This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as "data") within our online offer and the websites, functions and contents connected with it as well as external online presences, such as our Social Media Profile (hereinafter referred to collectively as "online offer"). With regard to the terms used, e.g. "processing" or "responsible person", we refer to the definitions in Art. 4 of the Basic Data Protection Regulation (DSGVO).
Janine Henry & Georg Langner
Welfenstr. 8a, 81541 Munich
types of data processed:
- stock data (for example, names, addresses).
- Contact data (e.g., e-mail, telephone numbers).
- Content data (e.g., text input, photographs, videos).
- usage data (e.g., web pages visited, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).
Categories of data subjects
Visitors and users of the online offer (in the following we will refer to the persons concerned collectively as "users").
Purpose of processing
- Provision of the online offer, its functions and contents.
- Answering of contact requests and communication with users.
- security measures.
- Range measurement/Marketing
"Personal data" shall mean any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
"Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually all processing of data.
"pseudonymisation" means the processing of personal data in such a way that the personal data cannot be related to a specific data subject without the inclusion of supplementary information, provided that this supplementary information is kept separate and is subject to technical and organisational measures ensuring that the personal data is not related to an identified or identifiable natural person
"profiling" shall mean any automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular with a view to analysing or predicting aspects relating to the performance of work, the economic situation, health, personal preferences, interests, reliability, conduct, whereabouts or movements of that natural person
The term "responsible" shall mean the natural or legal person, public authority, agency or any 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.
Relevant legal basis
In accordance with Art. 13 DSGVO, we inform you of the legal basis of our data processing. If the legal basis is not stated in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 Para. 1 lit. a and Art. 7 DSGVO, the legal basis for processing for the purpose of fulfilling our services and implementing contractual measures and answering enquiries is Art. 6 Para. 1 lit. b DSGVO, the legal basis for processing for the purpose of fulfilling our legal obligations is Art. 6 Para. 1 lit. c DSGVO, and the legal basis for processing for the purpose of safeguarding our legitimate interests is Art. 6 Para. 1 lit. f DSGVO. In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6 paragraph 1 letter d DSGVO serves as the legal basis.
In accordance with Art. 32 DSGVO and taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the varying probability of occurrence and severity of the risk to the rights and freedoms of natural persons, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.
Such measures shall include in particular safeguarding the confidentiality, integrity and availability of data by controlling physical access to data, as well as access, input, disclosure, safeguarding of availability and segregation of data relating to them. Furthermore, we have established procedures to ensure that data subjects' rights are exercised, data is deleted, and we respond to any threats to the data. 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 through data protection-friendly presettings (Art. 25 DSGVO).
Cooperation with contract processors and third parties
If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transfer it to them or otherwise grant them access to the data, this is only done on the basis of a legal authorisation (e.g. if the data must be transferred to third parties, such as payment service providers, in accordance with Art. 6 Para. 1 letter b DSGVO for the fulfilment of the contract), if you have given your consent, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we commission third parties to process data on the basis of a so-called "contract processing agreement", this is done on the basis of Art. 28 DSGVO.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using the services of third parties or disclosure or transfer of data to third parties, this will only take place if it is done to fulfil our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we will only process or transfer the data in a third country if the special requirements of Art. 44 ff. DSGVO. This means that the processing is carried out, for example, on the basis of special guarantees, such as the officially recognised determination of a level of data protection corresponding to that of the EU (e.g. for the USA through the "Privacy Shield") or compliance with officially recognised special contractual obligations (so-called "standard contractual clauses").
Rights of data subjects
You have the right to obtain confirmation as to whether or not data in question is being processed and to obtain information about this data and to receive further information and a copy of the data in accordance with Art. 15 DSGVO.
You have accordingly. Art. 16 DPA, you have the right to request the completion of data concerning you or the correction of incorrect data concerning you.
In accordance with Art. 17 DSGVO, you have the right to demand that data concerning you be deleted immediately, or alternatively, in accordance with Art. 18 DSGVO, to demand that the processing of the data be restricted.
