Data Privacy Policy
We are very delighted that you have shown interest in our enterprise. Data protection is of a particularly high priority for the management of the Bowspirit Management GmbH. The use of the internet pages of the Bowspirit Management GmbH is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to the Bowspirit Management GmbH. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
As the controller, the Bowspirit Management GmbH has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.
1. Definitions
The data protection declaration of the Bowspirit Management GmbH is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.
In this data protection declaration, we use, inter alia, the following terms:
a) Personal data
Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) Data subject
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
c) Processing
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
e) Profiling
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
f) Pseudonymisation
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
g) Controller or controller responsible for the processing
Controller or controller responsible for the processing 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; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
h) Processor
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
i) Recipient
Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
j) Third party
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
k) Consent
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. Name and Address of the controller
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
Bowspirit Management GmbH
c/o Speckenbach
An der Logleine 4
23570 Lübeck
Germany
Phone +49 4502 8491833
E-mail mail@bowspirit-management.com
Websites www.bowspirit-management.com | www.bowspirit-kids-group.org
3. External hosting
This website is hosted by an external service provider (hereinafter referred to as "hoster"). The personal data collected on this website is stored on the hoster's servers. This may include, but is not limited to, IP addresses, contact requests, meta and communication data, contractual data, contact details, names, website accesses and other data generated via a website.
The hoster is used for the purpose of fulfilling the contract with our potential and existing customers (Article 6 (1) lit. b GDPR) and in the interest of a secure, fast and efficient provision of our online offer by a professional provider (Article 6 (1) lit. f GDPR).
Our hoster will only process your data insofar as this is necessary for the fulfilment of its service obligations and will follow our instructions with regard to this data.
We have entered into an order processing agreement (AVV) with our hoster. This is a contract required by data protection law, which ensures that the hoster only processes the personal data of our website visitors in accordance with our instructions and in compliance with the GDPR.
4. Cookies
The Internet pages of the Bowspirit Management GmbH use cookies. Cookies are text files that are stored in a computer system via an Internet browser.
Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the dats subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.
Through the use of cookies, the Bowspirit Management GmbH can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.
By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user that uses cookies, e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user's computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.
The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.
5. Types of cookies & general removal option
a) Session cookies
We use cookies on our website. Cookies are small text files or other storage technologies stored on your computer by your browser. These cookies process certain specific information about you, such as your browser, location data, or IP address.
This processing makes our website more user-friendly, efficient, and secure, allowing us, for example, to display our website in different languages or to offer a shopping cart function.
The legal basis for such processing is Article 6 (1) lit. b GDPR, insofar as these cookies are used to collect data to initiate or process contractual relationships.
If the processing does not serve to initiate or process a contract, our legitimate interest lies in improving the functionality of our website. The legal basis is then Article 6 (1) lit. f GDPR.
When you close your browser, these session cookies are deleted.
b) Third-party cookies
If necessary, our website may also use cookies from companies with whom we cooperate for the purpose of advertising, analysing, or improving the features of our website.
Please refer to the following information for details, in particular for the legal basis and purpose of such third-party collection and processing of data collected through cookies.
c) Disabling cookies
You can refuse the use of cookies by changing the settings on your browser. Likewise, you can use the browser to delete cookies that have already been stored. However, the steps and measures required vary, depending on the browser you use. If you have any questions, please use the help function or consult the documentation for your browser or contact its maker for support. Browser settings cannot prevent so-called flash cookies from being set. Instead, you will need to change the setting of your Flash player. The steps and measures required for this also depend on the Flash player you are using. If you have any questions, please use the help function or consult the documentation for your Flash player or contact its maker for support.
If you prevent or restrict the installation of cookies, not all of the functions on our site may be fully usable.
6. Cookie Manager
We use a cookie opt-in. This means that we ask for your consent before using cookies or similar procedures in which personal data is processed. The legal basis for the processing in this case is the consent pursuant to Article 6 (1) lit. a, Article 7 GDPR. However, this legal basis only applies if the person concerned is at least 16 years old. Persons younger than 16 years do not give their consent. Their data will continue to be processed on the basis of our legitimate interests pursuant to Article 6 (1) lit. f GDPR (interest in the user-friendliness of our online services and business interests). We take into account the opt-in of the under-16s as their reasonable expectation with regard to possible cookie use.
To obtain consent for the use of technically unnecessary cookies on the website, the provider uses a cookie manager.
When the website is called up, a cookie with the settings information is stored on the end device of the user so that the request for consent does not have to be made on a subsequent visit.
The cookie is required to obtain legally compliant user consent.
You can prevent cookies from being installed by adjusting the settings on your internet browser.
7. Cookiebot
We use Cookiebot to display cookie banners. Cookiebot is a product of Usercentrics A/S, Havnegade 39, 1058 Copenhagen, Denmark (hereinafter referred to as "Usercentrics").
Cookiebot informs you about the use of cookies on the website and allows you to make a decision about their use.
If you agree to the use of cookies, the following data will be automatically recorded by Usercentrics:
- your anonymized IP address;
- the date and time of your consent;
- the user agent of your browser;
- the provider’s URL;
- an anonymous, random, and encrypted key;
- your cookie status which serves as proof of consent.
The legal basis for this processing of data is Article 6 (1) lit. f GDPR. Our legitimate interest is in the user-friendliness of the website and the fulfillment of the statutory requirements of GDPR.
You can prevent cookies from being installed and/or delete this cookie by adjusting the settings on your internet browser.
Go to this link to read the Usercentrics privacy policy: https://www.cookiebot.com/en/privacy-policy/
8. Collection of general data and information
The website of the Bowspirit Management GmbH collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using these general data and information, the Bowspirit Management GmbH does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the Bowspirit Management GmbH analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
9. SSL and/or TLS encryption
For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption programme.
You can recognise an encrypted connection by checking whether the address line of the browser switches from "http://" to "https://" and also by the appearance of the lock icon in the browser line.
If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.
10. Font Awesome (local hosting)
This website uses Font Awesome for the consistent display of fonts. Font Awesome is installed locally. A connection to servers of Fonticons, Inc. does not take place.
For more information about Font Awesome, please refer to the Font Awesome privacy policy at https://fontawesome.com/privacy.
11. Data protection provisions about the application and use of Matomo
On this website, the controller has integrated the Matomo component. Matomo is an open-source software tool for web analysis. Web analysis is the collection, gathering and evaluation of data on the behaviour of visitors from Internet sites. A web analysis tool collects, inter alia, data on the website from which a data subject came to a website (so-called referrer), which pages of the website were accessed or how often and for which period of time a sub-page was viewed. A web analysis is mainly used for the optimization of a website and the cost-benefit analysis of Internet advertising.
The software is operated on the server of the controller, the data protection-sensitive log files are stored exclusively on this server.
The purpose of the Matomo component is the analysis of the visitor flows on our website. The controller uses the obtained data and information, inter alia, to evaluate the use of this website in order to compile online reports, which show the activities on our Internet pages.
Matomo sets a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, an analysis of the use of our website is enabled. With each call-up to one of the individual pages of this website, the Internet browser on the information technology system of the data subject is automatically through the Matomo component prompted to submit data for the purpose of online analysis to our server. During the course of this technical procedure, we obtain knowledge about personal information, such as the IP address of the data subject, which serves to understand the origin of visitors and clicks.
