Webdesign Florian Brinkmann
Proprietor: Florian Brinkmann
Types of data processed:
- Inventory data (for example, names, addresses).
- Contact details (e.g., e-mail, telephone numbers).
- 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).
Categories of data subjects
Visitors and users of the online offer (hereinafter referred to as "users").
Purpose of processing
- Provision of the online offer, its functions and contents.
- Response to contact requests and communication with users.
- Security measures.
- Reach measurement/marketing.
"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 assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more special features that express the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
"processing" means any operation or series of operations carried out with or without the aid of automated procedures in connection with personal data. The term goes far and covers practically every handling of data.
"pseudonymisation" means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that this 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.
"Profiling" means any automated processing of personal data consisting in the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to the work performance, economic situation, health, personal preferences, interests, reliability, behaviour, location or relocation of that natural person.
"controller" means 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.
"processor" means a natural or legal person, authority, institution or other body processing personal data on behalf of the responsible person.
Applicable legal bases
We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, implementation costs and the nature, scope, circumstances and purposes of processing as well as the different probability of occurrence and severity of the risk to the rights and freedoms of natural persons, in accordance with Art. 32 GDPR.
Such measures shall in particular include ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, transmission, security of availability and its separation. Furthermore, we have established procedures to ensure the exercise of rights of data subjects, deletion of data and reaction to endangerment of data. Furthermore, we already consider the protection of personal data during the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design and by default (Art. 25 GDPR).
Cooperation with contract processors and third parties
If we disclose data to other persons and companies (contract processors or third parties) within the scope of our processing, transmit it to them or otherwise grant them access to the data, this shall only take place on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as payment service providers, is in accordance with Art. 6 Para. 1 lit. b GDPR for contract fulfilment is necessary), if you have consented, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we commission third parties with the processing of data on the basis of a so-called "data processing agreement", this is done on the basis of Art. 28 GDPR.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this only takes place if it occurs for the fulfilment of our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special requirements of Art. 44 GDPR ff. are met. This means, for example, processing is carried out on the basis of special guarantees, such as the officially recognised determination of a data protection level corresponding to the EU (e.g. for the USA by the "Privacy Shield") or compliance with officially recognised special contractual obligations (so-called "standard contractual clauses").
Rights of data subjects
You have the right to request confirmation as to whether the data concerned are being processed and to request information about these data as well as further information and a copy of the data in accordance with Art. 15 GDPR.
In accordance with Art. 16 GDPR, you have the right to request the completion of data concerning you or the correction of incorrect data concerning you.
In accordance with Art. 17 GDPR, you have the right to demand that personal data be deleted immediately or, alternatively, to demand a restriction on the processing of the data in accordance with Art. 18 GDPR.
You have the right to request that the data concerning you that you have provided to us be received in accordance with Art. 20 GDPR and to request its transmission to other persons responsible.
In accordance with Art. 77 GDPR, you also have the right to lodge a complaint with a supervisory authority.
Right of withdrawal
You have the right to withdrawal consents granted pursuant to Art. 7 para. 3 GDPR with effect for the future.
Right of object
You can object to the future processing of the data concerning you in accordance with Art. 21 GDPR at any time. The objection may be lodged in particular against processing for direct marketing purposes.
"Cookies" are small files that are stored on the user's computer. Various data can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his or her visit to an online offer. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the content of a shopping basket in an online shop or a login status can be stored. Cookies are referred to as "permanent" or "persistent" if they remain stored even after the browser is closed. For example, the login status can be saved when users visit it after several days. Likewise, the interests of users used for range measurement or marketing purposes may be stored in such a cookie. "Third-party cookies" are cookies that are offered by providers other than the controller, who is running the online offer (otherwise, if they are only his cookies, they are referred to as "first-party cookies").
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
Deletion of data
According to legal requirements in Germany, the storage is carried out in particular for 10 years in accordance with §§ 147 para. 1 AO, 257 para. 1 no. 1 and 4, para. 4 HGB (books, records, management reports, accounting documents, trading books, documents relevant for taxation, etc.) and 6 years in accordance with § 257 para. 1 no. 2 and 3, para. 4 HGB (commercial letters).
