" and "particularly sensitive personal data", the terms used in the GDPR "processing" of "personal data" as well as "legitimate interest" and "special categories of data" are used. However, the legal meaning of the terms will continue to be determined under the Swiss DPA within the scope of its applicability.
Security measures
We take appropriate technical and organizational measures in accordance with legal requirements, considering the state of the art, implementation costs, the nature, scope, circumstances, and purposes of the processing, as well as the varying 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 access, input, transmission, availability assurance, and separation related to it. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data, and responses to data threats. Additionally, we consider the protection of personal data already during the development or selection of hardware, software, and procedures according to the principle of data protection by design and by default.
Truncation of the IP address: If IP addresses are processed by us or by the service providers and technologies used, and the processing of a complete IP address is not necessary, the IP address will be truncated (also referred to as "IP masking"). In this process, the last two digits or the last part of the IP address after a dot are removed or replaced by placeholders. The truncation of the IP address is intended to prevent or significantly complicate the identification of a person based on their IP address.
TLS/SSL encryption (https): To protect the data of users transmitted via our online services, we use TLS/SSL encryption. Secure Sockets Layer (SSL) is the standard technology for securing internet connections by encrypting data transmitted between a website or app and a browser (or between two servers). Transport Layer Security (TLS) is an updated and more secure version of SSL. Hyper Text Transfer Protocol Secure (HTTPS) is displayed in the URL when a website is secured by an SSL/TLS certificate.
Transmission of personal data
In the course of our processing of personal data, it may happen that the data is transmitted to other entities, companies, legally independent organizational units, or persons, or disclosed to them. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content embedded in a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.
Data transmission within the organization: We may transmit personal data to other entities within our organization or grant them access to this data. If this transmission occurs for administrative purposes, it is based on our legitimate business and economic interests or takes place if it is necessary to fulfill our contractual obligations or if the consent of the data subjects or a legal permission is present.
International data transfers
Data processing in third countries: If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of using third-party services or the disclosure or transmission of data to other persons, entities, or companies, this is done only in accordance with legal requirements. If the level of data protection in the third country has been recognized by an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers only take place if the level of data protection is otherwise secured, in particular through standard contractual clauses (Art. 46 para. 2 lit. c) GDPR), explicit consent, or in the case of contractual or legally required transmission (Art. 49 para. 1 GDPR). Furthermore, we inform you of the bases for third-country transfers with the individual providers from the third country, whereby adequacy decisions primarily apply as the basis. Information on third-country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.
EU-US Trans-Atlantic Data Privacy Framework: As part of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognized the level of data protection as secure for certain companies from the USA under the adequacy decision of 10.07.2023. The list of certified companies as well as further information about the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). We inform you within the scope of the data protection notices which service providers used by us are certified under the Data Privacy Framework.
Deletion of data
The data we process will be deleted in accordance with legal requirements as soon as the consents permitting their processing are revoked or other permissions cease to apply (e.g., if the purpose of processing this data no longer exists or they are not necessary for the purpose). If the data is not deleted because it is required for other legally permissible purposes, its processing will be limited to these purposes. That means the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for asserting, exercising, or defending legal claims or for protecting the rights of another natural or legal person. Our privacy notices may also contain further information on the retention and deletion of data, which take precedence for the respective processing.
Rights of data subjects
Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, particularly arising from Articles 15 to 21 GDPR:
- Right to object: You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you that is carried out on the basis of Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions. If personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such advertising purposes; this also applies to profiling insofar as it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw given consents at any time.
- Right of access: You have the right to request confirmation as to whether data concerning you is being processed and to access this data as well as further information and a copy of the data in accordance with legal requirements.
- Right to rectification: You have the right, in accordance with legal requirements, to request the completion of data concerning you or the correction of incorrect data concerning you.
- Right to deletion and restriction of processing: You have the right, in accordance with legal requirements, to request the immediate deletion of data concerning you, or alternatively, to request a restriction of the processing of the data in accordance with legal requirements.
- Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used, and machine-readable format, or to request the transmission of such data to another controller, in accordance with legal requirements.
- Complaint to supervisory authority: You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your workplace, or the place of the alleged infringement, without prejudice to any other administrative or judicial remedy, if you believe that the processing of your personal data violates the provisions of the GDPR.
