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 websites, functions and content associated with it as well as external online presences, such as our Social Media Profile (hereinafter jointly referred to as “online offering”). With regard to the terms used, such as “processing” or “person responsible”, we refer you to the definitions in Art. 4 of the Data Protection Basic Regulation (DSGVO).
c/o Postflex #362
Helmers Kamp 74
E-mail address: firstname.lastname@example.org
Link to the imprint: https://saschawolf.me/imprint/en/
Types of data processed
- Inventory data (e.g., personal 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, etc.).
Categories of affected persons
Visitors and users of the online offer (hereinafter referred to collectively as “users”).
Purpose of processing
- Provision of the online offer, its functions and contents.
- Answering contact requests and communicating with users.
- Security measures.
- Range measurement/Marketing
“personal data” means any information relating to an identified or identifiable natural person (hereinafter “affected person”); 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 carried out with or without the aid of automated processes, or set of operations, involving 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 affected person 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.
The “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
“processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Applicable legal bases
In accordance with Art. 13 DSGVO we inform you about the legal basis of our data processing. For users from the area of application of the data protection basic regulation (DSGVO), 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 DSGVO;
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 DSGVO;
The legal basis for the processing for the fulfilment of our legal obligations is Art. 6 para. 1 lit. c DSGVO;
Art. 6 para. 1 lit. d DSGVO serves as the legal basis in the event that vital interests of the affected person 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 DSGVO.
The legal basis for the processing to safeguard our legitimate interests is Art. 6 para. 1 lit. f DSGVO.
The processing of data for purposes other than those for which they were collected is governed by the provisions of Art. 6 (4) DSGVO.
The processing of special categories of data (pursuant to Art. 9 (1) DSGVO) is governed by the provisions of Art. 9 (2) DSGVO.
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 affected persons’ rights, the deletion of data and the response 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, jointly responsible persons 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 express consent or contractually required transfer, we process or allow the data to be processed only in third countries with a recognised level of data protection, which includes US processors certified under the “Privacy Shield” or on the basis of special guarantees, such as a contractual obligation through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission).
Rights of the affected persons
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 inaccurate data concerning you.
In accordance with the statutory provisions, you have the right to demand that the data concerned 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 the data concerning you which you have made available to us be received in accordance with the statutory provisions and that it be transferred to other persons responsible.
You also have the right to file a complaint with the competent supervisory authority in accordance with the statutory provisions.
Right of revocation
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 personal 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) during or after the user’s visit to an online service. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer 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 is 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 online service (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 restrictions of this online offer.
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.
DISQUS comment function
On the basis of our legitimate interests in an efficient, secure and user-friendly comment management in accordance with Art. 6 Para. 1 lit. f., we set the following standards for our services DSGVO, the comment service DISQUS, offered by DISQUS, Inc., 301 Howard St, Floor 3 San Francisco, California- 94105, USA. DISQUS 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=a2zt0000000TRkEAAW&status=Active.
To use the DISQUS comment function, users can log in via their own DISQUS user account or an existing social media account (e.g. OpenID, Facebook, Twitter or Google). DISQUS obtains the user’s login data from the platforms. It is also possible to use the DISQUS comment function as a guest without creating or using a user account with DISQUS or one of the specified social media providers.
We merely embed DISQUS and its functions into our website, whereby we can influence the comments of the users. However, the users enter into a direct contractual relationship with DISQUS, within the framework of which DISQUS processes the user’s comments and is a contact person for any deletion of the user’s data. We refer here to the DISQUS data protection declaration: https://help.disqus.com/terms-and-policies/disqus-privacy-policy and also point out to the users that they can assume that DISQUS stores not only the comment content but also their IP address and the time of the comment as well as cookies on the user’s computer and can use them to display advertisements. Users may, however, object to the processing of their data for the purpose of displaying advertisements: https://disqus.com/data-sharing-settings.
Retrieval of profile pictures from Gravatar
We use the service Gravatar of Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA, within our online offer and especially in the blog.
