With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) for which purposes and to what extent. The data protection declaration applies to all processing of personal data that we carry out, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, e.g. our social media profiles (hereinafter collectively referred to as the “online offer”). The terms used are not gender-specific. As of May 7, 2020
Table of contents
GRGSoft UG (limited liability)
Adress: Kaiser-Wilhelm-Str 44 – 12247 Berlin
Email address: firstname.lastname@example.org
Overview of processing
The following overview summarizes the types of data processed and the purposes of their processing together and refers to the data subjects.
Types of data processed
Inventory data (e.g. names, addresses).
Content data (e.g. text input, photographs, videos).
Contact details (e.g. email, telephone numbers).
Meta / communication data (e.g. device information, IP addresses).
Usage data (e.g. visited websites, interest in content, access times).
Location data (data indicating the location of an end user’s device).
Categories of data subjects
Users (e.g. website visitors, users of online services).
Purposes of processing
Visit action evaluation.
Cross-device tracking (cross-device processing of user data for
Interest-based and behavioral marketing.
Contact requests and communication.
Conversion measurement (measurement of the effectiveness of marketing measures).
Profiling (creating user profiles).
Target group formation (determination of target groups relevant for marketing purposes or
other output of content).
Relevant legal bases
In the following, we share the legal basis of the General Data Protection Regulation (GDPR), on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, the national data protection requirements in your or our country of residence and domicile may apply. Should more specific legal bases also apply in individual cases, we will inform you of this in the data protection declaration.
Consent (Art. 6 Para. 1 S. 1 lit. a GDPR)
The data subject has their consent to the processing of your personal data for you given specific purpose or multiple specific purposes.
Fulfillment of the contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b GDPR)
Processing is for the performance of a contract, the contracting party of which is concerned Person is, or required to take pre-contractual measures based on Data subject request.
Legitimate interests (Art. 6 Para. 1 S. 1 lit. GDPR)
The processing is necessary to safeguard the legitimate interests of the person responsible or a third party, unless the interests or fundamental rights and freedoms of the data subject that protect personal data Data require, outweigh.
National data protection regulations in Germany
In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection in Germany apply. This includes in particular the law on protection against misuse of personal data in data processing (Federal Data Protection Act – BDSG). The BDSG contains in particular special regulations on the right to information, the right to deletion, the right to object, the processing of special categories of personal data, the processing for other purposes and for transmission as well as automated decision-making in individual cases including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. State data protection laws of the individual federal states can also be applied.
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of processing, as well as the different occurrence probabilities and the extent of the threat to the rights and freedoms of natural persons to ensure a level of protection appropriate to the risk. The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling the physical and electronic access to the data as well as the access, input, transfer, safeguarding of availability and their separation. Furthermore, we have set up procedures that guarantee the exercise of data subject rights, the deletion of data and reactions to the risk to the data. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
Transmission and disclosure of personal data
As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons, or that it is disclosed to them. The recipients of this data can e.g. Payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such a case, we observe the legal requirements and in particular conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.
Data processing in third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing as part of the use of third-party services or the disclosure or transmission of data to other people, positions or companies takes place, this takes place only in accordance with the legal requirements. Subject to express consent or contractually or legally required transmission, we process or leave the data only in third countries with a recognized data protection level, to which the US processors certified under the “Privacy Shield” belong, or on the basis of special guarantees, such as process contractual obligations through so-called standard protection clauses of the EU Commission, the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of)
Cookies are text files that contain data from visited websites or domains and from saved in a browser on the user’s computer. A cookie serves first Line to this, the information about a user during or after their visit within to save an online offer. For the stored information, e.g. the language settings on a website, the login status, a shopping cart or the place where a Video was watched belong. We also count others to the term cookies technologies that perform the same functions as cookies (e.g., if user information stored on the basis of pseudonymous online identifiers, also as “user IDs”designated)
A distinction is made between the following types of cookies and functions: Temporary cookies (also: session or session cookies): Temporary cookies deleted at the latest after a user leaves an online offer and his browser has closed.
Permanent cookies: Permanent cookies remain saved even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users who are used for range measurement or for marketing purposes can be saved in such a cookie.
First-party cookies: We set first-party cookies ourselves. Third-party cookies (also: third-party cookies): third-party cookies mainly used by advertisers (so-called third parties) to collect user information to process.
Necessary (also: essential or absolutely necessary) cookies: Cookies may be absolutely necessary for the operation of a website (e.g. to save logins or other user inputs or for security reasons).
General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke your consent or to object to the processing of your data by cookie technologies ( collectively referred to as “opt-out”).
Websites https://optout.aboutads.info and https://www.youronlinechoices.com/ are explained. In addition, you can add further contradiction notices in the context of the information on the used Service providers and cookies received.
Their use is based on our interest and the interest of the users in the expected functionality of our online offer.
Processed data types: usage data (e.g. visited websites, interest in content, access times), meta / communication data (e.g. device information, IP addresses).
Affected persons: users (e.g. website visitors, users of online services).