Use of Cookies
Cookies are small text files or other storage markers that store information on end devices and read information from the end devices. For example, to store the login status in a user account, a shopping cart content in an e-shop, the accessed content, or used functions of an online offer. Cookies can also be used for various purposes, such as functionality, security, and convenience of online offers, as well as creating analyses of visitor flows.
Notes on consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, except when this is not legally required. Consent is particularly not necessary if storing and reading information, including cookies, is absolutely necessary to provide users with a telemedia service they have explicitly requested (i.e., our online offer). Absolutely necessary cookies generally include cookies with functions that serve the display and operability of the online offer, load balancing, security, storage of user preferences and selections, or similar purposes related to providing the main and secondary functions of the online offer requested by users. The revocable consent is clearly communicated to users and contains information about the respective cookie usage.
Notes on data protection legal bases: The data protection legal basis on which we process users' personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing your data is the declared consent. Otherwise, the data processed with the help of cookies is processed based on our legitimate interests (e.g., in the economic operation of our online offer and improvement of its usability) or, if this is done in the context of fulfilling our contractual obligations, when the use of cookies is necessary to fulfill our contractual obligations. We clarify the purposes for which the cookies are processed by us in the course of this privacy policy or within 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 leaves an online offer and closes their device (e.g., browser or mobile application).
- Persistent cookies: Persistent cookies remain stored even after the device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, data collected from users 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 persistent and the storage duration can be up to two years.
General notes on revocation and objection (so-called "opt-out"): Users can revoke their given consents at any time and object to the processing in accordance with legal requirements. For this purpose, users can, among other things, restrict the use of cookies in their browser settings (which may also limit the functionality of our online offer). 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/.
Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing procedures, methods, and services:
- Processing of cookie data based on consent: We use a consent management procedure: a procedure for obtaining, logging, managing, and revoking consents, especially for the use of cookies and similar technologies for storing, reading, and processing information on users' end devices as well as their processing, within which the users' consents to the use of cookies, or the processing and providers named within the consent management procedure for obtaining, logging, managing, and revoking consents, especially for the use of cookies and similar technologies for storing, reading, and processing information on users' end devices as well as their processing, can be obtained, managed, and revoked by the users. The consent declaration is stored so that it does not have to be requested again and the consent can be proven in accordance with legal obligations. The storage can take place server-side and/or in a cookie (so-called opt-in cookie, or using comparable technologies) to assign the consent to a user or their device. Subject to individual information about the providers of cookie management services, the following notes apply: 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 about the scope of the consent (e.g., which categories of cookies and/or service providers), as well as the browser, system, and device used; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Business services
We process data of our contractual and business partners, e.g., customers and prospects (collectively referred to as "contractual partners") within the framework of contractual and comparable legal relationships as well as related measures and in the context of communication with the contractual partners (or pre-contractually), e.g., to respond to inquiries.
We process this data to fulfill our contractual obligations. This includes in particular the obligations to provide the agreed services, any update obligations, and remedies for warranty and other service disruptions. Furthermore, we process the data to protect our rights and for administrative tasks associated with these obligations as well as corporate organization. Additionally, we process the data based on our legitimate interests in proper and businesslike 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., involving telecommunications, transport, and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers, or financial authorities). Within the scope of applicable law, we only disclose contractual partner data to third parties to the extent necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners are informed about other forms of processing, e.g., for marketing purposes, within this privacy policy.
Which data is necessary for the aforementioned purposes, we inform the contractual partners before or during data collection, e.g., in online forms, by special marking (e.g., colors) or symbols (e.g., asterisks or similar), or personally.
We delete the data after the expiration of statutory warranty and comparable obligations, i.e., generally after 4 years, unless the data is stored in a customer account, e.g., as long as they must be retained for archival purposes for legal reasons. The statutory retention period for tax-relevant documents as well as for commercial books, inventories, opening balances, annual financial statements, the work instructions and other organizational documents and booking records necessary to understand these documents is ten years, and for received commercial and business letters and copies of sent commercial and business letters six years. 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, the annual financial statement or the management report was prepared, the commercial or business letter was received or sent, or the booking record was created, or 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 privacy notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.
Types of data processed: Master data (e.g., names, addresses); payment data (e.g., bank details, invoices, payment history); contact data (e.g., email, phone numbers); contract data (e.g., contract subject, duration, customer category); usage data (e.g., visited websites, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
Data subjects: Customers; prospects. Business and contractual partners.
Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; security measures; contact inquiries and communication; office and organizational procedures. Management and response to inquiries.
Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing procedures, methods, and services:
- Customer Account: Customers can create an account within our online offer (e.g., customer or user account, briefly "customer account"). If registration of a customer account is required, customers will be informed accordingly as well as about the information required for registration. Customer accounts are not public and cannot be indexed by search engines. As part of the registration and subsequent logins and uses of the customer account, we store the customers' IP addresses along with access times to verify the registration and prevent possible misuse of the customer account. If the customer account is terminated, the data of the customer account will be deleted after the termination date, unless it is retained for other purposes than providing the customer account or must be retained for legal reasons (e.g., internal storage of customer data, order processes, or invoices). It is the customers' responsibility to back up their data when terminating the customer account; Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- Online shop, order forms, e-commerce, and delivery: We process our customers' data to enable them to select, purchase, or order the chosen products, goods, and related services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, especially postal, freight, and shipping companies, to carry out the delivery or execution to our customers. For processing payment transactions, we use the services of banks and payment service providers. The required information is marked as such within the order or comparable acquisition process and includes the data needed for delivery, provision, and billing, as well as contact information to enable any necessary communication; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Provision of the online offer and web hosting
We process user data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or device.
Types of data processed: Usage data (e.g., visited web pages, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, consent status); content data (e.g., entries in online forms).
Affected persons: Users (e.g., website visitors, users of online services).
Purposes of processing: Provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing procedures, methods, and services:
- Collection of access data and log files: Access to our online offer is logged in the form of so-called "server log files." Server log files may include the address and name of the accessed web pages and files, date and time of access, amount of data transferred, message about successful retrieval, browser type and version, user's operating system, referrer URL (the previously visited page), and usually IP addresses and the requesting provider. The server log files can be used for security purposes, e.g., to prevent server overload (especially in the case of abusive attacks, so-called DDoS attacks), and to ensure server utilization and stability; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is necessary for evidentiary purposes are exempt from deletion until the final clarification of the respective incident.
- Email sending and hosting: The web hosting services we use also include the sending, receiving, and storage of emails. For these purposes, the addresses of recipients and senders as well as other information related to email transmission (e.g., the involved providers) and the contents of the respective emails are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that emails are generally not sent encrypted over the internet. Usually, emails are encrypted during transmission, but (unless an end-to-end encryption method is used) not on the servers from which they are sent and received. Therefore, we cannot assume responsibility for the transmission path of emails between the sender and reception on our server; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Shopify: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacities); Service provider: Shopify International Limited, Victoria Buildings, 2nd Floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.shopify.com/de; Privacy policy: https://www.shopify.com/legal/privacy.
Contact and inquiry management
When contacting us (e.g., by mail, contact form, email, phone, or via social media) as well as within existing user and business relationships, the information of the requesting persons is processed insofar as it is necessary to answer the contact inquiries and any requested measures.
Types of data processed: Contact data (e.g., email, phone numbers); content data (e.g., entries in online forms); usage data (e.g., visited websites, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
Data subjects: Communication partners.
Purposes of processing: Contact inquiries and communication; management and response to inquiries; feedback (e.g., collecting feedback via online form). Provision of our online offer and user-friendliness.
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing procedures, methods, and services:
- Contact form: When users contact us via our contact form, email, or other communication channels, we process the data provided in this context to handle the communicated request; Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Newsletters and electronic notifications
We send newsletters, emails, and other electronic notifications (hereinafter "newsletters") only with the consent of the recipients or a legal permission. If the content of the newsletter is specifically described during registration, it is decisive for the users' consent. Otherwise, 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 may ask you to provide a name for personal addressing in the newsletter or additional information if it is necessary for the purposes of the newsletter.
Double opt-in procedure: Registration for our newsletter is generally done using a so-called double opt-in procedure. This means that after registering, you will receive an email asking you to confirm your registration. This confirmation is necessary to ensure that no one can register with someone else's email address. Newsletter registrations are logged to be able to prove the registration process in accordance with legal requirements. This includes storing the registration and confirmation timestamps as well as the IP address. Changes to your data stored with the mailing service provider are also logged.
Deletion and restriction of processing: We can store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them, in order to prove a previously given consent. The processing of this data is limited to the purpose of possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a blocklist (so-called "Blocklist").
The logging of the registration process is based on our legitimate interests for the purpose of proving its proper execution. If we commission a service provider to send emails, this is done based on our legitimate interests in an efficient and secure delivery system.