The cookie is used to store personal information, such as the access time, the location from which access was made, and the frequency of visits to our website. With each visit of our Internet pages, these personal data, including the IP address of the Internet access used by the data subject, are transferred to our server. These personal data will be stored by us. We do not forward this personal data to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the used Internet browser would also prevent Matomo from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Matomo may be deleted at any time via a web browser or other software programs.
In addition, the data subject has the possibility of objecting to a collection of data relating to a use of this Internet site that are generated by Matomo as well as the processing of these data by Matomo and the chance to preclude any such. For this, the data subject must set a "Do Not Track" option in the browser.
With each setting of the opt-out cookie, however, there is the possibility that the websites of the controller are no longer fully usable for the data subject.
Further information and the applicable data protection provisions of Matomo may be retrieved under https://matomo.org/privacy/.
12. Routine erasure and blocking of personal data
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
13. Rights of the data subject
a) Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.
b) Right of access
Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.
c) Right to rectification
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.
d) Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the Bowspirit Management GmbH, he or she may, at any time, contact any employee of the controller. An employee of Bowspirit Management GmbH shall promptly ensure that the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17 (1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employees of the Bowspirit Management GmbH will arrange the necessary measures in individual cases.
e) Right of restriction of processing
Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the Bowspirit Management GmbH, he or she may at any time contact any employee of the controller. The employee of the Bowspirit Management GmbH will arrange the restriction of the processing.
f) Right to data portability
Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6 (1) of the GDPR or point (a) of Article 9 (2) of the GDPR, or on a contract pursuant to point (b) of Article 6 (1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20 (1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact any employee of the Bowspirit Management GmbH.
g) Right to object
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6 (1) of the GDPR. This also applies to profiling based on these provisions.
The Bowspirit Management GmbH shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
If the Bowspirit Management GmbH processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the Bowspirit Management GmbH to the processing for direct marketing purposes, the Bowspirit Management GmbH will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the Bowspirit Management GmbH for scientific or historical research purposes, or for statistical purposes pursuant to Article 89 (1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the data subject may contact any employee of the Bowspirit Management GmbH. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
h) Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, the Bowspirit Management GmbH shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the Bowspirit Management GmbH.
i) Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the Bowspirit Management GmbH.
14. Registration on our website
The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for his own purposes. The controller may request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to the controller.
By registering on the website of the controller, the IP address - assigned by the Internet service provider (ISP) and used by the data subject - date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.
The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.
The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the controller’s employees are available to the data subject in this respect as contact persons.
15. Contact possibility via the website
The website of the Bowspirit Management GmbH contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address).
If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.
16. Request by e-mail, telephone or fax
If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.
The processing of these data is based on Article 6 (1) lit. b GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases, the processing is based on your consent (Article 6 (1) lit. a GDPR) and/or on our legitimate interests (Article 6 (1) lit. f GDPR), since we have a legitimate interest in the effective processing of requests addressed to us.
The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.
17. Data protection for applications and the application procedures
The data controller shall collect and process the personal data of applicants for the purpose of the processing of the application procedure. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a web form on the website to the controller. If the data controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the controller, the application documents shall be automatically erased two months after notification of the refusal decision, provided that no other legitimate interests of the controller are opposed to the erasure. Other legitimate interest in this relation is, e.g. a burden of proof in a procedure under the General Equal Treatment Act (AGG).
18. Subscription to our newsletters
On the website of the Bowspirit Management GmbH, users are given the opportunity to subscribe to our enterprise's newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.
The Bowspirit Management GmbH informs its customers and business partners regularly by means of a newsletter about enterprise offers. The enterprise's newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.
During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.
The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller, or to communicate this to the controller in a different way.
Brevo is the email marketing software used. This means your information is transmitted to Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany (hereinafter referred to as "Brevo"). Brevo is prohibited from selling your data and from using it for purposes other than sending email. Brevo is a certified German email marketing software provider, working in accordance with the European directive 95/46 (GDPR), as well as the German Federal Data Protection Act (BDSG). More info: https://www.brevo.com/information-for-email-recipients/
19. Newsletter-Tracking
The newsletter of the Bowspirit Management GmbH contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, the Bowspirit Management GmbH may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.
Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. The Bowspirit Management GmbH automatically regards a withdrawal from the receipt of the newsletter as a revocation.
20. Mynewsdesk Newsroom
We use the services of Mynewsdesk AB, Rosenlundsgatan 40, 118 53 Stockholm, Sweden (hereinafter referred to as "Mynewsdesk") for our press and public relations work.
The cookie policy published by Mynewsdesk and available at https://www.mynewsdesk.com/about/terms-and-conditions/cookies and the overview of cookies used at https://www.mynewsdesk.com/com/about/terms-and-conditions/cookies/cookie-list provide information on the collection, processing and use of personal data by Mynewsdesk.
The privacy policy published by Mynewsdesk, which is available at https://www.mynewsdesk.com/about/terms-and-conditions/privacy_policy, and the privacy policy for users, which is available at https://www.mynewsdesk.com/about/terms-and-conditions/privacy_policy_contacts, discloses the collection, processing and use of personal data by Mynewsdesk.
The press releases of Bowspirit Management GmbH contain so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in e-mails sent in HTML-format to enable log file recording and analysis. This allows statistical evaluation of the success or failure of PR campaigns. Based on the embedded pixel-code, Bowspirit Management GmbH can recognize whether and when an e-mail was opened by a data subject and which links in the e-mail were called by the data subject.
Such personal data collected via the tracking pixels contained in the press releases are stored and evaluated by the controller for processing in order to optimise the dispatch of press releases and news and to adapt the content of messages even better to the interests of the data subject. This personal data will not be passed on to third parties. Data subjects are entitled at any time to revoke the relevant separate declaration of consent given via the double opt-in procedure. After a revocation these personal data will be deleted by the controller for the processing. Bowspirit Management GmbH automatically interprets a deregistration from the receipt of press releases as a revocation.
20a. WhatsApp
To establish contact, the provider enables the customer, among other things, to make contact via the messenger service WhatsApp.
The operating company of WhatsApp is WhatsApp LLC, 1601 Willow Road, Menlo Park, California 94025, United States.
If a person lives in the European Region the controller is the WhatsApp Ireland Limited, c/o Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.
When the user communicates with the provider via WhatsApp, both the provider and WhatsApp receive the mobile phone number of the user and the information that the user has contacted the provider.
The abovementioned data are also forwarded by WhatsApp to servers of their mother company Meta Platforms, Inc. in the United States and are processed by WhatsApp and Meta Platforms in accordance with the WhatsApp privacy policy, which also includes processing for their own purposes, such as improving the WhatsApp service.
In the opinion of the data protection supervisory authorities, however, the United States do not currently have an adequate level of data protection. However, there are so-called standard contractual clauses:
https://faq.whatsapp.com/general/about-standard-contractual-clauses
These are private law agreements, however, and therefore have no direct impact on the access options of the authorities in the United States.
More information about the purpose and scope of the data collection and the further processing of these data by WhatsApp and Meta Platforms as well as related rights and setting options for protecting privacy are contained in privacy guidelines from WhatsApp: https://www.whatsapp.com/legal/#privacy-policy.
The legal basis for this processing and the transmission to WhatsApp is Article 6 (1) lit. b GDPR, insofar as the establishment of contact relates to an existing contractual relationship or serves to initiate such a contractual relationship. If contact is not made for the above purposes, the legal basis is Article 6 (1) lit. f GDPR. The legitimate interest of the provider is to improve the quality of service.