Additionally we process
- Contract data (for example, contract object, term, customer category).
- Payment data (e.g., bank details, payment history)
from our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
Order processing in the online shop
We process the data of our customers in the context of the order processes in our online shop to enable them to select and order the selected products and services, as well as their payment and delivery, or execution.
The processed data includes inventory data, communication data, contract data, payment data and the data subjects affected by the processing include our customers, interested parties and other business partners. The processing takes place for the purpose of providing contractual services in the context of operating an online shop, billing, delivery and customer services. We use session cookies to store the contents of the shopping cart.
Processing is carried out on the basis of Art. 6 Para. 1 lit. b (execution of order processes) and c (legally required archiving) GDPR. The information marked as necessary is required to establish and fulfil the contract. We disclose the data to third parties only within the framework of delivery, payment or within the framework of legal permits and obligations to legal advisors and authorities. The data will only be processed in third countries if this is necessary for the fulfilment of the contract (e.g. at the customer's request upon delivery or payment).
The deletion takes place after the expiry of statutory warranty and comparable obligations, the necessity of data storage is reviewed every three years; in the case of statutory archiving obligations, the deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) storage obligation).
We process our customers' data as part of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development / consulting or maintenance, implementation of campaigns and processes / handling, server administration, data analysis / consulting services and training services.
We process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., email, telephone numbers), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter of the contract, term), payment data (e.g., bank details, payment history), usage and metadata (e.g. as part of the evaluation and performance measurement of marketing measures). We do not process special categories of personal data unless these are part of commissioned processing. Data subjects include our customers, prospects, their customers, users, website visitors or employees, as well as third parties. The purpose of the processing is to provide contractual services, billing and our customer service. The legal basis for processing results from Art. 6 para. 1 lit. b GDPR (contractual services), Art. 6 para. 1 lit. f GDPR (analysis, statistics, optimisation, safety measures). We process data which are necessary to justify and fulfil the contractual services and point out the necessity of their disclosure. Disclosure to external parties only takes place if it is necessary within the framework of an order. When processing the data provided to us within the scope of an order, we act in accordance with the instructions of the client and the legal requirements for order processing pursuant to Art. 28 DSGVO and process the data for no other purposes than those stipulated in the order.
We delete the data after the expiration of statutory warranty and comparable obligations. The necessity of the storage of the data is checked every three years; in the case of statutory archiving obligations the deletion takes place after their expiration (6 J, according to § 257 Abs. 1 HGB, 10 J, according to § 147 Abs. 1 AO). In the case of data disclosed to us within the scope of a job by the client, we delete the data in accordance with the specifications of the job, generally after the end of the job.
External payment service providers
We use Paypal (paypal.com/en/webapps/mpp/ua/privacy-full) as external payment service provider, via whose platform the users and we can make payment transactions.
Within the scope of the fulfilment of contracts, we use the payment service provider on the basis of Art. 6 para. 1 lit. b DSGVO. In all other respects, we shall appoint the external payment service provider on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. b. GDPR to provide our users with effective and secure payment options.
The data processed by the payment service provider includes inventory data such as name and address, bank data such as account numbers or credit card numbers, passwords, TANs and checksums as well as contract, totals and recipient information. This information is required to execute the transactions. However, the entered data will only be processed and stored by the payment service provider. This means that we do not receive any account or credit card related information, but only information with confirmation or negative information about the payment. The data may be transmitted by the payment service provider to credit agencies. The purpose of this transmission is to verify identity and creditworthiness. For this we refer to the terms and conditions and data protection information of the payment service providers.
The payment transactions are subject to the terms and conditions and privacy policies of the payment service provider, which can be accessed within the website or transaction applications. We refer to these also for the purpose of further information and assertion of rights of withdrawal, information and other interested parties.
Administration, financial accounting, office organization, contact management
We process data within the framework of administrative tasks as well as the organisation of our company, financial accounting and compliance with legal obligations, e.g. archiving. We process the same data that we process in the course of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers, prospects, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, thus tasks which serve the maintenance of our business activities, perception of our tasks and provision of our services. The deletion of the data with regard to contractual services and contractual communication corresponds to the information provided for these processing activities.