Content: Information about us, our services, promotions, and offers.
Types of data processed: Master data (e.g., names, addresses); contact data (e.g., email, phone numbers); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status); usage data (e.g., visited websites, interest in content, access times).
Data subjects: Communication partners.
Purposes of processing: Direct marketing (e.g., by email or postal mail).
Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Option to object (Opt-Out): You can unsubscribe from our newsletter at any time, i.e., revoke your consents or object to further receipt. A link to unsubscribe from the newsletter can be found either at the end of each newsletter or you can use one of the contact options listed above, preferably email, for this purpose.
Further information on processing procedures, methods, and services:
- Measurement of open and click rates: The newsletters contain a so-called "web beacon," i.e., a pixel-sized file that is retrieved from our server or, if we use a shipping service provider, from their server when the newsletter is opened. During this retrieval, technical information such as browser and system information, as well as your IP address and the time of retrieval, are collected. This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened, and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until deletion. The evaluations help us recognize the reading habits of our users and adapt our content to them or send different content according to the interests of our users. The measurement of open rates and click rates as well as the storage of measurement results in the users' profiles. Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Sweepstakes and Competitions
We process personal data of participants in sweepstakes and competitions only in compliance with the relevant data protection regulations, insofar as the processing is contractually necessary for the provision, execution, and handling of the sweepstakes, the participants have consented to the processing, or the processing serves our legitimate interests (e.g., the security of the sweepstakes or the protection of our interests against misuse through possible collection of IP addresses when submitting sweepstakes entries).
If participants' contributions are published as part of the sweepstakes (e.g., in the context 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 can 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 terms of use and privacy policies of the respective platforms also apply. In these cases, we point out that we are responsible for the information provided by participants in the context of the sweepstakes and that inquiries regarding the sweepstakes should be directed to us.
The participants' data will be deleted as soon as the sweepstakes or competition has ended and the data is no longer required to inform the winners or because no further inquiries regarding the sweepstakes are expected. As a rule, the participants' data will be deleted no later than 6 months after the end of the sweepstakes. Winners' data may be retained longer to, for example, answer inquiries about the prizes or fulfill the prize services; in this case, the retention period depends on the type of prize and is, for example, up to three years for goods or services to handle warranty cases. Furthermore, participants' data may be stored longer, for example, in the form of reporting on the sweepstakes in online and offline media.
If data collected in the context of the sweepstakes is also collected for other purposes, their processing and retention period are governed by the privacy notices for that use (e.g., in the case of newsletter registration as part of a sweepstakes).
Types of data processed: Inventory data (e.g., names, addresses); content data (e.g., entries in online forms); meta, communication, and procedure data (e.g., IP addresses, timestamps, identification numbers, consent status).
Data subjects: Sweepstakes and competition participants.
Purposes of processing: Conducting sweepstakes and competitions.
Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Web analysis, monitoring, and optimization
Web analysis (also referred to as "reach measurement") is used to evaluate the visitor flows of our online offering and can include behavior, interests, or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, determine at what times our online offering or its functions or content are most frequently used or invite reuse. We can also track which areas need optimization.
In addition to web analysis, we may also use testing procedures to, for example, test and optimize different versions of our online offer or its components.
Unless otherwise stated below, profiles, i.e., data combined for a usage event, can be created for these purposes and information can be stored in and read from a browser or device. The collected data particularly includes visited websites and elements used there, as well as technical information such as the browser used, the computer system used, and usage times. If users have consented to the collection of their location data either to us or to the providers of the services we use, location data may also be processed.
The IP addresses of users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) are stored in the context of web analysis, A/B testing, and optimization, but pseudonyms. That means neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.
Types of data processed: Usage data (e.g., visited websites, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
Affected persons: Users (e.g., website visitors, users of online services).
Purposes of processing: Reach measurement (e.g., access statistics, recognition of recurring visitors); profiles with user-related information (creating user profiles). Provision of our online offer and user-friendliness.
Security measures: IP masking (pseudonymization of the IP address).
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing procedures, methods, and services:
- Google Analytics: We use Google Analytics to measure and analyze the usage of our online offer based on a pseudonymous user identification number. This identification number does not contain any unique data such as names or email addresses. It serves to assign analysis information to an end device in order to recognize which content users have accessed within one or several usage sessions, which search terms they have used, revisited, or interacted with our online offer. The time of use and its duration are also stored, as well as the sources of users referring to our online offer and technical aspects of their devices and browsers. Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides coarse geographic location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based counterparts). For EU traffic, IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. They are not logged, are not accessible, and are not used for further purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymization of the IP address); Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: Data Privacy Framework (DPF); Objection possibility (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertising: https://myadcenter.google.com/personalizationoff. More information: https://business.safety.google/adsservices/ (types of processing and processed data).