20b. Broadcasting via WhatsApp Channels
You may subscribe to a broadcasting service of ours via the messenger service WhatsApp.
The operating company of WhatsApp is WhatsApp LLC, 1601 Willow Road, Menlo Park, California 94025, United States.
If a person lives in the European Region the controller is the WhatsApp Ireland Limited, c/o Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.
Some of the user data is processed on WhatsApp servers or servers of their mother company Meta Platforms, Inc. in the United States. You can find WhatsApp's privacy policy at https://www.whatsapp.com/legal/#privacy-policy. Further privacy information on WhatsApp Channels can be found at https://www.whatsapp.com/legal/channels-privacy-policy respectively https://www.whatsapp.com/legal/channels-privacy-policy-eea.
To receive our broadcast via WhatsApp Channels, you need a WhatsApp user account. Details of what information WhatsApp collects when you register can be found in WhatsApp's aforementioned privacy policy.
If you subscribe to our channel on WhatsApp, the mobile phone number you entered during the registration process will be processed by WhatsApp. In addition, your IP address and the date and time of your registration will be stored.
The legal basis for the broadcast is Article 6 (1) lit. a GDPR.
You can revoke your consent to the broadcast at any time with effect for the future in accordance with Article 7 (3) GDPR. To do so, you only need to cancel the corresponding subscription to our channel in the WhatsApp app.
On this website, the controller has integrated the Matomo component. Matomo is an open-source software tool for web analysis. Web analysis is the collection, gathering and evaluation of data on the behaviour of visitors from Internet sites. A web analysis tool collects, inter alia, data on the website from which a data subject came to a website (so-called referrer), which pages of the website were accessed or how often and for which period of time a sub-page was viewed. A web analysis is mainly used for the optimization of a website and the cost-benefit analysis of Internet advertising.
The software is operated on the server of the controller, the data protection-sensitive log files are stored exclusively on this server.
The purpose of the Matomo component is the analysis of the visitor flows on our website. The controller uses the obtained data and information, inter alia, to evaluate the use of this website in order to compile online reports, which show the activities on our Internet pages.
Matomo sets a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, an analysis of the use of our website is enabled. With each call-up to one of the individual pages of this website, the Internet browser on the information technology system of the data subject is automatically through the Matomo component prompted to submit data for the purpose of online analysis to our server. During the course of this technical procedure, we obtain knowledge about personal information, such as the IP address of the data subject, which serves to understand the origin of visitors and clicks.
The cookie is used to store personal information, such as the access time, the location from which access was made, and the frequency of visits to our website. With each visit of our Internet pages, these personal data, including the IP address of the Internet access used by the data subject, are transferred to our server. These personal data will be stored by us. We do not forward this personal data to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the used Internet browser would also prevent Matomo from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Matomo may be deleted at any time via a web browser or other software programs.
In addition, the data subject has the possibility of objecting to a collection of data relating to a use of this Internet site that are generated by Matomo as well as the processing of these data by Matomo and the chance to preclude any such. For this, the data subject must set a "Do Not Track" option in the browser.
With each setting of the opt-out cookie, however, there is the possibility that the websites of the controller are no longer fully usable for the data subject.
Further information and the applicable data protection provisions of Matomo may be retrieved under https://matomo.org/privacy/.
12. Routine erasure and blocking of personal data
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
13. Rights of the data subject
a) Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.
b) Right of access
Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
- the existence of the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from the data subject, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 22 (1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.
c) Right to rectification
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.
d) Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- The data subject withdraws consent to which the processing is based according to point (a) of Article 6 (1) of the GDPR, or point (a) of Article 9 (2) of the GDPR, and where there is no other legal ground for the processing.
- The data subject objects to the processing pursuant to Article 21 (1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21 (2) of the GDPR.
- The personal data have been unlawfully processed.
- The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
- The personal data have been collected in relation to the offer of information society services referred to in Article 8 (1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the Bowspirit Management GmbH, he or she may, at any time, contact any employee of the controller. An employee of Bowspirit Management GmbH shall promptly ensure that the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17 (1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employees of the Bowspirit Management GmbH will arrange the necessary measures in individual cases.
e) Right of restriction of processing
Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
- The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
- The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
- The data subject has objected to processing pursuant to Article 21 (1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the Bowspirit Management GmbH, he or she may at any time contact any employee of the controller. The employee of the Bowspirit Management GmbH will arrange the restriction of the processing.
f) Right to data portability
Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6 (1) of the GDPR or point (a) of Article 9 (2) of the GDPR, or on a contract pursuant to point (b) of Article 6 (1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20 (1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact any employee of the Bowspirit Management GmbH.
g) Right to object
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6 (1) of the GDPR. This also applies to profiling based on these provisions.
The Bowspirit Management GmbH shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
If the Bowspirit Management GmbH processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the Bowspirit Management GmbH to the processing for direct marketing purposes, the Bowspirit Management GmbH will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the Bowspirit Management GmbH for scientific or historical research purposes, or for statistical purposes pursuant to Article 89 (1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the data subject may contact any employee of the Bowspirit Management GmbH. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
h) Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, the Bowspirit Management GmbH shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the Bowspirit Management GmbH.
i) Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the Bowspirit Management GmbH.
14. Registration on our website
The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for his own purposes. The controller may request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to the controller.
By registering on the website of the controller, the IP address - assigned by the Internet service provider (ISP) and used by the data subject - date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.
The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.
The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the controller’s employees are available to the data subject in this respect as contact persons.
15. Contact possibility via the website
The website of the Bowspirit Management GmbH contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address).
If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.
16. Request by e-mail, telephone or fax
If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.
The processing of these data is based on Article 6 (1) lit. b GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases, the processing is based on your consent (Article 6 (1) lit. a GDPR) and/or on our legitimate interests (Article 6 (1) lit. f GDPR), since we have a legitimate interest in the effective processing of requests addressed to us.
The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.
17. Data protection for applications and the application procedures
The data controller shall collect and process the personal data of applicants for the purpose of the processing of the application procedure. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a web form on the website to the controller. If the data controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the controller, the application documents shall be automatically erased two months after notification of the refusal decision, provided that no other legitimate interests of the controller are opposed to the erasure. Other legitimate interest in this relation is, e.g. a burden of proof in a procedure under the General Equal Treatment Act (AGG).
18. Subscription to our newsletters
On the website of the Bowspirit Management GmbH, users are given the opportunity to subscribe to our enterprise's newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.
The Bowspirit Management GmbH informs its customers and business partners regularly by means of a newsletter about enterprise offers. The enterprise's newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.
During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.
The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller, or to communicate this to the controller in a different way.
Brevo is the email marketing software used. This means your information is transmitted to Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany (hereinafter referred to as "Brevo"). Brevo is prohibited from selling your data and from using it for purposes other than sending email. Brevo is a certified German email marketing software provider, working in accordance with the European directive 95/46 (GDPR), as well as the German Federal Data Protection Act (BDSG). More info: https://www.brevo.com/information-for-email-recipients/
19. Newsletter-Tracking
The newsletter of the Bowspirit Management GmbH contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, the Bowspirit Management GmbH may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.
Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. The Bowspirit Management GmbH automatically regards a withdrawal from the receipt of the newsletter as a revocation.
20. Mynewsdesk Newsroom
We use the services of Mynewsdesk AB, Rosenlundsgatan 40, 118 53 Stockholm, Sweden (hereinafter referred to as "Mynewsdesk") for our press and public relations work.