We disclose or transmit data to the tax authorities, consultants, such as tax consultants or auditors, as well as other fee offices and payment service providers.
Furthermore, we store information on suppliers, event organisers and other business partners on the basis of our business interests, e.g. for the purpose of making contact at a later date. We store this data, which is mainly company-related, permanently.
We reserve the right, on the basis of our legitimate interests in accordance with Art. 6 para. 1 lit. f. GDPR to process user information for spam detection.
The data provided in the context of comments will be permanently stored by us until the user objects.
Users may subscribe to the follow-up comments with their consent in accordance with Art. 6 para. 1 lit. a GDPR. Users will receive a confirmation email to verify that they are the owner of the email address they entered. Users can unsubscribe from ongoing comment subscriptions at any time. The confirmation email will contain information on the cancellation options. When the user has confirmed his subscription, a flag is set in the database, which is removed after the subscription has ended.
Cookies are also used to check:
- whether a comment writer with a certain e-mail address has already commented on a blog post (storage period one year).
- whether the user has checked the double opt-in checkbox for the comment subscription for a post or not (storage period one year).
Retrieval of profile pictures from Gravatar
Gravatar is a service where users can log in and store profile pictures and their e-mail addresses. If users leave contributions or comments with the respective email address on other online presences (above all in blogs), their profile pictures can be displayed next to the contributions or comments. For this purpose, the email address provided by the users is transmitted to Gravatar in encrypted form for the purpose of checking whether a profile has been saved for it. This is the sole purpose of the transmission of the email address and it will not be used for other purposes, but will be deleted thereafter.
This function is not used by default but must be activated by the user by checking a checkbox in the comment form. Only if this checkbox is activated, Gravatar checks whether the email address has been assigned to an image so that it can be displayed next to the comment.
The use of Gravatar is based on our legitimate interests within the meaning of Art. 6 Para. 1 letter f) GDPR, as we offer the possibility of personalising their contributions with a profile picture with the help of Gravatar.
The gravatars are cached locally on our web server, so there are no requests to Automattic's servers to display them on the website.
When contacting us (e.g. by email, telephone or via social media), the user's details are processed for processing the contact enquiry and its processing in accordance with Art. 6 para. 1 lit. b) GDPR. User information can be stored in a customer relationship management system ("CRM system") or comparable request organization.
We delete the requests if they are no longer necessary. We review this requirement every two years; the statutory archiving obligations also apply.
Hosting and email dispatch
The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail delivery, security services and technical maintenance services that we use for the purpose of operating this online offer.
We or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta- and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer according to Art. 6 Para. 1 lit. f GDPR in conjunction with. Art. 28 GDPR (conclusion of data processing agreement).
Collection of access data and log files
Site views are not stored in log files.
VG Wort / scalable central measuring method
We use the "Scalable Central Measurement Method" (SZM) of INFOnline GmbH (INFOnline GmbH, Brühler Str. 9, D-53119 Bonn, Germany) to determine statistical parameters for determining the copy probability of texts. Anonymous measured values are collected. The access number measurement alternatively uses a session cookie or a signature, which is created from various automatically transmitted information of your browser, to recognize computer systems. IP addresses are only processed in an anonymized form. The procedure was developed with data protection in mind. The sole aim of the procedure is to determine the likelihood of copying individual texts. Individual users are never identified at any time. Your identity is always protected. You will not receive any advertising through the system.
User data and metadata of the users are processed, whereby the IP addresses are shortened and the measurement methods are pseudonymous. The shortened IP address is stored for a maximum of 60 days. The usage data in connection with a pseudonymous assignment value ("identifier") are stored for a maximum of 6 months.
Furthermore, users have an opt-out at their disposal to object to the collection for the aforementioned purposes: https://optout.ioam.de. Further information can be found in INFOnline's data protection declaration https://www.infonline.de/datenschutz/benutzer.
Online presence in social media
We maintain online presences within social networks and platforms in order to communicate with active customers, interested parties and users and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and the data processing guidelines of their respective operators apply.
Functions and contents of the Twitter service, offered by Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, can be integrated into our online offering. This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online offer within Twitter.
Last updated: May 2018