Legal basis: consent (Art. 6 para. 1 sentence 1 lit. a GDPR), legitimate interests
(Art. 6 Para. 1 S. 1 lit. GDPR).
Provision of the online offer and web hosting
In order to be able to provide our online offer securely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we can use infrastructure and platform services, computing capacity, storage space and database services as well as security and technical maintenance services. The data processed as part of the provision of the hosting offer can include all information relating to the users of our online offer, which is incurred in the context of use and communication. This regularly includes the IP address that is necessary in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or on websites.
Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files can include the address and name of the accessed websites and files, date and time of access, transferred data volumes, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP Addresses and the requesting provider belong. The server log files can be used on the one hand for security purposes, e.g. to avoid overloading the server (in particular in the event of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the server’s load and stability.
Processed data types: content data (e.g. text input, photographs, videos), usage data (e.g. visited websites, interest in content, access times), meta / communication data (e.g. device information, IP addresses). Affected persons: users (e.g. website visitors, users of online services). Legal basis: legitimate interests (Art. 6 Para. 1 S. 1 lit. GDPR).
When contacting us (e.g. via contact form, email, telephone or via social media), the details of the inquiring person will be processed, insofar as this is necessary to answer the contact inquiries and any measures requested. The answering of contact inquiries within the framework of contractual or pre-contractual relationships takes place to fulfill our contractual obligations or to answer (pre) contractual inquiries and, moreover, on the basis of the legitimate interests in answering the inquiries.
Processed data types: inventory data (e.g. names, addresses), contact details (e.g. email, telephone numbers), content data (e.g. text input, photographs, videos).
Affected persons: communication partner.
Purposes of processing: contact requests and communication.
Legal basis: performance of the contract and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 GDPR), legitimate interests (Art. 6 Para. 1 Clause 1 GDPR).
We process personal data for the purposes of online marketing, which in particular includes the marketing of advertising space or the display of advertising and other content (collectively referred to as “content”) based on potential interests of the users and the measurement of their effectiveness. For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar processes are used, by means of which the information relevant to the presentation of the aforementioned content about the user is saved. For this information, e.g. Content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on times of use. If users have consented to the collection of their location data, this can also be processed.
The IP addresses of the users are also saved. However, we use available IP masking procedures (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that we, as well as the providers of the online marketing process, do not know the actual identity of the user, but only the information stored in their profiles.
The information in the profiles is usually saved in the cookies or by means of similar processes. These cookies can generally later also be read on other websites that use the same online marketing process and analyzed for the purpose of displaying content, as well as supplemented with further data and stored on the server of the online marketing process provider. In exceptional cases, clear data can be assigned to the profiles. This is the case if the users e.g. Are members of a social network whose online marketing process we use and the network connects the profiles of the users with the aforementioned information.
We ask you to note that users have additional agreements with the providers, e.g. by consent in the context of registration. We generally only have access to summarized information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e. e.g., to conclude a contract with us. The conversion measurement is used solely to analyze the success of our marketing measures. Unless otherwise stated, we ask you to assume that the cookies used will be stored for a period of two years.
Facebook pixel: With the help of the Facebook pixel, it is possible on the one hand for Facebook to determine the visitors of our online offer as a target group for the display of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to only display the Facebook ads that we place on Facebook and within the services of the partners who cooperate with Facebook (so-called “Audience Network” https://www.facebook.com/audiencenetwork/ ), which have also shown an interest in our online offer or which have certain features (e.g. interest in certain topics or products that can be seen from the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we would also like to ensure that our Facebook ads correspond to the potential interest of the users and do not have a nuisance. With the help of the Facebook pixel, we can also understand the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were forwarded to our website after clicking on a Facebook ad (so-called “conversion measurement”).
Processed data types: usage data (e.g. visited websites, interest in content, access times), meta / communication data (e.g. device information, IP addresses), location data (data indicating the location of the end device of an end user).
Affected persons: users (e.g. website visitors, users of online services).
Security measures: IP masking (pseudonymization of the IP address). Legal basis: consent (Art. 6 Para. 1 Clause 1 a) GDPR), legitimate interests (Art. 6 Para. 1 Clause 1 lit. GDPR).
Opposition option (opt-out): We refer to the data protection information of the respective provider and the options for objection given to the providers (so-called “opt-out”). Unless an explicit opt-out option has been specified, there is on the one hand the possibility that you can deactivate cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following opt-out options, which are offered in summary for each area:
- a) Europe: https://www.youronlinechoices.eu
- b) Canada: https://www.youradchoices.ca/choices
- c) USA: https://www.aboutads.info/choices
- d) Cross-Territory: https://optout.aboutads.info
Services and service providers used
Facebook pixel: Service provider: https://www.facebook.com, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA ;
Data protection declaration: https://www.facebook.com/about/privacy; Privacy Shield (guarantee of data protection level when processing data in the
USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Opposition option (opt-out): https://www.facebook.com/settings?tab=ads.