The cookie policy published by Mynewsdesk and available at https://www.mynewsdesk.com/about/terms-and-conditions/cookies and the overview of cookies used at https://www.mynewsdesk.com/com/about/terms-and-conditions/cookies/cookie-list provide information on the collection, processing and use of personal data by Mynewsdesk.
The privacy policy published by Mynewsdesk, which is available at https://www.mynewsdesk.com/about/terms-and-conditions/privacy_policy, and the privacy policy for users, which is available at https://www.mynewsdesk.com/about/terms-and-conditions/privacy_policy_contacts, discloses the collection, processing and use of personal data by Mynewsdesk.
The press releases of Bowspirit Management GmbH contain so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in e-mails sent in HTML-format to enable log file recording and analysis. This allows statistical evaluation of the success or failure of PR campaigns. Based on the embedded pixel-code, Bowspirit Management GmbH can recognize whether and when an e-mail was opened by a data subject and which links in the e-mail were called by the data subject.
Such personal data collected via the tracking pixels contained in the press releases are stored and evaluated by the controller for processing in order to optimise the dispatch of press releases and news and to adapt the content of messages even better to the interests of the data subject. This personal data will not be passed on to third parties. Data subjects are entitled at any time to revoke the relevant separate declaration of consent given via the double opt-in procedure. After a revocation these personal data will be deleted by the controller for the processing. Bowspirit Management GmbH automatically interprets a deregistration from the receipt of press releases as a revocation.
20a. WhatsApp
To establish contact, the provider enables the customer, among other things, to make contact via the messenger service WhatsApp.
The operating company of WhatsApp is WhatsApp LLC, 1601 Willow Road, Menlo Park, California 94025, United States.
If a person lives in the European Region the controller is the WhatsApp Ireland Limited, c/o Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.
When the user communicates with the provider via WhatsApp, both the provider and WhatsApp receive the mobile phone number of the user and the information that the user has contacted the provider.
The abovementioned data are also forwarded by WhatsApp to servers of their mother company Meta Platforms, Inc. in the United States and are processed by WhatsApp and Meta Platforms in accordance with the WhatsApp privacy policy, which also includes processing for their own purposes, such as improving the WhatsApp service.
In the opinion of the data protection supervisory authorities, however, the United States do not currently have an adequate level of data protection. However, there are so-called standard contractual clauses:
https://faq.whatsapp.com/general/about-standard-contractual-clauses
These are private law agreements, however, and therefore have no direct impact on the access options of the authorities in the United States.
More information about the purpose and scope of the data collection and the further processing of these data by WhatsApp and Meta Platforms as well as related rights and setting options for protecting privacy are contained in privacy guidelines from WhatsApp: https://www.whatsapp.com/legal/#privacy-policy.
The legal basis for this processing and the transmission to WhatsApp is Article 6 (1) lit. b GDPR, insofar as the establishment of contact relates to an existing contractual relationship or serves to initiate such a contractual relationship. If contact is not made for the above purposes, the legal basis is Article 6 (1) lit. f GDPR. The legitimate interest of the provider is to improve the quality of service.
20b. Broadcasting via WhatsApp Channels
You may subscribe to a broadcasting service of ours via the messenger service WhatsApp.
The operating company of WhatsApp is WhatsApp LLC, 1601 Willow Road, Menlo Park, California 94025, United States.
If a person lives in the European Region the controller is the WhatsApp Ireland Limited, c/o Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.
Some of the user data is processed on WhatsApp servers or servers of their mother company Meta Platforms, Inc. in the United States. You can find WhatsApp's privacy policy at https://www.whatsapp.com/legal/#privacy-policy. Further privacy information on WhatsApp Channels can be found at https://www.whatsapp.com/legal/channels-privacy-policy respectively https://www.whatsapp.com/legal/channels-privacy-policy-eea.
To receive our broadcast via WhatsApp Channels, you need a WhatsApp user account. Details of what information WhatsApp collects when you register can be found in WhatsApp's aforementioned privacy policy.
If you subscribe to our channel on WhatsApp, the mobile phone number you entered during the registration process will be processed by WhatsApp. In addition, your IP address and the date and time of your registration will be stored.
The legal basis for the broadcast is Article 6 (1) lit. a GDPR.
You can revoke your consent to the broadcast at any time with effect for the future in accordance with Article 7 (3) GDPR. To do so, you only need to cancel the corresponding subscription to our channel in the WhatsApp app.
21. Presences in social media
We maintain presences in so-called social media such as Facebook, Instagram, Youtube, LinkedIn and XING in order to communicate with interested parties and users active there and to inform them about our company.
From this website, we refer to the respective presences only by means of links and not via plug-ins. Data subjects will find references to the operators and their accessible data policy statements in the following sections 22 to 28.
Requests for information and the assertion of user rights can be asserted most effectively directly with the operators. Only the operating companies have access to the data of the users and can directly take appropriate measures and provide information. Should a data subject nevertheless require help, he or she can contact an employee of the controller at any time.
22. Presence on the Facebook platform
To advertise our products and services as well as to communicate with interested parties or customers, we have a presence on the Facebook platform.
On this social media platform, we are jointly responsible with the operator of the platform.
The operating company of Facebook is Meta Platforms, Inc., 1 Hacker Way, Menlo Park, California 94025, United States.
If a person lives outside of the United States or Canada, the controller is the Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
The data protection officer of Facebook can be reached via this contact form: https://www.facebook.com/help/contact/540977946302970
We have defined the joint responsibility in an agreement regarding the respective obligations within the meaning of the GDPR. This agreement, which sets out the reciprocal obligations, is available at the following link: https://www.facebook.com/legal/terms/page_controller_addendum
The legal basis for the processing of the resulting and subsequently disclosed personal data is Article 6 (1) lit. f GDPR. Our legitimate interest lies in the analysis, communication, sales, and promotion of our products and services.
The legal basis may also be your consent per Article 6 (1) lit. a GDPR granted to the platform operator. Per Article 7 (3) GDPR, you may revoke this consent with the platform operator at any time with future effect.
When accessing our online presence on the Facebook platform, Meta Platforms as the operator of the platform will process your data (e.g. personal information, IP address, etc.).
This data of the user is used for statistical information on the use of our company presence on Facebook. Meta Platforms uses this data for market research and advertising purposes as well as for the creation of user profiles. Based on these profiles, Meta Platforms can provide advertising both within and outside of Facebook based on your interests. If you are logged into Facebook at the time you access our site, Meta Platforms will also link this data to your user account.
If you contact us via Facebook, the personal data you provide at that time will be used to process the request. We will delete this data once we have completely responded to your query, unless there are legal obligations to retain the data, such as for subsequent fulfillment of contracts.
Meta Platforms might also set cookies when processing your data.
If you do not agree to this processing, you have the option of preventing the installation of cookies by making the appropriate settings in your browser. Cookies that have already been saved can be deleted at any time. The instructions to do this depend on the browser and system being used. For Flash cookies, the processing cannot be prevented by the settings in your browser, but instead by making the appropriate settings in your Flash player. If you prevent or restrict the installation of cookies, not all of the functions of Facebook may be fully usable.
Details on the processing activities, their suppression, and the deletion of the data processed by Facebook can be found in its privacy policy: https://www.facebook.com/privacy/explanation
It cannot be excluded that the processing by Meta Platforms Ireland Limited will also take place in the United States by Meta Platforms, Inc., 1 Hacker Way, Menlo Park, California 94025.