Online marketing
We process personal data for the purposes of online marketing, which particularly includes the marketing of advertising spaces or the display of advertising and other content (collectively referred to as "content") based on potential interests of the users as well as the measurement of their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar methods are used, by which information relevant to the display of the aforementioned content is stored about the user. This information can include, for example, viewed content, visited websites, used online networks, but also communication partners and technical details such as the browser used, the computer system used, as well as information about usage times and functions used. If users have consented to the collection of their location data, this may also be processed.
The IP addresses of the users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect the users. Generally, no clear data of the users (such as email addresses or names) are stored within the online marketing procedure, but pseudonyms. That means neither we nor the providers of the online marketing procedures know the actual identity of the users, only the information stored in their profiles.
The information in the profiles is usually stored in cookies or by similar methods. These cookies can later generally be read on other websites that use the same online marketing procedure, analyzed for the purpose of content presentation, supplemented with additional data, and stored on the server of the online marketing procedure provider.
Exceptionally, clear data can be assigned to the profiles. This is the case, for example, when users are members of a social network whose online marketing procedures we use and the network links the users' profiles with the aforementioned information. Please note that users can make additional agreements with the providers, e.g., by consenting during registration.
We generally only gain access to aggregated information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing methods have led to a so-called conversion, i.e., for example, to a contract conclusion with us. Conversion measurement is used solely to analyze the success of our marketing measures.
Unless otherwise stated, please assume that cookies used are stored for a period of two years.
Types of data processed: Usage data (e.g., visited websites, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
Affected persons: Users (e.g., website visitors, users of online services).
Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest-/behavior-based profiling, use of cookies); marketing; profiles with user-related information (creating user profiles). Conversion measurement (measuring the effectiveness of marketing measures).
Security measures: IP masking (pseudonymization of the IP address).
Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Option to object (Opt-Out): We refer to the privacy notices of the respective providers and the objection options provided by the providers (so-called "Opt-Out"). If no explicit opt-out option is provided, there is the possibility to disable cookies in your browser settings. However, this may restrict the functions of our online offer. Therefore, we additionally recommend the following opt-out options, which are offered collectively for respective areas:
a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-border: https://optout.aboutads.info.
Further information on processing procedures, methods, and services:
- Google Ads and Conversion Tracking: Online marketing methods for the purpose of placing content and ads within the service provider's advertising network (e.g., in search results, in videos, on websites, etc.) so that they are shown to users who are presumed to be interested in the ads. Furthermore, we measure the conversion of the ads, i.e., whether users have taken the ads as an occasion to interact with them and use the advertised offers (so-called conversion). However, we only receive anonymous information and no personal information about individual users; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR), Legitimate Interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for Third Country Transfers: Data Privacy Framework (DPF); More Information: Types of processing and data processed: https://business.safety.google/adsservices/. Data processing terms between controllers and standard contractual clauses for third country data transfers: https://business.safety.google/adscontrollerterms.
Presences in social networks (Social Media)
We maintain online presences within social networks and process user data in this context to communicate with users active there or to offer information about us.
We point out that user data may be processed outside the territory of the European Union. This can pose risks for users because, for example, enforcing users' rights could be made more difficult.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created based on user behavior and resulting interests. These usage profiles can in turn be used to display advertisements within and outside the networks that presumably correspond to the users' interests. For these purposes, cookies are usually stored on users' computers, in which the usage behavior and interests of the users are saved. Furthermore, data independent of the devices used by the users can also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in).
For a detailed presentation of the respective processing forms and the options to object (opt-out), we refer to the privacy policies and information of the operators of the respective networks.
Even in the case of information requests 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 users' data and can directly take appropriate measures and provide information. If you still need assistance, you can contact us.
Types of data processed: Contact data (e.g., email, phone numbers); content data (e.g., entries in online forms); usage data (e.g., visited websites, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status); master data (e.g., names, addresses).
Affected persons: Users (e.g., website visitors, users of online services).
Purposes of processing: Contact inquiries and communication; feedback (e.g., collecting feedback via online form); marketing; 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 sentence 1 lit. f) GDPR).