Gravatar is a service where users can register and store profile pictures and their e-mail addresses. If users leave contributions or comments with the respective e-mail address on other online presences (especially in blogs), their profile pictures can be displayed next to the contributions or comments. For this purpose, the e-mail address provided by the users is encrypted and transmitted to Gravatar for the purpose of checking whether a profile is stored for it. This is the only purpose of the transmission of the e-mail address and it is not used for other purposes, but deleted afterwards.
Gravatar is used on the basis of our legitimate interests within the meaning of Art. 6 Para. 1 lit. f) DSGVO, as we use Gravatar to offer authors of contributions and comments the opportunity to personalise their contributions with a profile picture.
If users do not want a user image associated with their Gravatar e-mail address to appear in the comments, they should use an e-mail address that is not registered with Gravatar to comment. We would also like to point out that it is also possible to use an anonymous e-mail address or no e-mail address at all if users do not wish their own e-mail address to be sent to Gravatar. Users can completely prevent the transmission of data by not using our comment system.
Hosting and emailing
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 online service.
Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors to this online service on the basis of our legitimate interests in the efficient and secure provision of this online service in accordance with Art. 6 Para. 1 lit. f DSGVO in connection with Art. 28 DSGVO (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. DSGVO 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. to clarify abuse or fraud actions) for a maximum period of 7 days and then deleted. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.
Content Delivery Network of Cloudflare
We use a so-called “Content Delivery Network” (CDN), offered by Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA. Cloudflare is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnZKAA0&status=Active).
A CDN is a service that enables us to deliver content from our online services, especially large media files such as graphics or scripts, more quickly with the help of regionally distributed servers connected via the Internet. The processing of user data is carried out solely for the aforementioned purposes and to maintain the security and functionality of the CDN.
The use is made on the basis of our legitimate interests, i.e. interest in a secure and efficient provision, analysis and optimisation of our online offer in accordance with Art. 6 Para. 1 letter f. DSGVO.
Further information can be found in the Cloudflare data protection declaration: https://www.cloudflare.com/security-policy.
Google will use this information on our behalf to evaluate the use of our website by users, to compile reports on activities within this website and to provide us with other services relating to the use of this website and the Internet. Pseudonymous user profiles can be created from the processed data.
We use Google Analytics only with activated IP anonymization. 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.
If we ask the users for their consent (e.g. in the context of a cookie consent), the legal basis for this processing is Art. 6 Para. 1 lit. a. DSGVO. Otherwise, the personal data of the user will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online service in the sense of Art. 6 Para. 1 lit. f. of the German Data Protection Act). DSGVO).
As far as data is processed in the USA, we point out that Google is certified under the Privacy Shield Agreement and thereby assures compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Users’ personal data will be deleted or anonymised after 14 months.
Online presence 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 can result in risks for users, as it could, for example, make it more difficult to enforce the rights of users. 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.
In addition, user data is usually processed for market research and advertising purposes. For example, user profiles can be created on the basis of user behavior and the resulting interests of users. The usage 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 the personal data of the users takes place on the basis of our legitimate interests in effective information of the users and communication with the users in accordance with Art. 6 Para. 1 letter f. DSGVO. 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 DSGVO.
For a detailed description of the respective processing operations and the opt-out options, 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.
Google/ YouTube (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) - Privacy Statement: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&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, Ireland) - 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.
Xing (XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany) - Privacy Statement / Opt-Out: https://privacy.xing.com/de/datenschutzerklaerung.
Wakalet (Wakelet Limited, 76 Quay Street, Manchester, M3 4PR, United Kingdom) - Privacy Statement / Opt-Out: https://wakelet.com/privacy.html.
Soundcloud (SoundCloud Limited, Rheinsberger Str. 76⁄77, 10115 Berlin, Germany) - Privacy Statement / Opt-Out: https://soundcloud.com/pages/privacy.
Integration of services and contents of third parties
Within the scope of our online offer, we act on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. f. of the German Civil Code). DSGVO) 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 web pages, visit times and other information about the use of our online services, as well as may be linked to such information from other sources.
Functions and contents of the Twitter service offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, can be integrated into our online offer. This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online service within Twitter.