You have the right to demand that the data concerning you which you have made available to us be received in accordance with Art. 20 DSGVO and to demand that it be passed on to other responsible parties.
You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 DSGVO.
Right of withdrawal
You have the right to revoke consents granted in accordance with Art. 7 Para. 3 DSGVO with effect for the future
Right of objection
You can object to the future processing of data concerning you at any time in accordance with Art. 21 DSGVO. The objection may in particular be made against processing for the purposes of direct advertising.
Cookies and right of objection for direct advertising
Cookies" are small files that are stored on the user's computer. Different information 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 his visit to an online offer. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the contents of a shopping cart in an online shop or a login status can be stored. Cookies are described as "permanent" or "persistent" if they remain stored even after the browser is closed. For example, the login status can be saved if the user visits it after several days. Likewise, the interests of the users can be stored in such a cookie, which are used for range measurement or marketing purposes. Third-party cookies" are cookies that are offered by providers other than the person responsible for the online offer (otherwise, if it is only their cookies, it is called "first-party cookies").
If users do not want 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 or restricted in their processing in accordance with articles 17 and 18 DSGVO. 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 the deletion does not conflict with any statutory storage obligations. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
According to legal requirements in Germany, the storage is in particular for 10 years in accordance with §§ 147 para. 1 AO, 257 para. 1 nos. 1 and 4, para. 4 HGB (books, records, management reports, accounting vouchers, trading books, documents relevant for taxation, etc.) and 6 years in accordance with § 257 para. 1 nos. 2 and 3, para. 4 HGB (commercial letters).
According to legal requirements in Austria, the storage is carried out in particular for 7 J in accordance with § 132 para. 1 BAO (accounting documents, vouchers / invoices, accounts, records, business documents, statement of income and expenditure, etc.), for 22 years in connection with real estate and for 10 years in the case of documents in connection with electronically provided services, telecommunications, radio and television services which are provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.
Users can create a user account. As part of the registration process, the required mandatory data is provided to the users and processed on the basis of Art. 6 para. 1 lit. b DSGVO for the purposes 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 is used for the purposes of the use of the user account and its purpose.
Users can be informed by e-mail about information relevant to their user account, such as technical changes. If users have cancelled their user account, their data with regard to the user account will be deleted, subject to a legal obligation to keep records. It is the responsibility of users to save their data before the end of the contract if they have terminated their user account. We are entitled to irretrievably delete all user data stored during the contract period.
Within the scope of the use of our registration and login functions and 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 need for protection against misuse and other unauthorized use. As a matter of principle, this data is not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Art. 6 Para. 1 lit. c. DSGVO. The IP addresses are anonymised or deleted after 7 days at the latest.
When contacting us (e.g. via contact form, e-mail, telephone or via social media), the user's details will be used to process the contact request and its handling in accordance with Art. 6 Para. 1 lit. b. (within the framework of contractual/pre-contractual relations), Art. 6 para. 1 lit. f. (other inquiries) DSGVO are processed... User data may be stored in a customer relationship management system ("CRM system") or comparable enquiry organisation.
We delete the enquiries if they are no longer required. We check the necessity every two years; furthermore, the statutory archiving obligations apply.
With the following notes we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the described procedures.
Content of the newsletter: We send newsletters, e-mails and other electronic notifications containing advertising information (hereinafter referred to as "newsletter") only with the consent of the recipients or a legal permission. Insofar as the contents of the newsletter are specifically described in the context of a registration for the newsletter, they are decisive for the consent of the users. Furthermore, our newsletters contain information about our services and us.
Double-Opt-In and logging: The registration for our newsletter is done in a so-called Double-Opt-In procedure. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with foreign e-mail addresses. The newsletter registrations 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. Changes to your data stored by the shipping service provider are also 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 for personal contact in the newsletter.