Further information on processing procedures, methods, and services:
- Instagram: Social network; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy. Basis for third-country transfers: Data Privacy Framework (DPF).
- Facebook Pages: Profiles within the social network Facebook; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Basis for Third Country Transfers: Data Privacy Framework (DPF); Further Information: We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (so-called "Fanpage"). This data includes information about the types of content users view or interact with, or actions they take (see under "Things you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see under "Device Information" in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services, so-called "Page Insights," for page operators so they can gain insights into how people interact with their pages and the content connected to them. We have concluded a special agreement with Facebook ("Information about Page Insights", https://www.facebook.com/legal/terms/page_controller_addendum), which in particular regulates the security measures Facebook must observe and in which Facebook has agreed to fulfill data subject rights (i.e., users can, for example, directly address Facebook with requests for information or deletion). The rights of users (especially 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 about Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data). The joint responsibility is limited to the collection by and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which particularly concerns the transfer of data to the parent company Meta Platforms, Inc. in the USA.
- Pinterest: Social network; Service provider: Pinterest Europe Limited, 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);Website: https://www.pinterest.com. Privacy Policy: https://policy.pinterest.com/de/privacy-policy.
- TikTok: Social network / video platform; service provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);website: https://www.tiktok.com. privacy policy: https://www.tiktok.com/de/privacy-policy.
- YouTube: Social network and video platform; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);privacy policy: https://policies.google.com/privacy; basis for third-country transfers: Data Privacy Framework (DPF). opt-out option: https://myadcenter.google.com/personalizationoff.
Plugins and embedded functions as well as content
We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as "third parties"). These can be, for example, graphics, videos, or city maps (hereinafter uniformly referred to as "content").
Embedding always requires that the third-party providers of this content process the users' IP addresses, as they could not send the content to their browsers without the IP address. The IP address is therefore necessary for the display of this content or functions. We strive to use only such content whose respective providers use the IP address solely for delivering the content. Third parties may also use so-called pixel tags (invisible graphics, also called "web beacons") for statistical or marketing purposes. Through the "pixel tags," information such as visitor traffic on the pages of this website can be evaluated. The pseudonymous information may also be stored in cookies on the users' devices and may include, among other things, technical information about the browser and operating system, referring websites, visit time, as well as other details about the use of our online offer, and may be combined with such information from other sources.
Types of data processed: Usage data (e.g., visited websites, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status); master data (e.g., names, addresses); contact data (e.g., email, phone numbers); content data (e.g., entries in online forms).
Affected persons: Users (e.g., website visitors, users of online services).
Purposes of processing: Provision of our online offer and user-friendliness.
Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing procedures, methods, and services:
- Google Fonts (Access from the Google Server): Access to fonts (and symbols) for the purpose of technically secure, maintenance-free, and efficient use of fonts and symbols with regard to up-to-dateness and loading times, their uniform display, and consideration of possible licensing restrictions. The provider of the fonts is informed of the user's IP address so that the fonts can be made available in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) is transmitted, which is necessary for providing the fonts depending on the devices used and the technical environment. These data may be processed on a server of the font provider in the USA - When visiting our online offer, the users' browsers send their browser HTTP requests to the Google Fonts Web API (i.e., a software interface for retrieving the fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) from Google Fonts and then the fonts specified in the CSS. These HTTP requests include (1) the IP address used by the respective user to access the internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user agent, which describes the browser and operating system versions of the website visitors, as well as the referrer URL (i.e., the webpage on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers, and they are not analyzed. The Google Fonts Web API logs details of the HTTP requests (requested URL, user agent, and referrer URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. These data are logged so that Google can determine how often a particular font family is requested. In the Google Fonts Web API, the user agent must adjust the font generated for the respective browser type. The user agent is primarily logged for debugging and used to generate aggregated usage statistics that measure the popularity of font families. These aggregated usage statistics are published on the "Analytics" page of Google Fonts. Finally, the referrer URL is logged so that the data can be used for production maintenance and an aggregated report on the top integrations based on the number of font requests can be generated. According to its own statements, Google does not use any of the information collected by Google Fonts to create profiles of end users or to display targeted advertisements; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF). More information: https://developers.google.com/fonts/faq/privacy?hl=de.
- YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF). Option to object (Opt-Out): Opt-Out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertising: https://myadcenter.google.com/personalizationoff.