23. Presence on the Instagram platform
To advertise our products and services as well as to communicate with interested parties or customers, we have a presence on the Instagram platform.
On this social media platform, we are jointly responsible with the operator of the platform.
The operating company of Instagram is Meta Platforms, Inc., 1 Hacker Way, Menlo Park, California 94025, United States.
If a person lives outside of the United States or Canada, the controller is the Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
The data protection officer of Instagram can be reached via this contact form: https://www.facebook.com/help/contact/540977946302970
We have defined the joint responsibility in an agreement regarding the respective obligations
within the meaning of the GDPR. This agreement, which sets out the reciprocal obligations, is available at the following link: https://www.facebook.com/legal/terms/page_controller_addendum
The legal basis for the processing of the resulting and subsequently disclosed personal data is Article 6 (1) lit. f GDPR. Our legitimate interest lies in the analysis, communication, sales, and promotion of our products and services.
The legal basis may also be your consent per Article 6 (1) lit. a GDPR granted to the platform operator. Per Article 7 (3) GDPR, you may revoke this consent with the platform operator at any time with future effect.
When accessing our online presence on the Instagram platform, Meta Platforms as the operator of the platform will process your data (e.g. personal information, IP address, etc.).
This data of the user is used for statistical information on the use of our company presence on Instagram. Meta Platforms uses this data for market research and advertising purposes as well as for the creation of user profiles. Based on these profiles, Meta Platforms can provide advertising both within and outside of Instagram based on your interests. If you are logged into Instagram at the time you access our site, Meta Platforms will also link this data to your user account.
If you contact us via Instagram, the personal data you provide at that time will be used to process the request. We will delete this data once we have completely responded to your query, unless there are legal obligations to retain the data, such as for subsequent fulfillment of contracts.
Meta Platforms might also set cookies when processing your data.
If you do not agree to this processing, you have the option of preventing the installation of cookies by making the appropriate settings in your browser. Cookies that have already been saved can be deleted at any time. The instructions to do this depend on the browser and system being used. For Flash cookies, the processing cannot be prevented by the settings in your browser, but instead by making the appropriate settings in your Flash player. If you prevent or restrict the installation of cookies, not all of the functions of Instagram may be fully usable.
Details on the processing activities, their suppression, and the deletion of the data processed by Instagram can be found in its privacy policy: https://help.instagram.com/519522125107875
It cannot be excluded that the processing by Meta Platforms Ireland Limited will also take place in the United States by Meta Platforms, Inc., 1 Hacker Way, Menlo Park, California 94025.
24. Presence on the LinkedIn platform
We maintain an online presence on LinkedIn to present our company and our services and to communicate with customers / prospects.
The operating company of LinkedIn is LinkedIn Corporation, 1000 W. Maude Avenue, Sunnyvale, California 94085, United States.
If a person lives in the European Union (EU), European Economic Area (EEA), or Switzerland the controller is the LinkedIn Ireland Unlimited Company, Privacy Policy Issues, Wilton Place, Dublin 2, Ireland.
We would like to point out that this might cause user data to be processed outside the European Union, particularly in the United States. This may increase risks for users that, for example, may make subsequent access to the user data more difficult. We also do not have access to this user data. Access is only available to LinkedIn.
The LinkedIn privacy policy can be found here: https://www.linkedin.com/legal/privacy-policy
25. Presence on the XING platform
We maintain an online presence on XING to present our company and our services and to communicate with customers / prospects.
The operating company of XING is XING SE, Dammtorstraße 30, 20354 Hamburg, Germany.
The XING privacy policy can be found here: https://www.xing.com/privacy
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27. Presence on the YouTube platform
We maintain an online presence on YouTube to present our company and our services and to communicate with customers / prospects.
The operating company of YouTube is Google LLC, 1600 Amphitheatre Parkway, Mountain View, California 94043, United States.
If a person lives in the European Economic Area (EEA) or Switzerland the controller is the Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
We would like to point out that this might cause user data to be processed outside the European Union, particularly in the United States. This may increase risks for users that, for example, may make subsequent access to the user data more difficult. We also do not have access to this user data. Access is only available to YouTube.
The YouTube privacy policy can be found here: https://policies.google.com/privacy
28. General linking to third-party profiles
The provider uses a link on the website to the social networks listed below.
The legal basis for this is Article 6 (1) lit. f GDPR. The provider's legitimate interest is to improve the quality of use of the website.
Only by clicking on the corresponding graphic is the user redirected to the service of the respective social network.
After the customer has been forwarded, information about the user is collected by the respective network. This is initially data such as IP address, date, time and page visited. If the user is logged into his or her user account of the respective network during this time, the network operator may be able to assign the collected information of the user's specific visit to the user's personal account. If the user interacts via a "Share" button of the respective network, this information may be stored in the user's personal user account and possibly published. If the user wants to prevent the collected information from being directly assigned to his/her user account, the user must log out before clicking on the graphic. In addition, it is possible to configure the respective user account accordingly.
The following social networks are linked by the provider:
Facebook
The operating company of Facebook is Meta Platforms, Inc., 1 Hacker Way, Menlo Park, California 94025, United States.
If a person lives outside of the United States or Canada, the controller is the Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
Privacy Policy: https://www.facebook.com/policy.php
Instagram
The operating company of Instagram is Meta Platforms, Inc., 1 Hacker Way, Menlo Park, California 94025, United States.
If a person lives outside of the United States or Canada, the controller is the Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
Privacy Policy: https://help.instagram.com/519522125107875
LinkedIn
The operating company of LinkedIn is LinkedIn Corporation, 1000 W. Maude Avenue, Sunnyvale, California 94085, United States.
If a person lives in the European Union (EU), European Economic Area (EEA), or Switzerland the controller is the LinkedIn Ireland Unlimited Company, Privacy Policy Issues, Wilton Place, Dublin 2, Ireland.
Privacy Policy: https://www.linkedin.com/legal/privacy-policy
XING
The operating company of XING is XING SE, Dammtorstraße 30, 20354 Hamburg, Germany.
Privacy Policy: https://www.xing.com/privacy
YouTube
The operating company of YouTube is Google LLC, 1600 Amphitheatre Parkway, Mountain View, California 94043, United States.
If a person lives in the European Economic Area (EEA) or Switzerland the controller is the Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
Privacy Policy: https://policies.google.com/privacy
WhatsApp Channels
The operating company of WhatsApp is WhatsApp LLC, 1601 Willow Road, Menlo Park, California 94025, United States.
If a person lives in the European Region the controller is the WhatsApp Ireland Limited, c/o Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.
Privacy policy: https://www.whatsapp.com/legal/#privacy-policy
29. Payment Method: Data protection provisions about the use of PayPal as a payment processor
On this website, the controller has integrated components of PayPal. PayPal is an online payment service provider. Payments are processed via so-called PayPal accounts, which represent virtual private or business accounts. PayPal is also able to process virtual payments through credit cards when a user does not have a PayPal account. A PayPal account is managed via an e-mail address, which is why there are no classic account numbers. PayPal makes it possible to trigger online payments to third parties or to receive payments. PayPal also accepts trustee functions and offers buyer protection services.
The operating company of PayPal is PayPal Holdings, Inc., 2211 North First Street, San Jose, California 95131, United States.
The European operating company of PayPal is PayPal (Europe) S.à.r.l. & Cie. S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg.