The dispatch of the newsletter and the measurement of success associated with it are based on the consent of the recipients in accordance with Art. 6 Para. 1 lit. a, Art. 7 DSGVO in conjunction with § 7 Para. 2 No. 3 UWG or, if consent is not required, on our legitimate interests in direct marketing in accordance with Art. 6 Para. 1 lt. f. DSGVO in conjunction with § Art. 7 Para. 3 UWG.
The registration procedure is recorded on the basis of our legitimate interests in accordance with Art. 6 para. 1 lit. f DSGVO. We are interested in the use of a user-friendly and secure newsletter system that serves our business interests as well as meeting the expectations of the users and also allows us to provide proof of consent.
Cancellation/revocation - You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. A link to cancel the newsletter can be found 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 we delete them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible 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.
Hosting and e-mailing
The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services as well as technical maintenance services which we use for the purpose of operating this online offer.
In doing so, 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 of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer in accordance with Art. 6 para. 1 lit. f DSGVO in conjunction with Art. 28 DSGVO (conclusion of contract processing agreement).
Collection of access data and log files
We, or our hosting provider, on the basis of our legitimate interests as defined in Art. 6 Par. 1 lit. f. DSGVO data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the accessed website, file, date and time of access, transferred data volume, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited site), IP address and the requesting provider.
For security reasons (e.g. to clarify misuse or fraud), log file information is stored for a maximum of 7 days and then deleted. Data whose further storage is required for evidence purposes is excluded from deletion until the respective incident has been finally clarified.
Google is certified under the Privacy-Shield-Agreement and thus offers a guarantee to comply with the European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our website by users, to compile reports on the activities within this website and to provide us with further services associated with the use of this website and the internet. In doing so, pseudonymous user profiles of the users can be created from the processed data.
We only use Google Analytics with activated IP anonymisation. 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 transferred to a Google server in the USA and shortened there.
The IP address transmitted by the user's browser is not merged with other Google data. Users can prevent the storage of cookies by adjusting their browser software accordingly; users can also prevent the collection of data generated by the cookie and relating to their use of the online offer to Google and the processing of this data by Google by downloading and installing the browser plugin available under the following link:
The personal data of users will be deleted or anonymised after 14 months.
Online presences in social media
We maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.
Unless otherwise stated in our data protection declaration, we process the data of users if they communicate with us within the social networks and platforms, e.g. write articles on our online presences or send us messages.
Integration of third party services and content
Within our online offer, we set within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer in the sense of Art. 6 Par. 1 lit. f. DSGVO), we use 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 these contents are aware of the IP address of the users, as without the IP address they would not be able to send the contents to their browsers. The IP address is therefore necessary for the display of this content. We make every effort to use only such content whose respective providers use the IP address only to deliver the content. Third party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain technical information about the browser and operating system, referring websites, visiting time and other details about the use of our online offer, as well as being linked to such information from other sources.
Use of Facebook Social Plugins
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. DSGVO) Social Plugins ("Plugins") of the social network facebook.com, which is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook").
This may include, for example, content such as images, videos or text and buttons with which users can share content from this online offering within Facebook. The list and appearance of the Facebook social plugins can be viewed here:
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).
When a user calls up a function of this online offer that contains such a plugin, his device establishes a direct connection with the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user's device and integrated into the online offer by the user. User profiles can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects with the help of this plugin and therefore inform the users according to our state of knowledge.
By integrating the plugins, Facebook receives the information that a user has called up the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to his or her Facebook account. If users interact with the plugins, for example, by pressing the Like button or making a comment, the corresponding information is transmitted directly from your device to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to find out his or her IP address and store it. According to Facebook, only an anonymized IP address is stored in Germany.
If a user is a Facebook member and does not want Facebook to collect data about him or her via this online offer and link it to his or her membership data stored on Facebook, he or she must log out of Facebook and delete his or her cookies before using our online offer. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: or via the US-American page or the EU page The settings are platform-independent, i.e. they are adopted for all devices, such as desktop computers or mobile devices.