Deletion of data
The data processed by us will be deleted in accordance with the legal requirements as soon as their consent for processing is revoked or other permits no longer apply (e.g. if the purpose of processing this data has ceased to apply or if it is not necessary for the purpose).If the data is not deleted because it is required for other and legally permissible purposes, its processing is restricted to these purposes. That is, the data will blocked and not processed for other purposes. This applies e.g. for data that must be kept for commercial or tax law reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person. Further information on the deletion of personal data can also be given in the context of the individual data protection information in this data protection declaration.
Change and update of the data protection declaration
We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes make it necessary to act on your part (e.g. consent) or other individual notification. If we provide addresses and contact information of companies and organizations in this data protection declaration, please note that the addresses can change over time and ask you to check the information before contacting us.
Rights of the data subjects
As the person concerned, you have various rights under the GDPR, which arise in particular from Articles 15 to 18 and 21 GDPR:
Right of objection: You have the right, for reasons that arise from your particular situation, at any time against the processing of your personal data, which is based on Art. 6 Para. 1 lit. e or f GDPR occurs to file an objection; this also applies to profiling based on these provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is connected to such direct advertising.
Right to withdraw consent: You have the right to withdraw consent at any time.
Right to information: You have the right to request confirmation as to whether the data in question are being processed and to request information about this data as well as further information and a copy of the data in accordance with the legal requirements.
Right to correction: In accordance with the legal requirements, you have the right to request the completion of the data concerning you or the correction of the incorrect data concerning you.
Right to deletion and restriction of processing: In accordance with the legal requirements, you have the right to request that the data relating to you be deleted immediately or, alternatively, to request that the processing of the data be restricted in accordance with the legal requirements.
Right to data portability: You have the right to receive data relating to you that you have provided to us in a structured, common and machine-readable format in accordance with legal requirements or to request that it be transmitted to another person responsible.
Complaint to the supervisory authority: In accordance with the legal requirements, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you believe that the processing of your data affects your personal data violates the DSGVO.
Definitions of terms
This section gives you an overview of the terms used in this data protection declaration. Many of the terms are taken from the law and mainly defined in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended primarily for understanding. The terms are sorted alphabetically.
Visit campaign evaluation: “Visit campaign evaluation” (“Conversion Tracking”) describes a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users’ devices within the websites on which the marketing measures take place and then called up again on the target website. For example, we can use this to understand whether the advertisements we placed on other websites were successful).
Cross-device tracking: Cross-device tracking is a form of tracking in which behavioral and interest information of users is recorded across devices in so-called profiles by assigning users an online identifier. As a result, the user information can usually be analyzed for marketing purposes regardless of the browsers or devices used (e.g. mobile phones or desktop computers). For most providers, the online identifier is not linked to clear data such as names, postal addresses or email addresses.
IP masking: “IP masking” is a method in which the last octet, i.e. the last two digits of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymizing processing methods, especially in online marketing.
Interest-based and behavior-related marketing: One speaks of interest-based and / or behavior-related marketing if potential interests of users in advertisements and other content are predetermined as precisely as possible. This is done based on information about their previous behavior (e.g. visiting certain websites and lingering on them, buying behavior or interacting with other users), which is stored in a so-called profile. Cookies are generally used for these purposes.
Conversion measurement: Conversion measurement is a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users’ devices within the websites on which the marketing measures take place and then called up again on the target website. For example, we can use this to understand whether the advertisements we placed on other websites were successful.
Personal data: “Personal data” is all information that relates to an identified or identifiable natural person (hereinafter “data subject”); A natural person is considered to be identifiable if he or she indirectly, in particular by assigning to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special features, the expression of the physical, physiological, genetic, psychological, economic , cultural or social identity of this natural person.
Profiling: “Profiling” means any type of automated processing of personal data, which consists in the fact that this personal data is used to cover certain personal aspects that relate to a natural person (depending on the type of profiling, this includes information regarding the Analyze age, gender, location data and movement data, interaction with websites and their content, shopping behavior, social interactions with other people) or to predict them (e.g. interests in certain content or products, click behavior on a website or the whereabouts). Cookies and web beacons are often used for profiling purposes.
Remarketing: One speaks of “remarketing” or “retargeting” if e.g. for advertising purposes, it is noted which products a user was interested in on one website in order to inform the user about these products on other websites, e.g. in advertisements to remember.
Tracking: One speaks of “tracking” when the behavior of users can be traced across several online offers. As a rule, behavior and interest information is stored in cookies or on the servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can then e.g. are used to show users advertisements that are likely to correspond to their interests.
Responsible: The “responsible” is the natural or legal person, authority, institution or other body that alone or together with others decides on the purposes and means of processing personal data.
Processing: “Processing” is any process carried out with or without the help of automated processes or any such series of processes in connection with personal data. The term goes far and encompasses practically every handling of data, be it collection, evaluation, storage, transmission or deletion.
Target group formation: One speaks of target group formation (or “custom audiences”) if target groups for advertising purposes, e.g. Display of advertisements, can be determined. For example, based on a user’s interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which he viewed the products. “Lookalike Audiences” (or similar target groups) is referred to when the content deemed to be suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating custom audiences and lookalike audiences.