If the data subject chooses "PayPal" as the payment option in the online shop during the ordering process, we automatically transmit the data of the data subject to PayPal. By selecting this payment option, the data subject agrees to the transfer of personal data required for payment processing.
The personal data transmitted to PayPal is usually first name, last name, address, e-mail address, IP address, telephone number, mobile phone number, or other data necessary for payment processing. The processing of the purchase contract also requires such personal data, which are in connection with the respective order.
The transmission of the data is aimed at payment processing and fraud prevention. The controller will transfer personal data to PayPal, in particular, if a legitimate interest in the transmission is given. The personal data exchanged between PayPal and the controller for the processing of the data will be transmitted by PayPal to economic credit agencies. This transmission is intended for identity and creditworthiness checks.
PayPal will, if necessary, pass on personal data to affiliates and service providers or subcontractors to the extent that this is necessary to fulfill contractual obligations or for data to be processed in the order.
The data subject has the possibility to revoke consent for the handling of personal data at any time from PayPal. A revocation shall not have any effect on personal data which must be processed, used or transmitted in accordance with (contractual) payment processing.
The applicable data protection provisions of PayPal may be retrieved under https://www.paypal.com/us/webapps/mpp/ua/privacy-full.
30. Encrypted payment transactions on this website
If you are under an obligation to share your payment information (e.g. account number if you give us the authority to debit your bank account) with us after you have entered into a fee-based contract with us, this information is required to process payments.
Payment transactions using common modes of paying (Visa / MasterCard) are processed exclusively via encrypted SSL or TLS connections.
You can recognise an encrypted connection by checking whether the address line of the browser switches from "http://" to "https://" and also by the appearance of the lock icon in the browser line.
If the communication with us is encrypted, third parties will not be able to read the payment information you share with us.
We maintain presences in so-called social media such as Facebook, Instagram, Youtube, LinkedIn and XING in order to communicate with interested parties and users active there and to inform them about our company.
From this website, we refer to the respective presences only by means of links and not via plug-ins. Data subjects will find references to the operators and their accessible data policy statements in the following sections 22 to 28.
Requests for information and the assertion of user rights can be asserted most effectively directly with the operators. Only the operating companies have access to the data of the users and can directly take appropriate measures and provide information. Should a data subject nevertheless require help, he or she can contact an employee of the controller at any time.
22. Presence on the Facebook platform
To advertise our products and services as well as to communicate with interested parties or customers, we have a presence on the Facebook platform.
On this social media platform, we are jointly responsible with the operator of the platform.
The operating company of Facebook is Meta Platforms, Inc., 1 Hacker Way, Menlo Park, California 94025, United States.
If a person lives outside of the United States or Canada, the controller is the Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
The data protection officer of Facebook can be reached via this contact form: https://www.facebook.com/help/contact/540977946302970
We have defined the joint responsibility in an agreement regarding the respective obligations within the meaning of the GDPR. This agreement, which sets out the reciprocal obligations, is available at the following link: https://www.facebook.com/legal/terms/page_controller_addendum
The legal basis for the processing of the resulting and subsequently disclosed personal data is Article 6 (1) lit. f GDPR. Our legitimate interest lies in the analysis, communication, sales, and promotion of our products and services.
The legal basis may also be your consent per Article 6 (1) lit. a GDPR granted to the platform operator. Per Article 7 (3) GDPR, you may revoke this consent with the platform operator at any time with future effect.
When accessing our online presence on the Facebook platform, Meta Platforms as the operator of the platform will process your data (e.g. personal information, IP address, etc.).
This data of the user is used for statistical information on the use of our company presence on Facebook. Meta Platforms uses this data for market research and advertising purposes as well as for the creation of user profiles. Based on these profiles, Meta Platforms can provide advertising both within and outside of Facebook based on your interests. If you are logged into Facebook at the time you access our site, Meta Platforms will also link this data to your user account.
If you contact us via Facebook, the personal data you provide at that time will be used to process the request. We will delete this data once we have completely responded to your query, unless there are legal obligations to retain the data, such as for subsequent fulfillment of contracts.
Meta Platforms might also set cookies when processing your data.
If you do not agree to this processing, you have the option of preventing the installation of cookies by making the appropriate settings in your browser. Cookies that have already been saved can be deleted at any time. The instructions to do this depend on the browser and system being used. For Flash cookies, the processing cannot be prevented by the settings in your browser, but instead by making the appropriate settings in your Flash player. If you prevent or restrict the installation of cookies, not all of the functions of Facebook may be fully usable.
Details on the processing activities, their suppression, and the deletion of the data processed by Facebook can be found in its privacy policy: https://www.facebook.com/privacy/explanation
It cannot be excluded that the processing by Meta Platforms Ireland Limited will also take place in the United States by Meta Platforms, Inc., 1 Hacker Way, Menlo Park, California 94025.
23. Presence on the Instagram platform
To advertise our products and services as well as to communicate with interested parties or customers, we have a presence on the Instagram platform.
On this social media platform, we are jointly responsible with the operator of the platform.
The operating company of Instagram is Meta Platforms, Inc., 1 Hacker Way, Menlo Park, California 94025, United States.
If a person lives outside of the United States or Canada, the controller is the Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
The data protection officer of Instagram can be reached via this contact form: https://www.facebook.com/help/contact/540977946302970
We have defined the joint responsibility in an agreement regarding the respective obligations
within the meaning of the GDPR. This agreement, which sets out the reciprocal obligations, is available at the following link: https://www.facebook.com/legal/terms/page_controller_addendum
The legal basis for the processing of the resulting and subsequently disclosed personal data is Article 6 (1) lit. f GDPR. Our legitimate interest lies in the analysis, communication, sales, and promotion of our products and services.
The legal basis may also be your consent per Article 6 (1) lit. a GDPR granted to the platform operator. Per Article 7 (3) GDPR, you may revoke this consent with the platform operator at any time with future effect.
When accessing our online presence on the Instagram platform, Meta Platforms as the operator of the platform will process your data (e.g. personal information, IP address, etc.).
This data of the user is used for statistical information on the use of our company presence on Instagram. Meta Platforms uses this data for market research and advertising purposes as well as for the creation of user profiles. Based on these profiles, Meta Platforms can provide advertising both within and outside of Instagram based on your interests. If you are logged into Instagram at the time you access our site, Meta Platforms will also link this data to your user account.
If you contact us via Instagram, the personal data you provide at that time will be used to process the request. We will delete this data once we have completely responded to your query, unless there are legal obligations to retain the data, such as for subsequent fulfillment of contracts.
Meta Platforms might also set cookies when processing your data.
If you do not agree to this processing, you have the option of preventing the installation of cookies by making the appropriate settings in your browser. Cookies that have already been saved can be deleted at any time. The instructions to do this depend on the browser and system being used. For Flash cookies, the processing cannot be prevented by the settings in your browser, but instead by making the appropriate settings in your Flash player. If you prevent or restrict the installation of cookies, not all of the functions of Instagram may be fully usable.
Details on the processing activities, their suppression, and the deletion of the data processed by Instagram can be found in its privacy policy: https://help.instagram.com/519522125107875
It cannot be excluded that the processing by Meta Platforms Ireland Limited will also take place in the United States by Meta Platforms, Inc., 1 Hacker Way, Menlo Park, California 94025.
24. Presence on the LinkedIn platform
We maintain an online presence on LinkedIn to present our company and our services and to communicate with customers / prospects.
The operating company of LinkedIn is LinkedIn Corporation, 1000 W. Maude Avenue, Sunnyvale, California 94085, United States.
If a person lives in the European Union (EU), European Economic Area (EEA), or Switzerland the controller is the LinkedIn Ireland Unlimited Company, Privacy Policy Issues, Wilton Place, Dublin 2, Ireland.
We would like to point out that this might cause user data to be processed outside the European Union, particularly in the United States. This may increase risks for users that, for example, may make subsequent access to the user data more difficult. We also do not have access to this user data. Access is only available to LinkedIn.
The LinkedIn privacy policy can be found here: https://www.linkedin.com/legal/privacy-policy
25. Presence on the XING platform
We maintain an online presence on XING to present our company and our services and to communicate with customers / prospects.
The operating company of XING is XING SE, Dammtorstraße 30, 20354 Hamburg, Germany.
The XING privacy policy can be found here: https://www.xing.com/privacy
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27. Presence on the YouTube platform
We maintain an online presence on YouTube to present our company and our services and to communicate with customers / prospects.
The operating company of YouTube is Google LLC, 1600 Amphitheatre Parkway, Mountain View, California 94043, United States.
If a person lives in the European Economic Area (EEA) or Switzerland the controller is the Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
We would like to point out that this might cause user data to be processed outside the European Union, particularly in the United States. This may increase risks for users that, for example, may make subsequent access to the user data more difficult. We also do not have access to this user data. Access is only available to YouTube.
The YouTube privacy policy can be found here: https://policies.google.com/privacy
28. General linking to third-party profiles
The provider uses a link on the website to the social networks listed below.
The legal basis for this is Article 6 (1) lit. f GDPR. The provider's legitimate interest is to improve the quality of use of the website.
Only by clicking on the corresponding graphic is the user redirected to the service of the respective social network.
After the customer has been forwarded, information about the user is collected by the respective network. This is initially data such as IP address, date, time and page visited. If the user is logged into his or her user account of the respective network during this time, the network operator may be able to assign the collected information of the user's specific visit to the user's personal account. If the user interacts via a "Share" button of the respective network, this information may be stored in the user's personal user account and possibly published. If the user wants to prevent the collected information from being directly assigned to his/her user account, the user must log out before clicking on the graphic. In addition, it is possible to configure the respective user account accordingly.
The following social networks are linked by the provider:
The operating company of Facebook is Meta Platforms, Inc., 1 Hacker Way, Menlo Park, California 94025, United States.
If a person lives outside of the United States or Canada, the controller is the Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
Privacy Policy: https://www.facebook.com/policy.php
The operating company of Instagram is Meta Platforms, Inc., 1 Hacker Way, Menlo Park, California 94025, United States.
If a person lives outside of the United States or Canada, the controller is the Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
Privacy Policy: https://help.instagram.com/519522125107875
The operating company of LinkedIn is LinkedIn Corporation, 1000 W. Maude Avenue, Sunnyvale, California 94085, United States.
If a person lives in the European Union (EU), European Economic Area (EEA), or Switzerland the controller is the LinkedIn Ireland Unlimited Company, Privacy Policy Issues, Wilton Place, Dublin 2, Ireland.
Privacy Policy: https://www.linkedin.com/legal/privacy-policy
The operating company of XING is XING SE, Dammtorstraße 30, 20354 Hamburg, Germany.
Privacy Policy: https://www.xing.com/privacy
YouTube
The operating company of YouTube is Google LLC, 1600 Amphitheatre Parkway, Mountain View, California 94043, United States.
If a person lives in the European Economic Area (EEA) or Switzerland the controller is the Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
Privacy Policy: https://policies.google.com/privacy
WhatsApp Channels
The operating company of WhatsApp is WhatsApp LLC, 1601 Willow Road, Menlo Park, California 94025, United States.
If a person lives in the European Region the controller is the WhatsApp Ireland Limited, c/o Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.
Privacy policy: https://www.whatsapp.com/legal/#privacy-policy
29. Payment Method: Data protection provisions about the use of PayPal as a payment processor
On this website, the controller has integrated components of PayPal. PayPal is an online payment service provider. Payments are processed via so-called PayPal accounts, which represent virtual private or business accounts. PayPal is also able to process virtual payments through credit cards when a user does not have a PayPal account. A PayPal account is managed via an e-mail address, which is why there are no classic account numbers. PayPal makes it possible to trigger online payments to third parties or to receive payments. PayPal also accepts trustee functions and offers buyer protection services.
The operating company of PayPal is PayPal Holdings, Inc., 2211 North First Street, San Jose, California 95131, United States.
The European operating company of PayPal is PayPal (Europe) S.à.r.l. & Cie. S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg.
If the data subject chooses "PayPal" as the payment option in the online shop during the ordering process, we automatically transmit the data of the data subject to PayPal. By selecting this payment option, the data subject agrees to the transfer of personal data required for payment processing.
The personal data transmitted to PayPal is usually first name, last name, address, e-mail address, IP address, telephone number, mobile phone number, or other data necessary for payment processing. The processing of the purchase contract also requires such personal data, which are in connection with the respective order.
The transmission of the data is aimed at payment processing and fraud prevention. The controller will transfer personal data to PayPal, in particular, if a legitimate interest in the transmission is given. The personal data exchanged between PayPal and the controller for the processing of the data will be transmitted by PayPal to economic credit agencies. This transmission is intended for identity and creditworthiness checks.
PayPal will, if necessary, pass on personal data to affiliates and service providers or subcontractors to the extent that this is necessary to fulfill contractual obligations or for data to be processed in the order.
The data subject has the possibility to revoke consent for the handling of personal data at any time from PayPal. A revocation shall not have any effect on personal data which must be processed, used or transmitted in accordance with (contractual) payment processing.
The applicable data protection provisions of PayPal may be retrieved under https://www.paypal.com/us/webapps/mpp/ua/privacy-full.
30. Encrypted payment transactions on this website
If you are under an obligation to share your payment information (e.g. account number if you give us the authority to debit your bank account) with us after you have entered into a fee-based contract with us, this information is required to process payments.
Payment transactions using common modes of paying (Visa / MasterCard) are processed exclusively via encrypted SSL or TLS connections.
You can recognise an encrypted connection by checking whether the address line of the browser switches from "http://" to "https://" and also by the appearance of the lock icon in the browser line.
If the communication with us is encrypted, third parties will not be able to read the payment information you share with us.
31. Data protection provisions about the use of the Spreadshirt-Shop
Our website links to our shop at the printing-on-demand provider Spreadshirt.
The company operating the services of Spreadshirt is sprd.net AG, Gießerstraße 27, 04229 Leipzig, Germany (hereinafter referred to as "Spreadshirt").
According to Article 4 GDPR, "processor" is anyone who processes personal data on behalf of the person responsible. "Controller" is on the other hand who decides on the purposes and means of data processing.
Within the Spreadshirt-Shop, Spreadshirt always decides on the purposes and means of processing, i.e. the shop functionalities.
We are only intermediaries for any orders placed there. The processing by Spreadshirt does not take place "on our behalf" either, but on the basis of their own legal relationship with the (potential) customers in the shop.
A transmission of the customer's IP address from us to Spreadshirt does not take place.
Rather, the IP address is collected by Spreadshirt itself when loading the shop, if necessary again and independently of the user's visit to our websites.
Spreadshirt's current data privacy policy is available at https://service.spreadshirt.com/hc/en-gb/articles/115000978409/?shop_name=bowspirit-kids-group&shop_id=100393512.
32. Data protection provisions about the use of the Art Heroes-Shop
Our website links to our shop at the printing-on-demand provider Art Heroes.
The company operating the services of Art Heroes is We Make It Work BV, Bingerweg 8, 2031 AZ Haarlem, The Netherlands (hereinafter referred to as "Art Heroes").
According to Article 4 GDPR, "processor" is anyone who processes personal data on behalf of the person responsible. "Controller" is on the other hand who decides on the purposes and means of data processing.
Within the Art Heroes-Shop, Art Heroes always decides on the purposes and means of processing, i.e. the shop functionalities.
We are only intermediaries for any orders placed there. The processing by Art Heroes does not take place "on our behalf" either, but on the basis of their own legal relationship with the (potential) customers in the shop.
A transmission of the customer's IP address from us to Art Heroes does not take place.
Rather, the IP address is collected by Art Heroes itself when loading the shop, if necessary again and independently of the user's visit to our websites.
Art Heroes' current data privacy policy is available at https://www.artheroes.com/en/privacystatement-we-make-it-work-b-v-artheroes-1344420.
33. Legal basis for the processing
Article 6 (1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6 (1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Article 6 (1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Article 6 (1) lit. d GDPR. Finally, processing operations could be based on Article 6 (1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
34. The legitimate interests pursued by the controller or by a third party
Where the processing of personal data is based on Article 6 (1) lit. f GDPR our legitimate interest is to carry out our business in favour of the well-being of all our employees and the shareholders.
35. Period for which the personal data will be stored
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
36. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.
37. Note on data transfer to the United States and other third countries
Among other things, we use tools from companies based in the United States or other third countries that are not secure under data protection law. If these tools are active, your personal data may be transferred to these third countries and processed there. We would like to point out that no level of data protection comparable to that in the European Union (EU) can be guaranteed in these countries.
For example, US companies are obliged to hand over personal data to security authorities without you as the data subject being able to take legal action against this. It can therefore not be ruled out that US authorities (e.g. intelligence services) process, evaluate and permanently store your data located on US servers for monitoring purposes. We have no influence on these processing activities.
38. Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.
39. Supervisory authorities
You can complain to a supervisory authority at any time, e.g. to the competent supervisory authority of the (federal) state in which you live or to the authority responsible for us.
You can find a list of the supervisory authorities (for the non-public sector) and their addresses in Germany at: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html
40. Change of our privacy policy
We reserve the right to adapt this privacy policy so that it always complies with the current legal requirements or in order to implement changes to our services in the privacy policy, e.g. when introducing new services. Your new visit will then be subject to the new privacy policy.
Our website links to our shop at the printing-on-demand provider Spreadshirt.
The company operating the services of Spreadshirt is sprd.net AG, Gießerstraße 27, 04229 Leipzig, Germany (hereinafter referred to as "Spreadshirt").
According to Article 4 GDPR, "processor" is anyone who processes personal data on behalf of the person responsible. "Controller" is on the other hand who decides on the purposes and means of data processing.
Within the Spreadshirt-Shop, Spreadshirt always decides on the purposes and means of processing, i.e. the shop functionalities.
We are only intermediaries for any orders placed there. The processing by Spreadshirt does not take place "on our behalf" either, but on the basis of their own legal relationship with the (potential) customers in the shop.
A transmission of the customer's IP address from us to Spreadshirt does not take place.
Rather, the IP address is collected by Spreadshirt itself when loading the shop, if necessary again and independently of the user's visit to our websites.
Spreadshirt's current data privacy policy is available at https://service.spreadshirt.com/hc/en-gb/articles/115000978409/?shop_name=bowspirit-kids-group&shop_id=100393512.
32. Data protection provisions about the use of the Art Heroes-Shop
Our website links to our shop at the printing-on-demand provider Art Heroes.
The company operating the services of Art Heroes is We Make It Work BV, Bingerweg 8, 2031 AZ Haarlem, The Netherlands (hereinafter referred to as "Art Heroes").
According to Article 4 GDPR, "processor" is anyone who processes personal data on behalf of the person responsible. "Controller" is on the other hand who decides on the purposes and means of data processing.
Within the Art Heroes-Shop, Art Heroes always decides on the purposes and means of processing, i.e. the shop functionalities.
We are only intermediaries for any orders placed there. The processing by Art Heroes does not take place "on our behalf" either, but on the basis of their own legal relationship with the (potential) customers in the shop.
A transmission of the customer's IP address from us to Art Heroes does not take place.
Rather, the IP address is collected by Art Heroes itself when loading the shop, if necessary again and independently of the user's visit to our websites.
Art Heroes' current data privacy policy is available at https://www.artheroes.com/en/privacystatement-we-make-it-work-b-v-artheroes-1344420.
33. Legal basis for the processing
Article 6 (1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6 (1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Article 6 (1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Article 6 (1) lit. d GDPR. Finally, processing operations could be based on Article 6 (1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
34. The legitimate interests pursued by the controller or by a third party
Where the processing of personal data is based on Article 6 (1) lit. f GDPR our legitimate interest is to carry out our business in favour of the well-being of all our employees and the shareholders.
35. Period for which the personal data will be stored
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
36. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.
37. Note on data transfer to the United States and other third countries
Among other things, we use tools from companies based in the United States or other third countries that are not secure under data protection law. If these tools are active, your personal data may be transferred to these third countries and processed there. We would like to point out that no level of data protection comparable to that in the European Union (EU) can be guaranteed in these countries.
For example, US companies are obliged to hand over personal data to security authorities without you as the data subject being able to take legal action against this. It can therefore not be ruled out that US authorities (e.g. intelligence services) process, evaluate and permanently store your data located on US servers for monitoring purposes. We have no influence on these processing activities.
38. Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.
39. Supervisory authorities
You can complain to a supervisory authority at any time, e.g. to the competent supervisory authority of the (federal) state in which you live or to the authority responsible for us.
You can find a list of the supervisory authorities (for the non-public sector) and their addresses in Germany at: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html
40. Change of our privacy policy
We reserve the right to adapt this privacy policy so that it always complies with the current legal requirements or in order to implement changes to our services in the privacy policy, e.g. when introducing new services. Your new visit will then be subject to the new privacy policy.
This Privacy Policy has been generated by the Privacy Policy Generator of the External Data Protection Officers that was developed in cooperation with the Media Law Lawyers from WBS-LAW.
The corresponding draft was adapted by us using, among other things, elements from the Model Data Protection Statement for Anwaltskanzlei Weiß & Partner [sections 5, 6, 7, 20a, 20b, 22, 23, 24, 27, 28], elements from the Privacy Policy Generator of eRecht24 GmbH & Co. KG, Berlin, (premium package of the agency VICON, Lübeck) [sections 9, 10, 16, 30, 37] as well as elements from the Privacy Policy Generator of activeMIND AG, Munich, [sections 39, 40].
Version History
Date | Description of change/revision |
2023-06-19 | New version |
2023-10-25 | In sections 21, 26 and 28, the change of name from Twitter to X was added. Section 20a ("WhatsApp") was added. Section 20b ("Broadcasting via WhatsApp Channels") was added. In section 28, the reference to WhatsApp Channels was added. |
2024-05-06 | In section 32 the new address of Art Heroes (We Make It Work BV) was added. |
2024-06-17 | In sections 21 and 28, the reference to X (formerly Twitter) has been removed. Section 26 (formerly "Presence on the X (formerly Twitter) platform") has been removed. |